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Natural Soda LLC/Daub'& Associates, Inc. — tllCPermltCitinl�ffrlent, Novembar 2015— Draft UICPa it #C030358O0000 <br />Rem* <br />ulc Pernik location <br />A co*flt ' <br />NS/D&i"n <br />Rid Revision <br />5 <br />Pagesentence <br />Section <br />Paragraph/ <br />36 <br />Pg. A-1 <br />SOB pg. 11 <br />Surface <br />2nd Paragraph <br />1st sentence <br />Casing requirements are too restricting to current NS operations, and do <br />not match those listed in Table 3.1 of the SOB or the supporting figure <br />shown on pg A-2. <br />Surface and Intermediate casing size ranges should be revised in the permit to reflect the <br />casing size ranges stated in the SOB Table 3.1 and the figure shown on pg A-2. <br />Correct hole/casing sizes are: <br />Intermediate — Hole Size 8.75 to 12.25 inches. Casing Size 7.0 to 9.625 inches. <br />Intermediate <br />3rd Paragraph <br />1st sentence <br />Surface/Conductor -- Hole Size 12.25 to 24.0 inches. Casing Size 9.625 to 19.0 inches. <br />37 <br />Pg. A-1 <br />Appendix A <br />5th Paragraph <br />Last sentence <br />Workovers and alterations to the casing should be more clearly defined <br />as they were in the previous NS UIC. <br />EPA should include the following wording as part of the Long string/Intermediate casing <br />requirements: <br />A workover or alteration shall be considered any work performed which affects the casing <br />above the L-5 Zone. <br />38 <br />Pg. A-1 <br />Appendix A <br />5th Paragraph <br />3rd sentence <br />"This section of injection liner will be suspended by a liner hanger and not <br />cemented in place." <br />The statement as shown above is too restrictive and does not allow NS all <br />necessary options that may be necessary to successfully complete or <br />recomplete a well. <br />Update to read: <br />This section of infection liner will be installed in the well through the use of a suspended <br />liner hanger or by other appropriate means and may be cemented in place if the well bore <br />conditions warrant such. <br />Appendix 8 <br />39 <br />Pg. B-1 <br />Appendix B <br />Data Table <br />9th table field <br />Wording in the Appendix B Table (Temp Log (Part II MI) Item 2) states the <br />first temperature log will be conducted between 60 to 90 days of <br />authorization to inject. The permit language is unclear regarding the <br />acceptable timeline for commencement of injection prior to receiving <br />authorization to inject. Once injection has commenced on a well pair, <br />injection needs to continue until sufficient cavity volume has been <br />achieved to avoid adverse effects on the condition of the well. <br />The EPA should modify the permit language and clarify timelines as follows: <br />2. First MIT (Part II) log will be conducted between 60 to 90 days from the start of iniection. <br />The EPA should add a provision that 4. The permittee requires prompt response regarding <br />authorization for iniection to avoid compromising the well pair. If no response is received <br />from the director within twenty four (24) hours of notification (phone/e- <br />mail/fax/mail/overnight carrier), authorization is approved and the permittee may begin to <br />Infect. <br />Appendix C <br />40 <br />Pg. C-1 <br />Appendix C <br />1st Table <br />* sentence below <br />table <br />The duplicate word - "and" should be removed from the following <br />sentence. <br />Approximate too and base of formations and will vary across Permit Area <br />41 <br />Pg. C-1 <br />Appendix C <br />3rd requirement <br />The previous UIC did not have a temperature limitation for the Boies Bed, <br />this UIC draft states Max temp of 300 deg. F which may be to low for <br />future NS operations. <br />EPA should allow the maximum allowed injection temperature of: 350 (degree Fl. <br />Appendix D <br />42 <br />Pg. D-1 <br />(SOB Pg. 14) <br />Appendix D <br />Injection Well <br />Table <br />Parameter 1,2,3,5 <br />Record frequency is stated in this table to be recorded and calculated <br />weekly. The SOB (page 14) indicates the record frequency to be monthly. <br />The EPA should revise the table entries to indicate a monthly record frequency of mass <br />balance calculations and a monthly calculation of mass balance and min/max temperature, <br />pressure, and flow rate. <br />Daub & Associates, Inc. <br />Page 5 of 6 <br />UIC Draft Comments - November 2015 <br />