Implementation of Underground Injection Control Program Regulations for Class V Shallow Disposal Systems

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1 Implementation of Underground Injection Control Program Regulations for Class V Shallow Disposal Systems CPOW 2016 Annual Education Conference Lakewood, Colorado January 21, 2016 Wendy Cheung Underground Injection Control U.S. Environmental Protection Agency Region VIII

2 Objectives Provide an overview of the Underground Injection Control Program Provide Class V regulatory requirements Provide information on complying with Class V UIC regulations

3 Regulatory Timeline Early State Programs to Regulate Ground Water Discharges States Actively Involved in GW Pollution Issues CWA SDWA Section 1421 First Federal UIC Regulations Ban MVWD & LCCs 1930s 1960s April 5, 2000

4 Mission of the UIC Program The UIC program s mission is to protect underground sources of drinking water (USDW) from contamination by regulating the construction and operation of injection wells.

5 UIC Basics Well: A bored, drilled, or driven shaft, or a dug well or dug hole where the depth is greater than the largest surface dimension; or an improved sinkhole; or a subsurface distribution system Underground injection: Subsurface emplacement of fluids through a well

6 UIC Basics Underground source of drinking water: An aquifer or portion of an aquifer that: Supplies any public water system or Contains a quantity of ground water sufficient to supply a public water system and Currently supplies drinking water for human consumption, or Contains fewer than 10,000 mg/l total dissolved solids and Is not an exempted aquifer

7 UIC Well Classes Class I Class II Class III Class V Class VI

8 Federal Requirements Applicable to all UIC Wells 40 CFR Prohibition to Endanger Does not allow the movement of fluid containing any contaminant into USDWs, if the presence of that contaminant may cause a violation of any primary drinking water regulation or adversely affect public health.

9 UIC Requirements All wells are subject to the non-endangerment standard All wells must submit basic inventory data Some wells may be authorized by rule; permit not required if comply with basic requirements EPA may require permit or order action to prevent endangerment (including well closure)

10 What are Class V Wells? Class V: Injection wells that are not Class I-IV & VI Typically, these are shallow disposal systems, such as septic systems/leach field, french drains, & drywells Usually occur in unsewered areas Most inject into or above USDWs 1999 study estimates that more than 686,000 Class V wells exist nationwide.

11 Class V Wells (32 subclasses) Agricultural Drainage Wells Mining, Sand or Other Backfill Wells Storm Water Drainage Wells Solution Mining Wells Improved Sinkholes In-situ Fossil Fuel Recovery Wells Industrial Drainage Wells Spent-Brine Return Flow Wells Electric Power Reinjection Wells Cooling Water Return Flow Wells Direct Heat Reinjection Wells Heat Pump/Air Conditioning Return Flow Wells Industrial Process Water and Water Disposal Wells Motor Vehicle Waste Disposal Wells Groundwater Aquaculture Return Flow Wells Untreated Sewage Waste Disposal Wells Cesspools Septic Systems (Undifferentiated Disposal Method) Septic Systems (Well Disposal Method) Septic Systems (Drainfield Disposal Method) Domestic Wastewater Treatment Plant Effluent Disposal Wells Aquifer Recharge Wells Saline Water Intrusion Barrier Wells Subsidence Control Wells Air Scrubber Waste Disposal Wells Water Softener Regeneration Brine Disposal Wells Radioactive Waste Disposal Wells Experimental Technology Wells Aquifer Remediation Related Wells Abandoned Drinking Water Wells Other Wells

12 Class V Wells Industrial Facility Agricultural Areas Residential Areas Mineral & Fossil Fuel Recovery Improved Sinkhole Industrial Process Water and Waste Disposal Well Fractured Bedrock Commercial Drainage Areas Service Station Repair Bay Sandstone Limestone Agricultural Drainage Well Heat Pump Air Conditioning Return Flow System Septic Tank Treatment Plant

13 Class V Exclusions Individual or single-family residential waste disposal systems (cesspools or septic systems) Non-residential cesspools or septic systems if receive only sanitary waste and serve fewer than 20 people per day or 2000 gallon/day Dug holes not used for subsurface fluid emplacement

14 Class V Wells

15 2 Types of Banned Wells Large Capacity Cesspools (LCCs) Definition: typically dry wells that receive sanitary waste from multiple dwellings and community or regional establishments. Motor Vehicle Waste Disposal Wells (MVWD wells) Definition: receive or have received fluids from vehicular repairs or maintenance activities, such as auto body repair, automotive repair, car dealerships, or other vehicular repair work.

16 Large Capacity Cesspools New Large Capacity Cesspools BANNED effective April 5, 2000 Existing Large Capacity Cesspools closed by April 5, 2005 There are no extensions available to well owners and operators. Pre-closure notification: owners or operators must notify EPA 30 days prior to closing

17 Motor Vehicle Waste Disposal Well New Motor Vehicle Waste Disposal Wells are BANNED nationwide, effective April 5, Existing Motor Vehicle Waste Disposal Wells phased out by January 1, Owner and operators had the opportunity to seek a waiver from the ban and obtain a permit. Pre-closure notification: owners or operators must notify EPA 30 days prior to closing

18 EPA Region VIII s Approach Aquifer vulnerability assessments to determine target areas Partner with local authorities Inventory mail-outs to potential Class V facilities Inspections: 364 inspections between Compliance assistance Permit or close endangering wells Enforcement actions as needed

