COMPLIANCE INFO_FILE 1 - Laserfiche WebLink

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1 The annular pressure will be limited by the permit to a minimum operating value of 100 psig for leak detection. The permittee is required to continuously monitor the fluid level in the annular space. A total annular fluid volume change exceeding two gallons at Standard Temperature and Pressure (STP) would constitute a significant leak. The permittee is also required to notify EPA when the total an- nular fluid volume varies from the above range. Maintaining a positive annular pressure will allow for con- tinuous mechanical integrity monitoring of the casing, tubing, and packer. The draft permit specifies that the EPA, Region 9, be notified within 24 hours of the noncom- pliance. This notification of noncompliance must be fol- lowed by written notice within five days. Well repair and mechanical integrity testing are required if the problem is found to be within the well. The annular fluid volume range and minimum annular pressure must be maintained unless a demonstration for suitable al- ternate values is submitted by the permittee and has been approved, in writing, by the Director. d. Monitoring Requirements EPA regulations (40 CFR §146. 13) require continuous monitoring and recording of injection pressure, flow rate and volume, and annular pressure. Additional requirements have also been specified in Part II, Section C of the draft permit. EPA regulations also require sample analysis of the injected fluid with sufficient frequency so as to yield representative data of its characteristics. e. Reporting Requirements The draft permit requires the applicant to report the results of all monitoring on a quarterly basis to the EPA and the Central Valley Regional Water Quality Control Board. In compliance with 40 CFR §146. 13, the draft permit re- quires the applicant to report the daily and monthly average injection pressure, maximum and minimum values for injection pressure, flow rate and volume, temperature, and the annular pressure and annular fluid volume for the in- jection well. The draft permit also requires the applicant to report the results of the injection fluid analysis. In addition to routine quarterly reporting, the draft per- mit requires reporting of the results of any mechanical in- tegrity testing or any other well workover, logging, or testing that may reveal the condition of the casing, tubing, or packer. These reports are due within ninety 9