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1989. These leaks were repaued using procedures accepted by the COGCC (the <br />COGCC regulates Class II wells on non-Indian lands in Colorado). <br />The well has passed a recent pressure test which indicates that the two casing <br />repairs were successful. This test was conducted using EPA's procedures and was <br />witnessed by the COGCC to demonstrate compliance with Class II Permit <br />requirements. Although the construction and cementing details of the disposal well <br />indicate that existing and potential USDWs aze protected with a combination ofthe <br />surface and long string casings and cement intervals, there is an absence of good <br />information on cement conditions adjacent to the casing. The adequacy of the <br />cement will be verified by further mechanical integrity testing of the well prior to <br />injection. A radioactive tracer survey must be conducted prior to injection. This <br />will be followed up by a temperature survey after 4 to 6 months of operation. <br />(c) Tubing and packer: Approximately 3,891 feet of 2-3/8 inch tubing will be run in <br />the hole with a 4-1/2 inch tension packer. The packer will be set no more than 100 <br />feet above the top most perforation at 3,911 feet. <br />Tubine and Packer Specifications <br />(Condition 2) <br />All Class I injection wells, except those municipal wells injecting non-corrosive wastes, <br />shall inject fluids through tubing with a packer set immediately above the injection zone, or tubing <br />with an approved fluid seal as an alternative (40 CFR § 146.12 (c)). A retrievable tension-type <br />packer was placed in the 4-1/2 inch casing string on 3,891 feet of 2-3/8 inch J-55 tubing after the <br />casing was repaired as part of the Class II activity. During the life of the Permit, the packer will be <br />maintained at a location that is no more than 100 feet above the top most perforation. <br />Monitorine Devices (Condition 3) <br />The primary method of monitoring shall be continuous pressure monitoring of the injection <br />and casing tubing annulus pressure and continuous monitoring of the injection rate and volume; <br />these devices shall be operated and maintained as long as the Permit is in effect. The <br />instrumentation must have a sampling capability sufficient to create a continuous record. In <br />addition, it is necessary to have a mechanism to access the wellhead and injection line to obtain <br />manual measurements of injection and annulus pressure and a samples of the injection fluid. The <br />fluid sampling point must be in the line that takes the fluid from the holding tanks, but the location <br />should be prior to entering the injection pump system. The injection pressure monitoring point <br />must be down gradient of the injection pump in an unobstructed portion of the injection line <br />immediately adjacent to the wellhead. Both the injection pressure and annulus pressure points <br />must be installed so that valid manual measurements can be taken as a means of verifying the <br />continuous monitoring. <br />Prior to beginning Class Inon-hazazdous injection operation, the operator shall install and <br />maintain in good operating condition the following equipment: <br />Statement of Basis for EPA Permit No. CO 10932-04664 Page 6 of 18 <br />