REVISION - 3/5/2010, 7:10:37 AM-JWD

• Permit No: P2008043
• IBM Index Class Name: REVISION
• Doc Date: 3/4/2010
• Doc Name: Third Review
• From: DRMS
• To: Powertech ‎(USA)‎ Inc.
• Type & Sequence: MD3
• Email Name: ACS
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY 7/ STATE OF COLORADO
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
March 4, 2010 I,?
Mr. Richard Blubaugh
0 Powertech (USA) Inc.
5575 DTC Parkway, Suite 140
Greenwood Village, CO 80111
(COLORADO
DIVISION OF
g CONFITIAL RECLAMATION
Vi® MINING
SAFETY
Bill Ritter, Jr.
Governor
( James B. MB. Martin
Executive Director
RE:. Centennial Project, Third Review of Notice of Intent Modification MD-03, File No. P-2008-043
Dear Mr. Blubaugh:
The Colorado Division of Reclamation, Mining, and Safety (DRMS) has reviewed Powertech's submittal dated
February 2, 2010 responding to DRMS second review of proposed modification MD-03 to Notice of Intent to Conduct
Prospecting P-2008-043, and has determined that there are several issues remaining to be addressed. Please respond to
the following items at your earliest convenience bearing in mind that if you have not addressed these items within sixty
days of the date of this letter the DRMS may terminate consideration of the proposed modification (Rule 5.1.3 of the
Mineral Rules and Regulations of the Mined Land Reclamation Board).
The initial submittal of MD-03 received by DRMS on September 2, 2009 and the subsequent submittals from
Powertech dated October 28, 2009 and February 2, 2010 describe a number of actions to be taken to ensure that the
tanks deployed to the pump test site will be suitable for storage and subsequent injection of ground water pumped from
well IN08-33-PW1. DRMS has determined that reporting and verification procedures are not sufficiently described;
please commit to completion of the following actions prior to deployment of the tanks.
1. Powertech's October 28, 2009 submittal states:
All cleaning and inspection procedures outlined in the Powertech Produced Water Vessel Cleaning and
Inspection Procedure will be adhered to and will be certified as complete before water containment vessels
are brought on the site. All manifolds valves and transfer pumps will be cleaned as described in the
attached procedure. Additionally piping will be new and National Sanitation Foundation or otherwise
certified for potable water.
Provide a commitment to provision to DRMS of the certifications described in the preceding statement and a
commitment that the tanks will not be used to store produced ground water until after the certifications have been
accepted by DRMS in writing.
2. Powertech's October 28, 2009 submittal states "(i)nitially natural background radiation levels shall be
measured and recorded" at the pump test site, and that "(r)adiological measurements using an alpha and gamma probe
shall be conducted on the containment vessel before it is utilized onsite and, again, after onsite use; all readings will be
documented on the appropriate Powertech form." Provide a commitment to provision to DRMS of the results of these
required radiological measurements and a commitment that the tanks will not be used to store produced ground water
until after the results have been accepted by DRMS in writing. Provide a commitment to notify DRMS in advance of
the schedule for collecting the radiological measurements, as DRMS may opt to inspect and audit the procedures.
3. Powertech's February 2, 2010 submittal states "Rain for Rent keeps a detailed history of the previous contents
of tanks. The water holding tanks to be used by Powertech and provided by Rain for Rent will have been previously
used to contain water only, at least back one tank use event." Provide a commitment to provision to DRMS of Rain for
Rent's detailed history of the previous contents of tanks, at least back one tank use event, and a commitment that the
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