2008-08-28_ENFORCEMENT - M1983194

• Permit No: M1983194
• IBM Index Class Name: ENFORCEMENT
• Doc Date: 8/28/2008
• Doc Name: EPA issues violation
• From: United States Environmental Protection Agency
• To: Natural Soda, Inc.
• Email Name: SSS
• Media Type: D
• Archive: No

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
9. The wells subject to this action are Class III solution mining injection wells. The
purpose of the solution mining is to produce the mineral nahcolite by injecting a
liquid lixiviant at approximately 1925 feet below surface, recovering the brine
rich in dissolved nahcolite via wells, and extracting the desired nahcolite at the
surface. The wells are located in Rio Blanco County, Colorado. The specific
wells subject to this complaint and their locations are:
10
Well Name EPA Permit No. Location
SH C030358-04668 T1 S, R98W, Section 26, SW/4, SE/4
6H C030358-04679 T1S, R98W, Section 26, NE/4, SW/4
These wells are authorized under an area permit issued to Respondent by EPA
Region 8, effective December 4, 2003, which has no expiration date.
11. Respondent is a Colorado company in good standing and incorporated under the
laws of the State of Colorado. Respondent's principal office address is 3200
County Road 31, Rifle, Colorado 81650, with telephone number [phone].
12. Respondent is a "person" within the meaning of section 1401(12) of the Act,
42 U.S.C. § 300f(12) and 40 C.F.R. § 144.3.
13. Pursuant to 40 C.F.R. §§ 144.3 and 146.3, "Director," as used in 40 C.F.R. parts
124, 144 and 146 and as applied in this matter, means the Regional Administrator
of EPA Region 8 or his or her authorized representative.
14. 40 C.F.R. Part 144, Subpart E includes additional conditions applicable to all UIC
permits. Respondent was issued an area permit for the subject wells and is the
permittee. The permittee must comply with all permit conditions. Any permit
noncompliance constitutes a violation of the Act, and is grounds for enforcement
action. 40 C.F.R. § 144.51(a).
15. The wells which are the subject of this complaint penetrate underground sources
of drinking water (USDWs) including, but not limited to, groundwater in the
"perched aquifer" at approximately 380 feet, the "A-Groove aquifer" at
approximately 1392 feet and the "B-Groove aquifer" at approximately 1582 feet,
below surface.
16. According to monitoring reports submitted by Respondent, the wells subject to
this complaint, when in use, inject approximating 754,000 barrels (32,000,000
gallons) of fluid per month.
17. 40 C.F.R. § 146.33(b)(3), and part II(C)(6) of the UIC permit, require Respondent
to demonstrate mechanical integrity of its wells at least every five years.
18. 40 C.F.R. §146.8 defines mechanical integrity for injection wells. An injection
well has mechanical integrity if there are no significant leaks in the well's casing,
Page 3 of 9