EPA-570/9-79-074
ANALYSIS OF COSTS
UNDERGROUND INJECTION
CONTROL REGULATIONS
CLASS I AND CLASS III WELLS
CLASS IV AND CLASS V WELLS
SUBMITTED TO.
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF DRINKING WATER
WASHINGTON, D. C.
BY.
TEMPLE, BARKER & SLOANE, INC.
33 HAYDEN AVENUE
LEXINGTON, MASSACHUSETTS 02173
MAY 1979
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NOTICE
This report replaces the following supporting documents
referenced in the Federal Register Notice of 40 CFR Part 146,
April 20, 1979, page 23752:
2. "Analysis of Costs Underground Injection
Control Regulations, Class I and III."
3. "Methods and Costs for Inventory and Assess-
ment of Injection Wells Covered Under
Classes IV and V."
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ANALYSIS OF COSTS
UNDERGROUND INJECTION
CONTROL REGULATIONS
CLASS I AND CLASS III WELLS
CLASS IV AND CLASS V WELLS
SUBMITTED TO.
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF DRINKING WATER
WASHINGTON, D. C.
BY:
TEMPLE, BARKER & SLOANE, INC.
33 HAYDEN AVENUE
LEXINGTON, MASSACHUSETTS 02173
MAY 1979 EiY>7
R-Y
(^ •
f-.* - -•
Ci::
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PART ONE
ANALYSIS OF COSTS
UNDERGROUND INJECTION CONTROL REGULATIONS
CLASS I AND III WELLS
SUBMITTED TO:
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF DRINKING WATER
WASHINGTON, D. C.
BY:
TEMPLE, BARKER & SLOANE, INC.
33 HAYDEN AVENUE
LEXINGTON, MASSACHUSETTS 02173
MAY 1979
TBS
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PREFACE
This report has been submitted to the United States En-
vironmental Protection Agency in partial fulfillment of Contract
Number 68-01-4778 by Temple, Barker & Sloane, Inc., 33 Hayden
Avenue, Lexington, Massachusetts. This report supercedes the
report "Analysis of Costs, Underground Injection Control
Regulations, Subparts C and E," submitted May 3, 1978. This
current version has been prepared in support of the reproposed
UIC Regulations of April 20, 1979.
The contributions of state offices, trade associations and
operating companies during the course of this study proved to
be invaluable. Specifically, The American Mining Congress, The
Salt Institute, and members of sulfur-producing, salt, and po-
tash companies were particularly helpful. Geraghty &, Miller,
Inc., groundwater geologists and hydrologists, provided exten-
sive information on costs of compliance and physical character-
istics of the practices.
TIBISI
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CONTENTS
PREFACE i
LIST OF TABLES iii
I. INTRODUCTION AND CONCLUSIONS
Introduction 1-1
Scope of the Study 1-2
Summary Conclusions 1-3
Methodology 1-10
II. COSTS TO OPERATORS
Overview II-l
Limits of the Analysis II-4
Class I Practices II-7
Class III Practices 11-14
III. STATE PROGRAM COSTS
Introduction III-l
State Program Elements III-2
Aggregate State Manpower Requirements III-7
State Costs for Manpower Requirements 111-12
11
IrlBlsi
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LIST OF TABLES
Table Page
1-1 Class I WeiIs--Summary of Estimated
Incremental One-Time Costs to Operators 1-4
1-2 Class I Wells--Summary of Estimated
Incremental Annual Recurring Costs to
Operators 1-4
1-3 Class III Wells—Summary of Estimated
Incremental One-Time Costs to Operators 1-5
1-4 Class III Wells—Summary of Estimated
Incremental Annual Recurring Costs to
Operators 1-6
1-5 Class I Wells--Sumrnary of Estimated
One-Time Costs to All States 1-6
1-6 Class I Wells—Summary of Estimated
Annual Recurring Costs to All States 1-7
1-7 Class III Wells—Summary of Estimated
One-Time Costs to All States 1-7
1-8 Class III Wells: Summary of Estimated
Annual Recurring Costs to All States 1-8
II-l Estimated Count and Distribution of
Practices II-3
II-2 Cost of Testing Mechanical Integrity of
Waste-Disposal Wells 11-10
H-3 Cost of Repairing Waste-Disposal Wells 11-11
II-4 Waste-Disposal Wells Injecting Into Saline
Aquifers—Summary of Costs to Operators 11-12
II-5 Nuclear Waste-Disposal Wells--Summary of
Costs to Operators 11-14
II-6 Geothermal Wells--Summary of Costs to
Operators 11-16
iii
TBS
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LIST OF TABLES
(continued)
Table Page
II-7 In-Situ Gasification—Summary of Costs
to Operators 11-18
II-8 In-Situ Uranium Leachlng--Summary of
Costs to Operators 11-20
II-9 In-Situ Copper Leaching—Summary of
Costs to Operators 11-22
11-10 Frasch Sulfur Mining—Summary of Costs
to Operators 11-24
11-11 Solution Mining of Salt—Summary of
Costs to Operators 11-27
11-12 Solution Mining of Potash--Summary of
Costs to Operators 11-29
III-l Class I Wells—State Program Time
Requirement Assumptions II1-5
III-2 Class III Wells—State Program Time
Requirement Assumptions II1-5
III-3 Site- and State-Based Labor Estimates III-8
III-4 Computational Formulas and Variables
Used in Computing Labor Estimates
for Program Elements III-9
III-5 Class I Wells--One-Time State Manpower
Estimates 111-10
III-6 Class I Wells--Annual Recurring Manpower
Estimates III-ll
III-7 Class III Wells--One-Time State
Manpower Estimates 111-12
III-8 Class III Wells--Annual Recurring
Manpower Estimates 111-12
III-9 State Program Total Costs 111-13
IV
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I. INTRODUCTION AND CONCLUSIONS
INTRODUCTION
This report presents an analysis of the costs associated
with implementing the requirements for Class I and Class III
wells under the proposed Underground Injection Control (UIC)
regulations. Class I wells include "industrial and municipal
disposal wells and nuclear storage and disposal wells that
inject below all underground sources of drinking water in
the area." Class III wells consist of "all special process
injection wells, for example, those involved in the solution
mining of minerals, in situ gasification of oil shale, coal,
etc., and the recovery of geothermal energy."1
Earlier versions of the presently proposed UIC regulations
had classified these wells differently. For example, the 1976
UIC regulations grouped these wells under its Subpart C. Under
the August 1977 draft UIC regulations, deep disposal and storage
wells were covered under Subpart C, while mining, geothermal,
and in situ gasification wells were to be regulated under Sub-
part E. As is clear from the definitions above, Subpart C wells
are equivalent to Class I wells, and Subpart E wells are equiv-
alent to Class III wells.
Though the well classification schemes have changed, the
intent of the UIC regulations has remained the same. These
regulations were developed by EPA in response to directives in
the Safe Drinking Water Act (Public Law 93-523)—to establish
minimum requirements for effective state programs to prevent
underground injection practices which endanger underground
sources of drinking water. Specifically, the states are re-
quired to (1) prohibit unauthorized underground injection, (2)
require applicants for underground injection permits to prove
that the injections will not endanger drinking water sources,
and (3) adopt inspection, monitoring, recordkeeping and report-
ing requirements consistent with the intent of the Act.
Definitions for both Class I and III from Proposed Rules,
Federal Register, Vol. 44, No. 78, April 20, 1979, pg. 23740.
T
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1-2
SCOPE OF THE STUDY
Temple, Barker & Sloane, Inc. (TBS) conducted a study of
the proposed UIC regulations to determine the costs of compli-
ance for specific injection well practices, for certain indus-
tries, and for state agencies. The study determined the costs
to operators associated with:
• Applying for a permit
—Submitting required information
--Performing a test of the mechanical
integrity of a well
—Repairing a leaky well, if necessary
• Conducting periodic monitoring
• Reporting periodically to the state
director.
These cost data were then combined with data on the number
and probable compliance status of wells contained within each
well class in order to estimate total costs for operators.
Total costs were grouped into two categories: total one-time
costs and annual recurring costs. Total one-time costs would be
associated with the preparation of the permit application, in-
cluding conducting a test of mechanical integrity of the well,
and supplying ownership and location data, engineering data,
maps and cross sections, and anticipated operating data. Annual
recurring costs include costs to well operators for monitoring
the wells which have been issued UIC permits, and for reporting
data to state directors on a regular basis.
In addition, the study determined the costs to state agen-
cies associated with:
• Developing a state regulatory program
• Reviewing permit applications and granting
permits
• Reviewing data submitted periodically by
well injectors
• Preparing and submitting reports periodically
to the EPA administrator
• Enforcing the accepted state program.
TIBIS
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1-3
These cost data were developed on a per state basis and
combined to estimate total costs to all states. Again, total
costs were divided into total one-time costs and annual recurring
costs. Total one-time costs include costs associated with de-
veloping state programs, granting permits for existing sites, and
holding public hearings when necessary. Annual recurring costs
include costs associated with conducting quarterly reviews of
data for known practices, preparing and submitting reports
regularly to the EPA administrator, and enforcing the UIC regu-
lations where practices are thought to be in non-compliance.
The economic analysis was primarily conducted for individual
wells and sites. The results of the analysis were then pro-
jected to cover all known sites in the 57 states and territories.
Only incremental costs were considered, that is, those costs
directly attributable to federal UIC requirements and not re-
quired by any existing state programs.
SUMMARY CONCLUSIONS
The conclusions derived from this study are summarized
below.2 Each conclusion is discussed in more detail later
in the report.
Class I Wells: Costs to Operators
• Total one-time costs to operators for all
identified practices would range from
$335,000 to $2.3 million as shown in
Table 1-1. The most significant costs
would result from the requirements for
mechanical integrity tests and repairs,
if necessary, for municipal and indus-
trial waste-disposal wells.
2
The total costs in these tables have been rounded off to
figures which reflect their general degree of precision.
TBS
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1-4
Table i-1
CLASS I WELLS
SUMMARY OF ESTIMATED INCREMENTAL ONE-TIME COSTS1
TO OPERATORS
(thousands of 1977 dollars)
Practice
Waste-Disposal Wells
Nuclear Storage and
Disposal Wells
Total All Practices
Incremental
One-Time Costs
$335 to $2,300
0
$335 to $2,300
One-time costs include permitting, mechanical integrity
testing and repairing where testing shows well failure.
Annual recurring costs to operators for
all identified practices would range from
$48,000 to $58,000, as shown in Table 1-2,
The most significant costs would result
from the requirement for quarterly report-
ing to the Director.
Table 1-2
CLASS I WELLS
SUMMARY OF ESTIMATED INCREMENTAL ANNUAL RECURRING COSTS
TO OPERATORS
(thousands of 1977 dollars)
Practice
Waste-Disposal Wells
Nuclear Storage and
Disposal Wells
Total All Practices
Incremental
Annual Recurring
Costs
$40 to $50
$48 to $58
T
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1-5
Class III Wells: Costs to Operators
• Total one-time costs for operators for
all identified practices would range
from $1.7 million to $2.9 million, as
shown in Table 1-3. The most significant
costs would result from the requirements
for mechanical integrity tests and re-
pairs, if necessary, for wells used for
solution mining of salt.
Table 1-3
CLASS III WELLS
SUMMARY OF ESTIMATED INCREMENTAL ONE-TIME COSTS1
TO OPERATORS
(thousands of 1977 dollars)
Practice
Geothermal Wells
In-Situ Gasification
In-Situ Uranium Leaching
In-Situ Copper Leaching
Frasch Sulfur Mining
Solution Mining of Salt
Solution Mining of Potash
Total All Practices
Incremental
One-Time Costs
$0
0
0
$42
$24
$1,585 to $2,670
$54 to $115
$1,705 to $2,851
One-time costs include permitting, mechanical integrity
testing and repairing where testing shows well failure.
Annual recurring costs to operators for
all identified practices would range
from $80,000 to $140,000, as shown in
Table 1-4.
T|B|S
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1-6
Table 1-4
CLASS III WELLS
SUMMARY OF ESTIMATED INCREMENTAL ANNUAL RECURRING COSTS
TO OPERATORS
(thousands of 1977 dollars)
Practice
Geothermal Wells
In-Situ Gasification
In-Situ Uranium Leaching
In-Situ Copper Leaching
Frasch Sulfur Mining
Solution Mining of Salt
Solution Mining of Potash
Total All Practices
Incremental
Annual Recurring
Costs
$0
0
0
$37
$7 to $67
$16
$20
$80 to $140
Class I Wells; Costs to States
• Total estimated one-time costs to the
24 states with Class I well practices
would range from $500,000 to $870,000,
as shown in Table 1-5.
Table 1-5
CLASS I WELLS
SUMMARY OF ESTIMATED ONE-TIME COSTS TO ALL STATES
(thousands of 1977 dollars)
Task
Developing State Programs
Program Hearings
Permitting Existing Sites
Permit Hearings
Total One-Time Costs
Incremental
One-Time Costs
$90 to $220
$70
$240 to $480
$100
$500 to $870
T
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1-7
• Total estimated annual recurring costs
to all states with Class I wells would
range from $469,000 to $815,000, as
shown in Table 1-6.
Table 1-6
CLASS I WELLS
SUMMARY OF ESTIMATED ANNUAL RECURRING COSTS TO ALL STATES
(thousands of 1977 dollars)
Task
Quarterly Reviews
Quarterly Compliance Reports
Annual Reports
Enforcement
Total Annual Costs
Incremental
Annual Recurring
Costs
$125
$21
$23 to $94
$300 to $575
$469 to $815
Class III Wells: Costs to States
• Total estimated one-time costs to all states
with Class III wells would range from $264,000
to $509,000, as shown in Table 1-7.
Table 1-7
CLASS III WELLS
SUMMARY OF ESTIMATED ONE-TIME COSTS TO ALL STATES
(thousands of 1977 dollars)
Task
Developing State Programs
Program Hearings
Permitting Existing Sites
Permit Hearings
Total One-Time Costs
Incremental
One-Time Costs
$28 to $73
$22
$160 to $360
$54
$264 to $509
TBS
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1-8
Total estimated annual recurring costs to
all states with Class III wells would range
from $131,000 to $230,000, as shown in
Table 1-8.
