Patrick A Shea Utah State BarNo. 2929 PATRICK A SHEA, P.C 215 South State Street, Suite 200 ,Salt Lake City, Utah 84111 Telephone: (801) 671-9902/305-4184 Facsimile' (801) 305-4181 Attorneys for Living Rivers

Jacque M Ramos Utah State Bar No. 10720 J Ramos Law Firm P L L C 2709 South Chadwick Street Salt Lake, City, Utah 84106 Telephone: 801-521-2442 Facsimile' (801)-582-0834

F I LED SEP f 0 2012

SECRETARY, BOARD OF Oil, GAS & MINlNG

Email' jramos@jramoslawfum com

BEFORE THE BOARD OF On., GAS AND MINING DEPARTMENT OF NATURAL RESOURCES

STATE OF UTAH

IN THE MA TIER OF THE APPLICATION OF NEW WATER FINANCIAL, LLC FOR ADMINISTRATIVE APPROVAL OF THE HARLEY DOME I-X SWD WELL WCATED IN SECTION 10, TOWNSHIP 19 SOUTH, RANGE 25 EAST, S.L.M., GRAND COUNTY, UTAH, AS A CLASS IT INJECTION WELL

LIVING RIVERS' OBJECTION TO GRANTING THE APPLICATION OF

NEW WATER FINANCIAL, LLC FOR ADMINISTRATIVE APPROVAL OF THE

HARLEY DOME I-X SWD WELL LOCATED IN SECTION 10, TOWNSHIP

19 SOUTH, RANGE 25 EAST, S.L.M., GRAND COUNIY, UTAH, AS A CLASS II

INJECTION WELL

Docket No. 2012-28

Cause No. 279-01

Living Rivers ("LR"), by and through counsel, respectfully submits its Objection to

Granting the Application of New Water Financial, LLC for Administrative Approval of the

Harley Dome I-X SWD Well Located in Section 10, Township 19 South, Range 25 East, SLM.

Grand County, Utah, as a Class II Injection Well Based on the information obtained by LR and

opinions of Dr D Kip Solomon, approval of the application should be denied andlor delayed

until the new injection well is installed and tested, and plans for additional monitoring andlor

data collection are in place

Living Rivers is a 501(c)(3) Utah not-for-profit corporation dedicated to protecting rivers

III general, but the Colorado River in particular Based on New Water Financial, LLC's

application, LR sought the expert opllllOn of D Kip Solomon, Ph D, PG to review the

hydrogeological aspects of injecting produced water into the Wingate Formation in the vicinity

of Harley Dome See, September 9, 2012 Expert Report of D Kip Solomon, Ph D, P G,

attached hereto as Exhibit A and incorporated herein by this reference I Dr Solomon's

September 9, 2012 incorporates data, analysis, and opinions previously contained in his February

20, 2011 Expert Report presented in Docket No 2010-029, Cause No. UlC-358 due to its

similarity and relevancy to the current application by New Water Financial, LLC Overall, LR

and Dr Solomon are concerned at the certain negative impact of reversing the groundwater flow

and discharge of natural formation water into the Colorado River that will arise from New Water

Financial LLC's proposed use of the underground injection well Exhibit A

As the Board is aware, Utah regulations specifically require that, "[iJnjection wells shall

be completed, equipped, operated, and maintained in a manner that will prevent pollution and

damage to any USDW (United States Drinking Water), or other resources and will confine

injected fluids to the interval approved" Utah Oil and Gas Conservation Rule R649-5-

2(1 )(emphasis added) To ensure the integrity of the well and to eliminate, prevent, or reduce

the possible pollution or contamination, other test procedures or devices may be required by the

division Utah Oil and Gas Conservation Rule R649-5-5(3 3) Preventing the likely pollution

and damage to the Colorado River arising from the injected fluids are grounds for LR seeking the

Board's denial or stay of New Water Financial, LLC's application for the injection well

1 Dr. Solomon's report is intended to outline the safety and health issues presented with New Water Financial, LLC's application for a Class II Underground Injection Well Dr Solomon will be presenting evidence and testimony concerning his report and findings to the Board at the scheduled hearing set for September 26, 2012

