U.S. ENVIRONMENTAL PROTECTION AGENCY

UNDERGROUND INJECTION CONTROL PERMIT

CLASS VITABLE OF CONTENTS

AUTHORITY ..................................................................................................................................... - 1

-

PERMIT CONDITIONS ........................................................................................................................2

A. EF FECT OF PERMIT ......................................................................................................................2

B. P ERMIT ACTIONS..........................................................................................................................2

1. Modi fication, Revocation and Reissuance, and Termination ............................................................... 2

2. Minor Modif

ications ............................................................................................................................. 2

3. Tra nsfer of Permits ............................................................................................................................... 2

C. SEV ERABILITY ..............................................................................................................................2

D. CON FIDENTIALITY.......................................................................................................................3

E. DE FINITION ....................................................................................................................................3

F. DU TIES AND REQUIREMENTS ...................................................................................................3

1. Dut y to Comply..................................................................................................................................... 3

2. Dut y to Reapply .................................................................................................................................... 3

3. P enalties for Violations of Permit Conditions ...................................................................................... 3

4. Ne ed to Halt or Reduce Activity Not a Defense ................................................................................... 3

5. Dut y to Mitigate .................................................................................................................................... 3

6. P roper Operation and Maintenance ...................................................................................................... 3

7. Dut y to Provide Information ................................................................................................................. 4

8. Inspection and Entry ............................................................................................................................. 4 9. Sig natory Requirements ........................................................................................................................ 4

G. AREA O F REVIEW AND CORRECTIVE ACTION .....................................................................4

H. F INANCIAL RESPONSIBILITY ....................................................................................................5

1. Financial Responsibility........................................................................................................................ 5

2. C ost Estimate Updates .......................................................................................................................... 5

3. Notific ation ........................................................................................................................................... 5

4. Establis hing Other Coverage ................................................................................................................ 6

I. C ONSTRUCTION ............................................................................................................................6

1. Sit ing ..................................................................................................................................................... 6

2. C asing and Cementing .......................................................................................................................... 6

3. Tubing and Packer Specifications ......................................................................................................... 6

J. P RE-INJECTION TESTING ............................................................................................................7

K. OPER ATIONS ..................................................................................................................................8

1. Injection Pressure Limitation ................................................................................................................ 8

2. S timulation Program ............................................................................................................................. 8

3. Additiona l Injection Limitation ............................................................................................................ 8

4. Annulus F luid........................................................................................................................................ 85. Annulus/Tubing Pressure Differential .................................................................................................. 8

6. Automatic A larms and Automatic Shut-off System ............................................................................. 8

7. P recautions to Prevent Well Blowouts ................................................................................................. 9

8. C ircumstances Under Which Injection Must Cease ............................................................................. 9 9. Appr oaches for Ceasing Injection ......................................................................................................... 9

L. MEC HANICAL INTEGRITY..........................................................................................................9

1. S tandards ............................................................................................................................................... 9

2. Me chanical Integrity Testing .............................................................................................................. 10

3. P rior Notice and Reporting ................................................................................................................. 11

4. Ga uge and Meter Calibration .............................................................................................................. 11

5. Loss of Mechanical Integrity .............................................................................................................. 11

6. Me chanical Integrity Testing on Request From Director ................................................................... 12

M. TEST ING AND MONITORING ...................................................................................................12

1. Te sting and Monitoring Plan .............................................................................................................. 12

2. C arbon Dioxide Stream Analysis........................................................................................................ 13

3. C ontinuous Monitoring ....................................................................................................................... 13

4. C orrosion Monitoring ......................................................................................................................... 13

5. Ground W ater Quality Monitoring ..................................................................................................... 13

6. Ex ternal Mechanical Integrity Testing................................................................................................ 13

7. Pre ssure Fall-Off Test ......................................................................................................................... 14

8. Plum e and Pressure Front Tracking .................................................................................................... 14

9. S urface Air and/or Soil Gas Monitoring ............................................................................................. 14

10. Additiona l Monitoring ...................................................................................................................... 14

N. R EPORTING AND RECORDKEEPING ......................................................................................14

1. Ele ctronic Reporting ........................................................................................................................... 14

2. Se mi-Annual Reports .......................................................................................................................... 14

3. 24 -Hour Reporting .............................................................................................................................. 15

4. Re ports on Well Tests and Workovers ............................................................................................... 16

5. Advanc e Notice Reporting .................................................................................................................. 16

6. Additi onal Reports .............................................................................................................................. 16

7. Re cords ............................................................................................................................................... 17

O. W ELL PLUGGING, POST-INJECTION SITE CARE, AND SITE CLOSURE ..........................18

1. We ll Plugging Plan ............................................................................................................................. 18

2. Re vision of Well Plugging Plan .......................................................................................................... 18

3. Notice of Plugging and Abandonment ................................................................................................ 18 4. Plug ging and Abandonment Approval and Report ............................................................................. 18

5. Te mporary Abandonment ................................................................................................................... 19

6. Post-Injection Site Care and Site Closure Plan ................................................................................... 19

P. EMERGEN CY AND REMEDIAL RESPONSE ...........................................................................21

Q. C OMMENCING INJECTION .......................................................................................................21ATTACHMENTS .................................................................................................................................23

A . SUMMARY OF REQUIREMENTS

B. AREA OF REVIEW AND CORRECTIVE ACTION PLAN

C. TESTING AND MONITORING PLAN

D. INJECTION WELL PLUGGING PLAN

E. POST-INJECTION SITE CARE AND SITE CLOSURE PLAN

F. EMERGENCY AND REMEDIAL RESPONSE PLAN

G. CONSTRUCTION DETAILS

H. FINANCIAL ASSURANCE DEMONSTRATION

I. STIMULATION PROGRAM- 2

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PERMIT CONDITIONS

A. EFFECT OF PERMIT

The permittee is allowed to engage in underground injection in accordance with the conditions of this permit. Notwithstanding any other provisions of this permit, the permittee authorized by this permit shall not construct, operate, maintain, convert, plug, abandon, or conduct any other injection activity in a manner that allows the movement of injection, annulus or formation fluids into underground sources of drinking water (USDWs) or any unauthorized zones. The objective of this permit is to prevent the movement of fluids into or between USDWs or into any

unauthoriz ed zones consistent with the requirements at 40 CFR 146.86(a). Any underground injection activity not specifically authorized in this permit is prohibited. For purposes of enforcement, compliance with this permit during its term constitutes compliance with Part C of the Safe Drinking Water Act (SDWA). Such compliance does not constitute a defense to any action brought under Section 1431 of the SDWA or any other common or statutory law other than Part C of the SDWA. Issuance of this permit does not convey property rights of any sort or any exclusive privilege; nor does it authorize any injury to persons or property, any invasion of other private rights, or any infringement of State or local laws or regulations. Nothing in this permit s hall be construed to relieve the permittee of any duties under applicable regulations.

