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Minor Permit Modification No. 6 to Parf II, Section 1 of EPA Final Area Permit No. CO3858-00000 <br />covers operating parameters that reflect stabile cavity operation under normal operating <br />conditions and what variation in parameters could occur before some corrective action is to <br />be taken. <br />These parameters and procedures are very acceptable and practical under normal <br />operations in which the well is in equilibrium and pressures and temperatures are being held at <br />constant values. To transition a well from normal operations to a depressurized standby status <br />requires that for an extended period of time each well will be operated in a not normal <br />operating mode. <br />Even though the permit states that these parameters are to be complied with during normal <br />operation there are no provisions in the permit for parameters out side of normal operation, ie, <br />decreasing cavity pressure, decreasing temperature in the cavity or increasing either <br />temperature or pressure any of which will create either a positive or negative <br />injection/production flow balance until equilibrium is reached. The larger the cavity the longer <br />the time required to reach equilibrium since the design of the cavities is such that the injection <br />and production flows are injected and removed from opposite ends of the cavity. <br />Since there are no provisions for operations out side of normal in the Permit, American Soda is <br />making notification to the Director in accordance with Part III, E, 10, (a) Anticipated <br />Noncompliance., that transitioning wells from normal operation to depressurized stand by may <br />result in noncompliance with Permit requirements. <br />Should you have any questions or require more information concerning this matter please <br />contact me at 970-285 -0407. <br />Si~nc/ere <br />~1//" ~ <br />Ed Cooley <br />Environmental Health <br />and Safety Manager <br />cc: Kent Walter/BLM <br />Erica Crosby/CDMG <br />