First, it is important to note that a glaring deficiency in New Water Financial LLC's

application is that it seeks approval without the new injection well being in place and tested with

a location less than six 6 miles from the Colorado River Exhibit A, pp 1, 4

Second, the primary concern that this Board should consider is the likely probability that

pressure build up around the well will cause a reversal in the direction of natural groundwater

flow and eventual discharge of the formation water into the Colorado River The natural

groundwater in the vicinity is known to be briny, "[a]nd if water of this salinity were forced into

the Colorado River it would have a negative impact on [this essential] public resource" Exhibit

A, p 1 As detailed in his report, Dr Solomon has found based upon his simulations that a

"[c]ontinuous injection of 10,000 barrels/day will result in a reversal of the direction of

groundwater flow" and that "[e]ven if the injection rate is mechanically limited to be no greater

than 350 psi, and the permeability as low as 20 milidarcy" will still create a distinct "[p]ossibility

to reverse the direction of groundwater flow and cause natural formation water to discharge into

the Colorado River" Exhibit A at p 4

The Board of Oil, Gas and Mining is specifically mandated to ensure that injection wells

are completed, equipped, operated, and maintained in a manner that will prevent pollution and

damage to any USDW, or other resources and will confine injected fluids to the interval

approved Utah Oil and Gas Conservation Rule R649-5-2(1) LR's written objection, Dr Kip

Solomon's expert report, and testimony to be presented at the September 26,2012 hearing, offers

or will offer substantial evidence and data supporting a finding that the proposed injection well

may cause formation fluid to enter the Colorado River prohibiting this Board to grant New Water

Financial, LLC's application and/or staying its determination until proper data collection is

compiled and additional monitoring measures are in place as outlined by Dr Solomon

Additional information and measures shall include a quantitative analysis to assure that the

Colorado River will not be impacted by the proposed operation, an extensive site

characterization program that provides site specific data needed to predict the performance of the

system, monitoring systems in place to assure that injection is not causing a reversal of

groundwater flow, and monitoring of the potentiometric surface at a point between the injection

well and River

Respectfully submitted this 10th day of September 2012.

Patrick A. Shea Counsel for Living Rivers

Jacque M. Ramos Counsel for Living Rivers

MAILING CERTIFICATE

I hereby certify that I mailed a true and correct copy of the foregoing SUPPLEMENT TO REQUEST FOR RECONSIDERATION AND IN THE ALTERNATIVE REQUEST FOR A STAY OF THE ORDER ISSUED ON JANUARY 13, 2011, postage prepaid, this 22nd day of February 2011 to the following-

Steven F Alder Assistant Attorney General Board of Oil, Gas and Mining 1594 West North Temple, Suite 300 Salt Lake City, Utah 84116

Grand County Road Department 125 East Center Moab, Utah 84532

Utah Division Federal Highway Administration 2520 West 4700 South, Suite 9-A Salt Lake City, Utah 84129

Utah School and Institutional Trust Lands Admini strati on 675 East 500 South, Suite 500 Salt Lake City, UT 84102-2818

Rockies Standard Oil Co , LLC 1411East 840 North Orem, Utah 84097-5846

Retamco Operating, Inc Attn- Joe Glennon One South Broadway Avenue, Suite 2 POBox 790 Red Lodge, MT 59068-0790

United States Fish and Wildlife Service Attn -Larry Crist Utah Field Office 2369 West Orton Circle, Suite 50 West Valley City, Utah 84119

Michael S Johnson Assistant Attorney General Board of Oil, Gas and Mining 1594 West North Temple, Suite 300 Salt Lake City, Utah 84116

United States Bureau of Land Management Moab Field Office 82 East Dogwood Moab, Utah 84532

Enterprise Mid-America Pipeline c/o Enterprise Products Partners, L P PO Box 4324 Houston, TX 77210-4324

Flatirons Resources, LLC 303 East 17'b Avenue, Suite 940 Denver, CO 80203-1262

Shiprock Helium, LLC PO Box 51166 Amarillo, TX 79159

Bill Love 2871 East Bench Road Moab, Utah 84532

Thomas W Clawson Vancott, Bagley, Cornwall & McCarthy, P C 36 South State Street, Suite 1900 Salt Lake City, Utah 84111-1478