Table 1-8
CLASS III WELLS
SUMMARY OF ESTIMATED ANNUAL RECURRING COSTS TO ALL STATES
(thousands of 1977 dollars)
Task
Incremental
Annual Recurring
Costs
Quarterly Reviews
Annual Reports
Enforcement
Total Annual Costs
$39
$7 to $26
$85 to $165
5131 to $230
Limits of the Analysis
A significant degree of uncertainty has been introduced
into the analysis of costs for several reasons;
• The inventory of injection well practices is
incomplete. In most cases, no formal national
inventory has been compiled. In some cases,
available records are out-of-date, and no
projections for the near future have been
accumulated. Moreover, the inventory of
practices used in this report was compiled
in late 1977 and was not updated with the com-
pletion of these reproposed UIC regulations.
• The area of review (or zone of endangering
influence) is to be specified by each state
director. That zone will determine the extent
of information that must be supplied in the
permit application and therefore the level of
effort required by the operator to complete the
application. Much of the cost to the operator
of compiling permit application data has been
included to allow for the need to assemble
TBS
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1-9
information relevant to the area of review.
This is especially true for copper, Frasch
sulfur, salt, and potash mining practices.
The operator is responsible for reviewing all
available well reports of producing and aban-
doned wells within the area of review, as well
as for proposing appropriate corrective action
for improperly completed and/or plugged wells
penetrating the injection zone within the area
of review. Though an attempt has been made to
estimate the extent of efforts required to ac-
complish these tasks, little documented infor-
mation exists regarding the number and location
of these wells. It should not be unduly diffi-
cult for most injection well operators to locate
wells near their facilities if well reports have
been submitted to local or state agencies. If
corrective action is required, plugging costs
could range from $6,000 to $20,000 per well.
State sources do not anticipate that operators
would be required to cement or plug additional
wells due specifically to the UIC regulations,
as some form of corrective action is currently
required in all states where these wells are
considered to be a potential problem. In other
states, regulators are unable to determine the
potential problems associated with abandoned
well requirements due to lack of data. Operators
experiencing hardship because of these require-
ments may inform the state of their particular
difficulties. These data will be considered by
the states during the implementation of the UIC
program. However, EPA believes that if the num-
ber of such wells is high, the costs will be
high but the danger to underground sources of
drinking water will be high as well. This study
did not include any costs to the operator for
completing and/or plugging producing and aban-
doned wells.
There is a lack of experience at the state
level in regulating underground injection
practices in a single, consistent program.
The overall estimate of manpower and cost
requirements has been developed from a base
of little actual experience and many as-
sumptions have been made regarding staff
organization, usefulness of existing infor-
mation, and similarities with other regulatory
TlBfS
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1-10
programs. EPA's consolidated permit program is
intended to assist states in carrying out sev-
eral regulatory programs simultaneously with
an efficient use of state resources. That
approach may lessen start-up problems at the
state level.
The proposed UIC regulations require a demon-
stration of "fiscal responsibility of permittees."
The permittee must assure adequate (financial)
resources, "for example, in the form of a
performance bond or a trust fund, to close,
plug, and abandon the well as prescribed by the
permitting authority." Costs to the operator
for this requirement have not been included in
this cost analysis for two reasons: (1) most
states already require plugging bonds for new
well permits and (2) for older wells or sites,
the cost of a plugging bond would be about $100
over the five-year period covered in this analysis,
This is estimated to provide up to $5,000 per well
in plugging coverage if the operator defaults on
his responsibilities. Current estimates of the
cost to plug a well are within this range.
METHODOLOGY
A brief discussion of the methodology and key assumptions
used in the analysis of the costs of compliance with the pro-
posed UIC regulations is presented in the following paragraphs.
An understanding of the analytic approach and assumptions will
aid in evaluating the conclusions and their implications.
Categorization and Characterization
of Injection Well Practices
Nine specific injection well practices are included in well
classes I and III of the UIC regulations. For the purpose of
this study, each unique practice was analyzed separately.
Using information available in previously completed EPA
studies and the advice of state officials, hydrogeologic consul-
tants, well drillers, trade associations and operators, the
environments at the sites and the characteristics of existing
wells were analyzed to develop an understanding of the status of
TBS
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1-11
current practices. An estimated inventory of existing and
planned future sites in the 57 states and territories was ac-
cumulated .
Research was conducted to determine the type of potential
contamination possible from each practice, and the history of
reported cases of actual contamination. Discussions were held
with hydrologists who had analyzed the problem for EPA in the
past and with state officials who were responsible for respond-
ing to public complaints of contamination.
Comparison of Existing State Regulations
and Proposed UIC Regulations
For each practice, and to the extent possible in each of
the states in which the practices were found, existing state
regulations and levels of enforcement were compared to require-
ments set forth in the federal UIC program. The intent was to
identify those areas where incremental effort would be required
as separate from those situations in which state officials said
that they already enforce current programs at a level of effort
consistent with federal UIC requirements.
Calculation of Costs of Compliance
with Proposed UIC Regulations
The consultants compiled an inventory of the estimated
number of wells and sites for each practice and assessed the
likelihood that a percent of the wells in each practice would
incur compliance costs. By multiplying unit costs and inventory
count, and probability for incurring costs, total costs were
calculated for all aspects of compliance.
The unit cost estimates for complying with federal UIC re-
quirements were obtained from many sources including EPA publi-
cations and officials, state permit files, well drillers, com-
pany engineers and field supervisors. Due to the variation
in estimates, all costs were developed as ranges. Only incre-
mental costs were considered, that is, if operators currently
were responsible for particular state compliance costs these
were omitted from development of similar federal costs of
compliance. All costs in this study, in the analysis of
Class II well impacts, and in the Class IV and V study, were
stated in 1977 dollars. Thus, total impacts can be examined
on a consistent basis.
TBS
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1-12
Determination of Significance of
Costs of Compliance to Operators
Research was conducted to determine, for each injection
well practice, the economic strength of its industry as a whole
and the financial characteristics of the operating companies
within the industry. An attempt was made to evaluate the rela-
tive impact of the calculated UIC compliance costs. In a few
cases, general industry data were readily available, such as in
the Bureau of Mines Mineral Yearbook. In most cases, data were
scarce, sometimes due to the fact that individual companies
protected operating performance information for competitive and
anti-trust purposes, sometimes due to the fact that companies
were vertically integrated and did not separate aspects of their
operations when reporting financial performance.
Determination of State Program
Manpower Time and Cost Requirements
Each aspect of state program manpower requirements and
costs was identified and researched, including costs associated
with program development, permitting, monitoring, reviewing, and
reporting. Costs were separated into one-time costs and annual
recurring costs.
Interviews were conducted with state officials to deter-
mine the current status of groundwater regulations within their
states, the level of staffing and enforcement for control of
existing injection «vell practices, and changes anticipated in
response to federal UIC requirements. The NPDES permit program
was also used as a guide in estimating staff time and related
personnel cost because that program has provided EPA with) a
broad base of experience in industrial permitting.
A key assumption in developing state program cost estimates
in this study was that the mix of personnel required to carry
out the program would be available for all states simultaneously,
During interviews with state officials, each said that personnel
would be available. However, when examining the aggregate needs
for all states and all groundwater protection programs expected
to be enforced within the next several years, there was some
question as to the simultaneous availability of manpower re-
sources with appropriate background and experience.
TIBISI
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II. COSTS TO OPERATORS
OVERVIEW
This chapter discusses costs to operators of injection well
practices covered under Well Classes I and III of the proposed
UIC regulations. Specifically, these practices include munici-
pal and industrial waste-disposal wells injecting into saline
aquifers, nuclear storage and waste-disposal wells, geothermal
wells, in-situ gasification, in-situ uranium and copper leaching,
Frasch sulfur processing, and solution mining of salt and potash.
The objective of this research and analysis has been to
provide EPA with estimates of the impacts of proposed UIC reg-
ulations in terms of both required physical modifications to
practices and costs associated with those modifications and with
other requirements of the regulations. The analysis has in-
cluded the following steps:
• Develop a technical understanding of oper-
ating techniques used in the practice
• Identify production, pilot, and proposed
sites
• Review existing state regulations governing
the practices
• Identify where potential modifications to
current practices might be required by the
UIC regulations and develop estimates of
the cost of such changes
• Develop total incremental cost estimates
for each practice
• Analyze the economic impact of these costs
on affected companies and industries, where
possible.
The results of these analyses are summarized in the fol-
lowing paragraphs. Succeeding sections of this chapter contain
more detailed reviews of each of the practices with the costs
of compliance highlighted.
TBS
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II-2
Table II-l presents an overview of the existence and loca-
tion of injection well practices covered under proposed UIC
regulations. Industrial and municipal waste-disposal wells are
most broadly distributed across the states, and those sites are
the most numerous. Usually, each disposal site has one well,
though occasionally a few wells are located at a single site.
Texas, Louisiana and Michigan account for two-thirds of all in-
dustrial and municipal waste-disposal wells. The mining prac-
tices generally have many wells per site; for example, there
are about 50 Frasch wells at sites in Texas and Louisiana and
about 10 salt wells per site in Michigan and Ohio. In all,
this study estimates that approximately 309 existing Class I
wells at 309 sites and 2,000 existing Class III wells at
approximately 97 sites will be impacted by these regulations.
A review of existing state regulations governing injection-
well practices and the protection of groundwater indicates that
legal statutes differ widely among states. Though all states
generally provide for the protection of groundwater and possess
authority to initiate action against contaminators, most states
do not have specific regulatory programs which control permit-
ting, monitoring, and reporting requirements to the extent
specified in the proposed federal UIC regulations. In addition,
control of underground injection activities is usually divided
among several state agencies which may function independently of
each other.
Federal UIC regulations should not require well operators
to modify current practices, but will require changes in prepa-
ration of permit data, compliance with mechanical integrity test
requirements, and submission of monitoring and reporting informa-
t i on.
Permit data adequate for compliance with the proposed regu-
lations could be obtained from state files for wells which are
not new, but the data must be current, accurate and complete.
There was general agreement among industry sources that addi-
tional time and effort would be needed to fulfill the provisions
of the new permit applications. This is a result of require-
ments in the April UIC regulations for maps showing "the number,
or name, and location of all producing wells, injection wells,
abandoned wells, dry holes, surface bodies of water, mines
(surface and subsurface), quarries, public water systems, water
wells and other pertinent surface features including residences
and roads. The map should also show faults, if known or sus-
pected." Detailed physical information is required for all
wells within the area of review. The requirement for hydro-
geologic maps and cross sections of the area affected by the
proposed injection would also add incremental time to permit
T
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II-3
State
Alabama
Arizona
Arkansas
California
Colorado
Florida
Hawaii
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Michigan
Mississippi
Nevada
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Tennessee
Texas
Utah
West Virginia
Wyoming
Total
Sources:
1. Dr. Donald
TA:-Lt 11- 1
ESTIMATED COUNT AND DISTRIBUTION OF PRACTICES
Mining Sites5
Industrial and
Municipal Disposal In-Situ Frasch Solution Solution
Wells (injecting Nuclear Waste Geothennal Gasification Uranium Copper Sulfur Mining Mining of
into saline aquifers)! Disposal Sites^ bites-* Sites'* Leaching Leaching Process of Salt Potash
5 1
4
1
4 Z
1 1 1
6
3
5
12 1
1
28 5
3 1
65 4 13
30 8
1
1
121 14
4 1 5
4
1
10 3
14 2
3
05 1 10 6 8
1
7 3
1 2 10
304 5 3 3 21 5 10 54 1
Warner, Compilation of Industrial and Municipal Injectir.n Wells in the Urited States, EPA-520/9-74-020, 1974.
2. Nuclear Regulatory Commission data.
3. Bureau of Mines and State sources in California and New Mexico.
4. Bureau of Mines and State sources in Texas and Wyoming.
5. Bureau of Mines data and Regional and State sources.
TIBS
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II-4
application preparation. Operating data would be required to an
extent not previously requested in permit applications and would
therefore add to the requirements for data to be submitted to
state agencies.
The mechanical integrity test, as specified in the UIC
regulations, would be performed to demonstrate the absence of
significant leaks through the tubing, packer, or casing, and the
absence of fluid migration between the outer casing and the well
bore. Several acceptable test methods are listed in the regu-
lations, and the director, with the approval of the administra-
tor, has the authority to accept additional methods for test-
ing. Well drilling experts have assisted the consultants in
an analysis of the most appropriate tests and their related
costs to be used in each practice. Results of this study have
led to the conclusion that the test requirements for mechanical
integrity would impact most heavily on the practices of waste-
disposal wells and solution mining of salt, and on Frasch sulfur
practices if the test for mechanical integrity is required
on these short-lived wells.
Incremental monitoring and reporting requirements would
have minimal impact on the existing injection-well practices.
The least significant impact would be no incremental time or a
few days per year of staff support to conduct monitoring tests
and record and report the results. The most significant impact
would occur in Frasch sulfur mining where existing monitoring
techniques might be inappropriate for new UIC requirements and a
system of monitor wells might be required at each site.
LIMITS OF THE ANALYSIS
There are areas of uncertainty in the economic analysis
which could affect the conclusions. Those which have been
identified to date include: (1) the accuracy of current inven-
tory information, (2) the zone of endangering influence, and
(3) improperly completed and/or plugged wells. These areas are
discussed below.
Accuracy of Current Inventory Information
The costs presented in this report are based on informa-
tion obtained in a comprehensive well inventory compiled in
late 1977. Since then, additional Class I and Class III wells
have been constructed and begun operation. The cost impact of
this recent growth is not expected to distort the major results
T|B|S
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II-5
of this analysis for two reasons: (1) for Class I, the five-
year cost estimates presented in the analysis for the most
costly practice, waste disposal wells injecting below all
underground sources of drinking water, have incorporated a
growth rate of 20 new wells per year; and (2) for Class III,
recent information reveals an increase in the inventory count
of 13 sites, with the greatest increase (10 additional sites)
occurring for uranium leaching sites and geothermal sites.
However, as is discussed in the sections on in-situ uranium
leaching and geothermal practices, UIC requirements will result
in modest incremental operating requirements.
The Zone of Endangering Influence
The area to be reviewed by the director in the issuance
of a permit may be either the zone of endangering influence as
based on a formula or a zone determined by a specific radius.
The suggested formula considers such influences as hydraulic
conductivity and thickness of the injection zone, time of in-
jection and injection rate, specific gravity of formation
fluid, original hydrostatic head of formation fluid, and the
hydrostatic head of the underground source of drinking water.
Alternative formulas of equal soundness may be used if based
on the parameters listed above. The specific radius takes into
consideration geology, hydrology, population, groundwater use,
and historical and other factors relating to potential endanger-
ment .
