GENERAL56541

• Permit No: M1999002
• IBM Index Class Name: General Documents
• Doc Date: 12/16/2002
• Doc Name: Report and Explanation of Fluid Flow Imbalance in two solution wells
• From: American Soda LLP
• To: DMG
• Media Type: D
• Archive: No

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AMERICAN
SODA, LLP
RECEIVED
Ed Cooley
Environmental Safety and
Health Manager
2717 County Road 215
PorachuTe. CO 81635
Friday, December 13, 2002
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DEC 162002

Division of Minerals and Geology
ENV 144.02
Mr. Paul Osborne
U.S. Environmental Protection Agency
Region VIII
Mai I Code 8P-W-GW
999 18'" Street, Suite 500
Denver, Colorado 802022466
Dear Paul:
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Direct Line [phone]
International Telephone [phone]
General Facsimile [phone]
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American Soda has investigated the issues surrounding the imbalance of flows on
Well 20-36 EPA# C03858-04562 and Well 29-24 EPA# C03858-04572.
The flow imbalance in Well 29-24 was due to an inaccurate injection flow meter, This problem
has been corrected by replacing the meter. During the time the meter was out of range the
pressure monitoring of the well indicated that there was no indication of loss of product or
gain of liquid from any outside source. The imbalance indicated more production than
injection flow and the pressure in the cavity is sufficiently high that back flow from an external
source would be highly unlikely. This meter was changed out on November 8, 2002 and the
balance has averaged approximately 2qo since that time. American Soda has also performed
an online Mechanical Integrity Test on this well to verify Casing and Annulus integrity. The
positive fluid balance was due to an inaccurate flow measurement of the injection meter on
well 29-24.
The flow imbalance for Well 20-36 during the month of September, 2002 was due to a glitch in
the data recovery from our PI Server. Periods of time when the well was by passed and a
minimum flow was maintained in the surface well piping to protect from freezing was not
segregated from the operating data, creating an incorrect balance. A corrected section for
the September 2002 portion of the Quarterly Report will be provided. This was not reported as
a 15 % imbalance as required by the Commercial Mine Plan since the glitch did not occur in
the well field operations daily data but at a later time when the reports were being prepared.
We are currently scanning our entire data collection system and spread sheet calculations in
an effort to detect and eliminate any similar situations. Should we find other cases of this
occurrence we will notify the agencies and provide corrected documentation. An on line
Mechanical Integrity Test has been preformed on this well to assure integrity of the Casing and
Annulus,