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

Sorenson, Allen
From: Ed Cooley [[e-mail]]
Sent: Monday, December 09, 2002 3:41 PM
To: '[e-mail]'; Robert Miller; Ed Cooley; [e-mail];
Jackson.DanC~epamail.epa.gov; paul_daggettC~co.blm.gov; Sorenson, Allen
Cc: Hogle.DavidC~epamail.epa.gov; Phillips.KenC~3epamail.epa.gov; Smith.Robert-
EuC~3epamail.epa.gov; [e-mail]
Subject: RE: Out of Balance Caverns-Note to Files
Paul,
I had planned to have a report out on this by 12/6/02,
but, we are going back through all of the data in detail to assure ourselves
that there are no errors in the compilations or calculations.
I will have this report in the mail by close of business on Thursday
December 12, 2002.
Sorry for the delay
Ed Cooley
-----Original Message-----
From: [e-mail] [mailto:[e-mail]]
Sent: Friday, November 22, 2002 9:21 AM
To: [e-mail]; [e-mail];
[e-mail]; [e-mail];
pau [e-mail]; Sorenson, Allen
Cc: [e-mail]; [e-mail];
Smith.Robert-Eu @epamail.epa.gov; [e-mail]
Subject: Out of Balance Caverns-Note to Files
Ed
This is a follow-up to our phone call on the 20th of November regarding two
caverns that are showing what to us is a significant out of balance
condition. Your recent monitoring report indicates that cavity 20-26 is out
of balance by a negative 16.56 percent. On the 18th, we had discussed that
the action level for possible failure is considered to be 15~. The
monitoring report, however, does not indicate if you have commenced the
process for addressing this condition.
We also noted that cavern 29-24 has an out of balance of by a positive 14,18
percent Although this is a positive value that is below the apparent action
level, it appears to be significant when compared to other caverns. This
bring up a question: is the criteria in the Mine Plan adequate? Based on
the snapshot of the most recent monitoring report, it appears that the
action number should be lower. I am of the opinion that the criteria should
be around 10 percent (negative) based on a review of the majority of the
operating cavity fluid balances. Although the EPA Permit does not presently
contain a specific criteria for defining when an out of balance condition
warrants further action, I am seriously considering recommending that we
have a minor modification of the Permit to include such a provision.
I am also concerned about the high positive value, but am uncertain what
would create this situation. Zs this indicative of a cooling of cavity
fluid? Zs it possible that the operation at the cavity intersected an
aquifer that is now contributing water to the production well? Could you
provide us with some additional information regarding the potential cause
for a large positive fluid balance"?
A major reason for many of the monitoring requirements in the Permit, such
as the requirement to determine the mass balance, was to ensure that caverns
were stable during and after mining was complete. When the cavern balance
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