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Letter to Richard Blubaugh 2 March 4, 2010 <br />Centennial Proiect, 3rd Review of MD-03 File No P-2008-043 <br />tanks will not be used to store produced ground water until after the detailed history has been accepted by DRMS in <br />writing. <br />4. Powertech's February 2, 2010 submittal describes tank rinsate testing in accordance with previous discussions <br />between Powertech and DRMS held on January 22, 2010. Since the date of those discussions, DRMS has learnt that <br />EPA will be requiring testing of the tanked water prior to injection, and analysis for RCRA metals, certain volatile and <br />semi-volatile organic compounds, total petroleum hydrocarbons, and total coliforms. Based on this information, <br />DRMS has determined that rinsate testing of each tank must be conducted, prior to deployment to the pump test site, as <br />follows. <br />a. Collection of rinse water sample prior to application to tanks for analysis of total organic carbon (TOC). <br />b. Analysis of rinsate for TOC and for dissolved arsenic, barium, cadmium, chromium, lead, mercury;, selenium, <br />and silver. <br />C. If the metals concentrations in any of the samples exceed Colorado ground water standards, then the DRMS <br />accepts the course of action described in Powertech's February 2, 2010 submittal to re-clean and re-sample the <br />tank(s). <br />d. If rinse water TOC is above two milligrams per liter (mg/1) and TOC in the rinsate is more than two mg/l <br />above the level measured in the rinse water, or if the rinse water TOC is below two mg/1 and the rinsate TOC <br />is above four mg/l, then additional analysis of the rinsate will be required. The tank(s) failing TOC must be re- <br />cleaned and rinsate analyzed for certain volatile and semi-volatile organic compounds (methods SMI-846 8260 <br />and 8270) and total petroleum hydrocarbons. If unacceptable levels of contamination are indicted by the test <br />results, then the tank(s) must either be rejected for use at the pump test site, or must again be re-cleaned and <br />re-tested. <br />DRMS estimates the cost to reclaim the pump test site at $136,101.00. The details of the cost estimate are enclosed <br />with this letter. Powertech may not commence operations proposed in MD-03 until the above listed issues have been <br />resolved, bond in the amount of $136,101.00 has been submitted, and Powertech is notified in writing that the bond <br />has been accepted by the DRMS. <br />If you have any questions, please contact me at 303-866-3567, ext. 8143. <br />Sincere , <br />Allen C. Sorenson <br />Reclamation Specialist <br />enclosure(s) <br />cc: Michael Beshore, Powertech, via email, w/ enclosures <br />cAacs filesNy Documents 4-19-06 thru\centennial Yd review of modification md3 p2008O43.doc