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shall be certified as accurate by the person who performed the plugging operation and the report shall consist of either: (1) a statement that the well was plugged in accordance with the plan; or (2) where actual plugging differed from the plan, a statement that specifies the different procedures followed. 5. Resuming Injection After Conclusion of Temporary Suspension: Prior to resuming injection into any well in temporary suspension status, the permittee shall notify the Director of its intent to resume normal mining operations and shall successfully demonstrate mechanical integrity, Part I (no significant leak from the casing). Because American Soda's wells do not use a packer, a successful Part I demonstration shall include passing an MIT pressure test on the casing (as referenced in Part II G(3)(a) of this section) at or above the maximum allowable injection pressure for the well, with no more than 10% change over a 30-minute period. When a well is returned to service, the monitoring analysis in Part II, Section D(1)(i) shall apply to well operations to evaluate cavity integrity. In addition, if a well has been shut in for more than 5 years, the permittee shall run a baseline temperature log, noise log, or oxygen activation log from surface to the top of the cavity, to be used to compare against temperature, noise, or oxygen activation logs run after resuming normal injection operations for the purpose of demonstrating Part II of mechanical integrity (no vertical movement behind casing). Only after a successful Part I mechanical integrity test and notification to the Director have occurred, and EPA written permission received, shall the permittee resume injection. N. Ground Water Monitoring Plan: Background and Prouosed Modifications The original "Ground Water, Surface Water and Process Monitoring Plan" dated December 23, 1999, was adopted as Appendix J of the UIC permit. That plan, referred to as the Water Monitoring Plan, included provisions for.baseline monitoring and operations monitoring. Since the implementation of that plan, baseline data collection has been completed and a substantial amount of operational monitoring has been completed. The data collected to date indicate that revisions to the monitoring requirements are warranted to better focus the data collection on meaningful parameters and cost- effective monitoring. The existing data show that some parameters currently measured in the groundwater monitoring program aze not useful in determining if mining fluid has migrated into an aquifer. For example, some pazameters are not present in the mining fluid at levels that exceed their concentration in the groundwater. Other pazameters are consistently non-detectable, and still others are simply unrelated to detecting a migration of mining fluid into an aquifer. Consequently, these pazameters aze being eliminated from regular monitoring while retaining those pazameters that aze present at significant levels in the mining fluid and are useful in identifying an excursion of mining fluid. The current full suite of pazameters will continue to be monitored but at a reduced frequency of once per yeaz rather than at each sampling event. The monitoring conducted to date has shown that monitoring water levels (pressure) provides the most direct and timely indication of a cavity leak. Water quality sampling has not shown an immediate response to a leak. Seasonal variation in the water quality data is evident but the month to month variation has been compazatively small. Therefore, during commercial operations, monthly water level monitoring will be maintained while water quality sampling is being reduced to a quarterly frequency. The proposed changes (see table 3 which summarizes the wells. constituents, and freauencv of sampling proposed the temporary suspension period) also include modifications to the uses of certain Draft Addendum to SOB For Modification No. 9, UIC Area Permit No. C030858-00000 Page 14 of 27