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Summary of the Underground Injection Control Program
and EPA Region 7 Requirements for Injection Wells in Iowa
Ben Meissner, Physical Scientist EPA Region 7
Purpose of UIC Program
• The UIC Program’s mission is the protection of underground sources of drinking water (USDW) from the subsurface emplacement of fluids through the regulation of the construction and operation of injection wells.
Established Under the Safe Drinking Water Act (SDWA)
• The SDWA, established in 1974, required EPA to promulgate regulations for the protection of drinking water sources from contamination through underground injection.
• Designed to allow states to implement the program themselves, if requested. Grants to fund the creation and operation of UIC agencies are provided by EPA for state implementation.
• If a state has chosen to implement the UIC program, then EPA provides oversight to the state agency implementing the UIC program.
• If a state has chosen not to implement the UIC program, it is directly implemented by EPA.
UIC Definitions • Aquifer – a geologic “formation,” group of formations, or part of a
formation that is capable of yielding a significant amount of water to a well or spring.
• USDW – an aquifer or portion: which supplies any public water system; or contains a sufficient quantity of groundwater 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.
• Well – a bored, drilled, or driven shaft whose depth is greater than the largest surface dimension; or a subsurface fluid distribution system.
UIC Definitions • Injection – the subsurface emplacement of fluids. • Fluids – any material or substance which flows or moves, whether in a
semisolid, liquid, sludge, gas, or any other form or state. • Subsurface fluid distribution system – an assemblage of perforated
pipes, drain tiles, or other similar mechanisms intended to distribute fluids below the surface of the ground.
• Improved sinkhole – a naturally-occurring karst depression or other natural crevice, which has been modified by someone for the purpose of directing and emplacing fluids into the subsurface.
Classifications for Injection Wells
• There are six classes of wells that are addressed within the UIC regulations.
• These classes are based on common operating characteristics and injection well design.
• Potential for endangerment depends on an injection well’s depth, injectate, and the geologic setting of the well.
Class I Injection Wells • Class I Hazardous - Inject hazardous waste beneath the lowermost
formation containing, within one-quarter mile of the well bore, a USDW.
• No-migration Petition Required • Must demonstrate hazardous waste will not migrate out of the injection interval for
10,000 years or while the waste remains hazardous. • Requires modeling based on injection parameters and injection zone characteristics.
• Class I Non-Hazardous - Other industrial and municipal disposal wells that inject fluids beneath the lowermost formation containing, within one quarter mile of the well bore, a USDW.
Class II Injection Wells • Class II Disposal - wells that inject fluids brought to the surface in
connection with natural gas storage, conventional oil or natural gas production.
• Class II Enhanced Oil Recovery - wells that inject fluids for the enhanced recovery of oil or natural gas.
• Class II Hydrocarbon Storage - wells that inject fluids for the storage of hydrocarbons, which are liquid at standard temperature and pressure.
Class III Injection Wells
• Wells that inject for the extraction of minerals including: • Mining of sulfur by the Frasch process. • In situ production of uranium or other metals – only includes in-situ
production from ore bodies that have not been conventionally mined. • Solution mining of salts or potash.
Class IV Injection Wells
• Used to dispose of hazardous or radioactive waste into or above a formation that contains a USDW within one-quarter mile of the well.
• Prohibited with one exception: wells that reinject into the same formation-treated groundwater, pursuant to approved CERCLA or RCRA cleanup sites.
Class VI Injection Wells
• Wells that are used for the geologic sequestration of carbon dioxide beneath the lowermost formations containing a USDW.
• Relatively new well class, promulgated in 2010. • Well requirements are similar to Class I well standards.
Class V Wells • Injection wells that do not fit into any of the other classes of wells are
Class V wells. • Commonly used for the shallow disposal of a variety of fluids below
the ground surface, and into or above USDWs. • Generally “low-tech” constructions. • Some “high-tech” wells fall into this category as well. • Subject to the non-endangerment standard, which does not allow for
the movement of a fluid containing any contaminant into USDWs if it may cause a violation of any primary drinking water regulation or adversely affect public health.
• Class V wells may be either rule authorized or authorized by permit.
Rule Authorized Class V Wells
• Utilized for Class V wells that do not have specific rules or requirements.
• Well owner/operators must submit inventory information. • Wells are not allowed to endanger USDWs. • The primacy agency may require permit or order action to prevent
endangerment.
Rule Authorized Class V Well Examples
• Large-capacity septic systems only receiving sanitary wastes • Agricultural drainage wells • Storm water drainage wells • Heat pump return flow wells • Some aquifer remediation wells
Permitted Class V Wells • Class V Injection Wells may require a permit due to:
• Potential for negatively impacting USDWs • Complex injection well design • Complex project design • May be required at the Director’s discretion
• Class V Permit Requirements: • Specific requirements to ensure operations do not endanger USDWs. • Permits are designed for a specific amount of time, not to exceed 10 years. • There are additional reporting requirements. • Potential requirements to demonstrate mechanical integrity.
