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4 Production Well Mechanical Integrity <br />In compliance with BLM and EPA stipulations, NS will perform a two component -monitoring <br />plan to demonstrate mechanical integrity of injection wells. All integrity testing is <br />performed under the Mechanical Integrity Test (MIT) Parts I & II guidance from the EPA <br />Underground Injection Control (UIC) Permits. <br />4.1 Casing Pressure Tests (MIT Part I) <br />Initial and periodic pressure tests will be conducted on active injection wells upon <br />completion and at least every five years to demonstrate mechanical integrity per EPA <br />regulations and guidance. Advances in drilling technologies or modifications to injection <br />well construction may necessitate alternate MIT methodologies such as annular pressure <br />testing. <br />4.2 Temperature Logs (MIT Part II) <br />Downhole temperature logs may be run in injection wells immediately following completion <br />(baseline logging) and following a period of injection. These logs are compared and <br />analyzed to ensure cement has adequately sealed the casing annulus. Reports pertaining to <br />the temperature logging results will be submitted to the BLM and EPA within 10 days after <br />the data are obtained. <br />5 Biological Monitoring <br />Pursuant to the BLM and Colorado DRMS requirements, a biology -monitoring program was <br />prepared to address the following items: <br />• Evaluate reclaimed areas for vegetative production, crown cover, plant composition, <br />and soil erosion rates versus representative control sites. <br />• Inventory raptor -breeding activity in proposed well development field for mitigation <br />or protection strategies. <br />• Develop and implement mitigation measures in cooperation with BLM and Colorado <br />Parks and Wildlife (CPW) to offset habitat loss associated with well -field <br />development. <br />5.1 Vegetation Program <br />Vegetation monitoring will be conducted on sites which were disturbed and revegetated <br />and on undisturbed or control locations. Monitoring techniques assess the progress of the <br />re-established vegetation, with progress evaluated by comparison with representative <br />control sites. <br />Daub & Associates, Inc. <br />Page 17 Natural Soda LLC 2015 EMP <br />