Once the director has determined the specific zone for
each practice or area, it is the operator's responsibility to
protect drinking water sources in that zone from contamination
by his practice. The extent of the zone of endangerment deter-
mines the amount of information that must be supplied in the
permit application, especially information pertinent to produc-
ing wells, injection wells and abandoned wells, dry holes,
surface bodies of water, mines, quarries, and other pertinent
features. A choice of zone size for an injection practice
should therefore be evaluated on the bases of economic and
administrative feasibility as well as on the basis of the
degree of public health protection afforded. Large zone sizes
would increase permit application costs for the well operators
and raise permit review costs for the states.
The costs of permit application and review used in this
study are estimates obtained from discussions with various well
operators and state regulators. Developed on a state-by-state
and practice-by-practice basis, the estimates are based on
experience and judgment, particularly in regard to two major
T
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II-6
areas of uncertainty: (1) the expected difficulty involved with
gathering the information required in the permit application,
and (2) the expected size of the zone of endangering influence
for states with these practices.
Improperly Completed and/or Plugged Wells
The purpose of the operator's review of completion and/or
plugging reports of all producing and abandoned wells pene-
trating the injection zone is to determine if these wells
would allow migration of contaminated fluids into drinking
water aquifers through the unplugged shafts of improperly com-
pleted wells. It has been recognized that the potential for
these wells to degrade groundwater quality is dependent on the
well's original function, design and construction, the site
geology, and the hydraulic characteristics of the emplaced
fluids.3
There are two areas of uncertainty with this requirement
that could significantly impact on costs associated with the
UIC program. These are (1) the operator's extent of responsi-
bility, and (2) the magnitude of the repair requirements for
the operator. These are discussed in the following paragraphs.
The operator is responsible for reviewing all active and
abandoned well reports and for proposing the type of remedial
actions to be taken when necessary. In some injection areas,
the number of abandoned wells is thought to be quite large and
the public records are inadequate. The operators in these
areas may find the task of locating and describing all aban-
doned wells within the prescribed area of review to be both
time-consuming and costly. Operators have argued, also, that
the requirement to plug and/or properly complete these wells
could be very expensive. The magnitude of the expense is dif-
ficult to estimate for several reasons. The extent of the zone
of endangering influence is uncertain, as the director must
make that determination for each practice or area in each state.
The number of improperly abandoned wells which endanger drinking
water sources is unknown and could range from none to several
at each site depending on the history of well drilling and com-
pletion in each area. Furthermore, of the wells located within
the area of review, it is only those improperly completed or
abandoned wells that actually penetrate the injection zone
under consideration that will require corrective action.
3Impact of Abandoned Wells on Ground Water, EPA-600/3-77-095,
August 1977. Ecological Research Series, p. 1.
TBS
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II-7
During discussions held with state-level water regulators,
most said that their current approach to the control of endan-
germent from abandoned wells provided adequate protection re-
gardless of the specific language in their regulations. A few
others believed that there was room for improvement, especially
in the extensiveness of geographic coverage, but that costs in-
curred would primarily be state enforcement costs. By far the
largest number of states were characterized by (1) general
plugging language, (2) poor historical data on abandoned wells,
(3) enforcement in response to specific complaints of contamin-
ation and during initial permitting of the injection practice,
and (4) confidence that a careful check in the area of review of
existing wells would confirm that there are no contaminating
abandoned and producing wells among those that exist.
No incremental costs to operators have been attributed
to the UIC program for those practices in states where correc-
tive action is already required. In other states, regulators
lacked supporting data to say that any wells would require
cementing or plugging, and, therefore, no costs could be attrib-
uted to the UIC regulations for those states.
CLASS I PRACTICES
The following discussions provide, for each practice and
to the extent possible, a technical description of the practice,
inventory and location of known sites, current state regulations
for identified sites, and practical and cost impacts of UIC
regulations for those sites and their operating companies.
Waste-Disposal Wells Injecting
Below Underground Sources of
Drinking Water
Waste-disposal wells covered under proposed UIC regula-
tions have been separated into two groups: (1) wells injecting
below all underground sources of drinking water in the area
(defined as Class I wells) and (2) wells injecting into or
above underground sources of drinking water (defined as Class
IV and V wells, depending on the characteristics of the waste
injected). This discussion centers on the former group; the
latter group will be discussed in a subsequent report.
Waste-disposal wells are sometimes referred to as deep
waste-disposal wells or industrial and municipal injection
wells. A wide variety of wastewater is injected, including
TBS
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II-8
chemicals, pharmaceutical products, metal manufacturing wastes
and municipal sewage. Deep disposal wells have been drilled to
depths greater than 8,000 feet but are typically between 1,000
and 6,000 feet deep.
Several attempts have been made to compile an inventory of
these wells, especially during the last ten years when there
developed an increasing awareness of the limited capability of
surface waters to receive effluents without violation of stan-
dards. In July 1975 a report was submitted to the EPA entitled
Review and Assessment of Deep-Well Injection of Hazardous Waste
by L. R. Reeder and others.4This report updated the 1974
compilation of industrial and municipal wells prepared princi-
pally by Dr. Donald Warner.^ The consultants used the more
recent, 1975, inventory to assess the impact of proposed UIC
regulations on waste-disposal well practices. A total of 383
wells were reported to be permitted as of 1975. Of those wells,
209 were in operation, 38 were not operating but unplugged, and
57 were drilled but never used. The remaining 79 were never
drilled, were plugged, or the status was unknown. More than
one half of the operational facilities were located in Louisiana
and Texas. Most sites of deep waste-disposal wells were the
location of just one Class I well. However, there were a few
sites, especially at large petrochemical companies, where two
or three wells occupied a single site. The analysis which
follows is based on 300 currently operating wells at approxi-
mately 300 sites to reflect that these numbers are, at best,
an estimate of current practices. Where appropriate, costs
are also calculated to reflect the 100 new waste-disposal
wells expected to begin operation in the next five years.
All states with deep disposal wells have some type of
underground disposal regulations; however, the strictness of
existing regulations varies widely. In general, the proposed
UIC regulations are consistent with regulations in those states
with the most numerous deep disposal well practices. Texas,
Louisiana and Michigan have recently adopted specific, stringent
requirements for permitting, monitoring and reporting. Other
states have detailed requirements for permitting new wells, and
more general guidelines for ongoing operations. In the latter
4
L. R. Reeder and others, Review and Assessment of Deep-Well
Injection of Hazardous Waste, Solid and Hazardous Waste Re-
search Laboratory, National Environmental Research Center,
Cincinnati, Ohio, 1975.
EPA-520/9-74-020, Compilation of Industrial and Municipal
Injection Wells in the United States.
T
B
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-------
II-9
group of states, the test of mechanical integrity and the
frequency of reporting would impose incremental requirements on
injection well operators, though no additional effort is antici-
pated in permitting existing or new wells.
Mechanical integrity testing would be required under the
proposed regulations to verify that leaks do not exist in the
long string casing, in the tubing, or in the packer; and that
there is no fluid movement through vertical channels adjacent
to the injection well bore. In order to develop costs of com-
pliance associated with the mechanical integrity test require-
ments, it is necessary to know the construction characteristics
of the deep waste-disposal wells. One state source indicated
that, to his knowledge, all wells in that state have tubing
and packer; yet when consultants reviewed the construction
details in the permit data in the references cited earlier,
they found that approximately half the permitted wells have
tubing and packer and half do not. In addition, a packer may
be pulled and not replaced, while a state source in Kansas
reported that, when wells without tubing and packer are re-
paired, the state specifies at that time that tubing and packer
must be installed. These variances lend some uncertainty to
the analysis. It is assumed here that, as in the references
cited, half the wells have tubing and packer and half do not.
Section 146.12c of CFR Part 146 states that "All Class I
injection wells, except for those municipal wells injecting
only non-corrosive wastes, shall inject fluids through tubing
and packer set immediately above the injection zone." Moreover,
the program director would have the discretion to permit the
use of alternatives to tubing and packer in cases where they
would provide adequate protection of underground sources of
drinking water. This report reflects the assumption that the
UIC regulations will not require that incremental action will
be necessary regarding retrofitting existing Class I wells
that do not have tubing and packer.
All wells are required to pass an approved test of mechan-
ical integrity. For wells without tubing and packer, geophysi-
cal logging can be performed to test the integrity of the long
string casing. A pressure test could also be performed: however,
this test is more costly than logging. It would be possible, at
the discretion of the director, for those wells with tubing and
packer to submit annulus data to comply with the regulations,
thus incurring no incremental expense. For wells with tubing
and for wells with tubing and packer, a pressure test would be
performed after the packer and/or tubing are removed. Absence
of fluid migration through vertical channels between the casing
T|B|S
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11-10
and borehole could be demonstrated through well records showing
the presence of adequate cement to prevent migration, or through
the results of tests such as a cement bond log, sonic log, dual
vention log or temperature log. These procedures are cited as
examples to give a general impression of technical requirements
of mechanical integrity testing.
Table II-2 illustrates the costs associated with testing
waste-disposal wells for the presence of leaks and fluid migra-
tion. These cost estimates were derived from interviews with
well drilling firms and well drilling service firms and repre-
sent the costs of testing typical wells. Because of the unique
characteristics of each disposal well, a more extensive examina-
tion of costs would be necessary to better assess the economic
impact. The cost of testing is estimated for 125 wells, as the
remainder of the wells are located in Texas, Louisiana and
Michigan—states which reported that the mechanical integrity
test is already required. The cost is estimated to range from
$5,000 for geophysical logging to $35,000 for downhole pressure
testing. The total cost of testing is estimated to range from
$300,000 to $2.10 million for the estimated 125 operating wells
in states that do not currently require the mechanical integrity
test.
Table II-2
COST OF TESTING MECHANICAL INTEGRITY OF yASTE-DISPOSAL WELLS
(thousands of 1977 dollars)
Well Construction
With tubing and packer
With tubing and no
packer or without
tubing and packer
Total
Estimated
Number
of Wells1
65
60
125
Testing Cost
Per Well
$5 to $35
Total Cost
$300 to $2.100
$300 to $2,100
The estimated number of wells for each well construction was derived
from permit data in Compilation of Industrial and Municipal Injection
Wei Is, 1974, prepared principally by Dr. Donald Warner.
Well drilling experts have estimated that approximately two
percent of all existing disposal wells will fail the mechanical
integrity test and require repair. There is even more variance
in repair procedures than in mechanical integrity testing. Costs
for repair, which will include costs of testing to determine
the location of the leak, have been derived from interviews
TBS
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11-11
with well drilling firms and well drilling service firms and
represent costs of repairing typical wells. The total cost
range for the repair process is between approximately $35,000
and $200,000, as illustrated in Table II-3 and discussed
greater detail in the following paragraphs.
in
Table II-3
COST OF REPAIRING WASTE-DISPOSAL WELLS
(thousands of 1977 dollars)
Well Construction
With tubing and packer
With tubing and no
packer or without
tubing and packer
Total
Estimated
Number of
Wells That
Will Leak1
1
Total
Repair Cost
Per Well
$17.5 to $100
$17.5 to $100
Total Cost
$17.5 to $100
$17.5 to $100
$35 to $200
The estimated number of wells for each well construction was derived
from permit data in Compilation of Industrial and Municipal Injection
Wells, 1974, prepared principally by Or. Donald Warner, and the esti-
mate of well drilling experts that two percent of wells will leak.
For wells without tubing and packer with a leak in the long
string casing, a pressure test and bridge-plug and packer inter-
val pressure test can be performed to locate the leak. The
pressure test cost will range between $25,000 and $35,000, and
the bridge-plug and packer interval pressure test will cost an
additional $12,500 or a total of approximately $50,000. The
cost of repairing the long string casing can range between
$5,000 and $50,000. The total cost of repairing wells without
tubing and packer will range between $50,000 and $100,000, based
on a cost of testing for leak location of $50,000 and a cost of
leak repair of $5,000 to $50,000.
To locate a leak in the long string in wells with tubing and
no packer and in wells with tubing and packer a bridge-plug and
packer interval pressure test will be required at an incremental
cost of approximately $12,500. If there is a leak in the tubing
or packer, remedial action incorporating either repair or replace-
ment of the tubing and packer would be necessary. The expense
for this procedure would exceed $40,000, not including the cost
of pulling the tubing and packer, which would be incorporated in
the pressure testing expense. Therefore, the cost of the repair
process would range from $17,500 for a bridge-plug ana packer
interval pressure test and minor repair of the long string
TBS
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11-12
casing to $100,000 for a bridge-plug and packer interval pres-
sure test, extensive repair of the long string casing and re-
placement of the tubing and packer.
The increase in new wells has averaged 20 operating wells
annually for the past several years. As this trend is expected
to continue within the next five years approximately 100 new
wells will become operational. Effective construction designs
are already required for new disposal wells by state permitting
agencies; consequently, no incremental expense for construction
or reworking should be incurred. The test for mechanical in-
tegrity should be performed as part of a standard construction
policy and would not result in additional costs.
Thus, the total one-time costs for both existing and new
wells complying with the proposed regulations over the next
five years are expected to be in the range of $335,000 to $2.3
mi 1 lion .
Recurring annual expenses would also be associated with
deep disposal well operations. As present requirements concern-
ing monitoring of operations closely parallel federal UIC regu-
lation requirements, it has been assumed that no incremental
monitoring would be required. It has been estimated, however,
that additional reporting would be necessary for the wells lo-
cated in states other than Texas, Louisiana and Michigan, and
could be satisfied with one day per quarter per well for an
annual cost of approximately $300 per well. Therefore, total
annual recurring costs would approximate $40,000 for 125 wells
and $50,000 for the 170 new and existing wells located in states
other than Texas, Louisiana and Michigan.
Table II-4 presents estimated one-time as well as recurring
costs resulting from the requirements of the proposed UIC
regulations .
Table 11-4
WASTE-DISPOSAL WELLS INJECTING
INTO SALINE AQUIFERS
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Existing Sites
Number of Existing Wells
Additional Wells Next 5 Years
One-Time Costs
Mechanical Integrity Test
Well Repairs
Annual Recurring Costs
Reporting
300 (or less)
300
100
$300 to $2,100
$35 to $200
J335 to $2,300
$40 to $50
|T|B|S|
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11-13
It should be recognized that the owners of the disposal
wells are almost all relatively large firms and that the three
companies with the largest number of deep disposal wells account
for 25 percent of all operating wells. Few small firms operate
their own deep disposal wells; consequently, the probability of
significant economic dislocation due to the regulations is small.
