Laserfiche WebLink
(d) Before commencement of injection, the operator shall run a radioactive <br />tracer survey (RATS) to verify that fluids are confined to the injection zone <br />and to establish the injection profile associated with the perforations; <br />(e) Within four (4) to six (6) months after initial injection, the operator shall run <br />a temperature log to demonstrate Part II of mechanical iategrity, as <br />outlined in the Guidance in Appendix E, to ensure that there is no <br />significant upwazd movement of fluid into or between USDWs in channels <br />adjacent to the casing; and <br />(~ A pressure fall-off test is required for Class I operations [40 CFR § 146.13 <br />(d) (1)] and must be performed on an annual basis for the purpose of <br />monitoring pressure buildup in the injection zone in order to detect any <br />significant loss of fluids due to fracturing in the injection and/or confining <br />zone, and to aid in determining the lateral extent of the injection plume. <br />The initial fallofftest shall take place within a one week period that is one <br />yeaz after the effective date of the Permit. Susequent yeazly tests shall take <br />place within one week of the effective date of the Permit. The pressure fall- <br />offtests shall involve injecting fluids at a constant rate for at least twenty- <br />four (24) hours, or a sufficient period of time until the reservoir pressure <br />reaches stability, followed immediately by ashut-in period of sufficient <br />duration to establish a valid observation of a pressure fall-off curve. This <br />test shall be considered complete when the pressure curve becomes <br />asymptotic to a horizontal line as the reservoir reaches ambient pressure. <br />The initial pressure buildup shall be performed with both a downhole quartz <br />pressure gauge with an accuracy of 0.01 psi and the established surface <br />monitoring equipment in order to avoid any effect of casing storage and to <br />establish a correlation between surface and downhole measwements. It is <br />important that the initial and subsequent tests follow the same test <br />procedure, so that valid comparisons of reservoir pressure, permeability, and <br />porosity can be made. The Director may require the use of downhole quartz <br />gages on any subsequent test if deemed necessary. The permittee shall <br />analyze test results and provide a report with an appropriate narrative <br />interpretation of the test results by a knowledgeable log analyst. The report <br />shall also compaze the test results with the previous yeazs test data. <br />B. CORRECTIVE ACTION <br />The operator is not required to take any corrective action before the effective date of this <br />Permit unless the RATS results indicate the need for additional remedial work. <br />EPA Draft Permit No. CO 10932-04664 Page 10 of 77 <br />