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Underground Injection Control Branch Guidance No. 5 <br />w~yg://35/h ttp://www. a pa. gov/reg5oh 20/u i s/r5_O5. h t m <br />aquifer with which the leak communicates will buffer volumetric changes in the annulus. In the e <br />of a tubing or packer leak, the annulus pressure will track injection pressure. These two pressures <br />will probably not be equal because of pressure loss due to friction in the injection tubing and den: <br />differences. <br />Region 5 Class I UIC permits require that a positive pressure differential be maintained between <br />annulus and injection tubing in Class I wells. The purpose of this requirement is to ensure that an <br />leak in the injection tubing will result in an inward leak so that the injectate will not leak into the <br />annulus. This is an important safeguard when the injectate is corrosive or very dangerous. <br />Compliance with this requirement is not equivalent to use of SAMT if the pressure is artificially <br />maintained through the addition of gas to a seal pot. <br />Unless any leak will result in an unimpeded pressure change, leaks might not be evident. To enha <br />the value of maintaining a positive pressure differential, Region 5 permits require volume <br />measurement of all liquid additions and subtractions from the annulus systems of Class I wells. T <br />results of these measurements are accumulated and a continuing need to add or remove fluid [o <br />maintain a set pressure is evidence of a leak in the well, although not necessazily an absence of M <br />When a loss becomes evident, the Director may require a SAPT to confirm MI. If the well <br />demonstrates MI, the Director may allow continued use if the leak does not cause violation of am <br />UIC regulation. <br />B. Advantages and Disadvantages of the SAMT <br />Advantages <br />~ Provides a continuous demonstration of MI <br />Inexpensive for simple annulus systems <br />Easy to interpret for simple annulus systems <br />Disadvan[aees <br />Is difficult or impossible to interpret for wells with annulus pressure maintenance systems <br />C. Equipment and Forms <br />In order to make determinations quickly and simply, measurements of both the annulus and injec~ <br />pressures should be made. Operators of Class I wells must use either an analog chart recorder or <br />electronic equipment recording in a digital format at short intervals. Class II operators must recor <br />these pressure measurements at a frequency set by petmit conditions. Other arrangements are <br />possible, but must be established as permit conditions. <br />There is no set form for reporting the results of the SAMT. Each operator using the SAMT propo <br />a monthly reporting form to the DI Section. To effectively use the SAMT, the form must list not. <br />the annulus pressure as measured at least once in any 24 hour period, but also the injection press[ <br />measured at the same time. In addition, information about the injection rate, the temperature of tt <br />injection fluid, and the injection pressure may be useful. Changes in any of these parameters can <br />affect the annulus pressure. <br />D. Procedure for the SAMT: <br />For Class I wells and other wells having a sealpot assembly and pressure maintenance the operate <br />must: <br />10 of 34 5/28/99 1:09 PM <br />