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Powertech Responses to the Colorado DRMS <br />Centennial Project, Second Review of Notice of Intent Modification MD-03, File No. P-2008-043 <br />DRMS Item #1) MD-03 proposes temporary storage of groundwater pumped to the surface in Rain for <br />Rent tanks and states that the tanks will be decontaminated before and after use. The terms and <br />conditions section of the Rain for Rent rental/sales estimate included with Powertech's October 28, <br />2009 submittal states that the tanks may have contained hazardous waste in the past, and provides <br />Powertech the option to test the units for hazardous waste prior to taking delivery. DRMS suggests <br />that through rinsing of the tanks with water of known quality followed by sampling and analysis of <br />the rinsate would be appropriate, but will consider any alternatives proposed by Powertech. The plan <br />provided must describe the analysis to be done, with the selected analytes based on the previous uses <br />of the tanks. The testing and analysis must be complete and evaluated by DRMS prior to bringing the <br />tanks onto the pump test site. <br />Powertech Response to DRMS Item #1: <br />The Rain for Rent tank rental estimate term and condition related to the previous contents of the tanks, <br />and stating that the tanks may have in the past contained hazardous waste, has been removed by Rain <br />for Rent from the estimate. Please refer to Attachment A for an updated tank rental estimate provided <br />by Rain for Rent. <br />Rain for Rent tanks are typically used to contain water onsite for use in oilfield operations or for <br />construction excavation dewatering, and Rain for Rent keeps a detailed history of the previous contents <br />of tanks. The water holding tanks to be used by Powertech and provided by Rain for Rent will have been <br />previously used to contain water only, at least back one tank use event. <br />Although Rain for Rent can ensure delivery of tanks that have previously held water and that the tanks <br />will be thoroughly cleaned before being delivered to the pump test site, Powertech has been informed <br />by the DRMS that testing of the tank cleaning rinsate will be required for some parameters to ensure <br />cleanliness. In a phone conversation with Mr. Sorenson (DRMS) on January 22, 2010, Powertech was <br />informed that chemical testing of the tank cleaning rinsate should include the following parameters. <br />• RCRA 8 Metals <br />o Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, Silver <br />• BTEX (Benzene, Toluene, Ethylbenzene, Xylenes) <br />• TOC (Total Organic Carbon as an indicator of contamination) <br />Powertech will commit to conducting the testing of the tank rinsate as described above. If the analytical <br />results of the above sample analysis exceed standards set forth in the Colorado Department of Public <br />Health and Environments-Groundwater Quality Standards for any of the tanks to be utilized, Powertech <br />will instruct Tactical Cleaning Company (Rain for Rents' tank cleaning contractor) to re-clean the tank <br />and an additional sample will be collected and analyzed.