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<br />B. CORRECTIVE ACTION <br />After reviewing the report on the results of an <br />analysis of the site ground water data done for the <br />applicant by Dr. Saulnier ("Groundwater Quality in <br />Piceance Creek Basin", G.J. Saulnier, Jr.), EPA is <br />reauirina the Permittee to properly plug and abandon <br />well 20-1 prior to commencement of injection <br />activities. Additionally, EPA is requiring submittal <br />of a plan for determining if the construction of well <br />17-1 is adequate to prevent communication between <br />aquifers. This plan must be submitted within six (6) <br />months of the effective date of this Permit. The <br />activities outlined in the 17-1 study plan must be <br />carried out within one (1) year of the effective date <br />of the Permit. If the construction of well 17-1 is <br />determined to be a potential problem, the Permittee <br />shall submit a corrective action plan and complete any <br />approved corrective action by the date specified by the <br />Director, or at most no later than three years of the <br />effective date of the Permit. <br />C. WELL OPERATION <br />1. Prior to Commencing Infection. Injection operations <br />shall not commence into any newly drilled or converted <br />well(s) until the Permittee has received written <br />authorization from the EPA as to the following: <br />(a) Formation data and infection fluid analyses have <br />been submitted in accordance with Part II A.S. and <br />B.2.(c), respectively; <br />(b) Submitted all pertinent loos, including the CBL, <br />and test(s) run during the drilling and completion <br />of the well. The Permittee shall include <br />appropriate narrative interpretations by a <br />knowledgeable log analyst when submitting all <br />required and other pertinent logs; <br />(c) Mechanical integrity of the well has been <br />successfully demonstrated in accordance with the <br />current Guidance found in Appendix F. The <br />Permittee shall notify the EPA at least ten (10) <br />business days prior to conducting these test(s) so <br />that an authorized representative may be present <br />to witness the test(s); <br />EPA FINAL Area Permit No. C03858-00000 <br />Page 15 of 164 <br />