Nuclear Storage and Waste-Disposal Wells
Nuclear storage and waste-disposal wells used for the
injection of fluids would be covered by proposed UIC regula-
tions. Five operating sites have been located at which fluid
radioactive wastes are injected underground. New Mexico has
two nuclear disposal sites. The Anaconda Company injects
liquid uranium processing wastes into a deep injection well
that is 1,800 feet deep with multiple casings and several
monitoring wells. The Los Alamos Laboratory puts solid wastes
into pits and also has several shafts that are lined with
asphalt into which a radioactive cement slurry is disposed.
Extensive dry-well monitoring is conducted at the New Mexico
sites to insure that no radioactive migration occurs. In New
York, Nuclear Fuels Service (NFS) has in the past used trenches,
tanks, and hydrofracturing, but these practices have been dis-
continued. There are additional sites in Maxey Flats, Kentucky,
and Michigan City, Indiana, where liquid wastes are disposed of
below the ground.
i
Due to the characteristics of the disposed products, there
is ongoing concern that radioactive wastes will migrate into and
contaminate freshwater aquifers. In one documented case, the NFS
site in West Valley, New York, was closed because some radio-
active materials had seeped into a nearby stream. In Kentucky,
state officials have been examining the need to close the Maxey
Flats nuclear waste-disposal site after radioactivity was de-
tected in water which had seeped into a newly-dug unused burial
trench. At the present time, extensive state and federal regu-
lations for permit and design requirements exist to insure safe
disposal of nuclear wastes. These regulations typically are
at least as strict as the requirements of the UIC regulations;
consequently, it is unlikely that either operating changes or
additional permitting would be required for either new or
existing wells.
Due to the increased frequency in monitoring and report-
ing required by the UIC regulations, annual recurrent costs
for nuclear waste disposal would include incremental monitor-
ing costs of $5,000 for all five sites, based on two hours per
week per site, and $3,000 for additional reporting costs for all
-------
11-14
five sites at a frequency of two days per quarter per site.
Therefore, total annual recurring costs would be $8,000 for the
five nuclear disposal sites.
Table II-5 highlights the incremental costs associated with
the compliance of nuclear waste disposal wells with proposed UIC
regulations.
Table II-5
NUCLEAR WASTE-DISPOSAL WELLS
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites
Number of Wei Is
One-Time Costs
Annual Recurring Costs
Monitoring
Reporting
Total Annual
Recurring Costs
$ 5
3
$ 8
CLASS III PRACTICES
The following discussions provide for each practice to
the extent possible, a technical description of the practice,
inventory and location of known sites, current state regulations
for identified sites, and practical and cost impacts of UIC
regulations for those sites and their operating companies.
Geothermal Wells
At the present time, there are three geothermal sites with
a total of 13 disposal wells. In California, the Geysers field
has eight injection wells that are currently operating. The
East Mesa experimental field in California's Imperial Valley has
two injection wells. In New Mexico, the Valles Caldera site has
three injection wells.
ITIBISI
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11-15
migrate into drinking water sources, then the total estimate
would be reduced proportionately, to less than one billion
gallons per year. Other leakage rates would alter the total
figure proportionately.
Data from Maryland, Florida, and Nassau County, New York,
were used to develop a national profile of volumes injected by
Class IV wells. As may be seen in Table II-2, 660 million to
1.7 billion gallons of hazardous wastes may be disposed of
yearly by these wells into or above underground sources of
drinking water. A "best" estimate of discharged volume would
be approximately one billion gallons yearly.
Table II-2
CLASS IV WELLS - NATIONAL PROFILE
|
,SIZE CATEGORIES j
j I: Wells injecting less than 100 gallons per day (gpd) -
! II: Wells injecting between 100 and 1,000 gpd ]
I III: Wells injecting over 1,000 gpd ;
|
I
'WELL POPULATION
I: 4,000 to 8,000; best estimate - 6,000 wells
II: 500 to 1,000; best estimate - 750 wells !
! Ill: 500 to 1,000; best estimate - 750 wells [
; TOTAL: 5,000 to 10,000; best estimate - 7,500 wells
'ANNUAL WELL INJECTION VOLUMES—MILLION GALLONS PER YEAR (MGY)
I: 15 MGY to 50 MGY; best estimate - 30 MGY
i II: 19 MGY to 62 MGY; best estimate - 38 MGY
III: 625 MGY to 1,625 MGY; best estimate - 938 MGY \
TOTAL: 659 MGY to 1,737 MGY; best estimate - 1,006 MGY
i |
It also appears that a few high volume facilities account
for a disproportionate percentage of the hazardous waste volume
discharged. High volume facilities, i.e., facilities injecting
over 1,000 gallons per day (gpd), represent approximately 10
percent of the national Class IV well population. However,
these facilities appear to discharge over 90 percent of the
hazardous waste volume attributable to Class IV wells. Small
volume facilities, representing 80 percent of all Class IV
wells, appear to inject only 3 percent of Class IV well hazard-
ous waste volume.
A national estimate of Class V injection volumes cannot be
developed without data which is to be collected during the state
ITIBIS
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11-16
New geothermal wells are expected to become operational
within the next several years; however, the exact number is
uncertain. It is likely that additional wells would be located
at existing sites; therefore, area permits would be applicable.
Since effective construction designs are a current requirement
of state and federal regulations, no incremental construction,
testing, or reworking expenses would be incurred.
When discussing with state experts the requirements for
proper plugging of abandoned wells, they have said that there
is a possibility that some abandoned wells exist off the sites
within the zone of endangerment, but the number would be diffi-
cult to judge. If remedial action were necessary, plugging
costs could range from $6,000 to $20,000 per abandoned well.
In terms of annual recurring costs, incremental costs would
not be incurred by operators of these wells as a result of the
UIC requirements for weekly monitoring and quarterly reporting.
Monitoring is currently performed on a regular, ongoing basis
as a component of the control of these practices. Reporting
frequency as dictated by DOE will be at least quarterly and
probably monthly.
Table
above.
II-6 highlights the likely conclusions discussed
In-Situ Gasification
There are three basic in-situ gasification processes: re-
covery of oil shale, coal, and tar sand oil and gas. To recover
oil shale, hydraulic or explosive fracturing or reverse combus-
tion is introduced through injection wells in order to increase
Table 11-6
GEOTHERMAL WELLS
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites
Number of Wei Is
One-Time Costs
Permitting
Testing
Total One-Time Costs
Annual Recurring Costs
Monitoring
Reporting
Total Annual
Recurring Costs
3
13
$ 0
S 0
$ 0
$ 0
$ 0
$ 0
IT
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11-17
the size of a permeable drainage channel. Then the combustion
zone is ignited, and oil and gas are produced. The spent frac-
turing gels and other solvents are typically disposed of through
deep disposal wells. In-situ gasification of coal involves both
an ignition well for introducing the fire and an injection well
for providing an oxygen source for the fire. Gases are then
given off by the air-injection induced fire. Tar sand oil and
gas recovery has been attempted with pyrolysis through several
production and injection wells.
In-situ production from oil shale has occurred from time
to time, but no permanent commercial production field has been
established. In-situ gasification of coal is still in its ex-
perimental stages. Pilot sites have been established at the
Laramie-ERDA site at Hanna, Wyoming, and at the Lawrence Liver-
more Laboratory's Powder River Basin site near Gillette, Wyoming.
In Texas, the Texas Utilities Generating Company has a site at
Fairfield. Two other proposed sites have been located in West
Virginia and Texas. The only known site for in-situ tar sand oil
and gas recovery in the United States is located near Vernal,
Utah. Experimental recovery was conducted there in 1975. In
general, the practice of in-situ gasification has grown rapidly
in Canada, and may follow the same trend in the United States
as the Federal government encourages the development of alter-
nate forms of energy.
A potential hazard of these processes is that the failure
of the injection or production wells in these operations could
cause the fracturing agents or the product itself to contaminate
drinking water aquifers. To date, no incidences of contamina-
tion have been reported.
In-situ gasification operations are located in states with
relatively stringent regulations covering the protection of
groundwater. These states are sensitive to the value of ground-
water supplies that have suitable quality for short-term and
long-term domestic and commercial use. Therefore, the economic
impact resulting from an existing site's complying with proposed
UIC regulations is expected to be minimal. Current operations in
Texas are required to have monitoring wells and an aquifer restor-
ation program and to properly plug abandoned wells. Wyoming is
in the process of requiring equally strict protection policies
separate from the UIC program.
The site data presented above were taken from information
available in late 1977 and were used in a cost analysis of the
August 1977 draft UIC regulations. The same information has
oeen used in the present analysis. One or more of these sites
may have progressed to a production stage since the time of
IT
B
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11-18
data collection; however, should these sites be converted to
production use, it is possible that states would regulate them
as oil and gas (energy-producing) practices rather than as
mining or waste-disposal practices, but all would comply with
federal permitting, monitoring and reporting requirements under
the UIC regulations. No incremental costs can be associated
with the UIC program at this time. This conclusion is shown in
Table II-7.
Table II-7
IN-SITU GASIFICATION
SUMMARY OF COSTS TO'OPERATORS
(thousands of 1977 dollars)
Number of Sites 3
One-Time Costs
Permitting $ 0
Total One-Time Costs $ 0
Annual Recurring Costs
Monitoring $ 0
Reporting $ 0
Total Annual
Recurring Costs $ 0
In-Situ Uranium Leaching
In-situ uranium leaching is used to reclaim low-grade
deposits of uranium that cannot be recovered economically
through alternative means. The process employs dilute sul-
furic acid solutions (or alkaline solutions such as ammonium
carbonate) that are introduced into an ore body to create a
uranium solution. The solution is then typically pumped back
through the production well to the surface.
Twenty-one currently active sites have been identified in
three states. In Colorado, there is one pilot operation. Texas
has six commercial operations and four pilot sites, and New
Mexico has two operations in the permitting state, two that are
presented inactive, and one whose application has been withdrawn
In addition, there are 14 sites in Wyoming, including three in
-------
11-19
the permit application stage, one that has discontinued opera-
tions, and ten pilot sites. Exploratory drilling is being
conducted in South Dakota.^
The potential hazard of this recovery process is the possi-
bility of contamination of potable aquifers by leachants used to
recover uranium and by the uranium itself. No reported inci-
dences of significant contamination have been attributed to this
process. However, the process is relatively new, and major
studies are still to be completed regarding monitoring and
aquifer restoration programs.
The three states with existing uranium leaching operations
have general requirements for monitoring wells, the proper plug-
ging of abandoned wells, and an aquifer restoration program.
Wyoming officials have been working closely with the Nuclear
Regulatory Commission (NRC) staff and hydrology consultants to
develop acceptable standards for systems of monitoring wells
surrounding uranium mining fields. One current theory is that,
/?
The Texas Department of Water Resources reported, in a phone
conversation with TBS in May 1979, that the practice of in-
situ uranium leaching is growing in that state due to eco-
nomic incentives. There are seven active, commercial sites
currently and at least as many planned for future development.
These seven sites have over 4,000 injection wells and almost
2,000 recovery wells. The projected total for installed wells
by May 1980 at these seven sites is about 6,700 injection wells
and 4,600 recovery wells. In addition, new companies may
establish sites in Texas in the near future.
The permit process now requires the accumulation of exten-
sive data. Operators spend three to twelve months in data
preparation and the state spends six to nine months reviewing
the application.
Monitor wells are required on the perimeter of the site at
400-foot intervals, especially where aquifers are known to
exist. Operators are required to monitor twice each month,
primarily for conductivity, uranium and ammonia.
The Texas Department of Water Resources estimates that the UIC
program will not establish requirements for the operators in
addition to those already required by the state. However,
state regulators will experience impacts as a result of per-
forming administrative tasks associated with repermitting,
reporting, and encouraging public participation.
-------
11-20
at a minimum, 24 monitor wells would be required to adequately
cover an ore body. Monitoring wells would be located in arrays
above and below the body in the appropriate surrounding zones
and would provide a water quality profile sufficient to meet
state standards and would actually exceed UIC requirements.
Texas and Colorado are also participating in studies to provide
assurance that monitoring wells will detect leachate excursion
before irreparable damage occurs to the aquifer.
The issue of aquifer restoration has been under study for
the past several months with no conclusive results to date.
Wyoming requires that aquifers must be "returned to baseline in
geologic time" after termination of the mining activities. This
has proved to be geochemically and physically impossible in
pilot tests because ammonia is adsorbed and absorbed into the
surrounding clay and permanently alters the baseline readings of
the aquifer. A five-phase restoration process has been at-
tempted with little success. Economics of the process have not
been considered to date because the pilot projects primarily
considered the environmental feasibility of the restoration pro-
gram rather than the economic feasibility.
It is impossible to predict at this time what the economic
impact will be to operators, or even if the operations will be
allowed to continue as production sites in areas other than
those where water quality is already poor. State sources have
indicated that permitting, operating, and reporting standards
will be established whether or not a UIC program exists. There-
fore, no incremental costs have been attributed to the UIC
regulations for in-situ uranium leaching. This conclusion is
reflected in Table II-8.
Table II-8
iN-SITU URANIUM LEACHING
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites 21
One-Time Costs
Permitting $ 0
Total One-Time Costs $ 0
Annual Recurring Costs
Monitoring $ 0
Reporting $ 0
Total Annual
Recurring Costs S 0
TBS
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11-21
In-Situ Copper Leaching
The process of in-situ copper leaching is used to recover
low-grade ore deposits and involves injection into a well of a
dilute sulfuric acid leachant or water and withdrawal of a
copper sulfate solution. A block caving technique is also used
in which a huge ore body has 1,000 holes (wells) drilled through
it to increase percolation and a surface leachant is applied to
dissolved copper deposits that are subsequently pumped back up
to the surface.
At the present time, the consultants have identified two
operating and two pilot sites in Arizona. One operation in New
Mexico, owned by Occidental Minerals, is in the permitting
stage. Formerly there were also copper leaching operations in
Nevada, Montana, Utah, and Michigan.
There is concern that the use of injected copper leaching
solutions could contaminate freshwater aquifers around produc-
tion sites. There have, in fact, been incidences of ground-
water contamination reported in the Miami, Arizona area.
New Mexico currently has groundwater regulations that re-
quire monitoring wells, the proper plugging of abandoned wells,
and an aquifer restoration program. In addition, according to
New Mexico state sources, special legislation concerning this
type of recovery process is anticipated in the near future.
Since New Mexico's current regulations are relatively stringent,
no operating changes should be required as a result of complying
with federal UIC regulations.
