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,~ <br />,~ <br />In your letter, you also request approval to modify the cavity pressure test procedure. <br />You requested approval to modify the pressure bleed off period for each pressure step by <br />reducing the time from one hour to 30 minutes. This change was based on the fact that most of <br />the pressure drop occurred in the first 30 minutes during the September 26, 2001, test performed <br />on the 20-30 well. You also requested that the number of test increments be changed by allowing <br />test increments of 25 psi instead of the 10 psi test increment used for well 20-30. <br />Based on our review, EPA does not object [o exploring potential changes in the test <br />procedure. We are concerned, however, that making changes in the bleed off period and the <br />pressure increment at the same time will make it difficult to assess the ability of the modified test <br />to provide a clear demonstration that raising cavern pressure is justified. EPA believes that the <br />test procedure should be tested in an incremental manner such that the final procedure has been <br />adequately tested. Our preference is [o maintain the bleed off period at one hour while making a <br />change in the pressure increments. <br />Based on our review and discussions with the BLM, EPA will approve the use of a <br />modified procedure that: <br />1. has a pressure bleed off period of one hour; and <br />2. allows for two 25 psi pressure increments followed by five (5) 10 psi pressure <br />increments. <br />Once we receive the results of this test we will consider the potential for further changes <br />in the procedure. <br />If you have any questions regazding this specific action, please contact Paul Osborne at <br />303.312.6125 or Dan Jackson at 303.312.6155. Please direct all correspondence concerning the <br />Permit to the attention of Chuck Williams at Mail Code 8P-W-GW. <br />Please send all compliance correspondence relative to this well to the ATTENTION Ken <br />Philli s, at the letterhead address, citing MAIL CODE: 8ENF-T very prominently. You may <br />call Mr. Philips at (303) 312-6405. <br />cc: Mr. Paul Daggett, BLM <br />White River Resource Area <br />Allen Sorenson, CDMG <br />Page 2 of 2 <br />Ground-Water Program <br />