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A. Sorenson, DRMS <br />Response to 3rd Review <br />March 9, 2010 <br />provision necessary even with the rinsate sampling analysis requirements, Powertech will <br />commit to the requirement in DBMS' Comment #s3. <br />DRMS Comment #4: <br />Powertech's February 2, 2010 submittal describes tank rinsate testing in accordance with <br />previous discussions between Powertech and DRMS held on January 22, 2010. Since the date of <br />those discussions, DRMS has learnt that EPA will be requiring testing of the tanked water prior <br />to injection, and analysis for RCRA metals, certain volatile and semi-volatile organic <br />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 <br />to the pump test site, as follows. <br />a. Collection of rinse water sample prior to application to tanks for analysis of total organic <br />carbon (TOC). <br />b. Analysis of rinsate for TOC and for dissolved arsenic, barium, cadmium, chromium, lead, <br />mercury, selenium, and silver. <br />c. If the metals concentrations in any samples exceed Colorado groundwater standards, <br />then the DRMS accepts the course of action described in Powertech's February 2, 2010 <br />submittal to re-clean and resample the tank(s). <br />d. If rinse water TOC is above two milligrams per liter (mg/l) and TOC in the rinsate is <br />more than two mg/1 above the level measured in the rinse water, or if the rinse water <br />TOC is below two mg/7 and the rinsate TOC is above four mg/l, then additional analysis <br />of the rinsate will be required. The tank(s) failing TOC must be re-cleaned and rinsate <br />analyzed for certain volatile and semi-volatile organic compounds (methods SW-846 <br />8260 and 8270) and total petroleum hydrocarbons. If unacceptable levels of <br />contamination are indicated by the test results, then the tank(s) must either be rejected <br />for use at the pump test site, or must again be re-cleaned and re-tested. <br />Powertech's Response to DRMS Comment #4: <br />Powertech commits to the sampling procedures outlined in the DRMS Comment 94a through <br />#4d. Additionally, Powertech will inform the DRMS of the sampling schedule for collection of <br />rinse water and rinsate for the cleaning of the water containment vessels. <br />Powertech's Response to the DRMS Costs to Reclaim Pump Test Site: <br />Freeze Protection: <br />Powertech will not be conducting the Centennial aquifer pumping test until April 15th, 2010, at <br />the earliest. The average low temperature at Nunn Colorado on April 15th is 36 degrees <br />Fahrenheit, and the record low temperature on April 15th is 20 degrees Fahrenheit. It is <br />incredibly unlikely that freezing conditions will exist at the pump test site that will be sufficient <br />enough in magnitude and duration to freeze water within the water containment vessels. With a