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A. Sorenson, DRMS <br />Response to 3rd Review <br />March 9, 2010 <br />Powertech's October 28, 2009 submittal states "initially natural background radiation levels <br />shall be measured and recorded" at the pump test site, and that "radiological measurements <br />using an alpha and gamma probe shall be conducted on the containment vessel before it is <br />utilized onsite and, again, after onsite use; all readings will be documented on the appropriate <br />Powertech form. " Provide a commitment to provision to DRMS of the results of these required <br />radiological measurements and a commitment that the tanks will not be used to store produced <br />groundwater until after the results have been accepted by DRMS in writing. Provide a <br />commitment to notify DRMS in advance of the schedule for collecting the radiological <br />measurements, as DRMS may opt to inspect and audit the procedures. <br />Powertech Response to DRMS Comment #2: <br />Powertech commits to provide to the DRMS the results of the radiological measurements <br />specified in Powertech's October 28, 2009 submittal and the DRMS Comment 42. Produced <br />water will not be stored in the water containment vessels until initial radiological measurements <br />are provided to the DRMS, and accepted in writing. Powertech also commits to notify the <br />DRMS in advance of the schedule for collecting radiological measurements. <br />DRMS Comment #3: <br />2 <br />Powertech's February 2, 2010 submittal states "Rain for Rent keeps a detailed history of the <br />previous contents of tanks. The water holding tanks to be used by Powertech and provided by <br />Rain for Rent will have been previously used to contain water only, at least back one tank use <br />event. " Provide a commitment to provision to DRMS of Rain for Rents detailed history of the <br />previous contents of tanks, at least back one tank event, and a commitment that the tanks will not <br />be used to store produced groundwater until after the detailed history has been accepted by <br />DRMS in writing. <br />Powertech's Response to DRMS Comment #3: <br />Powertech's February 2, 2010 submittal stated that water containment vessels to be used would <br />have been previously used to contain water only, at least back one tank use event. This was a <br />reasonable commitment prior to Powertech learning that geochemical analyses of rinsate would <br />be required by the DRMS during cleaning of the water containment vessels to be used to store <br />produced water. The necessity of assuring usage of tanks that have previously held only water <br />during their last usage is questionable since Powertech now will be required to analyze tank <br />rinsate for certain volatile and semi-volatile organic compounds, total petroleum hydrocarbons, <br />and RCRA metals. <br />Although Powertech will request from Rain for Rent tanks that have held only water during the <br />last usage event, Powertech would like the flexibility to utilize any tank available regardless of <br />its previously stored contents. Because Powertech will commit to the rinsate sample analysis <br />protocol required by DRMS, Powertech suggests that the "previous contents" provision outlined <br />in the DRMS Comment #3 be removed. However, if the DRMS finds the "previous contents"