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CNAP~ERFOUR. <br />Responses to Public and Agency Comments <br />Letter and i <br />Comment No. Response <br />intermediate casing would be cemented back to the surface with heat <br />resistant cement (silica flour added). American Soda kuu used tremmie- <br />line cementing with good results during the test phase. The principal <br />benefit of the tremmie line method relates to cementing through lost <br />circulation zones. The lower aquifer zone tends to be an area of lost <br />circulation. Using a conventional cement job, the cement is forced up <br />the annulus and there is potential for the cement to be :lost as it enters <br />the lost circulation zone. Obtaining ahigh-quality cement job in and <br />above a lost circulation zone can be difficult and methods to mitigate a <br />poor cement job aze possible but limited. The tremmis line method <br />allows the positive placement of the cement and also allows the <br />placement of different strength cements (or cement mixes) at specific <br />locations. <br />During a conventional cement job, the bottom section of the hole is <br />exposed to a high hydrostatic pressure due to the weight of the cement <br />(14 to 15 poundslgallon). The hydrostatic pressure of the cement can <br />break down the formation and the cement may not circulate properly. <br />The tremmie line method places cement in lifts in the :mnulaz space <br />between the casing and the wellbore. Using lifts minimizes the <br />hydrostatic pressure placed on the formation by the weight of the <br />cement. After each lift, the cement is tagged, the tremmie line <br />positioned, and another lift is performed. This allows a controlled <br />method to place the cement until complete cement fill is achieved. <br />Tremmie line cementing is more costly and time consruning than <br />conventional cementing. However, American Soda's experience at this <br />site indicates that it produces ahigh-quality cement job and may be <br />better in many instances than conventional cementing through the <br />wellbore. The cementing program would be provided in the APD and <br />approved by BLM on a per well basis. <br />e. A cement bond log and a temperature log would be run to determine the <br />adequacy of the cement job on the intermediate casing. If it is <br />determined that the cement job is not adequate the BLM would require <br />that American Soda perform remedial cement work to attain an <br />adequate cement job. <br />F-2.5 American Soda has not applied to the BLM to use the cavities for waste <br />disposal. The recycled water to be used as the injection fluid is a weak <br />brine and several streams from processing may be in the r~,cycled water. <br />Based on the test phase data, American Soda does not intend to use the <br />cavities directly for disposal of wastes. The recycled water would be the <br />fluid used in mining and no provisions have been made for separate storage <br />4~ <br />