2010-12-27_REVISION - P2008043

• Permit No: P2008043
• IBM Index Class Name: REVISION
• Doc Date: 12/27/2010
• Doc Name: Addendum to Fourth Adequacy Review
• From: DRMS
• To: Powertech ‎(USA)‎ Inc.
• Type & Sequence: MD3
• Email Name: DB2
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
27 December 2010

Mr. Richard Blubaugh
_Powertech (USA) Inc.
5575 DTC Parkway, Suite 140
Greenwood Village, CO 80111
Ill? -44M
` COLORADO
D I V I S I O N OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr,
Governor
Mike King
Executive Director
Loretta E. PiMeda
Director
Re: Addendum to Fourth Adequacy Review for Modification MD-03, Centennial Project Aquifer
Test, Powertech (USA) Inc., File No. P-2008-043
Dear Mr. Blubaugh:
New developments surrounding the aquifer pumping test proposed by Powertech (USA) Inc. (Powertech)
have forced the Colorado Division of Reclamation, Mining and Safety (Division) to revisit the Modification
MD-03 to Notice of intent to Conduct Prospecting P-2008-043. The UIC Class V injection permit granted
to Powertech (USA) Inc. by the U.S. Environmental Protection Agency (EPA) for the Centennial Project
contains some provisions that evoke additional adequacy concerns under MD-03. The Division therefore
provides this Addendum to the Fourth Adequacy Review of MD-03. Please incorporate into your reply to
the Division's Fourth Adequacy Review appropriate responses to the issues presented herein. Your reply
must be received no later than the decision deadline of 11 Feb 2011, bearing in mind that the Division will
require some time to process the response and perform calculations regarding additional financial warranty.
The U1C Class V injection permit granted to Powertech by the EPA for the aquifer pumping test specifies
water quality criteria that must be met before re-injection will be allowed to proceed. This introduces the
concept of an "alternative water disposal plan", which might be necessary if the water to be re-injected does
not meet the EPA's water quality criteria.
As received by the Colorado Division of Reclamation, Mining and Safety (Division), Modification MD-03
contains no provision or financial warranty for an alternative water disposal plan. As discussed during our
meeting of 20 December 2010, of the possible alternative disposal options available, Powertech will choose
the option of on-site water treatment and surface discharge. Therefore, Powertech must include in its
pending Fourth Review Response a sufficiently detailed plan that describes the water treatment and surface
water discharge procedures. The plan must include at a minimum the following:
1) Schedule for all aspects of the treatment and discharge, including mobilization, demobilization, hours of
operation, personnel required, and timing of project termination, bearing in mind that multiple
treatment circuits may be required to address the various constituents of concern.
2) Details and schedule for any ground preparation needed to provide access and a level surface on which
to place the portable treatment facility, including timing of mobilization and demobilization.
3) Procedures and schedule for sampling and analysis of the water to be discharged.
4) Procedures and schedule for transport and disposal of treatment sludge.
5) Documentation and reporting procedures.
6) Spill mitigation and reporting procedures. J1
Office of
Mined Land Reclamation
Office of
Denver • Grand Junction • Durango Active and Inactive Mines