B. PERMIT ACTIONS

1. Modification, Revocation and Reissuance, and Termination

– The Director of the Water Division of Region 5 of the U. S. Environmental Protection Agency (EPA), hereinafter, the Director, may, for cause or upon request from any interested person, including the permittee, modify, revoke and reissue, or terminate this permit in accordance with 40 CFR 124.5, 144.12, 146.86(a), 144.39, and 144.40. The permit is also subject to minor modifications for cause as specified in 40 CFR 144.41. The filing of a request for a permit modification, revocation and reissuance, or termination, or the notification of planned changes, or anticipated noncompliance on the part of the permittee does not stay the applicability or enforceability of any permit condition.

2. Minor Modifications

– Upon the consent of the permittee, the Director may modify a permit to make the corrections or allowances for minor changes in the permitted activity as

listed in 40 C FR 144.41. Any permit modification not processed as a minor modification

unde r 40 CFR 144.41 must be made for cause, and with part 124 draft permit and public

notic e as required in 40 CFR 144.39.

3. Transfer of Permits – This permit is not transferable to any person except in accordance with 40 CFR 144.38(a) and Section N(6)(b) of this permit.

C. SEVERABILITY

The provisions of this permit are severable, and if any provision of this permit or the application of any provision of this permit to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not be affected thereby.- 3

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D. CONFIDENTIALITY

In accordance with 40 CFR Part 2 (Public Information) and 40 CFR 144.5, any information submitted to EPA pursuant to this permit may be claimed as confidential business information by the submitter. Any such claim must be asserted at the time of submission by clearly identifying each page with the words "confidential business information" on every page containing such information. If no claim is made at the time of submission, EPA may make the information available to the public without further notice. If a claim is asserted, the validity of the claim will be assessed in accordance with the procedures in 40 CFR Part 2. Claims of confidentiality for the following information will be denied:

1. The name and address of the permittee; and

2. Information which deals with the existence, absence or level of contaminants in drinking

water.

E. DEFINITION

All terms used in this permit shall have the meaning set forth in the SDWA and Underground Inje ction Control regulations specified at 40 CFR parts 124, 144, 146, and 147. Unless specifically stated otherwise, all references to “days” in this permit should be interpreted as calendar days.

F. DUTIES AND REQUIREMENTS

1. Duty to Comply

– The permittee shall comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the SDWA and is grounds for enforcement action, permit termination, revocation and reissuance, modification, or for denial of a permit renewal application.

2. Duty to Reapply

–

If the permittee wishes to continue an activity regulated by this permit after the expiration or termination of this permit, the permittee must apply for and obtain a new permit.

3. Penalties for Violations of Permit Conditions

– Any person who violates a permit requirement is subject to civil penalties and other enforcement action under the SDWA. Any person who willfully violates permit conditions may be subject to criminal prosecution under the SDWA and other applicable statutes and regulations.

4. Need to Halt or Reduce Activity Not a Defense – It shall not be a defense for the permittee in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

5. Duty to Mitigate

–

The permittee shall take all timely and reasonable steps necessary to minimize or correct any adverse impact on the environment resulting from noncompliance with this permit.

6. Proper Operation and Maintenance

– The permittee shall at all times properly operate and- 4

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maintain all facilities and systems of treatment and control and related appurtenances which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance includes, among other things, effective perf ormance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of this perm it.

7. Duty to Provide Information

– The permittee shall furnish to the Director in an electronic

format , within a time specified, any information which the Director may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit or the UIC regulations. The permittee shall also furnish to the Director, upon request within a time specified, electronic copies of

rec ords required to be kept by this permit.

8. Inspection and Entry

– The permittee shall allow the Director or an authorized representative, upon the presentation of credentials and other documents as may be required by law, to:

(a) Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where electronic or non-electronic records are kept under the conditions of this pe rmit;

(b) Have access to and copy, at reasonable times, any electronic or non-electronic records

that are kept under the conditions of this permit;

(c) Inspect, at reasonable times, any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit; and

(d) Sample or monitor, at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the SDWA, any substances or parameters at any location, including facilities, equipment or operations regulated or required under this permit.

9. Signatory Requirements

– All reports or other information, required to be submitted by this permit or requested by the Director shall be signed and certified in accordance with 40

CFR 144.32.

G. AREA OF REVIEW AND CORRECTIVE ACTION

1. The Area of Review (AoR) is the region surrounding the geologic sequestration project where USDWs may be endangered by the injection activity. The area of review is delineated using computational modeling that accounts for the physical and chemical properties of all phases of the injected carbon dioxide stream and is based on available site characterization, monitoring, and operational data. The permittee shall maintain and comply with the

approv ed Area of Review and Corrective Action Plan (Attachment B of this permit) which

is an enfor ceable condition of this permit and shall meet the requirements of 40 CFR 146.84.- 5

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2. At the fixed frequency specified in the Area of Review and Corrective Action Plan, or more frequently when monitoring and operational conditions warrant, the permittee must

ree valuate the area of review and perform corrective action in the manner specified in 40

CFR 146.84 and update the Area of Review and Corrective Action Plan or demonstrate to the Director that no update is needed.

3. Following each AoR reevaluation or a demonstration that no evaluation is needed, the permittee shall submit the resultant information in an electronic format to the Director for review and approval of the AoR results. Once approved by the Director, the revised Area of Review and Corrective Action Plan will become an enforceable condition of this permit.

H. FINANCIAL RESPONSIBILITY

1. Financial Responsibility

– The permittee shall maintain financial responsibility and resources to meet the requirements of 40 CFR 146.85 and the conditions of this permit.

F inancial responsibility shall be maintained through all phases of the project. The approved

financial assurance mechanisms are found in Attachment H and in the administrative record of this permi t.

