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James B. Woodward <br />P.O. Box 599 . <br />Wellington, Colorado 80549 <br />970-897-3029 <br />jbwA,frii.com <br />SENT VIA EMAIL <br />July 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.valoisAepa. ov <br />Subject: Comments on UIC Class V Draft Permit Issued to Powertech (USA) Inc. <br />Dear Ms. Shea: <br />Thank you for considering these comments on the draft underground injection control <br />permit issued to Powertech (USA) Inc. for a proposed Class V well to be located on <br />Section 33, Township ION, Range 67W in Weld County, Colorado. <br />The draft permit has several material deficiencies with respect to the protection of <br />underground sources of drinking water, and a final permit should not be issued. <br />The applicant has not defined the area of the aquifer expected to be affected by the <br />proposed pump test and subsequent injection operation. The applicant has conducted <br />other pump tests in the Centennial Project area and in South Dakota, and has data <br />indicating the approximate areas affected by the tests. The applicant did not include <br />these data or an estimate of the area potentially-affected by the proposed injection <br />activity in its permit application. <br />As the applicant has publicly stated, water quality in the proposed mining area is highly <br />variable due to the presence of uranium roll-front deposits. According to EPA staff, the <br />proposed injection well would be drilled into a uranium ore body. Multiple water <br />samples should be taken in a valid statistical manner through the entire thickness of the <br />aquifer to develop an accurate characterization of the water quality in the area affected by <br />pumping and injection. <br />5