In contrast to New Mexico, Arizona has a fragmented system
of regulating and has no specific regulations covering leaching
wells beyond the development phase. When the UIC regulations
are enforced, Arizona sites could incur significant impacts,
especially in block caving operations, which use no casing and
cementing program, and no monitoring wells and have no aquifer
restoration program. The Arizona sites would have to be evalu-
ated for their effect on underground sources of drinking water.
However, it is possible that they are located in areas where
aquifers would be designated as non-potable.
The economic impact resulting from complying with the pro-
posed UIC regulations should be slight in New Mexico. Since
monitoring wells, a restoration program, and the proper plugging
of abandoned wells are currently required in that state, the
only incremental one-time expense for the existing site should
be one man-month of effort at $1,700 for completing the appli-
cation requirements. In Arizona, a substantial effort of
T|B|S|
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11-22
approximately six months per site would be required to apply
for a permit. Much of this effort would involve the setting
of standards for monitoring continuing operations. Based on
$1,700 per month and four sites, the permitting cost would be
$40,000.
The Arizona sites would incur an incremented expense for
the installation of monitor wells to establish baseline aquifer
conditions and to detect any leachant excursion due to the
mining process. Well drilling experts have estimated that the
average cost of installing a monitor well would be $20,000.
Each well lasts approximately 25 years. The present UIC regu-
lations require five monitoring wells at each site. Thus, the
cost for installing these wells at each site is estimated to
be $4,000 per site per year for each of the Arizona sites.
Therefore, incremental annual recurring costs for the in-situ
leaching sites would include $18,000 for daily monitoring costs
based on one hour of monitoring time per site per day spread
over five monitoring wells per site and $16,000 for monitor
well installation costs for a total of $34,000 per year. Also,
additional reporting costs of $3,000 based on one day per site
and one day for all five monitoring wells per site per quarter
would be required. The total recurring cost for the copper
leaching sites would be $37,000.
According to data available in 1977, in-situ copper leaching
is used only for low-grade recovery and represents less than one
percent of the total $2.5 billion of domestic copper production.
It is important to note that the process of in-situ copper
leaching has been marginally economical in recent years due to
low copper prices, slack demand, and price inelasticities of
the product. Several plants have been closed and significant
growth in this area is not expected in the foreseeable future.
Table II-9 presents one-time and annual recurring costs
which would be absorbed by operators due to UIC regulations.
Table II-9
IN-SITU COPPER LEACHING
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites 5
Number of Wells
One-Time Costs
Permitting $42
Total One-Time Costs $42
Annual Recurring Costs
Monitoring $34
Reporting $ 3
Total Annual
Recurring Costs $37
TBS
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11-23
Frasch Sulfur Mining
Elemental sulfur, resident in the lower part of cap rock
overlying salt domes or salt strata, is mined by the Frasch
process. The process involves injecting super-heated water into
a sulfur bearing formation, melting the sulfur, and raising the
melted sulfur to the surface by injecting compressed air near
the bottom of the well. Sulfur mined by the Frasch process is
generally 99 percent pure.
Ten mine fields with approximately 500 wells in Texas
and Louisiana account for all current Frasch mining. Wells
are replaced on average within one year, though the life of
a well ranges from a few months to 18 months. Approximately
35,000 wells have been drilled since the inception of this
practice more than 80 years ago.
Due to the hydrogeologic environment along the Gulf Coast,
fresh or brackish water used for injection contains less dis-
solved salts than the surrounding formation waters of the cap
rock. According to state regulatory officials there has been no
reported contamination of drinking water aquifers.
Texas and Louisiana regulate Frasch sulfur mining at the
exploratory stage only. Engineering plans, drilling specifica-
tions, and abandonment procedures must be acceptable before the
states approve an application. Though state rules are comprehen-
sive enough to cover all stages of the practice, state officials
responsible for enforcement of UIC regulations have stated that
it may not be necessary to impose more stringent controls on
Frasch processing where the practice takes place in an environ-
ment that precludes use of groundwater as a future drinking water
resource. However, the regulators would encourage the enforcement
of federal UIC standards in areas where groundwater reserves
are of high quality.
The economic impact on Frasch sulfur operations resulting
from complying with proposed UIC regulations could range broadly
from a relatively modest level to an extensive level, depending
on the discretionary judgment of the state director. Permit
application information includes engineering data, maps and
cross sections, and proposed operating data. It is likely that
the director will determine that existing information is adequate.
However, approximately one to two man-months of effort at $1,700
per month (salary plus fringe benefits) would be required to
gather and submit the data for each mainland site. One sulfur
mining company operating offshore fields has estimated that the
cost of preparing permit applications would be as high as $4,000
per site. (Mining costs for offshore operators are two to five
TlBlSl
-------
11-24
times higher than mainland costs.)
permitting expenses for 10 fields,
would be approximately $24,000.
Therefore, total one-time
assuming three are offshore,
No incremental costs would be incurred due to mechanical
integrity test requirements. New Frasch wells currently must
satisfy mechanical integrity requirements prior to injection.
State officials in Texas and Louisiana conduct site visits dur-
ing drilling and carefully review design and construction speci-
fications. Existing Frasch wells have such a short life that
mechanical integrity test data submitted during drilling
would suffice for federal UIC requirements.
Incremental monitoring costs would range from no cost, as-
suming states continued current requirements, to potentially
high costs, assuming a system of monitor wells was required at
one or more sites. One producer estimates that five perimeter
monitor wells, each replaced every five years because of sub-
sidence, would be necessary for each site. According to this
producer, costs per site on an annual basis would be $5,500
to drill and maintain five monitor wells and $3,000 to draw
and analyze weekly samples. Therefore, total annual monitoring
costs would range from no cost (no wells required) to $8,500
per site (five wells required). Total monitoring costs for
7 mainland sites would range from no cost to $60,000. It is
likely that monitor wells would not be required for offshore
practices; therefore, costs have not been included for those
3 sites.
Incremental annual reporting costs would be anticipated
and would cost approximately $700 per site based on two man-days
per quarter, or $7,000 for 10 sites. Combining monitoring and
reporting costs, total recurring costs would range from $7,000
to $67,000 for 10 sites.
The costs discussed above are summarized in Table 11-10.
Table 11-10
FRASCH SULFUR MINING
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites
Number of Wells
One-Time Costs
Permit Applications
Mechanical Integrity Test
Total One-Time Costs
Annual Recurring Costs
Monitoring
Reporting
Total Annual
Recurring Costs
10
500 (approximately)
$24
0
$24
$0 to $60
$7
$7 to $67
|T|B|S|
-------
11-25
A potentially large expense not included in the above anal-
ysis relates to improperly plugged abandoned wells. Extraction
of sulfur by the Frasch process occurs in fields where oil, gas,
and sulfur extraction have taken place over a number of years.
Thousands of abandoned wells exist in these fields. If a state
director determined that one of these wells was improperly
plugged and endangered underground sources of drinking water,
the Frasch producer would incur a cost ranging from $6,000 to
$20,000 to properly plug the well. Since state officials have
informed the consultants that no contamination has been reported
to date, and therefore that the likelihood of the existence of
improperly plugged abandoned wells is slight, the likelihood of
encountering significant remedial costs appears to be low. How-
ever, the determination remains within the director's discretion.
The market value of Frasch production is $250 million
per year (1977). Additional operating costs, especially for
fuel, have been passed on to the consumer without adversely
affecting demand. Prices have generally improved due to con-
tinuing strong demand for sulfur. Therefore, minimal economic
impact may be expected to result from enforcement of the pro-
posed UIC regulations.
Solution Mining of Salt
Solution mining of salt takes place in salt domes and salt
beds. Domed salt is typically mined at a depth of 10,000 feet
by injecting fresh or brackish water through a tubing in a cased
and cemented well. Brine is withdrawn through the annulus.
Bedded salt is typically mined at 2,500 feet using a similar
practice or using a system of separate injection and production
wells. Caverns created during solution mining are used for
storage of natural gas or liquid petroleum products.
Salt is mined at about 50 sites in the United States, with
principal production located in Texas and Louisiana (domed salt)
and Michigan, New York, Ohio, and Kansas (bedded salt).7 Approxi-
mately 500 wells are currently operating. Each well lasts an
average of seven years, though the range is several months to
about twenty years. Solution mining of salt has been practiced
for more than 100 years.
7
Though the inventory shown in Table II-l details 54 sites, not
all sites are active at all times. For the purpose of this
analysis 50 sites were assumed to be active during the first
five years of the UIC program.
IrlBlsl
-------
11-26
Though the mining sites are located near underground drink-
ing water sources, the consultants have not been able to locate
any reported contamination as a result of mining operations per
se. Subsidence has been reported in Michigan due to compaction
of strata after mining.
Existing regulations to control solution mining of salt
vary among the producing states. Texas and Louisiana, account-
ing for 55 percent of salt production, regulate applications for
exploratory drilling permits only. Rules and regulations to
protect pollution to groundwater may be issued with the permit,
but no monitoring requirements are imposed. New York, Kansas,
and Ohio have broad regulatory power on a case-by-case basis,
generally consistent with proposed UIC regulations with the
exception that monitoring and reporting are not legally re-
quired. In Michigan, Mineral Well Act #325 is in complete
compliance with proposed UIC regulations except for specific
requirements relative to the frequency of monitoring and
reporting.
Incremental one-time costs would be incurred for permit-
ting and testing of existing wells. In all states except
Michigan, more extensive research and paperwork would be re-
quired to prepare permit applications. It has been estimated
that one to two man-months of effort at $1,700 per month (salary
and fringe benefits) would be sufficient for each field.
Submitting permits for 50 fields would cost a total of $85,000
to $170,000. According to technical experts, an appropriate
test for mechanical integrity of existing wells would cost
$3,000 to $5,000 per well. Such testing for 500 wells would
total $1.5 million to $2.5 million.
Solution mining of salt requires monitoring on a regular,
frequent basis to assure operators of the efficiency of their
process. Therefore, it is likely that no additional steps would
be necessary to comply with monitoring requirements of the UIC
program. Due to the requirement for quarterly frequency of
reporting, operators would experience some incremental recurring
costs. These have been estimated to be $16,000 based on one day
per quarter for each of the 50 existing sites.
Therefore, total incremental costs attributable to UIC
regulations would range from $1.6 million to $2.7 million in
one-time costs and $16,000 in annual costs. These are sum-
marized in Table 11-11.
In addition to the above estimates, a Michigan state
official has reported that implementation of Michigan's strict
regulations increased the cost of well design and drilling by
T|B|S|
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11-27
15 percent. That belief has been discussed among EPA staff;
since no clear consensus has emerged, that impact on costs has
not been included in the analysis.
Table 11-11
SOLUTION MINING OF SALT
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites
Number of Wells
One-Time Costs
Permit Applications
Mechanical Integrity Test
Total One-Time Costs
Annual Recurring Costs
Monitoring
Reporting
Total Annual
Recurring Costs
50 (approximately)
500 (approximately)
$85 to $170
$1,500 to $2,500
$1,585 to $2,670
10
$16
$16
Salt extracted by the practice of solution mining carries
a market value of $120 million per year. During the last few
years, substantial price increases have been passed on to the
consumer to cover rising costs of fuel and other energy-related
expenses. Concentration of producers is significant; 12 compan-
ies account for 88 percent of salt production. UIC compliance
costs are not likely to cause significant hardship for these
major producers.
Solution Mining of Potash
Solution minin
approximately 3,000
is injected into an
which are cased and
and sodium chloride
cemented well; (2)
well which is drill
saturated brine is
g of potash is accomplished at a depth of
feet using either of two methods: (1) w'ater
existing mine cavity through injection wells
cemented to the surface. Potassium chloride
brine are extracted through a cased and
Water is injected through the annulus of a
ed, cased, and cemented to the surface. The
extracted through the inside casing.
One operating field with 18 wells (17 injection and one
extraction) exists in Moata, Utah, and is operated by Texasgulf,
Inc. No contamination of underground drinking water sources has
been reported in the vicinity of that field. That company also
is exploring two pilot sites near the western Canadian border.
ITIBIS
-------
11-28
Utah's Water Pollution Control Act generally protects
"beneficial uses of such waters, surface and underground";
however, a specific program would be required when Utah is
included in the UIC regulatory program.
The economic impact resulting from Utah's inclusion in UIC
enforcement should be modest. A Texasgulf, Inc. staff engineer
estimates that permitting the Moab, Utah site would result in a
one-time cost of $20,000 to $30,000 to cover consultants' fees
for preparing a thorough study of engineering and hydrogeologic
characteristics, maps and cross sections of all underground
sources of drinking water, and anticipated operating data.
Since Texasgulf does not have the available staff to complete
permit applications, professional geologic consultants would be
hired to develop the required data. Mechanical integrity (pres-
sure) test of the injection wells would cost $2,000 to $5,000
per well, for a total cost of approximately $60,000. All known
abandoned wells in the field are thought to be properly com-
pleted and plugged, as that is an operating requirement in
extractive mining if future problems are to be avoided. There-
fore, no cost would be incurred by the operator.
Recurring incremental costs would be encountered due to a
change in monitoring and reporting requirements. Currently,
materials balance is monitored monthly. The requirement for
weekly monitoring and quarterly record-keeping would exceed
available company manpower. Texasgulf estimates that one
additional full-time employee would be needed in the field at
a salary of $20,000 per year (including fringe benefits).
Total incremental costs for potash mining operations under
the UIC regulations would be approximately $54,000 to $105,000
in one-time costs and $20,000 in annual costs. Table 11-12
summarizes these costs.
Potash production in the United States was valued at
approximately $160 million in 1974. Currently, solution mining
at Texasgulf accounts for about 5 percent of total production,
yielding a market value of $8.5 million. During the last few
years, potash production costs have been severely affected by a
general rise in price levels, particularly for fuel, power, and
explosives. Though Texasgulf says that additional increases in
costs could make the mining practice economically infeasible, to
date price rises have been passed on to the consumer without
noticeably affecting demand. However, solution mining of potash
TBS
-------
11-29
Table 11-12
SOLUTION MINING OF POTASH
SUMMARY OF COSTS TO OPERATORS
(thousands of 1977 dollars)
Number of Sites 1
Number of Wells 17
One-Time Costs
Permit Applications $20 to $30
Mechanical Integrity Test $34 to $85
Total One-Time Costs $54 to $115
Annual Recurring Costs
Monitoring and
Reporting $20
Total Annual
Recurring Costs $20
is becoming more difficult due to the reduction in the amount
of reserves and the greater drilling depth required to extract
remaining supplies. The fixed cost component of total oper-
ating costs has been increasing at the same time that reserves
have been decreasing. This could lead to further price pressures
for the industry.
