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/1 gy_ DD~f <br />~«~,~~ <br />_~ <br />Ref: 8ENF-UFO <br />LIAR Z 6 2004 <br />CERTIFIED MAIL 7002-0860-0005-3834-8538 <br />RETURN RECEIPT REQUESTED <br />Mr. Ed Cooley <br />V}}'~~e President, Strategic Development & Environmental Affairs <br />(/American Soda, LLP <br />2717 County Road 215 <br />Pazachute, CO 81635 <br />R//ECEIVED <br />BAR 7.9 2004 <br />Diriaion of Minerals & Gealopy <br />Re: Underground Injection Control (UIC) <br />Notice of Violation: <br />Loss of Mechanical Integrity <br />Well No. 21-16 and Its Cavity <br />EPA Permit No. C030858-04565 <br />Rio Blanco County, Colorado <br />Deaz Mr. Cooley: <br />On March 16, 2004, EPA learned via telephone that the American Soda injection well or <br />its mining cavity, referenced above, lost mechanical integrity on Mazch 15, 2004, as evidenced <br />by a strong imbalance condition measuring well input vs. output. As you report, the input into <br />the well remained the same while the output from the well fell to neazly zero. Pursuant to the <br />above-referenced UIC Pennit and Title 40 of the Code of Federal Regulations (40 CFR) Section <br />144.51(q)(1), you must establish and maintain mechanical integrity. A loss of mechanical <br />integrity is a violation of this requirement. <br />Pursuant to the above-referenced UIC Permit and 40 CFR § 144.51(q)(2), you must <br />immediately cease injection into this well, if you have not already done so. Before injection may <br />resume you must demonstrate that the well has mechanical integrity by passing a mechanical <br />integrity test (MIT) and receive written authorization from the Director. <br />Within thirty (30) days of receipt of this letter please submit a letter describing what <br />action you intend to take regarding the well, including a time frame in which you anticipate the <br />work to be completed. <br />If you choose to plug and abandon this well, a plugging and abandonment plan must.be <br />submitted to EPA.for approval prior to the plugging operation. <br />~~~ <br />UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />REGION 8 <br />999 i8T" STREET -SUITE 30D <br />DENVER, CO 80202-2466 <br />~Pnnted on Recycled Paper <br />