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Underground Injection Control Branch Guidance No. 5 '~ ,~ • wy s i wyg://35/hup://www.epa.gov/reg5oh 20/u i s/r5_O5. h t m 353-4148; during nonbusiness hours a message can be left on the voice mail system. Also, pursuant to 144.28(6) or 144.51(1)(6) a written submission shall be prepared and sent to Region 5 within five days c the time the operator becomes aware of a loss of MI. Injection into wells which have lost MI can be resumed only after a letter authorizing injection is receiv from the Director. The Director will prepare such a letter only if: 1) the well is repaired, a report detailit the means used to effect the repair is submitted, and MI is demonstrated or 2) the owner/operator demonstrates, by means acceptable to the Director, an absence of flow into or between USDWs pursuat 40 CFR § 144.28(!)(4) or 40 CFR 144.5 l(q)(3). As an alternative, the well can be plugged in accordanc with 40 CFR § 146.10. The plugging procedures must remove any threat posed by the absence of MI. If failure is of part 1 of MI, this is usually accomplished through cementing the leaking portion. If the fails is of part 2 the means required to eliminate the fluid movement might be more demanding. Falsificatior MI testing is a violation of 18 USC § 1001 and violators may be subject to criminal penalties. ATTACHMENT 1 STANDARD ANNULUS PRESSURE TEST (SAPT) A. Basis Pascal's Law states that any pressure applied to a fluid filling a closed vessel will be transmitted, undiminished, throughout the vessel. This fact is the basis for the selection of the SAPT as the primary means to determine if a well's casing, tubing, packer, and wellhead (the annulus system) are liquid tight fully test the well bore, the pressure applied to the annulus system must be transmitted through the emir well bore. Therefore, no mechanical plug may be placed above the packer in any well subject to testing means of the SAPT. Because the annulus system is not an isolated system (e.g. it transmits energy, but not matter), the meas pressure applied may not be constant through time. The temperatures along the well bore must change t injection rates and temperatures change because of heat exchange between injectate and the surrounding rock. When the well is shut in part of the well bore may cool and part may become warmer. As this happens, the liquid in the annulus contracts or expands. Because liquids are only very slightly compressible, it is very unlikely that the pressure will appear to remain absolutely stable either while [h~ well is shut in or being used for injection. B. Advantages and Disadvantages of the SAPT Advantages of the SAPT • Easy to interpret • Inexpensive to perform Disadvantage of the SAPT • Provides a demonstration at a single point in time C. Equipment and Forms Pressure measurements must be made using a gauge which can be read with sufficient accuracy to ident 7 of 34 5!28/99 1:09 PM