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Undergroyrjd Injection Control Branch Guidance No. 5 <br />`~-~~. i <br />w~yg://35/hup://www.epa.gov/reg5oh2o/uic/r5 OS.htm <br />microannulus has developed due to past expansion of the casing while it was pressurized during <br />operations or testing. It is sometimes necessary to pressurize the casing above the highest pressur <br />which it has been subjected. The presence of a microannulus does not indicate a lack of part 2 of <br />Microannuli aze very minute, while they may allow the passage of gas, they do not pass liquids. <br />If there is a question about the adequacy of cement to prevent the movement of liquids into USD' <br />then one of the previously described logs, pre-approved by Region 5, should be utilized to <br />demonstrate MI. <br />ATTACHMENT 10 <br />RADIOACTIVE TRACER SURVEYS FOR <br />THE INTEGRITY OF CEMENT AT THE TOP OF THE INJECTION INTERVAL <br />A. Basis <br />The basis of the use of the RTS for confirming the integrity of the cement at the top of the injecti~ <br />interval is identical [o that of demonstrating part 2 of MI. In fact, if there are no aquifers above th <br />injection interval from which the waters might degrade any USDW, the demonstration of cement <br />integrity becomes a demonstration of part 2 of MI. <br />B. Advantages and Disadvantages <br />This test is required annually for Class I wells which are used to inject hazardous waste; there is I <br />alternative test. The logs used to demonstrate part 2 of MI may also make a similar demonstratiot <br />but such a demonstration cannot be substituted for the RTS for this purpose. Because there is no <br />alternative, and the advantages and disadvantages of [he log have been previously listed in <br />Attachment 8, they are not listed here. <br />C. Equipment and Forms <br />These are identical [o the equipment and forms listed in Attachment 3 for the RTS. <br />D. Procedures <br />The procedures for using the RTS to confirm the integrity of cement are identical to those used fc <br />the demonstration of part 2 of MI. <br />E. Interpretation <br />The interpretation of the RTS used for confirming the integrity of cement is similar to that for <br />demonstrating part 2. If any upwazd movement is observed, it becomes critical to determine the e <br />amount of upward movement. The upper limits of upward movement are recorded and compared <br />from year to year to check for any increase. <br />ATTACHMENT 11 <br />ANNULAR PRESSURE TEST <br />32 or 34 5/28!99 I ~.09 PM <br />