2011-01-03_GENERAL DOCUMENTS - P2008043 (3)

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F. MECHANICAL INTEGRITY (MI) TEST REQUIREMENTS Injection into a well that lacks MI is prohibited. An injection well has MI if there is no significant leak in the casing, tubing, or packer (Part I); and there is no significant fluid movement into a USDW through vertical channels adjacent to the injection well bore (Part II). 1. Requirement to Demonstrate MI. The penm.ittee shall demonstrate MI prior to commencing injection. Well construction dictates the methods for demonstrating MI. A demonstration of mechanical integrity shall include both internal (Part I) and external (Part II). The Director may require additional or alternative tests if the results presented by the operator are not satisfactory to the Director to demonstrate there is no movement of fluids into or between USDWs resulting from injection activity. Results of MI tests shall be submitted to the Director for review before injection begins. 2. Methods for Demonstrating MI. The pernuttee shall demonstrate Part I MI by a standard tubing-casing annulus pressure test using a pressure of 100 psi that shall be held for 15 minutes with less than 10 % pressure loss. Test results shall be submitted to the Director for review. The pemiittee shall demonstrate Part 11 Ml by submitting to the Director a well completion report. including information about the cementing of the annulus between the well casing and the borehole. G. AUTHORIZATION TO INJECT The Director shall review the report of analytical results required under Section E.3 and the demonstration of mechanical integrity required under Section F.2. After determining that (a) the analytical results from the injectate sample demonstrate that the A2 sandstone groundwater meets permit limits or does not exceed the concentrations of the samples collected under Section E. I (a), (b) results of the Part I MI test and the well completion report demonstrate adequate mechanical integrity. and (c) the sutnmary of the aquifer-pump test results meets the requirements of Section E.4. the Director shall issue an Authorization to Inject notification letter to the pennittee. Injection of the stored A2 sandstone groundwater before receiving the Authorization to Inject notification letter shall be considered a violation of this permit. If the results of the aquifer-pump test shows that there is a breach in the confinement zones of the A2 sandstone. the authorization to inject may contain additional monitoring requirements during injection, as deemed necessary by the Director. The results of that monitoring will be submitted to EPA for review. Powertech (USA), Incorporated Final UIC Class V Permit No. C051237-08412 Pale 6 of 14