Laserfiche WebLink
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 performed <br /> under the Mechanical Integrity Test (MIT) Parts I & II guidance from the EPA Underground <br /> 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 completion <br /> and at least every five years to demonstrate mechanical integrity per EPA regulations and <br /> guidance. Typically, a bridge plug will be utilized and placed proximal to the top of the L-5 Zone <br /> to isolate the test interval. Advances in drilling technologies or modifications to injection well <br /> construction may necessitate alternate MIT methodologies such as annular pressure testing. <br /> 4.2 Temperature Logs (MIT Part II) <br /> Downhole temperature logs may be run in injection wells during well construction (baseline <br /> logging) and the first comparative logs collected approximately 60 to 90 days after <br /> authorization to inject. These logs are compared and analyzed to ensure cement has <br /> adequately sealed the casing annulus. Reports pertaining to the temperature logging results <br /> will be submitted to the BLM and EPA within 30 days after the data are obtained. <br /> 5 Biological Monitoring <br /> Pursuant to 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 or <br /> 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 development. <br /> 5.1 Vegetation Program <br /> Vegetation monitoring will be conducted on sites that were disturbed and revegetated and on <br /> undisturbed or control locations. Monitoring techniques assess the progress of the re- <br /> established vegetation, with progress evaluated by comparison with representative control <br /> sites. <br /> A gross herbaceous evaluation will be conducted in conjunction with visual observations for the <br /> first two years after final reclamation activities on a site, because identification is difficult and <br /> Daub&Associates, Inc. Page 17 Natural Soda LLC 2022 EMP <br />