The financial instrument(s) must be sufficient to cover the cost of:

(a) Corrective action (that meets the requirements of 40 CFR 146.84);

(b) Injection well plugging (that meets the requirements of 40 CFR 146.92);

(c) Post injection site care and site closure (that meets the requirements of 40 CFR 146.93);

(d) Emergency and remedial response (that meets the requirements of 40 CFR 146.94).

2. Cost Estimate Updates

– During the active life of the geologic sequestration project, the permittee must adjust the cost estimate for inflation within 60 days prior to the anniversary date of the establishment of the financial instrument(s) and provide this adjustment to the

Director in an electronic format. The permittee must also provide to the Director written upda tes in an electronic format of adjustments to the cost estimate within 60 days of any

amendme nts to the Project Plans included as Attachments B – F of this permit, which

addre ss items (a) through (d) in Section H(1) of this permit.

3. Notification

–

(a) Whenever the current cost estimate increases to an amount greater than the face amount of a financial instrument currently in use, the permittee, within 60 days after the increase, must either cause the face amount to be increased to an amount at least equal to the current cost estimate and submit evidence of such increase to the Director, or obtain other financial responsibility instruments to cover the increase. Whenever the current cost estimate decreases, the face amount of the financial assurance instrument may be reduced to the amount of the current cost estimate only after the permittee has received written approval from the Director.- 6

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(b) The permittee must notify the Director by certified mail and in an electronic format of

adve rse financial conditions such as bankruptcy that may affect the ability to carry out injection well plugging, post-injection site care and site closure, and any applicable ongoing actions under Corrective Action and/or Emergency and Remedial Response.

(i) In the event that the permittee or the third party provider of a financial

re sponsibility instrument is going through a bankruptcy, the permittee must notify the Director by certified mail and in an electronic format of the commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the permittee as debtor, within 10 days after commencement of the proceeding.

(ii) A guarantor of a corporate guarantee must make such a notification if he or she is named as debtor, as required under the terms of the guarantee.

(iii) A permittee who fulfills the requirements of paragraph (a) of this section by obtaining a trust fund, surety bond, letter of credit, escrow account, or insurance policy will be deemed to be without the required financial assurance in the event of bankruptcy of the trustee or issuing institution, or a suspension or revocation of the authority of the trustee institution to act as trustee of the institution issuing the trust fund, surety bond, letter of credit, escrow account, or insurance policy.

4. Establishing Other Coverage

– The permittee must establish other financial assurance or liability coverage acceptable to the Director, within 60 days of the occurrence of the events

in S ection H (2 ) or H(3) of this permit.

I. CONSTRUCTION

1. Siting

– The permittee has demonstrated to the satisfaction of the Director that the well is in

an area with suitable geology in accordance with the requirements at 40 CFR 146.83.

2. Casing and Cementing

– Casing and cement or other materials used in the construction of

the well must have sufficient structural strength for the life of the geologic sequestration project. All well materials must be compatible with all fluids with which the materials may be expected to come into contact and must meet or exceed standards developed for such materials by the American Petroleum Institute, ASTM International, or comparable standards acceptable to the Director. The casing and cementing program must prevent the movement of fluids into or between USDWs for the expected life of the well in accordance

with 40 CF R 146.86. The casing and cement used in the construction of this well are shown

in Attachment G of this permit and in the administrative record for this permit. Any change

must be submitted in an electronic format for approval by the Director before installation.

3. Tubing and Packer Specifications

– Tubing and packer materials used in the construction

of the well must be compatible with fluids with which the materials may be expected to come into contact and must meet or exceed standards developed for such materials by the American Petroleum Institute, ASTM International, or comparable standards acceptable to the Director. The permittee shall inject only through tubing with a packer set within the long string casing at a point within or below the confining zone immediately above the injection- 7

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zone. The tubing and packer used in the well are represented in engineering drawings contained in Attachment G of this permit. Any change must be submitted in an electronic

format for approval by the Director before installation.

J. PRE-INJECTION TESTING

1. Prior to the Director authorizing injection, the permittee shall perform all pre-injection loggin g, sampling, and testing specified at 40 CFR 146.87. This testing shall include:

(a) L ogs, surveys and tests to determine or verify the depth, thickness, porosity, permeability, lithology, and fo rma tion fluid salinity in all relevant geologic formations.

These tests shall include:

(i) Deviation checks that meet the requirements of 40 CFR 146.87(a)(1);

(ii) Logs and tests before and upon installation of the surface casing that meet the requirements of 40 CFR 146.87(a)(2);

(iii) Logs and tests before and upon installation of the long-string casing that meet the requirements of 40 CFR 146.87(a)(3 );

(iv) Tests to demonstrate internal and external mechanical integrity that meet the requirements of 40 CFR 146.87(a)(4); and

(v) Any alternative methods that are required by and/or approved by the Director pursuant to 40 CFR 146.87(a)(5).

(b) Whole cores or sidewall cores of the injection zone and confining system and formation fluid samples from the injection zone that meet the requirements of 40 CFR 146.87(b);

(c) Records of the fluid temperature, pH, conductivity, reservoir pressure, and static fluid level of the injection zone that meet the requirements of 40 CFR 146.87 (c );

(d) Tests as necessary to provide information about the injection and confining zones to

all ow determination or calculation of the fracture pressure and the physical and chemical

c haracteristics of the injection and confining zones and the formation fluids in the injection zone that meet the requirements of 40 CFR 146.87(d); and

(e) T ests to verify hydrogeologic characteristics of the injection zone that meet the requirements of 40 CFR 146.87 (e ), including:

(i) A pressure fall-off test and

(ii) A pumping test or injectivity tests.

2. The permittee shall submit to the Director for approval in an electronic format a schedule for loggin g and testing activities 30 days prior to conducting the first test and submit any changes to the schedule 30 days prior to the next scheduled test. The permittee must provide- 8

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the Director or their representative with the opportunity to witness all logging, sampling, and testing required under this Section.

K. OPERATIONS

1. Injection Pressure Limitation

– Except during stimulation, the permittee must ensure that injection pressure does not exceed 90 percent of the fracture pressure of the injection zone(s) so as to ensure that the injection does not initiate new fractures or propagate existing

fra ctures in the injection zone(s). In no case shall injection pressure initiate fractures or propagate existing fractures in the confining zone or cause the movement of injection or formation fluids into a USDW. The maximum injection pressure limit is listed in

Atta chment A.

