Laserfiche WebLink
Instead, the applicant submitted test results from a single well located 500 feet south of <br />the proposed injection well, asserting that this single sample would be "representative of <br />the inj ectate". <br />The closest domestic well to the proposed injection site is roughly one mile to the west. <br />The applicant proposes to inject fluid into the Fox Hills aquifer at a depth of 500 to 550 <br />feet. The permit application claims the domestic well is "much deeper than the zone of <br />injection (620 feet)" and is "likely" screened in a part of the aquifer that is separated from <br />the injection zone by a "continuous confining layer" of mudstone. <br />The 2001 Well Construction and Test Report for the domestic well indicates that the well <br />is 620 feet deep but is screened in two intervals: 440 to 460 feet, and 520 to 560 feet. <br />The applicant is in possession of this report and not only failed to include this <br />information in its application, but made an assertion that appears to contradict the well <br />construction report. <br />In addition, the applicant did not submit geologic well logs from the proposed injection <br />area to support the contention that an impervious and continuous confining layer of <br />mudstone separates the injection zone from the overlying Laramie aquifer with its higher- <br />quality water. <br />The draft permit does not adequately address the potential for injectate to contaminate the <br />Laramie aquifer by migrating up through improperly-plugged historical exploration drill <br />holes. According to government and industry documents, thousands of holes were drilled <br />in the area nearly 30 years ago when companies were prospecting for uranium. Several <br />dozen, or perhaps hundreds, of these holes exist within one mile of the proposed injection <br />site. Records show that these drill holes were routinely plugged in a manner that would <br />not prevent leakage between the Fox Hills aquifer and the overlying Laramie aquifer. <br />Instead of using cement plugs to separate and protect the aquifers, the holes were plugged <br />with drilling mud, and in some cases, beet pulp. Cement was only used to plug the top <br />few feet of the holes. <br />To make matters worse, local landowners have discovered and photographed plastic well <br />casings that were broken off and remained buried for decades. The applicant has <br />indicated that historical exploration operators were responsible for these broken casings. <br />Once the potentially-affected area of the aquifer is determined, the applicant should be <br />required to locate all historical exploration drill holes in this area. The holes should be <br />inspected and, if necessary, repaired using modern plugging methods prior to any <br />injection taking place. <br />The draft permit does not require testing of the injectate prior to injection. The water <br />extracted during the proposed pump test would be stored in metal tanks prior to <br />reinjection into the aquifer. The applicant estimates it will take 45 days to inject the <br />water. <br />6