Permitted Class V Well Examples
• Aquifer storage and recovery wells • Septic systems receiving anything other than sanitary wastes • Industrial waste disposal wells • Non-contact cooling water return flow wells • Experimental technology wells • Some aquifer remediation wells
Regional/State Injection Well Inventory Injection Well Class Regional Inventory Iowa Inventory
Class I – Hazardous 5 (<1%) 0
Class I – Non-Hazardous 73 (<1%) 0
Class II – Disposal 5,206 (12%) 3 (<1%)
Class II – Enhanced Oil Recovery 12,664 (30%) 0
Class III 4,927 (12%) 0
Class IV 0 0
Class V 18,864 (45%) 3,299 (>99%)
Class VI 0 0
Prominent Types of Class V Wells in Iowa • Subsurface remediation wells
• Typically rule authorized • Used for site cleanup activities
• Septic systems • Typically rule authorized • Applies to septic systems used only for the disposal of sanitary waste, and has
the capacity to serve 20 or more persons a day • Does not apply to individual or single family waste disposal systems, such as
domestic cesspools or septic systems
• Agricultural drainage wells • Typically rule authorized
Prohibited Class V Wells – Large-Capacity Cesspools • Shallow system for disposal of sanitary waste. Most cesspools consist
of a concrete cylinder with an open bottom or perforated sides. Sanitary wastes from toilets, sinks, and washing machines directly enter the cesspool with no treatment and percolate out the bottom.
• Includes residential multiple-dwelling, community, or regional systems that dispose of sanitary waste, or non-residential cesspools that have the capacity to serve 20 or more persons per day that receive solely sanitary wastes.
• Prohibition on new construction. • Existing large-capacity cesspools require closure.
Large-Capacity Cesspools – Why Banned • Not designed to treat sanitary waste. • Often have higher levels of nitrates and coliform bacteria than are
allowed in drinking water. • Additionally, may contain other pollutants such as phosphates,
chlorides, grease, viruses, and chemicals used to clean cesspools. • Areas that rely on cesspools are more likely to rely on groundwater
for drinking water supplies, which may be compromised by contaminants.
Large-Capacity Cesspools – Options After Closure • Connecting your facility to the sewer system. • Storing sanitary waste in a holding tank and periodically pumping it
out for proper disposal. • Installing a large-capacity septic system at your facility. • Installation of a package plant, which is designed to treat limited
sewage flow. • Must get permission to build and operate a package plant.
Prohibited Class V Wells – Motor Vehicle Waste Disposal Wells • Wells that receive or have received fluids from vehicular repair or
maintenance activities, such as an auto body repair shop, automotive repair shop, new and used car dealership, specialty repair shop, or any facility that does any vehicular repair work.
• Prohibition on new construction. • May be permitted if constructed prior to April 5, 2000. These permits
require additional conditions. • Typical fluids (engine oil, transmission fluid, antifreeze, solvents, etc.)
disposed of in these wells may contaminate groundwater.
Motor Vehicle Waste Disposal Wells – Options After Closure • Alter practices to run a dry shop by using absorbents and vacuums to
pick up spills and drips, and dispose of the materials according to state guidelines and regulations.
• Use a holding tank to store motor vehicle waste, which can be periodically pumped out for proper disposal.
• Connect floor drains to the sewer system, if available. • In some cases, motor vehicle waste disposal wells may be converted
to another Class V well. This requires all motor vehicle fluids be kept away from drains using physical barriers.
Process for Registering a Class V Well with Region 7
• Contact the Region 7 office to receive a Class V Registration Form. • This registration form includes the information required to be submitted for
the inventory requirements.
• Provide required information on the Class V Registration Form. • EPA Review of provided information. • Potential follow-up questions.
Potential Consequences for Not Submitting Inventory Information • Required to cease injection activities. • May be subject to fines. • May resume injection activities 90 days after submitting, unless EPA
notifies owner/operator to close the well. • Easier for all parties to reach out with potential injection wells you
may have, rather than an unregistered well being found by an inspector.
For Additional Information EPA Region 7 – Water, Wetlands and Pesticides Division Drinking Water Management Branch UIC Program (WWPD/DRWM) 11201 Renner Boulevard Lenexa, Kansas 66219 Attention: Ben Meissner or Kurt Hildebrandt Ben Meissner Phone: (913) 551-7992 Fax: (913) 551-9992 Email: [email protected]
Kurt Hildebrandt Phone: (913) 551-7413 Fax: (913) 551-7765 Email: [email protected]
