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<br />size of the cavity. Section 4 of the Water Monitoring Plan contains the details of the process <br />water monitoring and Section 5.9.3 lays out the required response to a formation failure, cavity <br />failure, or well breach. Any reported values that differ significantly from normal operating <br />conditions will be immediately investigated by the operator and reported to EPA. To assure that <br />this information is available for long-term usage, the values for these parameters will be <br />automatically recorded at a master control facility. The operator is also required to maintain a <br />copy of all recorded data for at least 3 years. <br />As outlined in the Permit application, the operator will initiate appropriate response <br />measures for process monitoring abnormalities, such as loss of well head pressure, decrease in <br />mine fluid temperatures, significant difference between inflow and outflow volumes, etc. The <br />anticipated measures would include the following: 1) Pressure, flow, and temperature <br />instrumentation would be checked for accuracy; 2) Valves would be checked for leakage; 3) <br />Injection activities would be discontinued, and fluid densities within the well would be balanced; <br />4) Tubing strings, and annular azeas would be pressure tested; 5) A temperature ]og would be run <br />to check for temperature changes above the mining interval; 6) The results of the analyses listed <br />above would be evaluated to develop a solution; and 7) The EPA and other regulatory agencies <br />would be notified of the response data and the proposed corrective action. <br />As described in the Water Monitoring Plan, the operator is required to monitor hydrostatic <br />pressure at the Dissolution Surface in several monitoring wells, utilizing a transducer <br />monitoring/recording system. The baseline measurements will be recorded, at least monthly, but <br />during commercial operation, measurements will be recorded weekly. Evidence of significant <br />pressure deviations from the established baseline that cannot be attributed to ambient conditions <br />or equipment problems will be cause for the initiation of response procedures. These response <br />procedures aze as follows: 1) The EPA and other regulatory agencies will be notified within the <br />next working day; 2) The integrity of the pressure transducer will be evaluated; 3) Other <br />Dissolution Surface monitoring systems will be evaluated; 4) The mass balance data from neazby <br />solution mining wells will be evaluated; 5) Injection into solution mining wells with questionable <br />mass balance data will be discontinued; 6) Tubing, strings, and annulaz azeas ofthe solution <br />mining well(s) in question would be pressure tested; 7) A temperature log would be run to check <br />for temperature changes above the mining interval for the solution mining well(s) in question; 8) <br />The results of the analyses listed above would be evaluated to develop a solution; and 9) EPA and <br />other regulatory agencies would be notified of the results of the evaluations and the proposed <br />corrective action, if any, within the timeframe established by the Permit. It is important to <br />emphasize that the solution mining process is highly dependent on maintaining temperature and <br />pressure in solution mining cavities. If there were a leak, the cavity would not be able to maintain <br />pressure. This would require corrective action that would include the well being shut in until the <br />issue is resolved. Depending on the nature of the problem the final response may require closure <br />of the well. <br />An underlying concern behind the UIC regulations is the potential pathway associated <br />with injecting at a pressure that could initiate fractures out of the injection zone into a USDW. In <br />this case there is some concern that fracturing the injection zone might affect the stability of the <br />24 <br />