HYDRO29443

• Permit No: M1999002
• IBM Index Class Name: Hydrology
• Doc Date: 5/28/1999
• Doc Name: UIC INFO
• Media Type: D
• Archive: No

Underground Injection Control Branch Guidance No. 5
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D. Tests which are not MI Tests but are Specifically Required by Regulation
1. Radioactive Tracer Survey
The regulations a[ 40 CFR 146.68(d)(2) require annual demonstrations of the integrity of cement at the
of [he injection interval in Class Ihazardous-waste injection wells. The RTS is more often used for that
purpose than to demonstrate either part 1 or 2 of MI. The procedures for demonstrating cement integriq
using the RTS aze presented in Attachment l0.
2. Casing Inspection Logs (CIL)
The regulations at 40 CFR 146.68(d)(4)require periodic monitoring of change in casing thickness for C.
I wells injecting hazardous wastes. The procedures for running the logs and presentation of the results a
set by the logging company. Because the standards adopted by the logging companies aze appropriate, n
additional information is provided for running casing inspection logs.
IV. CONDUCTING TESTS WITHOUT A REPRESENTATIVE OF THE USEPA
It is, and has been, the policy of Region 5 to witness mechanical integrity testing to [he extent practicab
Tests for which a mechanical or third-party record is produced may be conducted without an Agency
witness when it proves impossible to resolve scheduling conflicts with both the USEPA contract inspec
and the Regional technical staff.
In order to conduct testing without an USEPA representative [he following procedures should be fo11oN
1. The owner/operator must submit proposed procedures including the information that no USEPA
representative is available, and receive permission from the DI Section of the UIC Branch to proc
2. The [es[ must be documented using either a mechanical device which records the value of the
parameter of interest, or by a service company job record;
3. A report of the testing including all data available at [he conclusion of the test and a certification
accuracy which is signed by an authorized representative of the company must be submitted to th
Section within 10 calendar days of the completion of testing; and
4. A final report, including any additional interpretation necessary for evaluation of the testing, mus
submitted prior to or with the next regularly scheduled monitoring report or as required under the
appropriate permit for the injection well.
NOTE: Pursuant to § 146.8(f) of the UIC regulations, Region 5 may, at any time, require a test witnesse
by a USEPA representative [o verify the results of an unwitnessed test. This is possible if results aze
ambiguous or if documentation is lacking.
V. ACTIONS TO BE TAKEN IN THE EVENT OF A FAILURE TO DEMONSTRATE MI OR
LOSS OF MI DURING OPERATIONS
If upon investigation, the well appears to be lacking MI, the operator should cease injection immediatel
and attempt to mitigate any environmental effects of the loss of MI. The Director may allow up to 48 he
of injection if necessary to allow for a smooth shut down of operations. Pursuant to 144.28(b) or
144.51(1)(6), owners/operators are required to report any known loss of MI which might endanger heap
the environment to Region 5 within 24 hours. To report a failure, operators may call Region 5 at (312)
b o(34 528/99 I :09 PM