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~ .JUN-21-1999 11 07 •~ ERRL CHEMICRL •~ 201 515 19[35 P.09i09 <br />., ]east 12 months prior to entering a new panel so the data can be scrutinized and the <br />proper monitoring constraints developed. <br />8. The EPA draft permit does not mention or identify We1120-6, the American Soda high <br />TD5 fluid disposal well. This should be included as part of the discussion in the <br />Statement of Basis, permit application and draft permit, <br />9. Perched aquifers are kttown to exist in surrounding azea to the American Soda sight <br />which suggests the potential for perched aquifers in the American Soda mining area. <br />How will American Soda monitor the drilling and hydrogeologic system to accurately <br />detect the presence of perched aquifers in any future drilling operations, especially <br />those located west and northwest of the experimental pilot-plant operations? What is <br />the EPA's position regarding the potential for perched aquifers and how will the EPA <br />ensure the protection of these aquifers? <br />10. Por mechanical integrity testing and annual cement bonding performance, does the <br />frequent movement of rubulars in and out ur up and down inside the intermediate <br />casing constitute a "major alteration or workover?" <br />11. Will the intermediate string of casing be centralized in the welt bore with the placement <br />of periodic centralizers to ensure an adequate cement job? If not, what techniques will <br />be employed to ensure an adequate or acceptable cement job is performed? <br />12. As part of American Soda's plans for plugging and abandoning a production well, a <br />cement basket inside the casing or well bore will not be of sufficient durability or <br />strength to withhold or hold the weigh[ of the overlying cement. At a minirreum, a cast <br />iron bridge plug should be used. We do not agree with the method suggested to plug <br />and abandon these welts, <br />TOTRL P.09 <br />