Suffolk County Highway Superintendents Association

Transcription

1 Presentation For: Suffolk County Highway Superintendents Association Underground Injection Control Operation and Closure In Suffolk County, New York By: Thomas P. Fox, P.G. September 2012

2 About D&B Engineers and Architects, P.C. Over 45 years experience in Environmental Engineering and Science Staff of over 200 Engineers, Scientists and Support Personnel including: Civil, Mechanical, Electrical, Structural, Chemical and Environmental Engineers Environmental Scientists Geologists and Hydrogeologists Biologists and Ecologists Health Risk and Environmental analysts QA/QC Specialists Health and Safety Specialists Designers and CADD Operators Asbestos Inspectors Resident Engineers and Construction Inspectors

3 About D&B Engineers and Architects, P.C. D&B has provided services for all the Suffolk County Townships Babylon East Hampton Islip Shelter Island Southampton Brookhaven Huntington Riverhead Southold Smithtown Suffolk County Department of Health Services Nassau County Department of Public Works Metropolitan Transportation Authority Brookhaven National Laboratory N AT I O N A L L A B O R AT O R Y National Grid New York State Office of Parks, Recreation and Historic Preservation New York City Department of Environmental Protection

4 - U.S. MERCHANT MARINE A CADEMY - About D&B Engineers and Architects, P.C. Consolidated Edison Company of New York, Inc. Dormitory Authority of New York State International Business Machines Corporation Long Island University Northrop Grumman Corporation PSC Chemical Pollution Control, LLC Safety Kleen Corporation U.S. Merchant Marine Academy New York State Environmental Facilities Corporation Empire State Development New York State Department of Environmental Conservation KINGS POINT NEW YORK

5 Background Underground Injection Control (UIC) program established under the Safe Drinking Water Act in 1980 Objective: Prevent the contamination of underground source of drinking water (USDW) supplies from contaminants being injected into the subsurface Suffolk County relies strictly on USDW for our water supply, the underlying aquifer system Rules of the program established by the USEPA to regulate the construction and operation of injection wells

6 What is an Injection Well Underground Injection is defined as: the subsurface emplacement of fluids by well injection Any bored, drilled, or driven shaft or dug hole that is deeper than its widest surface dimension, or an improved sinkhole or subsurface fluid distribution system EPA has grouped injection wells into five classes

7 Well Type Injection Well Description Considerations Class I Wells that inject wastes underneath the lowermost formation containing an underground source of drinking water (USDW). Stringent protective requirements Very few Class I facilities can accept offsite waste Disposal of slurries and solids allowed in limited circumstances Can be expensive to construct Class II Class III Class IV Class V Wells used to inject fluids associated with oil and natural gas recovery and storage of liquid hydrocarbons Wells associated with solution mining (e.g., extraction of uranium, copper, and salts) Wells used to inject hazardous or radioactive waste into or above USDWs. These wells are banned. Class V - Any injection well that is not contained in Classes I to IV Treatment residuals that are non-hazardous and non-radioactive may be disposed of into a Class II well if they are associated with oil and gas related production or the enhanced recovery of oil or natural gas. Store liquid hydrocarbons (II-H) Used for solution mining minerals, such as salt, sulphur, uranium and copper Inject chemical solutions, super-hot steam, or water into mineral formations Hot injectate dissolves and mixes with minerals underground; mineral-saturated solution pumped to surface for mineral extraction Inject fluids are frequently reused after some treatment Approximately 17,000 Class III wells Used to dispose of hazardous or radioactive waste into or above a formation which contains a USDW within ¼ mile of the well Prohibited One exception: wells that reinject into same formation treated ground water pursuant to approved CERCLA or RCRA clean-ups Voluntary site clean-ups not subject to exception Class V: All injection wells that do not meet the definitions of Classes I, II, III, or IV Most are shallow and low-tech Most inject into or above USDWs Operators must submit inventory information Must not endanger USDWs

8 Well Types

9 Class V Injection Wells Class V are what we are concerned with in Suffolk County EPA conducted a study of Class V well types and estimated that there are more than 650,000 of these wells in use in the United States

10 Common Class V Injection Wells Gas stations where service floor drains lead to a septic system Motor Vehicle Maintenance Facility Drains Apartment buildings that use septic systems for sanitary waste disposal Highway rest areas that use cesspools Municipalities where storm water flows into drywells Strip malls where businesses such as photo processors and dry cleaners discharge sanitary wastes and process chemicals into septic systems Office buildings that inject water passed through heat exchangers to cool the buildings Carwashes where wastewater enters a floor drain that leads to a drywell or septic system

11 Class V Injection Wells Storm water drains/dry wells are by far the most common and are authorized by rule under 40 CFR 144 Storm water drains can be operated without a permit from USEPA if discharge does not endanger a USDW Do need to submit inventory of all such drains to USEPA Other Class V Injection Wells would require a permit to operate This permit would likely require specific maintenance, testing and reporting

12 What do you have to do if you operate a Class V Injection Well? Complete basic inventory form (EPA Form 7520)

13 What do you have to do if you operate a Class V Injection Well? Must meet non-endangerment standard, does not have the potential of impacting USDW. USEPA may request additional information to determine if you have an injection well that requires permitting. Injection wells requiring a permit will need to meet specific permit requirements such as maintenance and periodic monitoring. Injection wells that do not meet the non-endangerment standard and are not permitted to operate by USEPA or the local authority must be closed.

14 Class V Rule of 1999 Prohibits the use of: 1. Large Capacity Cesspools, by Motor Vehicle Waste Disposal Wells, by 2000 Owners can seek waiver and obtain a permit to operate a motor vehicle waste disposal well but difficult and lots of requirements. Impossible in Suffolk County due to sole-source aquifer Disposal of commercial and industrial waste fluids

15 Class V Rule of 1999 Large capacity cesspool: a nonresidential cesspool system with the capacity to serve 20 or more persons as well as multi-residential systems for apartment buildings and condominiums Motor vehicle waste disposal wells: injection well that receives fluids from vehicle repair or maintenance facilities This can include dry wells or cesspools that are connected to floor drains or sinks in service bays or storm drains located immediately outside of these areas

16 Closure of Class V Injection Wells In Suffolk Co., most often performed under the oversight of Suffolk County Department of Health Services (SCDHS). All floor drains sealed and connecting dry wells remediated and closed. Large capacity cesspools need to be upgraded to meet Suffolk County Article 6 Standards.

17 Closure of Class V Injection Wells SCDHS has their standard operating procedures for dry well/ leaching pool remediation, which includes: 1. Sampling to determine extent of contamination, if any; 2. Sampling to determine disposal method of material; 3. Removal of all liquid, sludge and contaminated soil; 4. Post-remediation sampling to ensure cleanup is complete; and 5. Backfill with clean soil to grade. 6. Provide Report Documenting Closure

18 Can I Re-Open a Class V Injection Well After Closure? The answer is yes, if the future use of the injection well can meet the non-endangerment standard, in that: 1. Septic systems only receive uncontaminated sanitary wastes; and 2. Storm drains only receive uncontaminated storm water. Can require implementation of Best Management Practices (BMPs) as part of a Storm Water Pollution Prevention Plan (SWPPP).

19 Questions? For more information, please contact Thomas P. Fox, P.G. D&B Engineers and Architects, PC 330 Crossways Park Drive Woodbury, NY Phone: