2005-04-12_GENERAL DOCUMENTS - M1999002

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For example, where a monitoring well appears to be contaminated or does not produce enough water to be consistently sampled, or in a case where data for a specific parameter is not adding any substantive value to the monitoring program, a reduction in monitoring could be appropriate. 3) cannot reasonably be continued due to field conditions or technical considerations For example, in a case where high TDS concentrations in a well continually foul automatic recording equipment installed in the well or where a blockage in a wellbore precludes sampling the well, a reduction or substitution in monitoring could be appropriate. 4) not cost-effective relative to the value of the monitoring information For example, where other less costly methods provide a similar data quality and monitoring value, a substitution of methods could be appropriate. 5) the information is no longer necessary to ensure the protection of USDWs For example, if there is no longer a need for certain monitoring because operations have ceased or changed in a way that there is no longer a substantive potential to affect groundwater in the area, a reduction in monitoring could be appropriate. If EPA finds that an addition, reduction, or substitution in monitoring is warranted based on the 5 criteria listed above, such changes maybe made to the Water Monitoring Plan as a Minor Modification of the Permit. Proposed UIC permit changes for Ground-water Monitoring: • Part II, A (3), Cavity Development, 4th Paragraph is proposed to be changed as follows: Current language: The injection fluid and production fluid pipelines shall be equipped with sampling ports to facilitate periodic collection of samples for chemical analysis. Injection fluid samples shall be collected from the pipeline immediately upstream of where the pipeline branches to feed all solution mining wells. Production fluid shall be sampled on the production trunk pipeline prior to entering the steam stripper. Samples of both the production and the injection fluid shall be collected and analyzed (for WQ2 Parameters, Table 3), according to Section 4.0 Process Monitoring of the Ground Water, Surface Water and Process Monitoring Plan dated December 23, 1999, prepared by Agapito Associates, Inc. (the Water Monitoring Plan). Proposed language: The injection fluid and production fluid pipelines shall be equipped with sampling ports to facilitate periodic collection of samples for chemical analysis. Injection fluid samples shall be collected from the pipeline upstream of where the pipeline branches to feed all solution mining wells. Production fluid shall be sampled on the production trunk pipeline prior to entering a gas separator. Samples of both the production and the injection fluid shall be collected and analyzed according to the Ground Water, Surface Water, and Process Monitoring Plan (the Water Monitoring Plan), Appendix I. • Part II, A (3), Cavity Development, 5th Paragraph is proposed to be changed as follows: FINAL Addendum to SOB For Modification No. 9, UIC Area Permit No. C030858-00000 Page 24 of 29