Exhibit A

CONFIDENTIAL ATTORNEY WORK PRODUCT PRIVILEGE

D. Kip Solomon, PhD, PG 2355 East 900 South Salt Lake City, UT 84108

September 9, 2012

Patrick A. Shea 252 South 1300 East, Suite A Salt Lake City, Utah 84102

Dear Mr. Shea:

I have reviewed the application by New Water Financial LLC for a class II injection well that would be located approximately 100 feet north of the existing Harley Dome #1 welL This application is similar to the application by Westwater Farms for which I previously prepared a letter report dated February 20, 2011. Forreference I am attaching a copy of that letter report, as its fmdings are pertinent to the application by New Water Financial LLG. I also offer additional comments as outlined below.

The proposed injection would be into the Wingate Sandstone less than 6 miles from the Colorado River. The Wingate Sandstone dips to the northwest and intersects the land surface near the Colorado River. Thus, there are no hydrologic barriers between the injection well and the Colorado River. Currently, the potentiometric surface slopes slightly away from the Colorado River (approximately 0.0017 ftlft) indicating that natural groundwater flow in the Wingate Sandstone is also moving away from the River. The natural velocity of groundwater flow is on the order of 0.2 to 1.3 ftlyear suggesting that the water near the injection zone is very old. When injection begins, groundwater flow will be radially outward from the well with some of the injected fluid moving towards the Colorado River. Due to the distance and the proposed injection rate, my primary concern does not pertain to the migration of the injected brine to the Colorado River, but rather that the pressure build up around the well will cause a reversal in the direction of natural groundwater flow. Natural groundwater, at least in the vicinity of the injection well, is briny, and if water of this salinity were forced into the Colorado River it would have a negative impact on a public resource. Salinity rednction has been the focus of a large federal project throughout the entire Colorado River Basin. My report dated February 20, 2011 documents a quantitative evaluation ofthe possibility that the proposed injection operation would result in a reversal of the natural direction of groundwater flow and the discharge of natural formation water into the Colorado River. Only a limited amount of data is available and as a result my analysis considered a range of possible conditions. This is the scientifically proper way to perform a quantitative evaluation with uncertainty in parameter values. The range of values utilized is not arbitrary but rather is consistent with test resnlts reported from other locations within the Wingate Sandstone. My resnlts indicate that if a continuous injection of 4..5 barrels per minutes is sustained over time, a reversal in the direction of groundwater flow will occur. Even if the injection rate is lowered in order to stay below the hydraulic fracturing pressure, a reversal in groundwater flow will still occur if the injection is sustained. The simnlated timing of

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this reversal ranges from approximately 1 to 25 years depending on the specific parameter values utilized. The application by New Water Financial LLC requests an even larger injection rate of approximately 6.9 barrels/min that could potentially be divided between both the existing and a new injection welL Although I have not specifically simulated this injection rate at its precise proposed location (100 feet north of the existing well), the higher injection rate would result in a reversal in a shorter period of time.

In the text below I provide additional insight and clarification regarding my concerns. I want to emphasize that my simulations assume a continuous injection operation, as this is what is being requested in the application. Of course, ifthe injection is intennittent then my concerns are lessened and vanish at some de minimis injection rate.

•

•

My analysis of the pressuring testing performed on the Harley's Dome #1 well resulted in a permeability that is similar to the value of 20 millidarcy reported by David K. Dillon. All geologic formations are heterogeneous with respect to permeability and it would be highly coincidental that this single value is representative of the bulk permeability of the Wingate Sandstone between the injection well and the Colorado River. Moreover, the permeability near the new 1l.ndrilled well (Harley's Dome #I-X SWD) is unknown but could easily be a fuctor of2 to 7 higher than 20 millidarcy. An objective and quantitative analysis of the impact of the injection system on the regional flow field needs to include a range of possible values, as I have done in my report. If such an assessment showed, even when using values near the extremes of what has been measured at other locations, that no negative impacts are expected, then it might be reasonable to proceed with only minimal monitoring. However, in the case ofthe New Water LLC application, the negative impact of reversing the natural direction of groundwater flow is a very real possibility. As such, either (I) an extensive site characterization program should be undertaken that would provide the site­specific. data needed to predict the performance of the system, or (2) a monitoring system should be in place that will assure that the injection is not causing a reversal of groundwater flow near the Colorado River. A quantitative analysis, as opposed to bold qualitative claims, is needed to assure that a natural resource will not be impacted by the proposed operation ..

