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The interoffice mcmo referred to in this excerpt (exhibit 4, attachment D) also refers to <br />well abandonment procedures that were done in the 1970s, before Colorado legislation passed in <br />the early 1980s (House Bill 1 195) that required more substantial protections in drill hole <br />abandonment procedures to protect groundwater. These documents refer to use of such materials <br />"beet pulp" in the abandonment procedure in wells. <br />Other historic documents demonstrate that other companies drilled substantially more <br />numbers of wells in the area in the 1970s and 1980s, including Rocky Mountain Energy, who <br />reported to the State of Colorado in 1982 that it drilled some 2,142 holes in the area, including in <br />the section proposed for the injection permit (attached as exhibit 5). There is little data on the <br />abandonment procedures used in these wells, but one might assume they consisted of similar <br />techniques that were standard at the time that gave rise to the State of Colorado's concerns with <br />respect to aquifer communication and contamination with the Mobil project wells. In any case, <br />the EPA should require the applicant to provide all information regarding these wells, any <br />abandonment information, and require repair and proper closure prior to any injection <br />authorization. <br />In addition, the applicant's own documents demonstrate that there have been problems <br />encountered with abandonment procedures at historic drill holes. In an August 2007 Powertech <br />(USA) Inc. "Activity Update" (attached as exhibit 6), the company recounts its experiences in <br />discovering and attempting to repair broken well casings that appear to have been improperly <br />abandoned in the first instance. As stated by the applicant: <br />Some wells were broken off at ground surface during the intervening 20 plus years. We <br />have attempted to locate wells with GPS system and hand digging. Some wells we could <br />not locate this way and we used a backhoe to find the buried well. We gently raked 4 <br />inches at a time searching for the casing. We did not break any wells with our backhoe. <br />The photos found on some websites are actually jagged broken casings that were buried <br />for 20 plus years. <br />Further, Powertech is on record in a letter dated October 16, 2007 from Mr. Richard <br />Blubaugh, Powertech (USA) Inc. to Mr. Jim Woodward, «ww- owe rtecIt cx (except <br />attached as exhibit 7) overtly recognizing the problems associated with historic well <br />abandonment procedures in defending assertions that it or its contractors were responsible for <br />leaving open well casings: <br />While these open well casings are on property owned by Powertech, these are not wells <br />that were drilled by Powertech or its contractors. In fact, the wells left unprotected were <br />drilled by previous exploratory efforts in the 1980s, and were uncovered by Powertech's <br />geotechnical teams while in the process of locating each bore site. <br />In response to these local community concerns with respect to the potential failures of <br />historic well abandonment, the applicant affirmatively committed to "ensuring that all wells on <br />its properties meet state and local safety requirements and standards." We urge EPA to hold <br />Powertech to its promised commitments to the local community and require the applicant to <br />