2. Stimulation Program

– Pursuant to requirements at 40 CFR 146.82(a)(9), all stimulation programs proposed by the permittee must be approved by the Director as a permit

modification and incorporated into Attachment I of this permit.

3. Additional Injection Limitation

– No injectate other than that identified on page 1 of this permit shall be injected except fluids used for stimulation, rework, and well tests as approved by the Director.

4. Annulus Fluid

– The permittee must fill the annulus between the tubing and the long string casing with a non-corrosive fluid approved by the Director.

5. Annulus/Tubing Pressure Differential

– Except during workovers or times of annulus maintenance, the permittee must maintain on the annulus a pressure that exceeds the

opera ting injection pressure as specified in Attachment A of this permit, unless the Director

deter mines that such requirement might harm the integrity of the well or endanger USDWs.

6. Automatic Alarms and Automatic Shut-off System

–

(a) The permittee must:

(i) I nstall, continuously operate, and maintain an automatic alarm and an

autom atic shut-off system or, at the discretion of the Director, down-hole shutoff systems, or other mechanical devices that provide equivalent protection;

and

(ii) Successfully demonstrate the functionality of the alarm system and shut-off

sy stem prior to the Director authorizing injection, and at a minimum of once every twelfth month after the last approved demonstration.

(b) Testing under this Section must involve subjecting the system to simulated failure conditions and must be witnessed by the Director or his or her representative unless the Director authorizes an unwitnessed test in advance. The permittee must provide notice in an electronic format 30 days prior to running the test and must provide the

Direc tor or their representative the opportunity to attend. The test must be documented using either a mechanical or digital device which records the value of- 9

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the parameter of interest, or by a service company job record. A final report including a ny additional interpretation necessary for evaluation of the testing must be submitted in an electronic format within the time period specified in Section N(4) of this permit.

7. Precautions to Prevent Well Blowouts

– At all times, the permittee shall maintain on the well a pressure which will prevent the return of the injection fluid to the surface. The well bore must be filled with a high specific gravity fluid during workovers to maintain a positive (downward) gradient and/or a plug shall be installed which can resist the pressure differential. A blowout preventer must be installed and kept in proper operational condition whenever the wellhead is removed to work on the well. The permittee shall follow procedures su ch as those below to assure that a backflow or blowout does not occur:

(a) Limit the temperature and/or corrosivity of the injectate; and

(b) Develop procedures necessary to assure that pressure imbalances do not occur.

8. Circumstances Under Which Injection Must Cease

–

Injection shall cease when any of the following circumstances arises:

(a) Failure of the well to pass a mechanical integrity test;

(b) A loss of mechanical integrity during operation;

(c) The automatic alarm or automatic shut-off system is triggered;

(d) A signific ant unexpected change in the annulus or injection pressure;

(e) The Director determines that the well lacks mechanical integrity; or

(f) The permittee is unable to maintain compliance with any permit condition or regulatory requirement

and the Director determines that injection should cease.

9. Approaches for Ceasing Injection

–

(a) The permittee must shut-in the well by gradual reduction in the injection pressure as outlined in Attachment A of this permit; or

(b) The pe rmittee must immediately cease injection and shut-in the well as outlined in the Emergency and Remedial Response Plan (Attachment F of this permit).

L. ME CHANICAL INTEGRITY

1. Standards

– Other than during periods of well workover (maintenance) approved by the Director in which the sealed tubing-casing annulus is disassembled for maintenance or corrective procedures, the injection well must have and maintain mechanical integrity

consi stent with 40 CFR 146.89. To meet these requirements, mechanical integrity- 10

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tests/demonstrations must be witnessed by the Director or an authorized representative of the Director unless prior approval has been granted by the Director to run an un-witnessed test. In order to conduct testing without an EPA representative, the following procedures

must be followed.

(a) The permittee must submit prior notification in an electronic format within the time period spe cified in Section L(3) of this permit, including the information that no EPA

repre sentative is available, and receive permission from the Director to proceed;

(b) T he test must be performed in accordance with the Testing and Monitoring Plan (Attachment C of this permit) and documented using either a mechanical or digital

device that records the value of the parameter of interest;

(c) A f inal report including any additional interpretation necessary for evaluation of the testing must be submitted in an electronic format within the time period specified in

Section N (4 ) of this permit.

2. Mechanical Integrity Testing

– The permittee shall conduct a casing inspection log and mechanical integrity testing as follows:

(a) Prior to receiving authorization to inject, the permittee shall perform the following testing to demonstrate internal mechanical integrity pursuant to 40 CFR 146.87(a)(4):

(i) A pressure test with liquid or gas; and

(ii) A casing inspection log; or

(iii) An alternative approved by the Director that has been approved by the Administrator pursuant to requirements at 40 CFR 146.89(e).

(b) Prior to receiving authorization to inject, the permittee shall perform the following testing to demonstrate external mechanical integrity pursuant to 40 CFR 146.87(a)(4):

(i) A tracer survey such as an oxygen activation log; or

(ii) A temperature or noise log; or

(iii) An alternative approved by the Director that has been approved by the Administrator pursuant to requirements at 40 CFR 146.89(e).

(c) Other than during periods of well workover (maintenance) approved by the Director in

which the sealed tubing-casing annulus is disassembled for maintenance or corrective procedures, the permittee must continuously monitor injection pressure, injection rate, injection volumes; pressure on the annulus between tubing and long string casing; and

ann ulus fluid volume as specified in 40 CFR 146.88(e), and 146.89(b).

(d) A t least once per year, the permittee must perform the following testing to demonstrate external mechanical integrity pursuant to 40 CFR 146.89(c) :- 11

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(i) An Administrator-approved tracer survey such as an oxygen-activation log; or

(ii) A temperature or noise log. The Director may require such tests whenever the well is worked over; or

(iii) An alternative approved by the Director that has been approved by the Administrator pursuant to requirements at 40 CFR 146.89(e).

(e) After any workover that may compromise the internal mechanical integrity of the well,

the we ll shall be tested by means of a pressure test approved by the Director and the well

must pa ss the test to demonstrate mechanical integrity.

(f) Prior to plugging the well, the permittee shall demonstrate external mechanical integrity as described in the Injection Well Plugging Plan and that meets the requirements of 40 CFR 146.92(a).

(g) The Director may require the use of any other tests to demonstrate mechanical integrity

other than those listed above with the written approval of the Administrator pursuant to requirements at 40 CFR 146.89(e).