It is important to recognize that the pores of the Wingate Sandstone are already filled with liquid. Nevertheless, it is possible to inject additional liquid under pressure into the formation because (1) the liquid itself compresses and (2) the formation is not rigid and will deform slightly to accommodate the additional fluid. As such, the compressibility of the formation is a key factor for evaluating the hydraulic response of the system. If the formation were completely rigid, the induced pressure from the injection would spread out radially away from the injection point at a very rapid rate and would be detectable many miles away. The more compressible the system, the greater the storage capacity, and therefore the radius of influence of the well will be smaller. In spite of the importance of

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this parameter, I have been unable to locate even an estimate of its value in the New Water Financial LLC application ..

• The use of the Harley Dome #1 well to monitor fluid pressures during testing of the new Harley Dome I-X SWD well is useful and will lead to a better definition of the hydraulic properties of the Wingate Sandstone. However, the Harley Dome #1 well will not be useful as a monitoring well in the context referred to in my February 20, 2011 report because it is too close to the injection well. The potentiometric surface near the Harley Dome #1 will be sloping toward the Colorado River after only a short period oftime after the injection begins (unless the injection rate is vastly lower than 6.9 barrels/min.) The idea behind the suggested monitoring well in my February 20, 2011 report is to assure that the potentiometric surface Itt a distance of 1 mile or more from the injection well remains sloping away from the Colorado River. In less than 2 days and with an injection rate of only 2 barrel/min, the simulated potentiometric surface 100 feet from the injection well is greater than the elevation of the Colorado River, but the potentiometric surface remains below the River elevation at a greater distance. Thus, a monitoring well at a greater distance (e.g. 1 mile) from the injection well is needed.

• Because the new injection well does not currently exist, it is ouly possible to bracket the range of injection rates that will be possible and still stay below the hydraulic fracturing pressure limit. Blanchard (1990) reports transmissivity values ranging from 40 to 150 ft2 /day and this is approximately equal to a permeability ranging from 42 to 156 millidarcy. If the permeability near the new injection well is near the upper range of these values, it will be possible to continuously inject 10,000 barrels/day as requested, and my analysis shows that this would reverse the flow direction more than 5 miles away in a time period ranging from days to 10 years, depending on the bulk hydraulic diffusivity of the Wingate Sandstone. If the only distal monitoring is observations of discharge where the Wingate outcrops at the Colorado River, it could take up to 10 years to realize this was happening. Even if the injection were then to stop immediately, it would be many years before the system would return to a pre-injection pressure and cessation of flnid discharge. This underscores the importance of monitoring the potentiometric surface at a point between the injection well and the River so that a flow reversal can be recognized sooner.

• I am aware that some hydraulic head data are available from the wells located north of injection site that are completed in the Entrada Sandstone. I am further aware that these valnes have been interpreted by David L. Allin to indicate that the potentiometric surface associated with the Wingate Sandstone slopes more steeply to the north than it does to the south. However, the Entrada Sandstone overlies and is separated from the Wingate Sandstone by the Kayenta Formation. The application by New Water LLC claims the Kayenta will function as the required confining layer for the injection operation. As such, the hydraulic head in a formation above the confining layer is not representative of the Wingate

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Sandstone and cannot be used to assess the slope of the potentiometric surface north of the injection site.