ITIBISI
-------
III. STATE PROGRAM COSTS
INTRODUCTION
The Safe Drinking Water Act of 1974 was passed by Congress
with the intent that states exercise primary enforcement re-
sponsibility for proposed regulations. Consistent with that
intent, proposed UIC regulations place responsibility at the
state level for protection of existing and potential under-
ground sources of drinking water from contamination caused
by underground injection of fluids. Additionally, the regula-
tions are intended to be administratively compatible with
existing state programs while broadening and strengthening
these programs.
The objective of the following analysis is to estimate
the general level of incremental staff required to implement
UIC programs at the state level and to determine for what regu-
latory functions the staff will be needed. The analysis is
presented in terms of manpower, time, and dollar requirements.
The NPDES permit program has provided EPA with a broad
base of experience in industrial permitting. Analyses have
been conducted by EPA to determine the amount of staff time
and related personnel cost associated with this program on a
per permit basis. For a major NPDES permit, for example, ten
man-days were required using a mix ol personnel. These stan-
dards have been used by TBS in the estimates of UIC program
staff requirements and costs.
Several functions specific to the UIC regulations are
required to be performed at the state level. These include:
• Development of a state plan for regulation
and enforcement of the UIC program, and sub-
mission of that plan to the state legislature
and federal EPA administrator
• Submission of semi-annual reports to EPA
administrator during development of the
state plan and prior to receiving approval
of the plan
Review of permit applications, issuance of
permits if approved, and possible public
hearing with respect to UIC permit applica-
tion
TBS
-------
• Collection and
data submitted
III-2
periodic review of reporting
by permittees
Enforcement of the operator requirements of
the DIG regulations, e.g., mechanical integrity
testing, monitoring, corrective action where
necessary, and record-keeping
Submission of quarterly reports to EPA adminis-
trator on the compliance status of Class I
wells within the state
Submission of annual reports to EPA adminis-
trator summarizing regulatory action at the
state level during preceding year.
STATE PROGRAM ELEMENTS
Each of these elements, along with its related manpower
estimate, is discussed in greater detail below. After this
discussion, the manpower estimates are compiled in tabular
form and cost totals are developed.
Development of a State Plan
Most states already have underground injection control
programs which are similar, at least in part, to the proposed
federal UIC standards. For example, states with industrial or
municipal disposal wells have programs regulating these wells,
and states with Frasch sulfur practices have programs regu-
lating these wells. However, control of underground injection
activities is usually divided between two or more state agencies
which may function independently of each other. Moreover, the
extent of regulation of specific practices may vary from permit
control only to extensive control over permitting, monitoring,
and reporting requirements.
Although states have fully staffed agencies administering
existing responsibilities, present estimates are that states
will have to augment their staffs in order to plan and develop
comprehensive UIC regulatory programs. Furthermore, to ensure
adequate public participation in program formulation, these
programs must pass through a period of public hearings and
comment before they can be submitted to the EPA administrator
for approval.
TBS
-------
III-3
Incremental manpower requirements for program development
are expected to range from 8 to 15 work-days of effort per
state for states with no or very few Class I and Class III
practices.^ About 32 states and territories belong in this
"minimal effort" category. The remaining 25 states may need
30 to 80 man-days each to develop suitable UIC programs. The
lower end of this range applies to states with few injection
practices or with existing UIC programs comparable to the
federal UIC regulations; the upper end of the range applies
to states with many injection well practices and/or without
adequate existing programs.
Staff time needed for hearings on the state plan is ex-
pected to vary similarly. States with no or few practices
have been estimated to require an average of five work-days
per state for hearings. The more heavily impacted states are
estimated to devote an average of 25 days per state for hearings,
Submission of Semi-annual Report to EPA
States are required to submit semi-annual reports to EPA
during the time they are developing their state plans. These
reports are designed to provide EPA with information on the
states' progress in formulation of an approvable program for
the regulation of well classes existing within the state. A
typical state is expected to submit one semi-annual report to
EPA during its 270-day period of program development. The
effort is estimated to require approximately five man-days per
state for states with Class I wells and three man-days per state
for states with Class III wells. These estimates are included
in the total staff needs described in Development of State Plan
above.
Review of Permit Applications,
Issuance Permits, and Public Hearings
States granted primacy are responsible for assuring the
EPA administrator that all terms and conditions of an approved
permitting program are carried out. The requirements at the
state level are extensive. They include:
• Determination of the area of review, whether
it is the zone of endangering influence or
an area described by a specific radius
o
This estimate refers to the work-hours needed to develop
a state program for both Class I and Class III wells.
T|B|S|
-------
III-4
• Review of permit applications, each applica-
tion containing detailed maps, plans, test
results, and operating data
• Provision for public hearings, where required,
and preparation of a summary of the Director's
response to any public comments which have been
submitted.
As discussed above, states generally have agencies involved in
the process of permitting new and existing practices. However,
additional and more comprehensive requirements necessitate
augmenting the current staffing levels. The estimate of
incremental time required to review and process permits for
individual operating sites ranges from 5 to 40 days each.
These estimates apply to applications for both existing and
new injection sites.
Since the level of complexity of each application relates
to the type of practice being permitted, the estimates of time
requirement vary by practice. The resulting range of 5 to
40 days per permit represents a low estimate of 5 days for
an existing deep waste-disposal well likely to already have a
permit file, and a high estimate of 40 days for certain Frasch
sulfur fields.
With the permitting of many of these practices, public
hearings will be required according to the provisions of the
regulations. For some practices, hearings will very likely be
needed, while for other less controversial practices they are
less likely. For each hearing required, approximately 20 days
of state staff time have been allocated in these estimates.
Time Requirement Assumptions
As discussed above, each state program function has been
assigned an estimated time requirement range. In most cases,
the range presented above has been developed on a per practice
basis. Tables III-l and III-2 present the ranges estimated
for each practice; first, for processing permit applications,
and, second, for the proportion of permits that would require
a public hearing. The first column of each table also shows
the number of sites in the 57 states and territories where
these practices are known to be operating commercially or as
pilot projects.
TBS
-------
III-5
As the number of deep waste-disposal well practices is
growing rapidly, an additional 100 wells are included in the
count to reflect that expansion over the next five years. As
in the previous analysis, these new wells are assumed to occupy
individual sites. This growth will have an effect on the cal-
culation of costs for different program elements. For one-time
program functions such as permitting of sites, all 405 Class I
sites are used in computation of total five-year cost for that
task. This is because each of the 405 sites will be affected
once and only once during the five-year period by this require-
ment. However, certain recurring program functions, such as
quarterly reviews of operators' reports, will require addition-
al state effort each year as the Class I well population in-
creases from 304 sites in the first year of program operation
to 400 sites in the fifth year. Rather than calculating dif-
ferent yearly costs for these program functions, this analysis
has used an average five-year Class I well population of 357
wells in developing average annual costs for Class I recurring
program functions.
Table III-l
CLASS I WELLS
STATE PROGRAM TIME REQUIREMENT ASSUMPTIONS
Practice
Deep-Waste Disposal
Nuclear Storage and
Waste Disposal
Total Number
of Sites
400
Man-days/Site
for Permitting
5-10
5-10
Proportion of Permits
Requiring Hearings
(percent)
10
50
Table III-2
CLASS III WELLS
STATE PROGRAM TIME REQUIREMENT ASSUMPTIONS
Total
Practice of
Geothermal
In-Site Gasification
Uranium Leaching
Copper Leaching
Frasch Sulfur
Salt Solution Mining
Potash Solution Mining
The number of sites includes
solution mining practices, i
are currently operating.
Number Man-days/Si te
Sitesi for Permitting
3 5-10
3 10-20
21 20-40
5 20-40
10 30-40
50 10-30
Proportion of Permits
Requiring Hearings
(percent)
0
0
50
50
25
15
1 10-30 0
production and pilot operations, and for
t includes permitted sites whether or not they
TBS
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III-6
Collection and Review of
Reporting Data
The regulations require each permittee to submit monitor-
ing data to the state regulatory body on a quarterly basis.
For operators with more than one site under permit, the sub-
mission would be on a site-by-site basis.
The state program requirement is to receive, review, and
file these data when they are submitted on a quarterly basis.
Six man-hours per submission for a Class I site and seven man-
hours per submission for a Class III site have been allocated
to this task, though the time required would be less in many
cases. In at least a few cases, however, state personnel would
need to review data carefully and follow up with permittees to
verify data items. Such reviews could take more than a single
man-day, pulling the average review times up to the six and
seven man-hour figures given above for Class I and Class III
wells, respectively.
Enforcement
States are to have the responsibility of enforcing the
requirements of the UIC regulations. The term "enforcement,"
in this report, refers to state efforts aimed at educating and
working with well operators as well as efforts devoted to de-
tecting infractions and to penalizing operators responsible
for those infractions. The states are expected to offer
educational assistance to well operators, conduct inspection
and surveillance programs, and respond to reports of groundwater
contamination. This study assumes that eight man-days of effort
are required annually for a minimally impacted state, whereas
120 to 240 man-days of effort should be needed annually for
moderately to maximally impacted states.
Submission of Quarterly Reports to EPA
Reports on the compliance status of all Class I wells
within the state must be submitted by the state director to
EPA each quarter. The information required by EPA in these
reports will be an organized summary of the data received by
the state each quarter from the Class I well operators and
will require one man-hour of effort per site for each quar-
terly report submitted to EPA. These reports will provide
the foundation for the annual report to EPA on the status
of Class I wells.
TBS
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III-7
Submission of Annual Reports to EPA
On an annual basis, each state must prepare and submit
a report to EPA summarizing regulatory activities that have
taken place in the state under the program. The report would
contain information on applications for permits received,
permits issued, quarterly reports received, and other regu-
latory action. States minimally impacted by the regulatory
requirements for Class I and Class III wells are estimated to
use three man-days of effort each in preparing these reports
annually. States more heavily impacted could require from
5 to 35 man-days of effort per state for annual report
preparation.
AGGREGATE STATE MANPOWER REQUIREMENTS
Methodology
The manpower estimates presented above must be combined
with further information in order to project a total manpower
requirement for each well class. As may be seen in Table III-3
on the next page, labor estimates for each program element
presently belong to two major categories: site-based estimates
and state-based estimates.
These two categories are used only as a convenient means of
displaying the labor estimates obtained in the course of this
study. They are not meant to imply that program elements shown
with site-based manpower estimates are analogous to "variable"
costs or that program elements shown with state-based manpower
estimates are analogous to "fixed" costs.
"Site-based estimates" refer to labor requirements ex-
pressed as being proportional, albeit roughly, to the number
or type (category of injection practice) of sites involved.
Although well population is not the only factor determining
the total labor requirements for these program elements, it
is perhaps the primary factor.
T|B|S|
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III-8
Table III-3
SITE- AND STATE-BASED LABOR ESTIMATES
Program Element
Site-Based
Permitting
Permit hearings
Quarterly review of monitoring data
Quarterly report to EPA
State-Based
Program development
Program hearings
Enforcement
Annual reports
Manpower Estimate
5-40 man-days/site, depending on
practice
20 man-days/hearingl
(6 man-hours/Class I site per quarter
I 7 man-hours/Class III site per quarter
1 man-hour/Class I site per quarter
8-15 man-days/"minimal effort" state
30-80 man-days/"moderate to maximal
effort" state
(5 man-days/"minimally impacted" state
\25 man-days/"moderate to maximally
(impacted" state
/ 8 man-days/"minimally impacted" state
) per year
|120-240 man-days/"moderately to maximally
impacted" state per year
, 3 man-days/"minimally impacted" state
)per year
15-35 man-days/"mooerately to maximally
impacted" state per year
Number of hearings required estimated from number of sites.
"State-based estimates" refer to labor requirements ex-
pressed as being proportional to the number or type (level of
effort or level of impact expected) of states involved. Well
population is implicitly taken into account, as is the adequacy
of present state regulation of the well classes.
Information on these additional parameters had been sup-
plied earlier, both in the text and tables of this report.
This allows conversion of the labor requirements for important
program elements into more manageable form, i.e., into labor
estimates for each program element for each class of wells, or
for each injection practice. The computational formulas and
component variables may be seen in Table III-4.
TBS
-------
III-9
Table III-4
COMPUTATIONAL FORMULAS AND VARIABLES USED IN
COMPUTING LABOR ESTIMATES FOR PROGRAM ELEMENTS
Cost
Program Element Calculated Class I Wells Class III Wei
Program Development One-time Iq (32 • slpj_ + 25 • slp2) k2 (32 • slpi +• 25
Program Hearings One-time Iq (32 • slh^ + 25 • slh2) kj (32 • slhi + 25
2 9
Permitting One-time Z nc • plc Z "c ' P!c
c=l c=3
2 9
Permit Hearings One-time I nc • PC • hi Z nc • PC • hi
c=l c=3
2 9
Quarterly Reviews Annual £ 4 • nc • mli Z 4 • nc • ml2
c=l c=3
Enforcement Annual ki (32 • el], + 25 • elg) k2 (32 - eli + 25-
2
Quarterly Reports Annual Z 4 • nc • ql n/a
c=l
Annual Report Annual Iq (32 • rl^ + 25 • r!2) kg (32 • rl^ + 25
Iq, kg = relative level of effort required for Class I and Class III well
populations, respectively
sip}, slp2 = state labor required to develop state program plan for minimal
effort states and moderate-to-maximal effort states
slh^, slhj = state labor required to conduct program hearing for minimally and
moderately-to-maximally impacted states
c » category of injection practices (9 categories)
nc = number of sites
plc = labor requirement to permit one site
PC = probability that a public hearing will be required
hi = labor required to conduct a permit hearing
mil, ml2 = monitoring labor required to review each quarterly submission from
well operation for Class I and Class III sites
eH> e^2 = 1 abor requirement for enforcement for minimally and moderately-
to-maximally impacted states
ql = report preparation labor required for each quarterly report to EPA
rl]_, rig = report preparation labor required for annual reports to EPA for
minimally and moderately-to-maximally impacted states
Is
- slP2)
• slh2)
e!2)
• r!2)
|T|B|S
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111-10
Estimates of Manpower Requirements--
Class I Wells
One-Time State Manpower Estimates
As may be seen in Table 1II-5, the largest time require-
ment, 9 to 19 man-years of effort, has been estimated to
arise from issuing permits for existing UIC programs.^ The
second largest amount of effort would be the four to nine man-
years used in developing state plans. Permit hearings require
four man-years and program hearings three man-years. Total
one-time state manpower requirements range from 19 to 34 man-
years of effort.
