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<br />Sufficient quantities of cement shall be used so that the <br />'~ base of each plug is located at a depth at least equal to or <br />below the base of the Boies Bed, and the top of each plug is <br />located at least 50 feet above the top of the Dissolution <br />Surface. <br />Within thirty (30) days after plugging each well, the <br />permittee shall submit a report on Form 7520-13 to the Director. <br />The report shall be certified as accurate by the person who <br />performed the plugging operation and the report shall consist of <br />either: (1) a statement that the well was plugged in accordance <br />with the plan; or (2) where actual plugging differed from the <br />plan, a statement that specifies the different procedures <br />followed. <br />All required corrective action shall be completed prior <br />commencement of injection operations. <br />C. WELL OPERATION <br />1. Pilot Project Operations. The permittee is authorized <br />to conduct a test phase according to procedures proposed in the <br />application. One (1) pair of wells may be cemented and may be <br />tested for the presence of fluid movement behind the casing, as <br />proposed by the permittee. The permittee shall submit data which <br />verifies the appropriateness of any proposed methods of <br />construction, operation, testing, or monitoring. Any CBL's <br />performed shall be submitted to the EPA prior to commbncement of <br />injection operations. Following completion of the Pilot Phase, <br />the EPA shall evaluate the results of: <br />(a) the permittee's tubing/casing annulus monitoring <br />program and ability to correlate the depth to the <br />air/liquid interface with surface pressure values; <br />(b) casing and cementing procedures for well <br />construction; and <br />(c) mechanical integrity testing techniques for <br />measuring the presence or absence of fluid flow <br />behind the long string casing. <br />Based on EPA's evaluation of the data and its acceptability, <br />the permit may be modified, in accordance with 40 CFR 144.39, to <br />require less stringent construction requirements for subsequent <br />wells. The permittee may request that two (2) additional well <br />pairs, on an individual case by case basis, be incoporated into <br />the Pilot Project if said well pairs are necessary for further <br />testing. <br />Page 9 of 61 <br />EPA Permit No. COS2358-0696 <br />