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Sampling and analysis should be required and should include testing for all chemicals <br />and pathogenic microorganisms that could potentially exist in the tanks. <br />6. Powertech personnel are not qualified to develop procedures for cleaning and <br />decontaminating the storage tanks, to inspect the tanks and verify that no <br />residual chemicals or pathogenic microorganisms are present, and to ensure that <br />the injectate has not been contaminated. <br />The procedures for cleaning, decontaminating, inspecting, and maintaining the storage <br />tanks should be developed by someone with a professional background in microbiology, <br />toxicology, and disinfection/sterilization procedures. <br />Because of the numerous deficiencies in Powertech's proposal to store injectate in <br />potentially contaminated metal tanks, and the resulting risk of contamination of the <br />receiving aquifer, a final Class V UIC permit should be denied. Please call me if you <br />have any questions regarding these comments. <br />Sincerely, <br />James B. Woodward <br />4