2015-11-30_HYDROLOGY - M1983194 - Laserfiche WebLink

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Natural Soda LLC/Daub & Assodates, Inc. — UIClie rnfit Comment, November 201S— Draft !!IC Penult *C030358-00000 Ran 4 UIC Penn@ Location - NS/b&A Comment - Requested Revision Pap 4 Section Pereira./ Semana 15 SOB Page 13 Mechanical Integrity (40 CFR 146.8) 4th Paragraph 5th sentence The MIT Part II temperature survey will be required on both injection and recovery strings. No MIT requirements are currently in place or identified elsewhere in the permit for recovery wells. The EPA should omit the following sentence from the SOB: The temperature survey will be required on both production and iniection strings. 16 SOB Page 14 Mining Interval Monitoring 1st Paragraph 1st Sentence Replace "2,000" with "3,000" For the recovery of nahcolite, directionally drilled horizontal injection or recovery wells may vary in horizontal length from 600 feet to 3.000 feet, the thickness and width ranges from 30- 40 feet and 90-120 feet, respectively. 17 SOB Page 14 Subsidence Monitoring 3rd Paragraph Last Sentence This sentence is unclear as to the meaning and intention and should be omitted from the SOB. The EPA should omit the following sentence from the SOB: Additional discussion on the aquifer exemption is discussed in the proposed Record of Decision. 18 SOB Page 17 Part VII 1st Paragraph 1st Sentence Replace "production" with "recovery" Additional new injection and recovery wells may be added to the area permit as necessary pursuant to 40 CFR § 144.33, provided the Permittee provides notice to the Director. 19 SOB Page 18 Part VIII lst Paragraph 2nd Sentence Omit sentence if MIT prior to P&A is omitted from Appendix A (see comments for Appendix A) The EPA should omit the following sentence: If remained in place. the Mechanical Integrity Test shall be run after attempts have been made to pull the liner. UIC Aquifer Exemption 20 Aq. Exempt Pg.1 (SOB pg. 10) Table 1.1 (SOB Table 2.4) 1st entry The TDS range in Table 1.1 is incorrect with the actual TDS range being 2,400 - 140,000. TDS range description in the SOB text indicates these values can be well in excess of the currently stated range, see SOB pg 9. EPA should update the TDS range to the correct values of 2,400 mg/I - 140,000 mg/1. Acknowledging max TDS has potential for values in excess of 10,000 mg/I. UIC Permit 21 Cover Letter Address All correspondence should be addressed to Mr. Kirk Daehling, Natural Soda LLC EPA should remove Mr. Bob Warneke, Natural Soda, Inc. and replace with Mr. Kirk Daehling, Natural Soda LLC Part 11. Specific Permit Conditions 22 Permit pg. 8 Section C - 5 bullet point list Draft UIC allows only depleted solution, fresh water from the A-Groove, and water from the process pond to be recycled to the injection wells as part of the solution mining process. Allowance for additional fresh water sources may be necessary for successful mining. Insoluble components which are removed from the mining interval as part of the mining process may be reinjected to the mining interval prior to plugging and abandoning a well to help stabilize the formation. EPA should add a statement allowing NS the following: • depleted solution mining production fluid from which the bicarbonate/carbonate content has been mostly removed. This fluid is recycled to the injection wells as part of the solution mining process; and • fresh water pumped from the A-Groove Aquifer or other fresh water source used as make- up water; • make-up water from the process pond. • infection of recovered insoluble material from formation to aid in the stability of a cavity. 23 Permit pg. 8 Section C 6 1st Paragraph 2nd Sentence NS requires prompt response for approval from the Director to allow for timely completion of necessary work. Early in the development of a cavity, the potential exists to cool off and plug the flow path through the cavity rendering the well pair permanently inoperable. EPA should add a statement as follows: Additionally, the Director's approval must be obtained if the addition or physical alteration to the injection well modifies the approved well construction found in APPENDIX A and any subsequent modifications. The Director will respond to the permittee within twenty four (24) hours of receiving notification followed by written approval. If no response is received from the director within twenty four (241 hours of notification (phone/e-mail/fax/mail/overnight carrier), the permittee has authorization to proceed with proposed operations. Daub & Associates, Inc. Page 2 of 6 UIC Draft Comments - November 2015