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Underground Injection Control Branch Guidance No. 5 _ ~ ~ r w~ yg://15/hup://www.epa.gov/reg5oh2o/uidr5_OS.hlm Attachment 6 -The Noise Log (NLl Attachment 7 - Oxv_een Activation Method (OALI Attachment 8 -Radioactive Tracer Survey (RTSI Attachment 9 -Cement Records Attachment l0 -Radioactive Tracer Survey to Determine Cement Inteeri[v Attachment 11 -Annulus Pressure Test Form UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 -- UNDERGROUND INJECTION CONTROL (UIC) SECTION REGIONAL GUIDANCE #5 DETERMINATION OF THE MECHANICAL INTEGRITY OF INJECTION WELLS Revised June 11, 1998 I. ISSUE Demonstrations of mechanical integrity (MI) are the most common means of demonstrating that there is movement of fluids into or between underground sources of drinking water (USDWs) associated with injection wells. Although relatively simple in theory, MI tests (MITs) must be conducted so that their validity as well as their outcome is evident. The Underground Injection Control (UIC) Branch of the W. Division in Region 5, United States Environmental Protection Agency (USEPA), as the authority in ma of MI in Region 5, should establish guidelines which will assist operators and regulators of injection we in Region 5 subject to demonstrations of MI to conduct those demonstrations such that the results will t useful. II. PURPOSE OF GUIDANCE The guidelines were developed by the UIC Branch of Region 5 USEPA, to assist owner/operators of injection wells in Region 5 to demonstrate MI. Procedures varying from these guidelines may be accept if first approved by the Director of the USEPA. Pursuant to 40 CFR § 146.8(a) "an injection well has mechanical integrity if: (1) there is no significant in the casing, tubing, or packer; and (2) there is no significant fluid movement into an USDW through vertical channels adjacent to the injection well bore". The absence of significant leaks is demonstrated through the use of tests which have been approved for that purpose by the Administrator (MI tests). The methods presently accepted for establishing MI pursuant to 40 CFR § 146.8(a)(l) [part 1] of MI for wet operating in states in which the UIC Branch implements the UIC regulations, include: 1) the standard annulus pressure test (SAPT), 2) the standard annulus monitoring test (SAMT), 3) the radioactive tracer survey (RTS), and for certain Class III wells: the water-brine interface test (W-BIT. Other methods, including the Ada pressure test(AT) and the cementing pressure/single point resistivity test, are approve for national use under certain circumstances, but are not used in Region 5. In addition, [he dual complel monitoring test (DCMT) is used by a few wells in Michigan and Indiana although interim approval has expired. The procedures for this test are under review. Accepted methods for demonstrating MI pursuar 40 CFR § 146.8(a)(2) [part 2] include: 1) the results of a temperature log, 2) noise log, 3) oxygen activa log, 4) [he results of a radioactive tracer survey (RTS) (when the injection zone is separated from the lowermost USDW by a single confining layer), or 5) for all Class II wells and for Class III wells in whit 2 of 34 5/?S/99 1:09 PM