3. Prior Notice and Reporting

–

(a) The permittee shall notify the Director in an electronic format of his or her intent to

demons trate mechanical integrity in an electronic format at least 30 days prior to such

demons tration. At the discretion of the Director a shorter time period may be allowed.

(b) Reports of mechanical integrity demonstrations which include logs must include an interpretation of results by a knowledgeable log analyst. The permittee shall report in an

elec tronic format the results of a mechanical integrity demonstration within the time period specified in Section N(4) of this permit.

4. Gauge and Meter Calibration

– The permittee shall calibrate all gauges used in mechanical integrity demonstrations and other required monitoring to an accuracy of not less than 0.5 percent of full scale, within one year prior to each required test. The date of the most recent calibration shall be noted on or near the gauge or meter. A copy of the

calibration certificate shall be submitted to the Director in an electronic format with the report of the test. Pressure gauge resolution shall be no greater than five psi. Certain

mecha nical integrity and other testing may require greater accuracy and shall be identified in the procedure submitted to the Director prior to the test.

5. Loss of Mechanical Integrity

–

(a) If the permittee or the Director finds that the well fails to demonstrate mechanical integrity during a test, or fails to maintain mechanical integrity during operation, or that a loss of mechanical integrity as defined by 40 CFR 146.89(a)(1) or (2) is suspected during operation (such as a significant unexpected change in the annulus or injection pressure), the permittee must:- 12

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(i) Cease injection in accordance with Sections K(8) and K(9)(a) or (b), and

Attac hments C or F of this permit;

(ii) Take all steps reasonably necessary to determine whether there may have been a release of the injected carbon dioxide stream or formation fluids into any unauthorized zone. If there is evidence of USDW endangerment, implement the Emergency and Remedial Response Plan (Attachment F of this permit);

(iii) Follow the reporting requirements as directed in Section N of this permit;

(iv) R estore and demonstrate mechanical integrity to the satisfaction of the Director and receive written approval from the Director prior to resuming injection; and

(v) Notify

the Director in an electronic format when injection can be expected to

resume

.

(b) If a shutdown ( i.e., down-hole or at the surface) is triggered, the permittee must immediately investigate and identify as expeditiously as possible the cause of the shutdown. If, upon such investigation, the well appears to be lacking mechanical integrity, or if monitoring required indicates that the well may be lacking mechanical integrity, the permittee must take the actions listed above in Section L(5)(a)(i) through (v).

(c) If the well loses mechanical integrity prior to the next scheduled test date, then the well

must either be plugged or repaired and retested within 30 days of losing mechanical integrity. The permittee shall not resume injection until mechanical integrity is demonstrated and the Director gives written approval to recommence injection in cases where the well has lost mechanical integrity.

6. Mechanical Integrity Testing on Request From Director

– The permittee shall demonstrate mechanical integrity at any time upon written notice from the Director.

M. TESTING AND MONITORING

1. Testing and Monitoring Plan

–

(a) The permittee shall maintain and comply with the approved Testing and Monitoring Plan (A ttachment C of this permit) and with the requirements at 40 CFR 144.51(j), 146.88(e),

a nd 146.90. The Testing and Monitoring Plan is an enforceable condition of this permit. Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. Procedures for all testing and monitoring under this permit

must be submitted to the Director in an electronic format for approval at least 30 days prior to the test. In performing all testing and monitoring under this permit, the permittee must follow the procedures approved by the Director. If the permittee is unable to follow the EPA approved procedures, then, the permittee must contact the Director at least 30 days prior to testing to discuss options, if any are feasible. When the test report is submitted, a full explanation must be provided as to why any approved procedures were- 13

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not followed. If the approved procedures were not followed, EPA may take an appropriate action, including but not limited to, requiring the permittee to re-run the test.

(b) The permittee must update the Testing and Monitoring Plan as required at 40 CFR

146.90 (j ) to incorporate monitoring and operational data and in response to AoR reevaluations required under Section G.2. of this permit or demonstrate to the Director that no update is needed. The amended Testing and Monitoring Plan or demonstration

shall be submitted to the Director in an electronic format within one year of an AoR reevaluation; following any significant changes to the facility such as addition of monitoring wells or newly permitted injection wells within the AoR; or when required by the Director.

(c) Following each update of the Testing and Monitoring Plan or a demonstration that no update is needed, the permittee shall submit the resultant information in an electronic format to the Director for review and approval of the results. Once approved by the

Direc tor, the revised Testing and Monitoring Plan will become an enforceable condition of this permit.

2. Carbon Dioxide Stream Analysis

– The permittee shall analyze the carbon dioxide stream with sufficient frequency to yield data representative of its chemical and physical characteristics, as described in the Testing and Monitoring Plan and to meet the requirements of 40 CFR 146.90(a).

3. Continuous Monitoring

– The permittee shall maintain continuous monitoring devices and use them to monitor injection pressure, flow rate, volume, the pressure on the annulus between the tubing and the long string of casing, annulus fluid level, and temperature. This monitoring shall be performed as described in the Testing and Monitoring Plan to meet the requirements of 40 CFR 146.90(b). The permittee shall maintain for EPA's inspection at the

fa cility an appropriately scaled, continuous record of these monitoring results as well as original files of any digitally recorded information pertaining to these operations.

4. Corrosion Monitoring

– The permittee shall perform corrosion monitoring of the well materials for loss of mass, thickness, cracking, pitting, and other signs of corrosion on a quarterly basis using the procedures described in the Testing and Monitoring Plan and in

ac cordance with 40 CFR 146.90(c) to ensure that the well components meet the minimum standards for material strength and performance set forth in 40 CFR 146.86(b).

5. Ground Water Quality Monitoring

– The permittee shall monitor ground water quality and geochemical changes above the confining zone(s) that may be a result of carbon dioxide movement through the confining zone(s) or additional identified zones. This monitoring shall be performed for the parameters identified in the Testing and Monitoring Plan at the locations and depths, and at frequencies described in the Testing and Monitoring Plan to

meet t he requirements of 40 CFR 146.90(d).

