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GENERAL45492
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GENERAL45492
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Last modified
8/24/2016 8:14:53 PM
Creation date
11/23/2007 1:53:15 PM
Metadata
Fields
Template:
DRMS Permit Index
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
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(a) The permittee shall notify tb"e EPA that construction is complete and submit the <br />Completion Report For Brine Disposal (EPA Form 7520-10); <br />(b) A successfully passed mechanical integrity test (NIIT) has been performed and <br />witnessed according to the guidance found in Appendix G. Demonstration of <br />mechanical integrity shall consist of two parts: (I) a casing/tubing annulus <br />pressure test to verify the absence of leaks in the casing, tubing, and packer, and <br />(2) a radioactive tracer survey (RATS) to verify that no movement of fluids <br />exists outside the casing into an underground source of drinking water (USDW) <br />through vertical channels adjacent to the wellbore. The permittee shall notify the <br />EPA two (2) weeks prior to conducting these tests so that an authorized <br />representative may be present to witness the tests; <br />(c) The permittee has submitted the results of the downhole reservoir pressure <br />monitoring; and <br />(d) The permittee has submitted a copy of the RATS and temperature logs run during <br />the conversion of the well. Along with this suite of logs, or any other pertinent <br />logs, the permittee shall include appropriate narrative interpretations by a <br />knowledgeable log analyst. <br />Mechanical Intea-ity <br />(Condition 2) <br />To ensure the existing and continued mechanical integrity of the well, the operator must <br />run an initial mechanical integrity test of the injection well that demonstrates: 1) there aze no leaks <br />in the tubing, casing and packer; and 2) there is no flow into or between USDWs adjacent to the <br />wellbore. The Permittee must also demonstrate part I and part II of mechanical integrity on a <br />continuing basis by arranging and conducting a test at least once every five years. A tubing/casing <br />annulus pressure test must be conducted to demonstrate Part I (no leaks in the tubing, casing or <br />packer) at the maximum injection pressure and either a temperature log or a noise log shall be <br />conducted to demonstrate Part II (no flow into or between USDWs adjacent to the casing). Also <br />an M1T is to be successfully conducted after workovers (see Part II. A. 5.). Results of the test <br />shall be submitted (on EPA form found in Appendix B), with documentation, to the Director as <br />soon as possible but no later than thirty (30) days after the test is complete. <br />Test methods and criteria aze to follow current UIC Guidance (Appendix G) for <br />Conducting a Pressure Test to Determine if a Well has leaks in the Tubing, Casing or <br />Packer. The absence of any flow behind casing must also be demonstrated; this shall be initially <br />accomplished by perfomung a radioactive tracer survey (RATS) prior to commencing injection. <br />The EPA has provided a guidance procedure for running the RATS (Appendix F). A Follow up <br />test, for no flow behind pipe, will be done after four to six months of injection using a <br />temperature survey. <br />Statement of Basis for EPA Permit No. CO 10932-04664 Page 11 of 18 <br /> <br />
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