Laserfiche WebLink
analyses greater than 30,000 mg/liter. Although the USA 1-1 LW well is located nearby, a review <br />of all available data by EPA indicates that the sample from this well is probably not representative <br />of the Cozzette and. Corcoran sands as the well is also perforated into the overlying Rollins <br />Member and into sand zones of the Williams Fork Formation. In any case, the TDS value of fluids <br />from the USA 1-1 LW is also indicative of anon-USDW. <br />American Soda has submitted all required information and data necessary for permit <br />issuance in accordance with 40 CFR Parts 124, 144, 146, and 147, and a draft permit has been <br />prepazed. The permit will be issued for a period of ten (IO) years, no reapplication will be <br />necessary during this period, unless the permit is terminated for reasonable cause (40 CFR 144.39, <br />144.40 and 144.41). However, the permit will be reviewed aRer five years of operation, and the <br />results of the review will be used to determine if changes in the permit are needed. <br />This Statement of Basis (SOB) gives the derivation of the site-specific permit conditions <br />and reasons for them. The referenced sections and conditions correspond to the sections and <br />conditions in EPA Permit C010932-04664. The general permit conditions for which the content <br />is mandatory and not subject to site specific differences (based on 40 CFR Parts 124, 144, 146 and <br />147), are not included in the discussion. <br />Part II, Section A WELL CONSTRUCTION REQUIREMENTS <br />Cosine and Cementing <br />(Condition 1) <br />All casing and cementing details were submitted with the permit application and are <br />incorporated into this permit as part of Appendix A which graphically displays the details of the <br />injection well under consideration. The Getty No. 1-7LW is an existing Class II injecfion well that <br />and is presently regulated by the Colorado Oil and Gas Conservation Commission. The permittee <br />intends to convert the injection welLto aClass Inon-hazardous disposal well in the following <br />manner: T <br />(a) SURFACE CASING (8-5/8 inch) is set in a 12-1/4 inch diameter hole to a depth <br />of 31 l feet into bedrock. The casing is secured with cement which has been <br />circulated to the surface with 300 sacks of cement, isolating the casing from the <br />wellbore. <br />(b) LONG STRING CASING (4-112 inch) has been set in a 7-7/8 inch diameter hole <br />to a depth of approximately 4,364 feet KB and cemented from TD to approximately <br />3,240 with 350 sacks of 65/35 Posmix. An EPA review of the of the original <br />cement bond log indicates that there is cement from about 3,240 to TD, but the <br />1981 log lacks sufficient detail to allow a detailed analysis of the cement quality <br />and bonding. The 1981 CBL was conducted with a single receiver that is not as <br />reliable as current methodologies. A casing leak was repaired in September 2001 <br />by squeezing the interval from 617 feet to 682 feet with 237 sacks of cement and a <br />casing leak was squeezed from 2,460 feet to 2,525 feet with 350 sacks in August <br />Statement of Basis for EPA Permit No. CO 10932-04664 Page 5 of 18 <br />