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

C. WELL OPERATION
Prior to Commencing_Injection. Injection operations as a Class I well may not
commence until the permittee has complied with (a), (b), (c), and (d) as follows:
(a) Well conversion is complete, and the permittee has submitted a Well
Completion Record (Form 7520-10) in Appendix B, and copies of all
required reservoir tests, mechanical integrity tests and water quality
analyses, and
(i) The Director has inspected or otherwise reviewed the new injection
well and finds it is in compliance with the conditions of the permit;
or
(ii) The permittee has not received notice from the Director of his or her
intent to inspect or otherwise review the injection well within
thirteen (13) days of the effective date of this permit, in which case
prior inspection or review is waived and the pemuttee may
commence injection.
(b) The pemvttee demonstrates that the well has mechanical integrity and has
received notice from the Director that such a demonstration is satisfactory.
Demonstration of mechanical integrity shall consist of two parts: (1) a
tubing casing annulus pressure test in accordance with 40 CFR 146.8 and
Part II, Section C. 2. {b), below, and (2) a RATS to verify that no movement
of fluids exists outside the casing into an underground source of drinking
water (USDW) through vertical channels adjacent to the wellbore.
Additionally, the initial baseline temperature survey (see Guidance E) shall
be run during conversion (Part II, Section A. 5 (c) of the Permit) of the well. T
The initial demonstration of mechanical integrity and the baseline
temperature survey shall be subaatted to EPA prior to commencement of
injection.
The final portion of the temperature survey will be run after injection has
commenced (Part II, Section A. 5(d) of the Pemut). The pemuttee shall
notify the EPA two (2) weeks prior to conducting these tests so that an
authorized representative maybe present to witness the tests. The results of
the tests, including a strip chart recording of the pressure test, shall be
submitted to the Director with the Quarterly Report for the period in which
the activity was completed;
(c) The permittee has submitted the results of the downhole reservoir pressure
monitoring; and
EPA Draft Permit No. CO 10932-04664 Page 11 of 77