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Feasibility Evaluation of the Arkansas Valley Pipeline Water Works! Committee June 2003 Monitoring requirements include: 1) analysis of injected fluids to yield representative data of its characteristics; 2) installation and use of continuous recording devices to monitor injection pressure, flow rate and volume, and the pressure on the annulus between the tubing and the long string of casing; 3) a demonstration of mechanical integrity at least once every five years; and 4) installation or use of existing wells to monitor any migration of fluids into and pressure in the USDW. The regulations for Class I wells also include ambient monitoring and reporting requirements on a quarterly basis. Feasibility of Using Deep-Well Injection for RO Reject Disposal in Southeastern Colorado Brown & Caldwell obtained information regarding the possibility of drilling and permitting a Class I injection well in the Lower Arkansas River Valley. EPA Region 8, which regulates these types of wells in Colorado, has discussed with Brown & Caldwell the general feasibility of using this type of disposal in the Lower Arkansas River Valley (personal communication with Paul Osborne, US EPA, June 19, 2002). However, without site-specific information on the hydrogeologic nature of the proposed injection site and the chemical characteristics of the RO reject water, US EPA could not make specific recommendations concerning the feasibility of this type of disposal for the Lower Arkansas River Valley municipalities. In general, EPA states that when wells are properly sited, constructed, and operated, underground injection is an effective and environmentally safe method for waste disposal. In Colorado there exists only one commercial Class I injection well, a well near Fort Morgan called the Wattenberg Disposal Well, which accepts various wastewaters for disposal. However, the distance of this well from the Lower Arkansas River Valley and the large volumes of RO reject potentially produced by the municipalities would make utilization of this well infeasible because of transportation costs. A less expensive option suggested by EPA would be to find a local, abandoned Class II disposal well, or an abandoned, properly constructed oil and gas well, and convert it to a Class I injection well. This has been done in other areas of US EPA Region 8. If the well is proven to be acceptable to EPA for Class I injection, and is located very close to a community's RO plant, this could be a lower cost option than transporting RO reject to the Wattenberg Disposal Well. However, it is unlikely that suitable abandoned oil and gas wells, sufficiently close to the locations for municipal RO plants in the Lower Arkansas River Valley, could be located. Consequently, costs for this type of conversion were not gathered for this Technical Memorandum, but could be addressed in a subsequent phase of study. 42 GEI Consultants, Inc. Ot 284 03-06-30 Feasibility Evaluation Final