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James B. Woodward <br />P.O. Box 599 <br />Wellington, Colorado 80549 <br />970-897-3029 <br />ibwAfrii.com <br />SENT VIA EMAIL <br />December 24, 2009 <br />Valois Shea <br />U.S. Environmental Protection Agency Region 8 <br />8P-W-GW, UIC <br />1595 Wynkoop Street <br />Denver, CO 80202 <br />shea. valois(& epa. gov <br />Subject: Comments on UIC Class V Draft Permit No. C051237-08412 Issued to <br />Powertech (USA) Inc. and dated October 2009 <br />Dear Ms. Shea: <br />Thank you for the opportunity to comment on the draft underground injection control <br />permit issued to Powertech (USA) Inc. for a proposed Class V well located in Section 33, <br />Township ION, Range 67W in Weld County, Colorado. <br />I hereby incorporate by reference my attached comments dated July 24, 2009 and all of <br />the public comments submitted in this comment period, to the extent such comments <br />address issues or detail facts or evidence not included in my comments. <br />1. The receiving aquifer is potentially endangered by storage of the inj ectate in <br />metal tanks which may have been used to store hazardous waste. <br />Powertech proposes to store water produced by the pump test in several large metal tanks <br />rented from Western Oilfields Supply Company (doing business as Rain for Rent.) The <br />corrugated steel tanks, measuring 36 feet long by 8 feet wide by 11 feet high, are rented <br />to oilfield companies, refineries, chemical plants, industrial companies, construction <br />contractors, utilities, and government agencies. The tanks are used to temporarily store a <br />variety of fluids and liquid wastes, some of which contain hazardous chemicals, toxins, <br />and pathogenic microorganisms. <br />While Powertech proposes to clean and inspect the tanks prior to their use for storage of <br />injectate, the proposed procedures for preventing contamination of the injectate are <br />deficient.