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2011-05-12_PERMIT FILE - P2010026
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2011-05-12_PERMIT FILE - P2010026
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Last modified
8/24/2016 4:33:28 PM
Creation date
5/12/2011 11:14:26 AM
Metadata
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Template:
DRMS Permit Index
Permit No
P2010026
IBM Index Class Name
PERMIT FILE
Doc Date
5/12/2011
Doc Name
Response to comments to NOI
From
Shell Frontier Oil & Gas Inc.
To
DRMS
Email Name
THM
DB2
Media Type
D
Archive
No
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Mr. Travis Marshall <br />Mr. David Bird <br />Division of Reclamation, Mining, & Safety <br />• May 11, 2011 <br />Page 2 <br />The 135-4-298 SAW-1 well has been drilled already under NOI #P-2009-024 <br />previously issued by DRMS for appraisal of the East RDD Lease. This well <br />will be used as an "exterior" observation well for geomechanics <br />observations. The surface location is as located in the field; the <br />location of the well at depth is approximately 2 ft east and 2 ft north of <br />the well at surface, according to our down hole surveys. This illustrates <br />that our "vertical" wells do in fact deviate very slightly, but remain <br />within the tight tolerances necessary for project success. <br />The following sections respond to DRMS comments in the order received. <br />The DRMS comments are repeated below, verbatim, for ease of reference. <br />RESPONSE TO DBMS CONMENTS (from Travis Marshall 2/23/2011): <br />1. Initial review of the NOI submittal revealed that a hydrologic sampling and analysis plan <br />was not included with the original submittal. Please submit a hydrologic sampling and <br />analysis plan that complies with the requirements of Rules 3.1.6 and 3.1.7. Also, please <br />specify proposed reporting intervals. <br />• A Sampling and Analysis Plan is attached. This SAP includes sampling <br />and monitoring of ground water at the down gradient hydrology wells. <br />Sampling and reporting frequencies are included. <br />2. Hydrology pad 138-4-298 is not identified/mislabeled on the East RD&D Pilot Facilities <br />Planfigure located in the figure section. Please provide a revised facilities layout figure <br />that clearly locates the 138-4-298 point of compliance. <br />A revised map showing properly labeled wells is provided in this <br />Response to Comments letter (Figure 36, attached). <br />3. Is the proposed location of a single L4 hydrology monitoring well sufficient to serve as <br />an "early warning" or should additional wells be installed to the northwest and <br />southeast? If no other wells are necessary please give a reason that explains why only <br />one "early warning" well is sufficient. <br />The logic for design and placement of the single L4 hydrology <br />monitoring well is as follows: <br />• The proposed well is down the hydrologic gradient from the <br />proposed underground activities. <br />• The location is as close as feasible to the leaching, heater, and <br />production activities and well heads without interfering with <br />access and operations, and without drilling a deviated well. <br />• The L4, which is the first water bearing interval above the <br />• dissolution surface, is isolated from overlying water bearing
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