Table III-5
CLASS I WELLS
ONE-TIME STATE MANPOWER ESTIMATES
Program Element
Program Development
Program Hearings
Permitting
Permit Hearings
Manpower Required
(Man-Years)
3.5-8.5
2.7
9.2-18.5
3.8
19.2-33.5
Recurring State Manpower Estimates
These recurring annual manpower requirements begin once a
state completes its program development and initial permitting
of existing sites. As these tasks will be completed over a
period of five years, the number of sites
year will depend on the rate at which the
new and existing sites. For the purposes
it is assumed that permits will be issued
to be reviewed each
state personnel permit
of this discussion
for all known sites.
Table III-6 shows these costs. Enforcement constitutes
the largest component of the on-going effort with an estimated
12 to 22 man-years of effort expected in each calendar year.
Although this level of effort would range widely among states,
9 This
report assumes 220 man-days per man-year
TBS
-------
III-ll
the average state effort would be between one-quarter and one-
half years. The tasks of reviewing quarterly reports from
operators will require an additional five man-years, while sub-
mittal of quarterly and annual reports to EPA will take from
one and a half to four man-years. Overall, on-going efforts
will require from 18 to 31 man-years of effort or one quarter to
one-half full-time person in an average state.
Table III-6
CLASS I WELLS
ANNUAL RECURRING MANPOWER ESTIMATES
Program Element
Quarterly Reviews
Enforcement
Quarterly Reports
Annual Report
Manpower Required
(Man-Years)
4.9
11.5-22.1
0.8
0.7-3.4
17.9-31.2
Estimates of Manpower Requirements--
Class III Wells
Qne-Time State Manpower Estimates
Again, as may be seen in Table III-7, the largest one-
time cost to the states is in permitting, requiring 6 to 14
man-years. Program development costs and permit hearings
require one to three man-years and two man-years, respectively.
Program hearings will take up to one man-year of effort. Total
one-time manpower requirements for all states range from 10 to
20 man-years.
T|B|S|
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111-12
Table III-7
CLASS III WELLS
ONE-TIME STATE MANPOWER ESTIMATES
Program Element
Program Development
Program Hearings
Permitting
Permit Hearings
Manpower Required
(Man-Years)
1.1-2.8
0.9
6.2-13.8
2.1
10.2-19.6
Recurring State Manpower Estimates
Table III-8 presents the annually recurring costs to the
states for regulation of Class III wells. The greatest annual
cost is in enforcement, needing three to six man-years of ef-
fort. Quarterly reviews of well reports take up to two man-
years, and submission of an annual report to EPA requires 0.3
to one man-year of effort for all states. In all, five to
nine man-years of effort are required annually.
Table III-8
CLASS III WELLS
ANNUAL RECURRING MANPOWER ESTIMATES
Program Element
Quarterly Reviews
Enforcement
Annual Report
Manpower Required
(Man-Years)
1.5
3.3-6.3
0.3-1.0
5.1-S
STATE COSTS FOR MANPOWER REljUIHEMENTS
The state requirements above have all been estimated in
terms of time or manpower needed. To convert these to actual
costs requires an estimate of the weighted average state staff
wage and fringe benefit level. Experience with NPDES permit-
ting has shown that the ratio of technical or supervisory
-------
111-13
personnel to clerical personnel has been about 70/30. Using
this ratio along with recent wage and benefit rates,10 an
estimated cost per man-year of $22,500 has been used in the
NPDES program.
Using this manpower wage estimate, and adding 15 per-
cent to the base salary for direct expenses such as office
supplies and travel, the one-time state costs for Class I wells
would be in the range of $500,000 to $870,000 for the 57 states
and territories. The one-time state costs for Class III wells
range from $264,000 to $509,000. The annual recurring costs for
Class I wells for 57 states and territories fall in the range
of $469,000 to $815,000; the annual recurring costs for Class
III wells range from $131,000 to $230,000. These costs are
presented in Table III-9.
Table III-9
STATE PROGRAM
TOTAL COSTS
(57 states and territories)
(thousands of 1977 dollars)
Class I Wells
One-Time Costs:
Program Development
Program Hearings
Permitting
Permit Hearings
Annual Recurring Costs:
Quarterly Reviews
Enforcement
Quarterly Reports
Annual Reports
Class III Wells
One-Time Costs:
Program Development
Program Hearings
Permitting
Permit Hearings
Annual Recurring Costs:
Quarterly Review
Enforcement
Annual Report
$ 90-220
70
240-480
100
$500-5870
$146
300-575
5
19-94
$470-$820
$ 28-73
22
160-360
54
S264-S509
$ 39
85-165
7-26
$131-$230
10
These estimates were provided to TBS in 1978 by the Office of
Water Enforcement of the EPA.
TIBISI
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PART TWO
ANALYSIS OF COSTS
UNDERGROUND INJECTION CONTROL REGULATIONS
CLASS IV AND CLASS V WELLS
PREPARED FOR:
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER SUPPLY
BY:
TEMPLE, BARKER & SLOANE, INC.
33 HAYDEN AVENUE
LEXINGTON, MASSACHUSETTS 02173
MAY 1979
T|B|S
-------
PREFACE
This report has been submitted to the United States En-
vironmental Protection Agency in partial fulfillment of Con-
tract Number 68-01-4778 by Temple, Barker & Sloane, Inc. (TBS),
33 Hayden Avenue, Lexington, Massachusetts. This is a revision
of a report submitted May 2, 1978, titled Analysis of Costs,
Underground Injection Control Regulations, Subpart F Injection
Well Practices, prepared jointly by Geraghty & Miller, Inc.
and TBS.
This current version incorporates revisions to the UIC
regulations as they appear i.a the reproposed regulations of
April 1979. The most significant change is the redistribu-
tion of Subpart F wells into two categories: Class IV and
Class V wells. Class IV includes wells used by gen.-M-ators of
hazardous wastes or hazardous .vast9 management facilities to
inject into or above underground sources of drinking water.
Class V consists of wells that \verrj no! Included in well
Classes I through IV. This latter class includes, though
is not limited to, wells injecting nonhazardous materials
into or above underground sources of drinking water.
In addition to the classification changes, this report
Incorporates newly collected informat LOM j-u'uered by TBS
during state visits regarding Cl^ss TV veils, alternative
disposal methods and co-;r,s, and the status of state regula-
tory programs.
TBS acknowledges the significant contribution to this
study of Geraghty & Miller, Inc., groundwater hydrology con-
sultants. Tiio report issued jointly in 1978 would have be«n
difficult to produce without their collaboration. In the
process of revising that report to incorporate consideration
for Class IV and Class V wells, Jirn Geraghty provided valu-
able advice and served as a critical reviewer as data were
accuwul -ii,(->.•!.
TBS acknowledges the informed assistance >r roderal,
state, and county regulators, es^i--.; i ally in EPA's Office of
Drinking Water, In Maryland, and in Nassau County, New York,
respectively.
ITIBISI
-------
CONTENTS
PREFACE
LIST OF TAULKS AND FIGURES
INTRODUCTION
Background
Statement of Problem
Scope of Investigation
Major Findings
1-1
1-5
1-5
1-5
II. DESCRIPTION OF PRACTICES
Technical Description
Estimation of the Number of Wells in Use
Potential for Groundwater Pollution
Examples of Groundwater Contamination
by Class IV and Class V Wells
II-2
II-4
11-10
11-16
III. COSTS TO INDUSTRY—CLASS IV WELLS
Introduction
Operator Requirements
Generator Requirements
Methodology
Results
III-l
III-2
III-5
III-7
III-8
IV. INCREMENTAL MANPOWER REQUIREMENTS AND
COSTS TO THE STATES—CLASS IV WELLS
Introduction
Program Elements
Methodology
Results
IV-1
IV-i
IV-5
IV-6
11
TBS
-------
CONTENTS
(continued)
V. GUIDELINES FOR AN ASSESSMENT—CLASS V WELLS
Introduction
Phase I: Data Collection and Review
Phase II: Field Verification
Phase III: Evaluation and Recommendations
Page
V-l
V-3
V-8
V-10
VI. STATE PROGRAM MANPOWER AND COSTS—CLASS V WELLS
Introduction
Staffing
State Costs
VI-1
VI-1
VI-4
BIBLIOGRAPHY
APPENDIX A: Summary of Contacts With State Officials
APPENDIX B: Regulatory History—Well Classes IV and V
111
-------
LIST OF TABLES AND FIGURES
Table l-l
Table 1-2
Table 1-3
Table II-l
Table II-2
Table III-l
Table III-2
Table III-3
Table III-4
Table IV-1
Table IV-2
Table IV-3
Table IV-4
Figure V-l
Table VI-1
Class IV Wells—Total Five-Year
Costs to Industry
Class IV Wells—Total Five-Year Costs
to States
Class V Wells--Total Assessment Costs
to States
Reported Number of Class IV and Class V
Wells in Eight States
Class IV Wells—National Profile
Class IV Wells—Annual Costs of
Treatment and Disposal
Class IV Wells--Chronology of Industry
Tasks and Well Population
Class IV Wells—Unit Costs for Industry
Expenditures
Class IV Wells—Chronology of Industry
Expenditures
Class IV Weils--Estimated State Manpower
Requi rements
Class IV Wells—Chronology of State Tasks
and Well Population
Class IV Wells—Chronology of State
Manpower Requirements
Class IV Wells—Chronology of State
Expenditures
General Structure of the State Assessment
Process
Staffing Requirements for Assessment and
Advisory Report
IV
Page
1-7
1-8
1-9
II-7
11-15
III-6
III-9
111-10
III-ll
IV-5
IV-6
IV-7
IV-8
V-2
VI-2
TBS
-------
LIST OF TABLES AND FIGURES
(continued)
Table VI-2
Table VI-3
Table VI-4
Table VI-5
Aggregate Staffing Requirements for Two
Years of Program Assessment
Costs of Assessment and Advisory Report
(per State)
Assessment and Advisory Report Costs
for 22 Designated UIC States
Assessment and Advisory Report Costs
for 57 States and Territories
Page
VI-3
VI-5
VI-6
VI-6
T|B
s
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I. INTRODUCTION
BACKGROUND
History
Section 1421 of the Safe Drinking Water Act (SDWA, PL
93-523) requires that a federal-state system of regulations
be established to insure that actual and potential underground
sources of drinking water are not endangered by the injection
of contaminants.^ As a result of the SDWA, regulations de-
scribing the State Underground Injection Control (UIC) program
were proposed by the Environmental Protection Agency (EPA) to
establish minimum requirements for effective state programs
(40 CFR Part 146, August 31, 1976).
Initially, three categories of injection wells were in-
cluded in these regulations (Subparts C, D, and E). Later
drafts of the UIC regulations recognized four categories of
injection wells (Subparts C, D, E, and F). These categories
were based on two major considerations: (1) the depth of the
injection well relative to nearby underground sources of drink-
ing water, and (2) the principal function of the well, e.g.,
oil and gas production, waste disposal, or mining and energy
production.
Currently Proposed UIC Regulations
The currently proposed UIC regulations have differentiated
between injection well categories still further. The Preamble
to the reproposed regulations (40 CFR Part 146, April 20, 1979)
gives definitions for these new classes:
EPA's proposed definition (in 40 CFR Part 146, April 20, 1979)
of "underground sources of drinking water" includes all aqui-
fers, or their portions, which are presently providing drinking
water and, "as a general rule, all aquifers or their portions
with fewer than 10,000 ppm/TDS." States are allowed to exclude
portions of aquifers which are not "in a real sense" potential
drinking water sources. In this report, the term "freshwater
aquifer" is used as a synonym for "underground sources of
drinking water" as defined by the regulations.
IrBlsl
-------
1-2
• "Class I includes industrial and municipal
disposal wells and nuclear storage and dis-
posal wells that inject below all underground
sources of drinking water.
• "Class II includes all injection wells as-
sociated with oil and gas storage and
production.
• "Class III includes all special process in-
jection wells, for example, those involved
in the solution mining of minerals, in situ
gasification of oil shale, coal, etc., and
the recovery of geothermal energy.
• "Class IV includes wells used by generators
of hazardous wastes or hazardous waste man-
agement facilities to inject into or above
underground sources of drinking water.
• "Class V includes all other injection wells."^
The major change from earlier draft versions has been the
decision to redistribute the well practices injecting into or
above underground sources of drinking water among well Classes
IV and V. These two classes pose different degrees of threat
to human health and the environment and are, therefore, to be
regulated separately. However, as both classes of wells are
thought to be of serious concern, they have required additional
attention and are the subject of this report.^
o
Subpart F of 40 CFR Part 146 describes Class V in more detail,
stating that this class "includes but is not limited to the
following types of injection wells: waste disposal wells,
such as dry wells, non-residential septic system wells, and
sand backfill wells; and recharge wells, such as drainage
wells, cooling water return flow wells, air conditioning
return flow wells, salt water barrier wells and subsidence
control wells (not associated with oil and gas production)."
3
In 1978, Temple, Barker & Sloane, Inc. (TBS) assisted EPA
in the evaluation of several possible regulatory approaches
for the wells covered by the then Subpart F. This earlier
study has been updated and included as Appendix B in the
present report for two purposes: (1) to provide historical
perspective on the problem of regulating wells injecting into
or above underground sources of drinking water, and (2) to
explain the reasoning underlying the structure of the cur-
rently proposed UIC regulations.
-------
1-3
The states are required to develop state programs to
administer and enforce the minimum requirements and standards
of the federal UIC regulations. In addition to developing
procedures and plans for implementation of general UIC program
requirements, the states must develop programs for each class
of wells present in their state. States are also required to
adopt rules to regulate well practices that do not presently
exist in that state in order to guard against the possibility
of unregulated future injection.
The minimum requirements for an acceptable state program
regulating Class IV wells are as follows:
• Inventory of Class IV wells
• Formulation of an enforcement strategy that
will result in the closure of Class IV wells
within three years of the effective date of
the UIC program
• Ban on new Class IV wells
• Review of quarterly reports submitted by
Class IV well operators
• Submission of quarterly and annual reports
to EPA
• Periodic inspection and surveillance
procedures
• Adequate enforcement penalties.
