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Other historic documents demonstrate that other companies drilled substantially more <br />numbers of wells in the area in the 1970s and 1980s, including Rocky Mountain Energy, who <br />reported to the State of Colorado in 1982 that it drilled some 2,142 holes in the area, including in <br />the section proposed for the injection permit (attached as exhibit 11). There is little data on the <br />abandonment procedures used in these wells, but one might assume they consisted of similar <br />techniques that were standard at the time that gave rise to the State of Colorado's concerns with <br />respect to aquifer communication and contamination with the Mobil project wells. In any case, <br />the EPA should require the applicant to provide all information regarding these wells, any <br />abandonment information, and require repair and proper closure prior to any injection <br />authorization. <br />In addition, the applicant's own documents demonstrate that there have been problems <br />encountered with abandonment procedures at historic drill holes. In an August 2007 Powertech <br />(USA) Inc. "Activity Update" (attached as exhibit 12), the company recounts its experiences in <br />discovering and attempting to repair broken well casings that appear to have been improperly <br />abandoned in the first instance. As stated by the applicant: <br />Some wells were broken off at ground surface during the intervening 20 plus years. We <br />have attempted to locate wells with GPS system and hand digging. Some wells we could <br />not locate this way and we used a backhoe to find the buried well. We gently raked 4 <br />inches at a time searching for the casing. We did not break any wells with our backhoe. <br />The photos found on some websites are actually jagged broken casings that were buried <br />for 20 plus years. <br />Further, Powertech is on record in a letter dated October 16, 2007 from Mr. Richard <br />Blubaugh, Powertech (USA) Inc. to Mr. Jim Woodward, www.powertecheaosed.com (excerpt <br />attached as exhibit 13) overtly recognizing the problems associated with historic well <br />abandonment procedures in defending assertions that it or its contractors were responsible for <br />leaving open well casings: <br />15