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Sc~~ s ~,/ <br />,~ s.,,~ <br />.''A s. L~j~~ <br />UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />a oao+E~'A= REGION 8 <br />999 18T" STREET -SUITE 300 <br />DENVER, CO 80202.2466 <br />Phone 800.227-8917 <br />http://www.epa.gov/region08 RECEIVED <br />JAN - 8 2Q03 ~N ~ 0 2C03 <br />Ref: 8P-W-GW <br />Oivisien of Minerals and Geolosy <br />CERTIFIED MAIL <br />RETURN RECEIPT REQUESTED <br />Mr. Ed Cooley <br />Environmental, Health <br />& Safety Manager <br />American Soda, L.L.P. `~'O <br />2717 County Road 215 <br />Parachute, CO 81635 <br />m-(999-~(~- <br />RE: UNDERGROUND INJECTION CONTROL (iJIC) <br />Minor Permit Modification No. 5 <br />dlincrease Maximum Allowable Injection Pressure <br />(MAIP) Three (3) Class III Solution Mining <br />Wells, EPA Area Permit No. C03858-00000 <br />Rio Blanco County, Colorado. <br />Dear Mr. Cooley: <br />We are in receipt of your letter dated December 5, 2002, regarding your continuing efforts <br />to modify the maximum authorized injection pressure (MAIP) by performing step pressure tests <br />to demonstrate that injection pressure could be increased from 700 psi to 800 psi in operating <br />wells without causing formation fracturing. These cavities were tested using American Soda's <br />test procedure (August 29, 2001, letter from Ed Cooley} that was initially approved by EPA on <br />September 10, 2001. The EPA approved procedure, was tested on we1120-30 (EPA # 003858- <br />04557) on September 26, 2001. This test procedure (with some approved modifications) was <br />found to be adequate to demonstrate that the formation fracture pressure would not be exceeded <br />at a higher pressure. American Soda submitted a revision of pages 3-3 and 8-5 of the Yankee <br />Gulch Sodium Minerals Project Commercial Mine Plan to the BLM on December 12, 2001. <br />This revision which incorporates this pressure test procedure and the new maximum injection <br />pressure into the mine plan was approved by the BLM on February 27, 2002. Prior to increasing <br />the MAIP of a well, an EPA approved step pressure test must be completed. Initially, tests were <br />proposed for the following wells: <br />Page 1 of 6 <br />pia Pdnted on Recycled Paper <br />