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<br />tubing/casing annulus pressure. The permittee <br />'' proposes to utilize a packerless completion to <br />monitor the annuluar fluid Snterface. The annular <br />space between the tubing and long string casing <br />will contain air, compressed to approximately 967 <br />pounds per square inch gauge (psig). The <br />permittee is required to maintain the air/fluid <br />interface within the bottom 100 feet of the <br />cemented interval of the long string casing. <br />During the Pilot Phase, the permittee shall <br />develop mechanical integrity failure criteria for <br />the annulus pressure monitoring. The criteria <br />must be sensitive enough to detect levels of <br />mechanical integrity failures deemed significant <br />by th~a EPA. The annulus pressure and its range of <br />normal fluctuations, due to variations in <br />injection pressure and injection fluid <br />temperatures, shall be defined or determined by <br />the pressure monitoring program undertaken by the <br />permittee. This criteria, upon approval by the <br />EPA, :shall be applied to the commercial phase. <br />(b) Schedule for Demonstration of Mechanical <br />Integrity. The continuous demonstration of <br />mechanical integrity shall begin upon commencement <br />of injection operations, in accordance with 40 CFR <br />146.8 and paragraph (a), above, unless otherwise <br />modified. Mechanical integrity monitoring will be <br />accorciing to the following provisions: <br />(i) It shall be the permittee's responsibility <br />to arrange for continuous observations. <br />Observed values for annulus pressure and <br />depth to the air/liquid interface shall be <br />recorded in accordance with Part II, Section <br />D. 1. (c), and reported in accordance with <br />Part II, Section D. 5. <br />(11) In addition to any demonstration made under <br />paragraph (i), above, the Director may <br />require a demonstration of mechanical <br />integrity, as described in Part II, Section <br />C. 2. (b), at any time during the permitted <br />life of any well. <br />(c) Loss of Mechanical Integrity. If any well fails <br />to demonstrate mechanical integrity, or a loss of <br />mechanical integrity as defined by 40 CFR 146.8 or <br />(a), above, becomes evident during operation, the <br />permit:tee shall notify the Director in accordance <br />with ]?art III, Section E. 10. of this permit. <br />Page 11 of 61 <br />EPA Permit No. COS2358-0696 <br />