2011-01-03_GENERAL DOCUMENTS - P2008043

Home Browse Search

confinement breaches that are serious enough to deny Authorization to Inject and those that appear to be minor and require only additional monitoring, and should be rewritten. (3) Permit condition E.5. states that the Director will review the analytical results from the samples of stored groundwater and require that "corrective action" be performed if the concentration of any analyzed constituent over the permit limit also shows a "significant increase" from the levels measured in the groundwater sample described in Section E.1(a). This permit condition addresses the potential for contamination of the inj ectate resulting from possible residues inside the metal storage tanks. According to Permittee, the tanks may have been used to store hazardous wastes during the tank use event immediately preceding their use for storage of the proposed injectate. In fact, the Colorado Division of Reclamation, Mining & Safety ("DRMS") has specifically granted approval to Permittee to use tanks that may have held hazardous waste during the last tank use event. The DRMS will require cleaning of the tanks before use, but permit condition E.5. recognizes the potential for contamination of the injectate resulting from inadequately cleaned storage tanks. This permit condition is flawed because it does not include numerical limits to determine whether an analyzed constituent shows a "significant increase" over the level measured in the groundwater sample. In response to my question about this, a December 10, 2010 email from EPA states that they "will consider an increase above 25% of the background value to be significant, depending on evaluation of quality control sample results." Permit condition E.5. should be modified to include this definition of a significant increase. (4) Permit condition F.2. requires Permittee to demonstrate Part II Mechanical Integrity by submitting to the Director a well completion report. Part 11 Mechanical Integrity is