19 Regional Focus Class V wells Veterinarian Clinics: X-ray machines fluid, floor drains in the kennels and surgery rooms Taxidermy Shops Industrial Operations coating, painting, and finishing operations Car Washes Funeral Parlors Meat Processing Operations (including game processors)

20 EPA Regulatory Process EPA identifies an endangering Class V well Permit or Close Letter is sent Operator must notify EPA within 30 days of receiving the letter of their decision Permit: The operator may elect to apply for a permit, if they feel that the fluids they are disposing does not endanger the USDW Close: The operator elects to no longer use their Class V well and finds an alternative method of disposing the liquids

21 Well Closure Requirements A well must be closed in a manner that prevents movement of contaminated fluids that may endanger USDWs. Any soil, gravel, sludge, liquids, or other materials removed from or adjacent to the well must be disposed or managed in accordance with all applicable Federal, State, and local regulations and requirements.

22 Class V well: Closure Examples Permanently prevent fluids from entering the subsurface, such as place concrete in the outlet pipe or cement glue a cap on the pipe. Connect to a holding tank. Treat and recycle waste stream. Install evaporative pond. Connect to city sewer.

23 Class V well: Closure The operator must submit a well pre-closure notification form within 30 days of receiving the permit or close letter describing their closure plans. EPA reviews the form and will notify the operator if modifications are required. The operator may have up to 6 months from the date of the letter to close the well and provide documentation (such as pictures).

24 Other Closure Alternatives Conversion of wells to other Class V wells -- authorized by UIC Director if: All fluids of concern (i.e. motor vehicle-related fluids) must be segregated by a physical barrier and are not allowed to enter the well. Implement BMPs and ensure physical segregation of motor vehicle waste fluids from the injection well. Good compliance history of the facility and records of proper waste disposal.

25 Class V well: Applying for a Permit The operator must submit an application within 30 days of receiving the permit or close letter. The operator must submit a sample of their waste fluids that may include metals, VOCs, inorganics. EPA reviews the permit application and if approved, a public notice is placed in the local newspaper for public comment.

26 Permit Requirements Permit Requirements Minimum conditions Fluids released must meet the MCLs and other appropriate health-based standards at the point of injection. Best management practices (BMPs) must be identified in permit. Monitoring requirements must be identified to ensure the quality of the injectate and sludge, both initially and on a continuing basis, is in compliance with the MCLs and other health-based standards. (MVWD wells are sampled quarterly)

27 Region 8 Class V Inventory Region 8 CO CO (Permit) Storm Water Drainage Aquifer Remediation Septic System Motor Vehicle Waste Disposal Industrial Process Water Drinking Water Treatment Residual Aquifer Recharge Geothermal Experimental Technology Mining, Sand or Other Backfill Cesspool Vehicle Washing Veterinary Aquifer Storage and Recovery Total Wells

28 Contact and UIC Information Wendy Cheung Craig Boomgaard (303) (303) US EPA Office of Groundwater and Drinking Water US EPA Region VIII

29 BRINE WET - AQUIFER USDW DRY WATER TABLE Underground Source of Drinking Water (USDW) Drinkable Quality Water (<3,000 TDS) Useable Quality Water (3,000-10,000 TDS) Brine - Salt Water (>10,000 TDS)

30 Class V Wells in Region 8

31 Well Types Surveyed to be Most Likely to Endanger Motor Vehicle Waste Disposal Wells Large Capacity Cesspools Agricultural Drainage Wells Photo-Processing Facilities Wells Air Scrubber Waste Disposal Wells Funeral Home Wells In Situ Fossil Fuel Recovery Wells Solution Mining Wells Beautician Wells Sewage Treatment Effluent Wells Carwashes without Undercarriage Wells Veterinarian and Kennel Wells Medical Offices Wells Drainage/Stormwater Wells Experimental Wells

32 Region 8 Class V Wells abandoned drinking water 1 agricultural drainage 2 aquifer recharge 33 aquifer remediation 917 cesspool 15 cooling water return flow 8 experimental technology 18 geothermal heat pump/air condition return flow 12 improved sinkhole 1 industrial drainage 59 industrial process water 178 in-situ fossil fuel recover 1 mining, sand or other backfill 20 MVWD 1068 other 86 saline water intrusion barrier 1 septic system 130 sewage treatment effluent 2 special drainage 17 stormwater (MT)

33 Existing Motor Vehicle Waste Disposal Wells that Imminently Endanger USDWs Endangering wells: All motor vehicle waste disposal wells have the potential to endanger. States are expected to use authorities under 40 CFR (a) to address imminently endangering wells.

34 UIC Classes I - Industrial and Municipal Wells That Inject Beneath Lowermost USDW II - III - IV- V - Associated With Oil and Gas Production Associated With Mineral Recovery (e.g., extraction of uranium, copper and salts) Wells Injecting Hazardous Waste Into USDWs (Prohibited) Injection Wells Not Included in Other Classes

35 How to Identify a Class V Well Where are the waste fluids going? Class V: septic, dry wells, cesspools, french drains Not Class V: city sewer, lake, stream, ponds, lagoons What type of waste fluids is being disposed? Class V: agricultural or industrial fluids, storm water, washwater Not Class V: sanitary waste only (unless LCSS)