GENERAL40852

• Permit No: M1999002
• IBM Index Class Name: General Documents
• Doc Date: 12/22/2003
• Doc Name: Plug & Abandon Well 20-12
• From: American Soda LLP
• To: DMG
• Media Type: D
• Archive: No

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14MERICAN
Ed Cooley
S o o A, LLP Environmental Safety and
Health Mana er
2717 County Road 215
Parachute. CO 81635
Monday December 22, 2003
Elisabeth Evans
Director Technical Enforcement Program
U.S. Environmental Protection Agency
Region VIII
Mail Code 8ENF-T
999 18th Street, Suite 300
Denver, Colorado 80202-2466
Dear Elisabeth:
Direct Line [phone]
Intemafional Telephone [phone]
General Facsimile [phone]
ENV. 261.03
Specialist: ESC
smut#: M1999 02 Confidential?: /U~
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American Soda LLP submitted a letter dated December 3, 2003 stating that we have
completed an operational evaluation of Well 20-12 (EPA permit Number CO30858-04552) and
have determined that the appropriate corrective action for this well is to de-pressurize the
cavity and plug and abandon the well in accordance with the Plugging and Abandonment Plan
in EPA Area Permit CO3858-00000.
In subsequent meetings with the EPA, BLM and CDMG a determination was made that the
installation of a Time Domain Reflectometry Cable (TDR) in the short string casing of this well
during the plugging process will add to the Subsidence Monitoring Program.
The addition of the TDR Cable will require a modification to the current Plugging and
Abandonment Plan.
American Soda is requesting that the following changes to the Plugging and Abandonment
Plan for Well 20-12 (EPA Permit Number CO30858-04552) be approved:
A cast iron bridge plug will be set inside each string of 7" casing at approximately the elevation
of the bottom of the short string casing. If it is not possible to run a CIBP inside each string of
7" casing due to casing irregularities, acement basket shall be run inside the 7" casing to
establish the cement plug at approximately the elevation of the bottom of the short string
casing.
American Soda will establish a cement plug inside the short string 7" casing extending
from the bottom of the short string casing elevation to approximately the dissolution surface
elevation. A TDR cable will be strapped to 2 3/8" or 2 7/8" tubing and ran inside the 7" casing
to the top of the existing cement plug. Cement will be circulated down the tubing and back up
Delivering a Crystal Clear Advantage
www.americansoda.com