Laserfiche WebLink
Letter to Richard Blubaugh 3 September 25, 2009 <br />Centennial Project, Receipt of Modification MD-03 File No. P-2008-043 <br />injectate to flow into other water bearing strata above or below the screened interval is increased. If the <br />injection proceeds under atmospheric pressure only, it is unlikely that flow paths other than those <br />occurring under natural conditions in the A2 Sand will develop, but the development of such new paths <br />even under atmospheric pressure alone cannot be ruled-out. <br />In order to address issues l La and b, Powertech may choose to commit to storing the pump test water in <br />Baker Tanks until the pump test data are analyzed and a demonstration can be made that the A2 Sand is <br />sufficiently contained to allow pressurized injection without migration of injectate into overlying or <br />underlying strata. However, it is possible hydraulic connection between the A2 Sand and other strata via <br />open or ineffectively plugged wells will not be detected during the pump test. This is particularly true if <br />injectate were to flow along a leaky well and into a lenticular water bearing strata in the Laramie Formation <br />in which none of the pump test monitoring wells have been screened. See item no. 12 below for further <br />discussion of this issue. Another option would be for Powertech to combine existing available information <br />with a commitment to inject at or slightly above ambient A2 Sand pressure to demonstrate that injectate will <br />not migrate into overlying or underlying strata, at least not any more than A2 water would migrate under <br />natural conditions. Alternatively, DRMS will review any other proposals Powertech may proffer to address <br />these issues. <br />12. It is necessary to determine if there are any wells or bore holes within the potential zone of flow for the <br />injectate and the status condition of those wells or bore holes. Powertech must provide a report that includes <br />the following: <br />a. A technical analysis delineating the potential zone of flow for injectate. <br />b. A map illustrating all wells and bore holes within the potential zone of flow, a discussion of the sources of <br />information for the wells and bore holes, and a description of the efforts put forth to assure that all wells <br />and bore holes within the zone have been identified. <br />c. A description of the status condition of each well and bore hole including the sources of information for <br />and investigations conducted to determine the status condition. <br />d. For any wells or bore holes that are identified as being potential flow pathways for injectate or that cannot <br />be ruled out as potential flow pathways, provide a plan to prevent injectate from travelling along these <br />pathways and entering strata other than the A2 Sand. <br />13. Item 11 above discusses the DRMS's current position that injectate be contained within the A2 Sand or <br />be managed such that migration into overlying and underlying strata be no greater than would occur under <br />natural conditions. DRMS will consider modifying this position if Powertech can demonstrate that water <br />quality impacts to the other A Sands and the WE Sand can be minimized even with the introduction of <br />injectate into those strata. Such a demonstration would be largely dependent on water quality in these other <br />sands compared to the water quality in the A2 Sand. <br />14. Powertech stated in since withdrawn modification MD-02 to prospecting notice P-2008-043 that it has <br />done preliminary hydrogeologic modeling and water production calculations for the strata to be investigated