Although the application by New Water LLC is similar to the previously approved application by Westwater Farms, the New Water application seeks approval without the new injection well being in place and tested. As such, an objective and quantitative evaluation of the performance of this system can only be completed by using hydraulic properties obtained from other locations in the Wingate Sandstone. My analysis indicates that it may be possible to inject the requested 10,000 barrels/day of brine if the local permeability near the new well is near the upper range of values obtained from other \Vingate locations.. Furthennore, my simulations indicate that a continuous injection of 10,000 barrels/day will result in a reversal of the direction of groundwater flow. My simulations further indicate that even if the injection rate is mechanically limited to be no greater than 350 psi, and the permeability is as low as 20 millidarcy, it is still possible to reverse the direction of groundwater flow and cause natural formation water to discharge into the Colorado River. In my opinion, approval of this application should be delayed until the new injection well is installed and tested, and plans for additional monitoring and/or data collection are in place.

Respectfully Submitted,

D. Kip Solomon

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D. Kip Solomon, Ph.D, PG 2355 East 900 South Salt Lake City, UT 84108

February 20,2011

Patrick A. Shea 252 South 1300 East, Suite A Salt Lake City, Utah 84102

Dear Pat:

I have reviewed the hydrogeological aspects of the application from Westwater Farms to inject produced water into the Wingate Formation in the vicinity of Harley Dome. I have also reviewed supporting materials including the hydraulic stimulation report, the water quality report, structural contour maps, etc.

In order to evaluate the potential impact of this injection well on the hydrogeology of the Glen Canyon Group Aquifer, I have simulated the pressure field that would develop radially outward from the well. I have utilized the Theis Equation that is commonly used for evaluating aquifer tests that involve an extraction well and 1 or more observation wells. To use the Theis Equation in forward mode, estimates of the following parameters are needed: aquifer transmissivity (T), aquifer storativity (S), and injection rate (Q). The transmissivity was calculated using a permeability of 20 millidarcies (David K. Dillon, letter report dated July 20, 2010), a fluid density of 1033 kg/m3

, an aquifer thickness of 334 ft, and a fluid viscosity of9.86 X 10 -4 kg/mls (appropriate for water at 70 "F), to be 19 if/day. The aquifer storativity (S) is a function of the compressibility of the formation, the porosity, and compressibility of water. While the supporting material provides a porosity estimate, and the compressibility of water can be assumed to be about 4.5 X 1O-10 Pa-1

, I can find no site-specific estimates of the compressibility of the Wingate Formation (which I judge to be a major deficiency in the supporting data). The storativity for the Navajo Sandstone (which is also an aeolian sandstone) was reported by Hei1weil et al. (2000) to range from 0 .. 0025 to 0.0007. After adjusting this for the lesser thickness ofthe Wingate (334 ft versus approximately 1000 feet) yields estimates of 0.0008 to 0.0002 for the Wingate. In the absence of a site-specific value for S, I have assumed a value of 0.001 as this is also considered to be the upper limit for a confined aquifer (Lohman, 1979.) The injection rate was set to 4.5 barrels per minute (David K.. Dillon report dated July 20, 20l0) which is approximately 36,400 ft'/day.

TheTheis Equation assumes the aquifer is perfectly confined above and below, and is of infmite lateral extent. The geometric details of the actual aquifer could be incorporated into a standard numerical model such as MODFLOW or SEAWAT.

The outward propagation of pressure from the injection well is controlled by the ratio of the transmissivity to storativity (TIS), which is known as the hydraulic cliffusivity .. When the hydraulic cliffusivity is large (because T is large andlor S is small) the pressure mound

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will be spread out over a larger lateral extent than compared to a smaller hydraulic diffusivity. The figure below shows the simulated pressure distribution for a transmissvity of 19 fY/day and a storativity of 0.001. This transmissivity is derived from a permeability of 20 millidarcies,consistent with the value reported by David K. Dillon (letter report dated July 20, 2010. It is important to point out that this simulation produced a pressure at the injection well that exceeds the 360 psi limit recommended by David K. Dillon. The simulation agrees relatively well with hydraulic stimulation test conducted by BJ Services after an injection of about 1 hour (i.e. the time at which the stimulation test reached an injection of 5 bpm), but suggests that a prolonged injection at 4.5 barrels per minute will exceed the recommended pressure liinit. Nevertheless, an injection rate of 4.5 barrels per minute was utilized in the simulation because this is the value recommended by David K. Dillon, and it would be possible to inject at this rate if the permeability is somewhat higher than 20 rrJ.llidarcies and/or if multiple injection wells were utilized.