6. External Mechanical Integrity Testing

– The permittee shall demonstrate external mechanical integrity as described in the Testing and Monitoring Plan and Section L of this permit to meet the requirements of 40 CFR 146.90(e).- 14

- IL -137-6A-0003

7. Pressure Fall-Off Test

– The permittee shall conduct a pressure fall-off test at least onceevery five years unless more frequent testing is required by the Director based on sitespecific information. The test shall be performed as described in the Testing and Monitoring Plan to meet the requirements of 40 CFR 146.90(f).

8. Plume and Pressure Front Tracking

– The permittee shall track the extent of the carbon dioxide plume and the presence or absence of elevated pressure (e.g., the pressure front) as described in the Testing and Monitoring Plan.

(a) The permittee shall use direct methods to track the position of the carbon dioxide plume and the pressure front in the injection zone as described in the Testing and Monitoring Plan and to meet the requirements of 40 CFR 146.90(g)(1).

(b) The permittee shall use indirect methods to track the position of the carbon dioxide plume and pressure front as described in the Testing and Monitoring Plan and to meet the requirements of 40 CFR 146.90(g)(2).

9. Surface Air and/or Soil Gas Monitoring

– The permittee shall conduct any surface air monitoring and/or soil gas monitoring required by the Director to detect movement of carbon dioxide that could endanger a USDW at the frequency and locations described in the Testing and Monitoring Plan to meet the requirements of 40 CFR 146.90(h).

10. Additional Monitoring

– If required by the Director as provided in 40 CFR 146.90(i), the permittee shall perform any additional monitoring determined to be necessary to support, upgrade, and improve computational modeling of the AoR evaluation required under 40 CFR 146.84(c) and to determine compliance with standards under 40 CFR 144.12 or 40

CF R 146.86(a). This monitoring shall be performed as described in a modification to the

Testi ng and Monitoring Plan.

N. REPORTING AND RECORDKEEPING

1. Electronic Reporting

– Electronic reports, submittals, notifications and records made and maintained by the permittee under this permit must be in an electronic format approved by

EPA. The permittee shall electronically submit all required reports to the Director at:

https://epa.velo.pnnl.gov/operators

2. Semi-Annual Reports

– The permittee shall submit semi-annual reports containing:

(a) Any changes to the physical, chemical, and other relevant characteristics of the carbon dioxide stream from the proposed operating data;

(b) Monthly average, maximum, and minimum values for injection pressure, flow rate and daily volume, temperature, and annular pressure;

(c) A description of any event that exceeds operating parameters for annulus pressure or injection pressure specified in the permit;- 15

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(d) A description of any event which triggers the shut-off systems required in Section(K)(6) of this per

mit pursuant to 40 CFR 146.88(e), and the response taken;

(e ) The monthly volume and/or mass of the carbon dioxide stream injected over the reporting period and the volume and/or mass injected cumulatively over the life of the project;

(f) Monthly annulus fluid volume added or produced; and

(g) R esults of the continuous monitoring required in Section M(3) including:

(i) A tabulation of: (1) daily maximum injection pressure, (2) daily minimum annulus pressure, (3) daily minimum value of the difference between simultaneous measurements of annulus and injection pressure, (4) daily volume, (5) daily maximum flow rate, and (6) average annulus tank fluid level; and

(ii) Graph(s) of the continuous monitoring as required in Section M(3) of this permit, or of daily average values of these parameters. The injection pressure, injection volume and flow rate, annulus fluid level, annulus pressure, and temperature shall be submitted on one or more graphs, using contrasting symbols or colors, or in another manner approved by the Director; and

(h) Results of any additional monitoring identified in the Testing and Monitoring Plan and described in Section M of this permit.

3. 24 -Hour Reporting

–

(a) The permittee shall report to the Director any permit noncompliance which may endanger human health or the environment and/or any events that require impleme ntation of actions in the Emergency and Remedial Response Plan (Attachment F of this permit) . Any information shall be provided orally within 24 hours from the time the permittee becomes aware of the circumstances. Su ch verbal reports shall include, but not be limited to the following information:

(i) Any evidence that the injected carbon dioxide stream or associated pressure front may cause an endangerment to a USDW, or any monitoring or other information which indicates that any contaminant may cause endangerment to a USDW;

(ii) Any noncompliance with a permit condition, or malfunction of the injection system, which may cause fluid migration into or between USDWs;

(iii) Any triggering of the shut-off system required in Section (K )(6) of this permit (i.e.,

down- hole or at the surface);

(iv) Any failure to maintain mechanical integrity;

(v) Pursuant to compliance with the requirement at 40 CFR 146.90(h) for surface- 16

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air/soil gas monitoring or other monitoring technologies, if required by th e Director, any release of carbon dioxide to the atmosphere or biosphere; and

(vi) Actions taken to implement appropriate protocols outlined in the Emergency and Remedial Response Plan (Attachment F of this permit).

(b) A written submission shall be provided to the Director in an electronic format within

five da ys of the time the permittee becomes aware of the circumstances described in

Se ction(N)(3)(a) of this permit. The submission shall contain a description of the noncompl iance and its cause; the period of noncompliance, including exact dates and times, and, if the noncompliance has not been corrected, the anticipated time it is expected to continue as well as actions taken to implement appropriate protocols

outlined in the E mergency and Remedial Response Plan (Attachment F of this permit) ; and steps taken or planned to reduce, eliminate and prevent recurrence of the noncompliance.

4. Reports on Well Tests and Workovers

– Report, within 30 days, the results of:

(a) Periodic tests of mechanical integrity;

(b) Any well workover, including stimulation;

(c) Any other test of the injection well conducted by the permittee if required by the Director; and

(d) Any test of any monitoring we ll required by this permit.

5. Advance Notice Reporting

–

(a) Well Tests

– The permittee shall give at least 30 days advance written notice to the Director in an electronic format of any planned workover, stimulation, or other well test.

(b) Planned Changes

– The permittee shall give written notice to the Director in an electronic format, as soon as possible, of any planned physical alterations or additions to the permitted injection facility other than minor repair/replacement or maintenance activities. An analysis of any new injection fluid shall be submitted to the Director for review and written approval at least 30 days prior to injection; this approval may result in a permit modification.

(c) Anticipated Noncompliance

– The permittee shall give at least 14 days advance written notice to the Director in an electronic format of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements.

6. Additional Repor ts
–

(a) Compliance Schedules

– Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted in an electronic format by the permittee no- 17

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later than 30 days following each schedule date.

