Laserfiche WebLink
The following general circumstances may indicate well failure or instrumentation error <br />during normal well operations: <br />1) the pressure differential (difference between inlet and dischazge pressure) <br />increases, but the concentration of nahcolite in the production fluid does not <br />increase; <br />2) the volumetric flow rates of the injection fluid and production fluid differ by <br />greater than 15 percent; <br />3) the cavity temperature does not increase as the injection fluid temperature <br />increases; <br />4) the cavity temperature increases, but the concentration of nahcolite in the <br />production fluid does not increase; and <br />5) the pressure in the cavity decreases with a corresponding decrease in production <br />fluid flow. <br />The relationships listed above aze general rather than given specific numerical values <br />because of the synergistic effects of multiple variables. Furthermore, subsurface geology varies <br />somewhat across the Piceance Site. Although These variations aze small, they can affect sensitive <br />parameters such as flow, pressure, and temperature. It was decided at the January 29, 2003, that <br />the Yankee Gulch Permit would be modified under the provisions of 40 CFR 144.41 (b). This <br />minor modification of Part II, Section D. 1 of the Permit would establish a formal review, <br />notification and response process to be followed when the monitoring data indicates that a <br />potential problem might be occurring. As a result of the agreements made at the January <br />meeting, American Soda sent a February 7, 2003, letter to EPA outlining the results of the <br />meeting. <br />Minor Modification to Part II, Section 1 of the Permit <br />As a result of the review of the information submitted by the operator, the following <br />requirement is being added to Section 1 of the Permit: <br />Should any of the following conditions exist for a ninety six hour (96 hr) duration during <br />normal well operations a corrective action process shall be initiated. The conditions that <br />will initiate corrective action are: <br />a. the pressure differential (difference between inlet and dischazge pressure) <br />increases, but the concentration of nahcolite in the production fluid does not <br />increase; <br />b. the volumetric flow rates of the injection fluid and production fluid differ by <br />greater than 15 percent; <br />c. the cavity temperature does not increase as the injection fluid temperature <br />increases; <br />d. the cavity temperature increases, but the concentration of nahcolite in the <br />production fluid does not increase; or <br />Page 2 of 3 <br />