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<br />herein until written approval to add a new well to the <br />Area Permit has been issued by the Director. <br />2. Tubing Specifications. A packerless tubing system <br />shall be suspended within the intermediate casing. <br />Tubing may be used to transport both injection and <br />production fluid into and out of the well. Additional <br />tubing may be used as conduit for instrumentation <br />equipment. No specific procedure has been developed <br />for the depth of the tubing within the injection <br />cavity, depth of tubing is variable and flexible <br />depending on how much nahcolite is present. The tubing <br />strings are separated from the well bore because they <br />are situated within intermediate casing. The annulus <br />between the tubing and the intermediate casing is not <br />cemented because it is filled with a pressurized <br />annular gas (nitrogen) blanket, which shall be used to <br />assist in controlling the vertical growth of the <br />cavity. Removal or in-place repair of tubing will not <br />affect the isolation of the well from aquifers, thus an <br />MIT is not required after workover of the tubing. <br />3. Monitorino Devices. <br />Mechanical integrity testing (MIT <br />on each well prior to operation. <br />notify EPA at least ten (10} days <br />of the initial CBL and mechanical <br />well. Mechanical integrity shall <br />combination of methods, including <br />shall be performed <br />The Permittee shall <br />prior to the running <br />integrity test on a <br />be demonstrated by a <br />• drilling and cementing records, <br />• pressure testing, and <br />• cement bond logs (CBL) or use of a cement <br />evaluation tool. <br />Volumetric flow meters and density meters shall be <br />installed on the production and injection fluid flow <br />line of each solution mining well near the wellhead. <br />All meters shall be equipped with continuous measuring <br />devices recording at ten (10) minute intervals. The <br />mass balance may be performed on each well to <br />demonstrate that fluids have not migrated from the <br />solution mining cavity. The mass balance may also be <br />used to estimate cavity volume. <br />EPA FINAL Area Permit No. CO3858-00000 <br />Page 10 of 164 <br />