2008-02-11_GENERAL DOCUMENTS - M1983194

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.~,,a .. ,j: ~~ ~`'~~TURAL SODA January 31, 2008 ~ ~s ,/ Ken Phillips Ground Water Specialises ~~ USES PA -Region 8 1595 Wynkoop Street Denver, CO 80202-1129 USPS Certified Letter # 7004 2510 0002 6997 8844 Re: Violation Response ~/ Dear Mr. Phillips: ~~/ED FEB 1 12008 ~ I~ivi~6r~n of Reclamation, Mining and Safety Natural Soda, hic. (NSI) is presenting this Mechanical Integrity Testing Plan as required by permit 0030358- 00000 and by the recent Notice of Violation for we116H (date undetermined). As noted during our phone conversation, NSI has not received the original violation; however, we are looking at changing our mail practices to ensure that all correspondence is received in the future. NSI will be shutting down the plant for routine maintenance the week of March 2, 2008. It is our intent to conduct both the pressure testing and temperature survey of wells SH and 6H at that tune. Both wells were drilled and completed as dual purpose horizontal wells that can be either injection or production wells. As depicted ui the attached diagrams, the wells generally deviate from vertical at a depth of 1450 feet below ground surface (bgs) and make a 45° turn at a depth of approximately 1800 bgs. Previous experience has indicated that it is difficult to lower and retrieve the temperature tool around the 45° angle, often resulting in a lost tool and preventing the well from functioning. Therefore, NSI plans to set a packer at an approxunate depth of 1750 feet bgs, above which both the pressure testing and temperature survey will be run. The 1750 bgs depth is more than100 feet below the bottom of the B-Groove aquifer, which is the lowest of the protected groundwater aquifers. As the cement was pumped the entire annular space to the surface, and the cement bond logs uidicted a competent bond for at least 100 feet above and below each protected drinking water aquifer, NSI believes that this will meet the EPA's requirement to demonstrate the protection of the three protected drinking water aquifers (Perched, A-Groove and E-Groove Aquifers) remains intact, without compromising the well. Detailed work plans are attached for both 5-H and 6-H. As the testing will be performed in approximately one month, this response will serve as the minimum 10 days notice to EPA. As required by the permit, the results of the MIT will be submitted with the next quarterly report by April 28, 2008. However, should the results be abnormal, NSI will notify EPA immediately. To ensure that all MIT is conducted in a timely fashion in the future, NSI is reviewing all well files and noting the date the well was drilled, and critical permit mandated testing dates. This summary will be reviewed at least quarterly to ensure that all future requirements are met. Natural Soda, Inc. 3200 RBC Road 31 Rifle, Colorado 8160 Ph 970-878-3674 Fax 970-878-5866 w-evw•naturalsoda.com