PERMFILE54123

• Permit No: M1999002
• IBM Index Class Name: Permit File
• Doc Date: 6/18/1999
• Doc Name: OBJECTORS EXHIBITS
• Media Type: D
• Archive: No

of water and increased yr pressure to the groundwater syster~nitially through uncemented and
inadequately cased µ'ellbores.
yVcll Plugging
Solvay Process Company's ultimate successor, AlliedSignal Corporation, announced the c]osure
of the soda ash plant and the sale of four of the brine wells to another operator, LCP Chemicals, in 1986.
Although the legislative amendments passed in 1973 require plugging of all solution mining wells, the
compan}' proposed to plug only 20 and abandon the remainder. The Division of Mineral Resources
rejected this proposal, and AlliedSignal ultimatel}• plugged all 167 wells that could be found and safel}•
accessed, including the four that had been sold to LCP and abandoned in 1986. The wells plugged
ranged in age from ]0 to 100 years old. The Tull}' Valley well plugging project transformed
AlliedSignal's Solvay staff from a group with no solution mining well plugging experience to the team
with the most experience in plugging solution mining wells in Ne~v York, particularly old wells.
The goals of well plugging in Tull}' Valley were to:
1) eliminate the wells as potential conduits for groundwater mixing and aquifer
contamination,
2) stabilize the brine cavems t~ith respect to ~~•ater entry from the surface and/or shallow
aquifers, a-td
3) reduce the potential for future significant subsidence and sinkhole formation by reducing
or eliminating uncontrolled solutioning of soluble formations caused by water entry via
open wellbores.
Regui~oq~ Innovatioru.-Plugging of the first 31 wells between 1989 and 1991 revealed the difficulty
of plugging in an area that had been so extensively damaged by subsidence and fracturing. The
fofloµ~ng problems were common:
1) severe lost circulation zones, particularly in the limestone formations found 100 to 500
feet above the salt cavems,
2) extremely corroded or crushed and bent well casinos, increasing the difficulty of cleaning
out wellbores and/or removing pipe from the hole,
3) sheared µ•e11 casings, causing cieanout tools in the hole to exit the wellbore and begin
drilling rock, and
4) junk, rock, and other debris in the wellbores.
Because of the difficulties encountered during plugging the first 31 wells, a]ong with
disagreement between Division of 7`4ineral Resources staff and the compan}''s consultants regarding the
• effectiveness of plugging, .41IiedSignal initially declined to plug the remaining wells. Of major concern
to the company ~~as the unpredictable and possibly open-ended nature of the plugging vt•ork. The
company r~•as reluctant to commit to an unlimited agreement to plug all ~~•ells front just above the cavern
•• to the surface. The Division, however, vas un~tiilling to grant a blanket variance to standard solutior,
mining well plugging requirements. Experience vith the first 31 wells indicated that the amount of
subsidence at any given r~ell uas not a reliable predictor of plugging difficulty. This conclusion
supported the Division's position that waiver of ~~} requirements must be site-specific, based on actual
conditions encountered «hen the rig ~t•as over the hole.
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