As shown below, the simulated pressure rise at a distance of 5 miles after 5 years of injecting 4.5 barrels per minute would about 0.08 psi, which is equivalent to a rise in the potentiometric surface of about 0.18 feet

T=19 ftl/day; 5=0.001; Q=4.5 brls/min for 5 years

300

250

50

o 1 4

Oistance from Injection Well {mtlesl

Figure 1. Simulation of pressure mounding that results from injecting 4.5 barrels per minutes for 5 years. This simulation utilizes a transmissivity of19 fY/day (which is derived from a permeability of20 millidarcies), and a storativir; of 0.001. These values are considered to be the best available estimates, although no site-specific values for storativity have been presented.

Because the hydraulic properties of the Wingate in the vicinity ofthe injection well have uncertainty associated with them (only a single measurement of permeability is available

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and no measurements of storativity), I have also simulated the pressure distribution using more extreme, but still realistic values. For example, aquifer testing of the Navaj 0

Sandstone in the vicinity of St. George Utah resulted in transmissivities that ranged from 100 to 19,000 tY/day. Figure 2 below shows the simulated pressure distribution after injecting 4.5 barrels per minute for 5 years using a transmissvity of 100 ft2/day and a storativity of 0.0005 .. In this case the pressure at the injection wells stays below the recommended limit of 360 psi. The pressure rise at a distance of 5 miles is 7.9 psi which is equivalent to a rise in the potentiometric surface of about 18 feet.

T;;;100 ft2/day; 5;0;0.0005; Q"'4.5 oris/min for 5 years

300

50

1 5

Figure 2. Simulation of pressure mounding that results from injecting 4.5 barrels per minutes for 5 years. This simulation utilizes a transmissivity oflOO tY/day (derived from a permeability of 104 millidarcies), and a st~ativi1Y of 0.0005. These values are considered to be realistic, but result in a hydraulic diffusivity that is higher than the best available estimate.

While the simulation presented above does not take into account the geometric details of the aquifer, it does provide the basis for evaluating the potential impact of the injection operation on the regional hydrogeology. It is important to understand that although the Windgate outcrops near the Colorado River (approximately five miles away) at an elevation that is higher (800 feet according to David L. Allin) than at the proposed injection site, it is not necessary to raise the pressure head 5 miles away by that same amount (i.e .. 800 feet) in order affect regional5,oundwater flow near the Colorado River. The elevation of the Colorado River at a point nearest to Harley Dome is 4323' (Rebuttal Exhibit 3; notes by David L. Allin December 1, 2010). The static water level in the Wingate at the injection well is 4275' (Rebuttal Exhibit 3; notes by David L. Allin December 1, 2010).. In order to reverse the northward direction of groundwater flow to southward (towards the Colorado River) it is only necessary to raise the water level in the

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injection well to greater than 4323 (i.e. 48 feet.) Figure 3 is a cross section that starts at the injection well and terminates at the Colorado River (at the point labeled "Nearest outcrop 5.8 miles Jw 4350' near river level"; Rebuttal Exhibit 3; notes by David L. Allin December I, 2010). The redline is an estimate of the current potentiometric surface that connects the two known water levels; the Colorado River at 4325' aud the injection well at 4275'. Superimposed on this cross section is the simulated potentiometric surface after 5 years of injecting 4.5 barrels per min. Figure 4 is similar to Figure 3, except it utilized the larger hydraulic diffusivity value discussed previously. In both Figure 3 and Figure 4, the slope of the simulated potentiometric surface is towards the river for most of the cross section as a result of the injection. When the higher hydraulic diffusivity value is utilized, Figure 4 illustrates that existing Wingate Formation fluid would begin discharging into the Colorado River. The environmental impact of such discharge is not known as it depends on both the rate of discharge and the qualit-j of the \Vingate Formation water near the river. Nevertheless, this analysis illustrate my concern that the buildup of fluid pressure as a result of an injection could reverse the regional hydraulic gradient and cause existing Wingate Formation water to discharge into the Colorado River.. It is important to note that I am not particularly concerned about the actual migration of injected fluid a distance of over 5 utiles as this transit time is likely to be far greater than the life of the injection welL Rather, my concern is over the propagation of fluid pressure that might reverse what currently appears to be northward moving regional groundwater flow.

