2007-12-19_HYDROLOGY - M1983194 (2)

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internal (Part I) mechanical integrity. A temperature log (cool-down} was performed on the well on October 21, 2002. This temperature log was accepted by EPA as a demonstration of external (Part II) mechanical integrity. Violation: Overdue Internal Mechanical Integrity Demonstration (Pressure Test) At a minimum, NS should have conducted another pressure test of the 7-5/8" casing by September 29, 2007. EPA has no information that any additional demonstration of internal mechanical integrity has taken place since the 2002 initial pressure test. NS is in violation of its UIC permit requirements by failing to demonstrate internal mechanical integrity within five years of the previous demonstration. Violation: Overdue External. Mechanical Inte rite Demonstration (Temperature Loy) At a minimum, NS should have conducted a temperature log by October 21, 2007. EPA has no information that any additional demonstration of external mechanical integrity has taken place since the 2002 initial temperature log. NS is in violation of its UIC permit requirements by failing to demonstrate external mechanical integrity within five years of the previous demonstration. Requirement Contained in this Letter NS is directed to conduct these tests as soon as possible. Within 30 days of your receipt of this letter, please submit a written response describing (1) what action has been taken to correct this situation; (2) how NS intends to prevent any recurrence in the future; or (3) if NS believes the information iri this letter to be in error, your information to support this. If NS chooses to plug and abandon this well, a plugging and abandonment plan must be submitted to EPA for approval prior to the plugging operation. EPA's Su~~estion to Modify Well Construction In its August 14, 2002, approval to add the #6H well to the existing area permit, EPA set .forth mechanical integrity standards applicable to this particular well that included the setting of a packer at 1920 feet true vertical depth, and applying at least 300 psi for at least 30 minutes to the annulus created by the tubing, packer and 7-5/8" casing. EPA suggests that NS, when conducting these tests, leave the well with at least 1920 feet of tubing set on a packer within the 7-5/8" casing so as to create an annulus that can be routinely monitored throughout normal operations. This would also allow for simplified procedures to conduct future periodic mechanical integrity testing, by obviating the need to set a temporary plug in the well during such testing. Failure to comply with the UIC regulations found at'40 CFR Parts 144 through 148 constitutes one or more violations of the Safe Drinking Water Act, 42 U.S.C. §300h. Such non- compliance may subject you to formal enforcement by EPA, as codified at 40 CFR Part 22. 2'