HomeMy WebLinkAbout20021142.tiff th
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8
ktituktacteel 999 18T"STREET - SUITE 300
DENVER, CO 80202-2466
http://www.epa.govIregion08
APR 26 2002
Ref: 8P-W-GW
CERTIFIED MAIL
RETURN REOUESTED
Mr. Kevin P. Kauffinan
President
Kauffman Well Services, Inc.
1675 Broadway, Suite 2800
Denver, Colorado 80621
RE: UNDERGROUND INJECTION CONTROL(UIC)
Administrative & Technical Review Wattenberg
Disposal, LLC. Application for a New Class I, Non-
hazardous Disposal Well Permit, Suckla Farms #1:
CO10938-02115; Sec. 10 - T1N - R67W, 6"'PM
Weld County, Colorado.
Dear Mr. Kauffman:
The Environmental Protection Agency(EPA) has reviewed the contents of the referenced
UIC Permit application for a renewal of the existing Class I Permit for the Suckla Farms #1.
This request was received on March 7, 2002. After reviewing all of the submitted information
and the information contained in the existing Permit file, we have determined that the application
is administratively complete.
We are in the process of reviewing the technical aspects of the Suckla Farms #1 Permit.
Although you submitted some data and graphs relating to the October 26, 2001,pressure falloff
test, there is no written analysis of the test attached. We are requesting a narrative description of
the test, including an analysis of the flow characteristics of the reservoir and a comparison of
these test results with previous yearly falloff tests. We also need the injection rate, injection
pressure and volume data for the 48 hour period prior to the shut-in period.
In reviewing the October 26, 2001, temperature log results, we note that the test did not ll5,e
follow EPA's guidance for temperature surveys. A copy of the January 12, 1999, guidance is pi 00,_?y
(04/f/garlid& 2002-1142
5 D/-
de " AL *L Printed on Recycled Paper
enclosed. Our procedure calls for a temperature survey(at a logging speed of no more than 30
feet per minute) while injecting and three to four shut-in surveys. These are commonly run at 2
hours, 4 hours and at 8 and/or 24 hours after shut-in. More specific details are provided in the
guidance document. We are concerned that the number of runs are inadequate to assure no flow
above the perforations. The log we received did not have a header showing the logging speed
used for obtaining the temperature curves. EPA guidance recommends that temperature logs
used to demonstrate the absence of fluid movement be conducted at 30 feet per minute. A faster
logging speed may affect the results. We are requesting that you provide us with information on
the logging speed and any additional information that may shed light on the validity of the
logging results. There is a possibility that this test will need to be rerun.
We are starting to prepare the Draft Permit and Statement of Basis. This may lead to
additional questions regarding specific Permit conditions. If you have any questions or
comments (especially as it pertains to the preparation of the Draft Permit and Statement of
Basis), please contact Paul S. Osborne at 303.312.6125. If any additional information is
necessary to clarify, modify or supplement previously submitted material, you will be notified.
Since ,
D. dwin H gl
Director
Ground Water Program
Enclosure: EPA Guidance for Temperature logging
cc: Mr. Robert EU Smith, OGWDW
Weld County Commissioners
Mr. Ed DiMatteo, COGCC
Colorado State Engineer's Office
Attn: Mr. George Van Slyke
Mr. Morris Bell, COGCC
Mr. David Holm, CDPHE
Mr. Gary Baughman, CDPHE
2
I
s°t�'Fr. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
(`w a 1 REGION VIII
Y 999 18th STREET - SUITE 500
lc DENVER, COLORADO 80202-2466
TEMPERATURE LOGGING FOR MECHANICAL INTEGRITY
January 12, 1999
PURPOSE:
The purpose of this document is to provide a guideline for the acquisition of temperature
surveys, a procedure that may be used to determine the internal mechanical integrity of tubing and
casing in an injection well. A temperature survey may be used to verify confinement of injected fluids
within the injection formation.
Test results must be documented with service company or other appropriate (acceptable)
records and/or charts, and the test should be witnessed by an EPA inspector. Arrangements may be
made by contacting the EPA Region 8 Underground Injection Control (UIC) offices using the EPA toll-
free number 1-800-227-8917 (ask for extension 6137 or 6155).
LOGGING PROCEDURE
Run the temperature survey while going into the hole, with the temperature sensor located as close to
the bottom of the tool as possible. The tool need not be centralized.
Record temperatures a 1-5°F per inch, on a 5 inches per 100 feet log scale.
Logging speed should be within 20 - 30 feet per minute.
Run the log from ground level to total depth (or plug-back depth) of the well.
When using digital logging equipment, use the highest digital sampling rate as possible. Filtering
should be kept to a minimum so that small scale results are obtained and preserved.
Record the first log trace while injecting at up to the maximum allowed injection pressure.
Subsequent to the temperature survey, the maximum injection pressure will be limited to the pressure
used during the survey.
LOG TRACES
Log the first log trace while the well is actively injecting, and record traces for gamma ray,
temperature, and differential temperature. Shut-in (not injecting) temperature curves should be
recorded at intervals depending on the length of time that the injection well has been active.
Preferred time intervals are shown in the following table:
Active Injection Record Curves at These Times (In Hours)
1 month 1 3 6 12
6 months 1 6 10-122 22-24
1 year 1 10.12 22-24 45-48
5 years 1 10.12 22.24 45-48 90-96
10 years or more 1 22-24 45-48 90-96 186-192
13) Printed on Recycled Paper
Hello