GENERAL36036

• Permit No: M1999002
• IBM Index Class Name: General Documents
• Doc Date: 4/24/2002
• Doc Name: Approval of a Minor Modification
• From: EPA
• To: American Soda LLP
• Media Type: D
• Archive: No

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~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8
e"'+< 999 18T" STREET -SUITE 3D0
DENVER, CO 80202-2488
Phone [phone]
http:llwww.e pa.gov/regio n08
Ref: 8P-W-GW
ADDENDUM TO THE
STATEMENT OF BASIS
MINOR PERMIT MODIFICATION
EPA FINAL PERMIT
C03858-00000
AMERICAN SODA LLP.
XANKEE GULCH SODIUM LEASE
RIO BLANCO COUNTY, COLORADO
On Mazch 27, 2002, American Soda LLP requested a modification of their Class III
Permit to allow the addition of a limited amount of Lithium to the injection stream of several
cavities to test cavity fluid residence time. The modification of the Permit for changes in injected
fluid is allowed as a Minor Modification under 40 CFR 144.41 (e).
Lithium chloride is presently part of the injection stream at a concentration of about 8
parts per million (ppm). The applicant proposes to add up to 167 pounds of lithium chloride per
test to the fluid stream of each of six wells over a one hour period. This will increase the
injection liquor concentration by about 300 ppm. Once injected, the lithium chloride will mix
with approximately 4 million gallons of cavity fluid. Depending on the degree to which mixing
occurs, the lithium chloride concentration of the mixed cavity fluid will be increased by 0.8 to 4
ppm. The production fluid will be monitored over several days to detennine the turn azound for
the lithium tracer. The following six wells will be tested using the lithium chloride tracer:
1. We1128-21: C03858-04567
2. We1120-36: C03858-04562
3. We1120-31: C03858-04558
4. We1120-74: C03858-04563
5. We1129-28: C03858-0457$
6. We1121-16: C03858-04565.
Only two cavities will be tested at any one time. A maximum of 16 tests maybe needed
to test all of the variables that may affect flow within a cavity. Once completely mixed the
lithium chloride concentration of the production stream will be raised by only 0.04 ppm by each
test. After completion of the 16 tests for the cavity, the lithium chloride concentration will be
increased by about 0.64 ppm. This concentration will be reduced rapidly as it mixes with fluid
from the other cavities. Because the lithium chloride is not rejected by the soda ash and
bicarbonate crystals, it will ultimately leave the process stream as product.
Addendum to the Statement ofBasis-EPA FINAL PERMIT C03858-00000
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