GENERAL45492

• Permit No: M1999002
• IBM Index Class Name: General Documents
• Doc Date: 3/1/2002
• Doc Name: Draft Permit
• From: EPA
• To: American Soda LLP
• Media Type: D
• Archive: No

adjusting the gas pressure, the operator shall use the tazget value of
50 psi; or
(iii) If there is a 100 psi or greater drop in injection pressure during a one
hour period, the well shall be automatically shut-in.
(d) Magnetic flow meters, and continuous recording devices with a sampling
frequency of at least every 15 seconds must be installed in the injection line
immediately upstream of the wellhead to track and document disposal fluid
flow rates, and total fluid volumes.
For a given injection rate, the injection pressure will remain relatively
constant. Input flow volumes will be cross checked against injection
pressure records to identify any possible divergence in the injection pressure
for a given flow rate. A drop in injection pressure without a corresponding
reduction in input flow rate would indicate a possible casing, packer, or
other failure.
(e) Fluid analysis: the injection line must be equipped with sampling ports and
appropriate connections to facilitate periodic collection of fluid samples
representative of the injection fluids for chemical analysis. The sampling
point must be in an unobstructed portion of the injection line down stream
from the tanks but prior to the injection pumps.
Pronosed Chanties and Workovers
(Condition 4)
The permittee shall give advance notice to the Director, as soon as possible, of any planned
physical alterations or additions to the permitted well. Major alterations or workovers of the
permitted well shall meet all conditions as set forth in this permit. A major alteration/workover
shall be considered any work performed, which affects casing, packer(s), or tubing.
The permittee shall provide all records of well workovers, logging, or other test data to
EPA as part of the quarterly report for the period in which the activity was completed. Appendix
B contains samples of the appropriate reporting forms. After any workover that involves remedial
cementing of the casing, the operator shall run a new cement bond log (with a gamma ray, travel
time curve, casing collaz locator, amplitude curve, and variable density log) that covers the azea of
the cementing to verify the adequacy of the cement placement. This log will be run following the
guidelines in Appendix D.
Demonstration of mechanical integrity (tubing/casing annulus pressure test) must be
performed within thirty (30) days of completion of workovers/alterations and prior to resuming
injection activities, in accordance with Part II, Section C, Condition 2.
Lo¢ ig ng and We11 Testine Snecifrcations. (Condition 5)
Statement of Basis for EPA Permit No. CO I0932-O46C)4 Page 8 of 18