(b) Transfer of Permits

– This permit is not transferable to any person except after notice is sent to the Director in an electronic format at least 30 days prior to transfer and the requirements of 40 CFR 144.38(a) have been met. Pursuant to requirements at 40 CFR 144.38(a), the Director will require modification or revocation and reissuance of the permit to change the name of the permittee and incorporate such other requirements as may be necessary under the SDWA.

(c) Other Noncompliance

– The permittee shall report in an electronic format all other instances of noncompliance not otherwise reported with the next monitoring report. The reports shall contain the information listed in Section N(3)(b) of this permit.

(d) Other Information

– When the permittee becomes aware of failure to submit any relevant facts in the permit application or that incorrect information was submitted in a

p ermit application or in any report to the Director, the permittee shall submit such facts or corrected information in an electronic format within 10 days in accordance with 40

CF R 144.51(l)(8).

(e) Report on Permit Review

– Within 30 days of receipt of this permit, the permittee shall certify to the Director in an electronic format that he or she has read and is personally

fami liar with all terms and conditions of this permit.

7. Records

–

(a) The permittee shall retain records and all monitoring information, including all

ca libration and maintenance records and all original chart recordings for continuous monitoring instrumentation and copies of all reports required by this permit (including records from pre-injection, active injection, and post-injection phases) for a period of at least 10 years from collection.

(b) The pe rmittee shall maintain records of all data required to complete the permit appli cation form for this permit and any supplemental information (e.g. modeling inputs

for A oR delineations and reevaluations, plan modifications) submitted under 40 CFR

144.27

, 144.31 , 144.39, and 144.41 for a period of at least 10 years after site closure.

(c) The permittee shall retain records concerning the nature and composition of all injected

fluids until 10 years after site closure.

(d) The retention periods specified in Section N(7)(a) through (c) of this permit may be extended by request of the Director at any time. The permittee shall continue to retain records after the retention period specified in Section N(7)(a) through (c) of this permit or any requested extension thereof expires unless the permittee delivers the records to the Director or obtains written approval from the Director to discard the records.

(e) Records of monitoring information shall include:

(i) The date, exact place, and time of sampling or measurements;- 18

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(ii) The name(s) of the individual(s) who performed the sampling or measurements;

(iii) A precise description of both sampling methodology and the handling of samples;

(iv) The date(s) analyses were performed;

(v) The name(s) of the individual(s) who performed the analyses;

(vi) The analytical techniques or methods used; and

(vii) The results of such analyses.

O. WELL PLUGGING, POST-INJECTION SITE CARE, AND SITE CLOSURE

1. Well Plugging Plan – The permittee shall maintain and comply with the approved Well Plugging Plan (Attachment D of this permit) which is an enforceable condition of this permit and shall meet the requirements of 40 CFR 146.92.

2. Revision of Well Plugging Plan

– If the permittee finds it necessary to change the Well Plugging Plan (Attachment D of this permit), a revised plan shall be submitted in an elec tronic format to the Director for written approval. Any amendments to the Well Plugging Plan must be approved by the Director and must be incorporated into the permit, and are subject to the permit modification requirements at 40 CFR 144.39 or 144.41.

3. Notice of Plugging and Abandonment

– The permittee must notify the Director in writing in an electronic format pursuant to 40 CFR 146.92(c), at least 60 days before plugging,

conve rsion or abandonment of a well. At the discretion of the Director, a shorter notice period may be allowed.

4. Plugging and Abandonment Approval and Report

–

(a) The permittee must receive written approval of the Director before plugging the well and

shall plug and abandon the well in accordance with 40 CFR 146.92, as provided in the Well Plugging Plan (Attachment D of this permit)

.

(b) Within 60 days after plugging, the permittee must submit in an electronic format a pluggin g report to the Director. The report must be certified as accurate by the permittee and by the person who performed the plugging operation (if other than the permittee.)

The permittee shall retain the well plugging report in an electronic format for 10 years following sit e closure. The report must include:

(i) A statement that the well was plugged in accordance with the Well Plugging Plan previously approved by the Director (Attachment D of this permit); or

(ii) If the actual plugging differed from the approved plan, a statement describing the

ac tual plugging and an updated plan specifying the differences from the plan previous ly submitted and explaining why the Director should approve such- 19

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deviation. If the Director determines that a deviation from the plan incorporated in this permit may endanger underground sources of drinking water, the permittee

shall replug the well as required by the Director.

5. Temporary Abandonment

– If the permittee ceases injection into the well for more than 24 consecutive months, the well is considered to be in a temporar il y abandoned status, and the permittee shall plug and abandon the well in accordance with the approved Well PluggingPlan, 40 CFR 144.52 (a)(6), and 40 CFR 146.92, or make a demonstration of nonenda ngerment of this well while it is in temporary abandonment status. During any periods of temporary abandonment or disuse, the well will be tested to ensure that it maintains mechanical integrity, according to the requirements and frequency specified in Section L(2) of this permit. The permittee shall continue to comply with the conditions of this permit, including all monitoring and reporting requirements according to the frequencies outlined in the permit.

6. Post-Injection Site Care and Site Closure Plan

–

(a) The permittee shall maintain and comply with the Post-Injection Site Care and Site

Closure Plan , found as Attachment E of this permit, which meets the requirements of 40 CFR 146.93 and is an enforceable condition of this permit. The permittee shall:

(i) Upon cessation of injection, either submit in an electronic format for the Director’s

approv al an amended Post-Injection Site Care and Site Closure Plan or demonstrate through monitoring data and modeling results that no amendment to the plan is needed.

(ii) At an y time during the life of the project, the permittee may modify and resubmit in an electronic format the Post-Injection Site Care and Site Closure Plan for the

Direc tor’s approval. The permittee may, as part of such modifications to the Plan, request a modification to the post-injection site care timeframe that includes

documenta tion of the information at 40 CFR 146.93(c)(1).

(b) The permittee shall monitor the site following the cessation of injection to show the position of the carbon dioxide plume and pressure front and demonstrate that USDWs are not being endangered, as specified in the Post-Injection Site Care and Site Closure

Plan and in 40 CFR 146.90, and 40 CFR 146.93, includ ing:

(i) Ground water quality monitoring;

(ii) Tracking the position of the carbon dioxide plume and pressure front including direct pressure monitoring and geochemical plume monitoring and the use of

indirect methods;

(iii) Any other required monitoring, e.g., soil gas and/or surface air monitoring described in the Post-Injection Site Care and Site Closure Plan;- 20

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(iv) The permittee shall submit in an electronic format the results of all monitoring perf ormed according to the schedule identified in the Post-Injection Site Care and Site Closure Plan; and

(v) The permittee shall continue to conduct post-injection site monitoring for at least 50 years or for the duration of any alternative timeframe approved pursuant to 40

CF R 146.93(c) and the Post-Injection Site Care and Site Closure Plan.

