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DocuSign Envelope ID:6BC32598-B737-464E-898A-81 F1 F7131339133 <br /> Table D-2. Most Likely Causes of Well Failure List <br /> Item Failure Indicator with Constant Rate Failure Confirmation <br /> Surging the well does not result in <br /> Plugged Perforations Tubing Pressure Increase improvement <br /> Tubing Leak Annular Pressure Increase Spinner survey,tubing inspection <br /> Packer Leak Annular Pressure Increase Spinner survey, packer inspection <br /> Casing Leak above Packer Annular Pressure Decrease Spinner survey, casing test <br /> Casing Leak below Packer Tubing Pressure Increase Spinner survey, UST log <br /> In addition to potential shut-ins due to causes listed in Table D-2, shut-ins could also be triggered <br /> by surface facility failure, injection water exceeding constituent concentration limits set in the <br /> permit, and other testing requirements. Well failures will result in well shut-in until the causes <br /> have been successfully determined and addressed. <br /> Spill/Release Response <br /> The well operator will comply with federal and state spill response/reporting requirements. If a <br /> spill or release were to occur,field personnel are instructed to: <br /> • Assess immediate danger or threat to health, safety, and welfare and contact emergency <br /> responders, if appropriate. <br /> • Locate and stop the source of the spill, if safe to do so. <br /> • Report the spill to supervisors and arrange for additional response support, including <br /> contact support. <br /> • Take whatever steps are necessary to prevent the spill from impacting surface water, <br /> public health, safety, and welfare. <br /> Monitoring <br /> Realtime well monitoring will be conducted as specified in Table D-3. <br /> Table D-3. Realtime Well Monitoring <br /> Parameter Equipment Backup Equipment Precision Expected Range <br /> Tubing Pressure Pressure Transducer Analog Gauge +/- 10 psi 0 psi -3,000 psi <br /> Annular Pressure Pressure Transducer Analog Gauge +/-20 psi 0 psi -500 psi <br /> Tubing Injection Rate Turbine Meter I I +/-2 gpm 0 gpm -500 gpm <br /> A SCADA system will be used to capture real-time data and assure compliance with the <br /> operational limits, both regulatory and mechanical. <br /> Quarterly reports will be provided per EPA rules to summarize well operational parameters,water <br /> quality data, and the results of any MIT or pressure fall-off tests conducted during the relevant <br /> time period. The quarterly reports will include: <br /> • Monthly average, maximum and minimum values for injection pressure, flow rate and <br /> volume and annular pressure. <br /> • Water analysis reports including major anions and cations, pH, TDS, and any other <br /> constituents whose concentrations have a limit set in the permit. <br /> 13 <br />