2009-08-26_HYDROLOGY - M1999002

• Permit No: M1999002
• IBM Index Class Name: HYDROLOGY
• Doc Date: 8/26/2009
• Doc Name: Review of Mechanical Integrity Test Results
• From: Allen Sorenson
• To: Travis Marshall
• Email Name: THM
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DATE;
TO:
FROM
RE:
August 26, 2009
Travis Marshall l/
Allen Sorenson
Rev, iew of Mechanical Integrity Test Results, American Soda, LLP,
Yankee Gulch Sodium Minerals Project, Permit No. M-1999-002

COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
The Division of Reclamation, Mining, and Safety (DRMS) engineering staff has reviewed the Mechanical
Integrity Test (MIT) results from the testing that was done on American Soda's idle solution mining wells in
2008 and has discussed the results with Celina Akin, Environmental Specialist with American Soda. Based
on the review, it is likely that the wells that failed MIT are leaking around the cast iron bridge plugs that
were placed in the lower part of the strings when the wells were taken out of service. The rationale for this
determination is:
1. The wells that failed MIT required substantially more water to fill than the wells that passed,
indicating that the passing wells were still full of water from 2006 MIT, whereas the failed wells had
drained through the bridge plugs.
2. The coil inserted into the failed wells to place plugging cement tripped smoothly to the bridge plugs
indicating that there are no casing ruptures on which the coil could have been hung up.
3. The bridge plug elevations have not changed since the time of placement demonstrating that the
casings have not been stretched by subsidence.
4. No water from the dissolution surface or other water bearing strata was in the failed wells, and if any
water is entering the well string through damaged casing it is flowing down into the mined cavities
through leaking bridge plugs rather than building up in the string to pressures that might lead to
comingling of water between strata.
It is unlikely that the failed wells could cause ground water degradation, for the following reasons:
1. There is no significant hydrostatic pressure in the cased strings.
2. As discussed above, it is likely that the casings are intact, i.e., leaking casing is not the cause of the
MIT failures.
3. There are no indications of contamination in the results of the on-going ground water monitoring
program.
Therefore, there is no reason to change the current program in which the production strings undergo MIT
every two years and failed wells are plugged and abandoned. DRMS should inspect the 2010 MIT project.
Ms. Akin has agreed to notify DRMS in advance of the project so that an inspection can be scheduled.
cc: David Bird, DRMS, via email c:\acs files\My Documents 4-19-06 thru\amsoda MIT review.doc
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