(c ) The post-injection monitoring must continue until the project no longer poses an endangerment to USDWs and the demonstration pursuant to 40 CFR 146.93(b)(2) and as described in Section O(6 )( d) of this permit is approved by the Director.

(d) Prior to authorization for site closure, the permittee shall submit to the Director for review and approval, in an electronic format, a demonstration, based on information

c ollected pursuant to Section O(6)(b) of this permit, that the carbon dioxide plume and

the a ssociated pressure front do not pose an endangerment to USDWs and that no

addit ional monitoring is needed to ensure that the project does not pose an endangerment to USDWs, as required under 40 CFR 146.93(b)(3). The Director reserves the right to amend the post-injection site monitoring requirements (including extend the monitoring period) if there is a concern that USDWs are being endangered.

(e) The permittee shall notify the Director in an electronic format at least 120 days before

site closure. At this time, if any changes to the approved Post-Injection Site Care and Site Closure Plan in Attachment E of this permit are proposed, the permittee shall submit

a re vised plan.

(f) After the Director has authorized site closure, the permittee shall plug all monitoring wells as specified in Attachment E of this permit – the Post-Injection Site Care and Site

C losure Plan

– in a manner which will not allow movement of injection or formationfluids that endangers a USDW. The permittee shall also restore the site to its preinjection condition.

(g) The permittee shall submit a site closure report in an electronic format to the Director

within 90 da ys of site closure. The report must include the information specified at 40

CF R 146.93(f).

(h) The permittee shall record a notation on the deed to the facility property or any other document that is normally examined during a title search that will in perpetuity provide any potential purchaser of the property the information listed at 40 CFR 146.93(g).

(i) The pe rmittee shall retain for 10 years following site closure an electronic copy of the

site closure report , records collected during the post-injection site care period, and any

other re cords required under 40 CFR 146.91(f)(4). The permittee shall deliver the

rec ords in an electronic format to the Director at the conclusion of the retention period.- 21

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P. EMERGENCY AND REMEDIAL RESPONSE

1. The Emergency and Remedial Response Plan describes actions the permittee must take to address movement of the injection or formation fluids that may cause an endangerment to a USDW during construction, operation, and post-injection site care periods. The permittee

shall maintain and comply with the approved Emergency and Remedial Response Plan (Attachment F of this permit), which is an enforceable condition of this permit, and with 40

C FR 146.94.

2. If the permittee obtains evidence that the injected carbon dioxide and/or associated pressure front may cause endangerment to a USDW, the permittee must:

(a) Cease injection in accordance with Sections K(8) and K(9)(a) or (b), and Attachments

C or F of this permit;

(b) Take all steps reasonably necessary to identify and characterize any release;

(c) Notify the Director within 24 hours; and

(d) Implement the Emergency and Remedial Response Plan (Attachment F of this permit) approved by the Director.

3. At the frequency specified in the Area of Review and Corrective Action Plan, or more frequently when monitoring and operational conditions warrant, the permittee shall review

and update the Emergency and Remedial Response Plan as required at 40 CFR 146.94(d) or

demons trate to the Director that no update is needed. The permittee shall also incorporate monitoring and operational data and in response to AoR reevaluations required under Section G.2. of this permit or demonstrate to the Director that no update is needed. The amended Emergency and Remedial Response Plan or demonstration shall be submitted to the Director in an electronic format within one year of an AoR reevaluation; following any signific ant changes to the facility such as addition of injection wells ; or when required by

the Director.

4. Following each update of the Emergency and Remedial Response Plan or a demonstration

that no update is need ed, the permittee shall submit the resultant information in an electronic format to the Director for review and confirmation of the results. Once approved by the Director, the revised Emergency and Remedial Response Plan will become an enforceable condition of this permit.

Q. COMMENCING INJECTION

The permittee may not commence injection until:

1. Results of the formation testing and logging program as specified in Section J of this permit

and in 40 CFR 146.87 are submitted to the Director in an electronic format and subsequently

review ed and approved by the Director;- 22

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2. Mechanical integrity of the well has been demonstrated in accordance with 40 CFR 146.89(a)(1) and (2), and in accordance with Section L(1) through (3) of this permit;

3. The completion of corrective action required by the Area of Review and Corrective Action Plan found in Attachment B of this permit in accordance with 40 CFR 146.84;

4. All requirements at 40 CFR 146.82(c) have been met, including but not limited to reviewing

and updating of the Area of Review and Corrective Action, Testing and Monitoring, Well Plugging, Post-Injection Site Care and Site Closure, and Emergency and Remedial Response plans to incorporate final site characterization information, final delineation of the AoR, and

the re sults of pre-injection testing, and information has been submitted in an electronic

for mat, reviewed and approved by the Director;

5. Construction is complete and the permittee has submitted to the Director in an electronic format a notice that completed construction is in compliance with 40 CFR 146.86 and

Se ction I of this permit;

6. The Director has inspected or otherwise reviewed the injection well and all submitted information and finds it is in compliance with the conditions of the permit ;

7. The Director has approved demonstration of the alarm system and shut-off system under

Se ction K.6 of this permit; and.

8. The Director has given written authorization to commence injection.- 23

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ATTACHMENTS

These attachments include, but are not limited to, permit conditions and plans concerning operating procedures, monitoring and reporting, as required by 40 CFR Parts 144 and 146. The permittee shall comply with these conditions and adhere to these plans as approved by the Director, as

follows:

A. SUMMARY OF OPERATING REQUIREMENTS

B. AREA OF REVIEW AND CORRECTIVE ACTION PLAN

C. TESTING AND MONITORING PLAN

D. WELL PLUGGING PLAN

E. POST-INJECTION SITE CARE AND SITE CLOSURE PLAN

F. EMERGENCY AND REMEDIAL RESPONSE PLAN

G. CONSTRUCTION DETAILS

H. FINANCIAL ASSURANCE DEMONSTRATION

I. STIMULATION PROGRAM