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~~. <br />~~,cr~o srq~~s <br />2~ ~U <br />C :~ W <br />~T~~"rQr. Pao;~.~~.,c3~ <br />Ref: 8ENF-UFO <br />1595 Wynkoop Street <br />DENVER, CO 80202-1129 <br />Phone 800-227-8917 <br />http://www.epa.gov/region08 <br />DEG 1 7 2007 <br /> <br />._ .,~~~ <br />y~ <br />CERTIFIED LETTER 7005-0390-0000-4848-0547 <br />RETURN RECEIPT REQUESTED <br />Ms. Cindi Byres <br />Environmental Health and Safety Manager <br />Natural Soda, IncF` <br />P.Q. Drawer 72 <br />3200 County Road 31 <br />Rifle, Colorado 81650 <br />Dear Ms. Byrns: <br />~-- <br />Re: Underground Injection Control (UIC) <br />Notice of Violations: Overdue Mechanical Integrity <br />Demonstrations <br />EPA Permit and ID #C030358-04679-(Well #6H) <br />Rio Blanco County, Colorado ~--~ <br />The UIC area permit C030358-00000 governing the nahcolite solution mining at Natural <br />Soda Inc. (NS) was revoked and re-issued on December 4, 2003. This letter addresses what the <br />U.S. Environmental Protection Agency Region 8 (EPA) has identified as non-compliance at the <br />#6H well, one of the wells covered under this UIC area permit. It requires a written response <br />within 30 days. Finally, it suggests a modification to the well construction. <br />Well Construction <br />The #6H Class III injection well at Natural Soda Inc. (NS) was drilled and completed in <br />late 2002, with 7-5/8" longstring casing set at a. measured depth (MD) of 2247 feet, and a 5-1/2" <br />liner set from 1918 feet to the approximate end of drilled hole at 3532 feet MD. This well begins <br />its deviation from vertical to horizontal around .1500 feet depth. It has a true vertical depth of <br />1960'. Following an August 2006 liner "pullback" the length of 4-1/2" injection tubing hanging <br />from the wellhead was shortened from 1000 feet to 15 feet. 'The injection tubing is not set on a <br />packer, and there is no injection through tubing and packer. <br />Mechanical Integrity Requirement <br />The re-issued UIC permit, at part II(C)(6), governs mechanical integrity. In that part of <br />the permit, NS must demonstrate both internal and external mechanical integrity at least once <br />every five years. V~hen the well was first completed', a pressure test was conducted on the 7-5/8" <br />casing on September 29, 2002. This pressure test was accepted by EPA as a demonstration of <br />7T % ~/ . . <br />UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />REGION 8 <br />