Laserfiche WebLink
,f"pe`~A. UNITED STATES ENVIRONMENTAL PROTEC• N AGENCY <br />r ~ REGION VIII <br />`~ 999 18th STREET -SUITE 500 <br />DENVER, COLORADO 80202-2466 <br />SEP 2 7 1995 <br />SUBJECT: GROUND WATER SECTION GUIDANCE NO. 39 <br />Pressure testing injection W~ls for Part I (internal) <br />Mechanical integrity/ D <br />FROM: ~ Tom Pike, Chief ( J o'"" <br />UIC Direct Implementation Section <br />T0: All Section Staff <br />Montana Operations Office <br />Introduction <br />The Underground injection Control (UIC) regulations require <br />that an injection well have mechanical integrity at all times (40 <br />CFR 144.28 (f)(2) and 40 CFR 144.51 (q)(1)). A well has <br />mechanical integrity (40 CFR 146.8) if: <br />(1) There is no significant leak in the tubing, casing or <br />packer; and <br />(2) There is no significant fluid movement into an <br />underground source of drinking water (USDW) through <br />vertical channels adjacent to the injection wellbore. <br />Definition: Mechanical integrity Pressure Test for Part I. <br />A pressure test used to determine the integrity of all the <br />downhole components of an injection well, usually <br />tubing casing and packer. It is also used to test tubing <br />cemented in the hole by using a tubing plug or retrievable <br />packer. Pressure tests must be run at least once every five <br />years. If for nay reason the tubing/packer is pulled, the <br />injection well is required to pass another mechanical <br />integrity test of the tubing casing and packer prior to <br />recommencing injection regardless of when the last test was <br />conducted. Tests run by operators in the absence of an EPA <br />inspector must be conducted according to these procedures <br />and recorded oa either the attached form or an equivalent <br />form containing the necessary information. A pressure <br />recording chart documenting the actual annulus test <br />pressures must be attached to the form. <br />This guidance addresses making a determination of Part I of <br />Mechanical Integrity (no leaks in the tubing, casing or <br />Hinted on Recycled Pepsr <br />