HYDRO30213

• Permit No: M1999002
• IBM Index Class Name: Hydrology
• Doc Date: 2/10/2000
• Doc Name: UIC INFO
• Media Type: D
• Archive: No

Soda as outlined in the Water Monitoring Plan. American Soda has outlined a number of key
response measures for process monitoring abnormalities. These would include the following: 1)
Pressure, flow, and temperature instrumentation would be checked for leakage; 2) Injection
activities would be discontinued, and fluid densities within the well would be balanced; 3) Tubing
strings, and annulaz areas would be pressure tested; 4) A temperature log would be run to check
for temperature changes above the mining interval; 5) The information collected above would be
evaluated to develop a solution; and 6) EPA (and any other regulatory authority who requires
notification) would be notified, per the specific requirements of the Permit, of the response data
and the proposed corrective action, if any.
If the monitoring data indicates a failure in mechanical integrity, the operator is required
to immediately notify EPA in accordance with Section E. 10. (C) of the Permit. Furthermore,
injection activities shall be terminated immediately and operations shall not be resumed until the
Permittee has taken necessary actions to restore integrity to the well and the Director gives
approval to recommence injection (Section C. 2. (D)). If adverse impacts do occur as a result of
the well failure, the Permit requires the operator to take all reasonable steps to minimize or
correct such impact (Section E. 4.).
In addition to the requirements for process monitoring to demonstrate mechanical
integrity, the operator is required to cant' out monthly monitoring of the Dissolution Surface, the
B-Groove, the A-Groove and the Umta at several locations. The locations and specific details of
this monitoring aze detailed in the revised Water Monitoring Plan, dated December 23, 1999,
which has been incorporated into this Permit. This monitoring will include, at least 5 quarters of
baseline data (taken monthly) prior to commencement of commercial mining. Additionally, the
operator will be measuring hydrostatic pressure at the Dissolution Surface in monitoring wells
using a pressure transducer system with an above ground electronic recorder. During commercial
operation, pressure measurements will be taken at least one a week at the Dissolution Surface.
Evidence of significant pressure deviations from the established baseline that cannot be attributed
to natural ambient conditions or equipment problems will be cause for the initiation of response
procedures. The monitoring plan provides the following response procedures: 1) The EPA and
other regulatory authorities will be notified within the next working day; 2) The integrity of the
pressure transducer will be evaluated; 3) Other Dissolution Surface monitoring systems will be
evaluated; 4) The mass balance data from nearby solution mining wells will be evaluated; 5)
Injection into solution mining wells with questionable mass balance data will be discontinued; 6)
Tubing, strings, and annular areas of the solution mining well(s) in question would be pressure
tested; 7) A temperature log would be run to check for temperature changes above the mining
interval for the solution mining well(s) in question; 8) The results of these data collected above
would be evaluated to develop a solution; 9) The EPA and BLM would be notified of the
response data and the proposed corrective action, if any. The EPA will determine if the response
plan is adequate and will require modifications as appropriate. The EPA will also evaluate the
transducer data on a regular basis to determine if more frequent data collection is necessary.
It is important to note that the solution mining process is highly dependent on maintaining
temperature and pressure in solution mining cavities. If there were a leak, there should be
significant changes in both temperature and pressure in the cavity. The cavity monitoring is of
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