Recommendations:

I. A three dimensional numerical model of groundwater flow should be developed to further refme the possibility of reversing the direction of groundwater flow near the Colorado River. The model should account for the geometry of the aquifer and should consider the variations in fluid density that likely exist between the Colorado River and formation water at the injection welL The model should also be capable of simulating solute transport so that potential salt loading to the Colorado River can be assessed.

2.. A mouitoring well should be installed that penetrates the Wingate Formation and is located approximately 1 mile to the southeast of the injection well (between the Colorado River and the injection welL) This well can be used to obtain an estimate of the transmissivity and storativity of the aquifer that is integrated over a reasonably large scale. Aquifer parameters obtained from this well could be used to update the numerical modeL

3 .. A shallow monitoring well should be installed into the Wingate Formation approximately 0.25 miles northwest of the "Nearest outcrop 5.8 miles [of] Jw 4350' near [Colorado J river level" noted on the structural contour map prepared by David L. Allin, December 1, 2010. This well will help define the direction of groundwater flow in the Wingate, along with the quality of water in the Wingate near the Colorado River.

4. Mouitoring wells in the Wingate Formation at distances of approximately I and 5 miles from the injection well, could be used to establish a limit on the pressure

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build up from the injection well. For example, as long as the hydraulic head 1 mile from the injection well is lower than the head near the Colorado River, then it is unlikely that Wingate Formation water will discharge into the River. The simplified simulation presented in this report suggest that this will be the case for an injection rate less than about 11,300 W/day (1.4 barre1s per min) after 5 years, but not for larger injection rates. It would be reasonable to keep the head at 1 mile at least 10 feet lower than the Colorado River; however, I recommend that an exact criterion be established using a three-dimensional flow and transport model. The end goal is to prevent Wingate Formation water from discharging into the Colorado River as a result of the injection operation.

S. The hydraulic head in flnid bearing zones above the Wingate should be monitored during injection in order to evaluate the extent to which the Wingate Aqnifer is completely confined. Ideally snch monitoring wells would be as close a possible to the injection well and be fmished in the Kayenta Formation. However, existing wells in the area may be a cost-effective alternative to installing new monitoring wells above the Wingate Formation.

References

Heilweil, V. M, G. W. Freethey, Rl Stolp, C. D. Wilkowske, andD E. Wilberg, Geohydrology and numerical simulation of ground-water flow in the central Virgin River Basin oflron and Washington Counties, Utah, State of Utah Department ofNatoral Resources, Technical Publication No. 116,2000.

Lohman, S. W., Ground-water hydraulics: U. S. Geological Survey Professional Paper 708, 70 p., 1979.

Respectfully Submitted,

D. Kip Solomon

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• Figure 3. Cross section that extends from the injection well (distance = 0) to the Colorado River. The red lines shows the existing potentiometric surface that was estimated using the two known water levels (4275 at the injectioll well and 4323 at the Colorado River.) The blue line is the simulated potentiometric surface for pumping 4.5 barrels per minute for 5 years with a transmissivity of 19 ft2/day and a storativity of 0.001. Also shown are the upper aud lower contacts of the Wingate Formation (Jw). The simulated potentiometric surface slopes towards the Colorado River over most of the cross sectiOn and indicates that the injection could reverse the direction of regional gronndwater flow.

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Figure 4. Cross section that extends from the injection well (distance = 0) to the Colorado River. The red lines shows the existing potentiometric snrface that was estimated using the two known water levels (4275 at the injection well and 4323 at the Colorado River.) The blue line is the simulated potentiometric surface for pumping 4.5 barrels per minute for 5 years with a transmissivity of. 100 ft2/day and a storativity of 0.0005. Also shown are the upper and lower contacts of the Wingate Formation (Jw). The simnlated potentiometric surface slopes towards the Colorado River over all of the cross section and indicates that the injection could reverse the direction of regional groundwater flow. My concern is that this would in tum cause Wingate Formation fluid to discharge into the Colorado River.

7