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that "SEO Well Construction and Test Reports for groundwater wells utilized during the previous <br />pumping tests have been submitted to the DRMS in the form of the confidential Surety Reduction <br />Request for NOI P- 2007 - 015." Similarly, in the attachment to Powertech's October 28 submittal is a <br />report prepared by Petrotek Engineering Corporation dated October 27, 2009 ( "Petrotek Report"). <br />This document contends in response to Division requests for further information regarding the <br />potential for vertical communication between aquifers, that "[b]ased on previous pumping tests <br />conducted by Powertech in Section 33 and the observed aquifer response during development of <br />puunping well PW -1, it is estimated that PW -1 can be produced at a sustainable rate of 8 to 10 gallons <br />per minute for the planned test duration of 3 to 5 days." Petrotek Report at 3. <br />Thus, Powertech relies on data from previous pumping tests conducted under NOI File No. <br />P- 2007 -015 to support its analysis for the instant amendment to NOI File No. P- 2008 -043, yet this <br />critical information does not appear to have been made public. Indeed, throughout the Petrotek <br />document there are references to data from previous pump tests or other studies that do not appear to <br />have been made public. See Petrotek Report at p. 8 (`The results from the Theis simulations for the <br />well development scenario and from the previous pump tests are consistent and indicate the order of <br />magnitude of hydraulic conductivity and storativity. "). <br />This problem is not limited to just information on previous pump tests. The Petrotek Report <br />appears to rely on assumptions and assertions for which no data appears to have been produced for <br />public review, or to the best of commenters' knowledge, Division review. For example, on page 5 of <br />the Petrotek Report, Powertech references a conclusion regarding the potential zone of flow for <br />injectate, "based on the best estimate of aquifer properties for the A2 sand," yet no scientific basis for <br />this estimate is evident. In the same paragraph, the Petrotek Report purports to assume "'piston -like' <br />displacement" in the aquifer and an "assumed aquifer thickness." but fails to justify_ its reliance on <br />such assumptions with any data or related studies. <br />Lastly, with respect to the impacts associated with conductivity between aquifers via historic <br />well holes in the direct vicinity of the currently proposed aquifer pump test, Powertech simply asserts <br />that "the condition of the exploration boreholes and monitoring wells installed by others is unknown <br />but will be evaluated through ongoing monitoring during the pumping test and reinjection of the <br />produced fluid." Petrotek Report at 6. However, no information is provided as to what efforts <br />Powertech has made to assess the condition of these holes what methodology Powertech proposes to <br />use in conducting these evaluations, nor why such information is unavailable from the apparent <br />previous pump tests conducted in the vicinity. In a similar manner, Powertech asserts that a "detailed <br />review of available potentiometric -level data for Section 33 monitoring wells shows the data to be <br />consistent and does not indicate any apparent anomalies, which may be caused by vertical leakage <br />through artificial penetrations." Petrotek Report at 6. Again, the data upon which this review was <br />conducted does not appear to be included in the submittal or otherwise publicly available, nor is the <br />methodology or techniques used in conducting such a review evident. <br />Overall, Powertech's responses to the Division's September 25 adequacy letter do not <br />contain the necessary data upon which assumptions were made, nor a description of the scientific <br />methodology employed to arrive at such assumptions. Although commenters are aware that <br />some data has been produced by Powertech in response to Division requests subsequent to the <br />October 28, 2009 submittal, commenters` ability to review that data and information has been <br />considerably hampered by an unrelated issue concerning the inactive status of the Division's <br />electronic files. <br />Pa <br />