For Class V wells, the states are given two years after
the effective date of the UIC program in which to complete
and submit to EPA:
• An assessment of the contamination potential
of Class V wells
• An assessment of the regulatory alternatives
for these wells
• Recommendations for federal regulatory action.
Furthermore, the states are required to take immediate action
on Class V injection practices that pose a significant risk to
human health. After receiving and evaluating reports from the
states, EPA will promulgate further national requirements for
the regulation of Class V wells.
TIBISI
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1-4
Operators of Class IV wells are also subject to minimum
UIC requirements as soon as a state program becomes effective.
Specifically, operators must:
• Notify the program director of their
existence and the endangerment potential
of their operations
• Periodically monitor injection well
parameters and groundwater quality
• Submit quarterly reports to the program
director on the results of monitoring
• Close wells when scheduled to do so by the
program director.
Generators no longer using Class IV wells as their means of dis-
posal must, under the Resource Conservation and Recovery Act
(RCRA), dispose of future hazardous wastes in an approved haz-
ardous waste management facility and participate in the RCRA
manifest tracking system if disposing of over 100 kilograms of
hazardous waste off-site.
Soon after the effective date of a UIC program, operators
of Class V wells must submit the following to the state program
director:
• Notification of the existence of Class V wells
• Construction features of the well
• Nature and volume of injected fluids
• Alternative means of disposal available
to the operator
• Environmental and economic consequences
of well disposal and its alternatives.
EPA has also decided to consolidate the regulations for
its major permit programs. These regulations are to be pub-
lished in the near future as revisions to 40 CFR Parts 122,
123, and 124, which currently refer to the Clean Water Act's
NPDES regulations. The major permit programs included in this
undertaking are: the UIC program under the Safe Drinking Water
Act (SDWA); the NPDES regulations of the Clean Water Act; and
the hazardous waste management program under RCRA.
T|B
s
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1-5
STATEMENT OF PROBLEM
Little information is readily available on the number of
wells injecting into or above underground sources of drinking
water. These well practices are generally associated with
smaller industrial, commercial, and municipal facilities. Many
of these practices are thought to be widespread, such as the
injection of wastes into non-residential septic systems, multi-
family septic systems, dry wells, and the injection of storm-
water runoff into drainage and recharge wells. Others are used
only in a few scattered locations, as in the case of injection
wells installed to control land subsidence. All of these wells
have a potential for contaminating underground sources of drink-
ing water. This threat of contamination is real, and its con-
sequences significant, because groundwater is used for drinking
water by more than half the population of the United States.
SCOPE OF INVESTIGATION
The purpose of this investigation was threefold: (1) to
describe selected Class IV and V injection well practices, to
determine the number of these wells, and to estimate the volume
of fluid injected by these wells into or above underground
sources of drinking water; (2) to assist EPA in its determina-
tion of methods of regulating these practices; and (3) to
estimate the costs of regulation to both industry and the
states for these two well classes.
Most of this investigation was conducted in a five-month
period during the fall and winter of 1977-1978. Information
was obtained through a literature survey, telephone interviews
with federal, state, and local officials and industry repre-
sentatives, a mail survey, and visits to state and local offices
In all, 22 states were contacted and visits were made to 14 of
these states.
A second investigation was carried out in the winter of
1979. Its purpose was to improve on the earlier estimates
of Class IV well population and unit costs of disposal al-
ternatives .
MAJOR FINDINGS
The major findings and conclusions of this investigation
cover four areas: well population, well injection volume, in-
dustry costs, and state costs.
TBS
-------
1-6
Well Population
Class IV and V wells exist in large numbers.
Eight states with the most complete data
reported approximately 60,000 of these wells,
and these states appear to be somewhat
representative of the rest of the country.
Based on the limited information available, a
most likely national estimate for Class IV well
population is 7,500 wells. The probable well
population is estimated to range from 5,000 to
10,000 wells.
A national estimate for Class V wells, proje<;1 '•
-------
1-7
• On a nationwide basis, Class V wells' injection
volumes may rxc.»-<•- 30 billion gallons yearly.
Industry Costs
Total five-year costs to Industry resulting from
the proposed Class IV well re^ul itions are esti-
mated to be $120 million (in 1977 dollars) for a
Class IV well population of 7,500 wells.4 Total
costs could range from $80 million to $160 million,
based on well population range estimates of 5,000
to 10,000 wells. Using a well population estimate
of 7,500 wells, the five-year costs for each of the
various program tasks are shown in Table 1-1.
Table 1-1
CLASS IV WELLS
TOTAL FIVE-YEAR COSTS TO INDUSTRY
(thousands of 1977 dollars)
Program Element
One-Time
Notification
Total Five-Year One-Time Costs
Recurring
Monitoring
Quarterly Reports
Alternative Disposal
Manifests
Total Five-Year Recurring Costs
Total Five-Year Cost to Industry
Total Five-Year Cost
$ 1,100
$13,800
1,700
99,000
4,700
$ 1,100
$119,200
$120,300
Costs to industry have not been developed for'
Class V wells because the proposed regulations
currently require only an assessment,"conducted
by the state. Costs to individual operators
Industry costs have been shown as five-year c,-(^t i to illus-
trate the continuing effects of the UIC (and subsequently,
RCRA) regulations on Class IV well operators and on hazardous
waste generators using these wells.
TlBlSl
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1-8
are expected to be nominal, based on the use of
simplified registration procedures. Estimates
of costs to the operators will be developed when
a national regulatory strategy for Class V wells
has been proposed.
State Costs
Total program costs to the 57 states and ter-
ritories for the proposed Class IV well reg-
ulations are estimated to be $2.9 million, in
1977 dollars.5 Total program costs could
range from $2.2 million to $4.2 million, de-
pending on well population. Assuming a well
population of 7,500 wells, the total costs
for each of the program elements are shown
in Table 1-2.
Table 1-2
CLASS IV WELLS
TOTAL FIVE-YEAR COSTS TO STATES
(thousands of 1977 dollars)
Program Element
One-Time
Program Development
Program Hearings
Seni-annual Report
Well Authorization
Total Five-Year One-Time Cost
Recurring
Quarterly Reviews
Quarterly Reports
Annual Report
Enforcement Visits
Total Five-Year
Recurring Costs
Total Five-Year
Program Cost to States
Total Cost
101
34
34
220
$ 389
5 662
264
264
1,322
$2,512
$2,901
For purposes of consistency throughout the report, total costs
to industry and states are reported as five-year costs. Three
years is the allowable lifetime for Class IV state regulatory
programs, and costs for years four and five would be zero.
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1-9
Total assessment costs to the 57 states and
territories for the proposed Class V regula-
tions are estimated to range from $5.2 million
to $7.2 million.6 The range of one-time costs
for each of the three program phases is shown
in Table 1-3.
Table 1-3
CLASS V WELLS
TOTAL ASSESSMENT COSTS TO STATES
(thousands of 1977 dollars)
Program Element Total Cost
Phase I: Data Collection
and Review « $1,600-$2,220
Phase II: Field Verification 1,600- 2,220
Phase III: Evaluation and
Recommendations 1,980- 2,730
Total Assessment Cost to States $5,180-57,170
6
'Two years is the specified lifetime for the Class V assess-
ment process. Costs for state responsibilities beyond the
second year have not been estimated, as the requirements have
not yet been determined. For this analysis, costs for the
three years following the assessment have been omitted, but
there are expected to be additional regulatory costs to the
states in the future.
TIBIS
-------
II. DESCRIPTION OF PRACTICES
EPA broadly defines well injection to mean the "subsurface
emplacement of fluids through a bored, drilled, or driven well;
or through a dug well where the depth is greater than the largest
surface dimension and a principal function of the well is the
subsurface emplacement of fluids."? Moreover, the regulations
specify that Class IV includes "wells used by generators of haz-
ardous wastes or hazardous waste management facilities to inject
into or above underground sources of drinking water." Class V
consists of all injection well practices not included in Classes
I through IV.8
These general definitions denote the most important char-
acteristics of the terms "well injection," "Class IV," and
"Class V." More specifically, Class IV and V injection wells
can be grouped into two broad categories, disposal wells and
recharge wells, based on the principal purpose for which the
wells are installed. Disposal wells are those wells that
directly or indirectly inject wastes and include, but are not
limited to, cesspools, conventional cased wells, dry wells,
sand backfill wells, and septic system wells. Recharge wells
are those wells that are used primarily for replenishing aqui-
fers and include, but are not limited to, air conditioning
return flow wells, conventional recharge wells, cooling water
return flow wells, drainage wells, saltwater barrier wells, and
subsidence control wells not associated with oil and gas extrac-
tion. Generally speaking, Class IV wells belong to the category
of disposal wells, while Class V wells span both the disposal
and recharge well categories.
8
State Underground Injection Control Program, Proposed Regu-
lations, Federal Register, vol. 44, no. 78, April 20, 1979,
p. 23738.
To repeat, Class I includes "industrial and municipal disposal
wells and nuclear storage and disposal wells that inject below
all underground sources of drinking water in the area." Class
II includes "all injection wells associated with oil and gas
storage and production." Class III includes "all special pro-
cess injection wells, for example, those involved in the solu-
tion mining of minerals, in situ gasification of oil shale,
coal, etc., and the recovery of geothermal energy." Class IV
includes wells "used by generators of hazardous wastes or
hazardous waste management facilities to inject into or above
underground sources of drinking water." Ibid., p. 23740.
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II-2
Most of the injection wells discussed in this report are
widely used throughout the nation and in practically every state,
Commonly, as in the case of injection wells such as cesspools
and septic system wells, the operators believe that these prac-
tices represent the best technological means of disposal of
fluids. Furthermore, the operators are largely unaware that
EPA is now looking upon these practices as threats to the pota-
bility of underground sources of drinking water. Also, in many
instances, specifications and controls for these injection wells
are prescribed in building codes or in the regulations of health
departments because the wells are considered to be acceptable
means of waste disposal.
Few of the types of injection wells covered by this report
have ever been inventoried or assessed as to their contamina-
tion potential. Moreover, it is neither possible in the time
presently available to determine actual counts of each category
of injection well nor to determine actual volumes and toxicities
of the fluids being emplaced through the wells. In this report,
the quantitative estimates presented rely heavily on the infor-
mation from the few states with significant well data.
TECHNICAL DESCRIPTION
There is a lack of common terminology to describe these
wells. For example, a well that is accepting raw sewage might
be described as a drainage well by its owner in Florida, where-
as in other states it might be classified as a disposal well.
Different geologic environments also may require different
types of disposal wells. In the areas of lava terraces in the
Columbia River Plateau area of Idaho and Oregon, for example,
low permeability of the surficial geologic materials makes it
necessary to employ an unusual combination of a septic tank and
a shallow injection well for disposal of sanitary sewage. In
Long Island, New York, the high permeability of the surficial
soil deposits allows unlined sumps to be used to dispose of
storm runoff; in other places, storm water might be injected
through what is called a drainage well. The following sections
give expanded definitions of the well practices discussed in
this report.
Disposal Wells
These wells are used for the injection of wastes, and
depending on the type of waste discharged into the well, each
of the well practices described below may have facilities in-
cluded in well Classes IV or V.
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II-3
A cesspool typically consists of a concrete cylinder about
five feet in diameter with perforated sides and an open bottom.
It is buried at least several feet below ground surface. Waste
water commonly is discharged directly to the cesspool, and there
may be poor settling of solids before the effluent seeps into
the surrounding soil. (Single-family domestic cesspools will
not be regulated under these reproposed regulations.)
A conventional cased well is a vertical hole lined with a
casing and designed for the sole purpose of injecting fluids.
These wells are generally used for disposal of small volumes
of wastes that cannot be disposed of to a municipal sanitary-
sewage treatment system or where the only available treatment
facility is too far from the site of waste generation. These
wastes are injected under gravity flow or under pressure into
a permeable zone.
A dry well is used for the injection of wastes into the
unsaturated zone above an underground source of drinking water.
These wells are designed to transmit untreated wastes into a
permeable zone. In areas underlain by sand, dry wells are
typically filled with gravel to control discharge and maintain
the side walls.
A sand backfill well is used to inject a slurry, composed
of a mixture of water and mine-refuse materials, to control land
subsidence. The slurry can be injected under gravity or under
pressure into numerous closely-spaced bore-holes or conventional
cased wells.
A septic system well is used to inject the effluent from a
septic tank that receives and treats sewage from a multi-family
residence or from a commercial or industrial establishment,
whether or not a conventional drainfield or cesspool is used.
In addition to the biological process of anaerobic decomposition,
physical settling of solids occurs in a septic tank. Effluent
from the septic tank is discharged to a permeable zone through
a leach field, trench bed, or shallow well. (Single-family sep-
tic system wells will not be regulated under these reproposed
regulations.)
Recharge Wells
These wells are used for the injection of water to replen-
ish an aquifer. It is expected that, except for a few special
cases, all facilities belonging to this category will be in-
cluded in Class V.
TIBISI
-------
II-4
An air conditioning return flow well is used to inject
water that is circulated through an air-conditioning system.
A conventional recharge well is used to inject water into
an underground source of drinking water to augment natural in-
filtration or to increase the volume of water that is naturally
in storage in an aquifer that is an underground source of drink-
ing water.
A cooling water return flow well is used to inject water
that has been used in an industrial or commercial cooling system.
A drainage well is used to inject urban, agricultural, or
highway runoff, or excess ponded surface water.
A saltwater barrier well is used to inject water into an
aquifer to prevent or retard intrusion of salty groundwater.
A groundwater mound is established by the injection of fresh-
water through a series of wells located along the saltwater
interface. The freshwater mound inhibits the lateral encroach-
ment of salty groundwater.
A subsidence control well is used to inject water into an
aquifer that is a non-oil and gas producing zone to reduce or
eliminate land subsidence in an area of excessive pumping of
groundwater. Compaction of the underground reservoir and sub-
sidence of the land surface may result from the removal of
groundwater. The reintroduction of water to fill voids and
provide buoyancy to the aquifer materials can arrest subsidence
and may even cause a surficial rebound of the land surface.
ESTIMATION OF THE NUMBER OF WELLS IN USE
As part of this investigation, estimates were made of
the number of disposal wells and recharge wells in use and
covered by well Classes IV and V. This effort represents
perhaps the first attempt at making an estimate for more than
a single state of the number of such wells that inject fluids
into or above underground sources of drinking water. In most
states, these wells have not been inventoried, and there is
some uncertainty in regard to the identification and existence
of these facilities, owing to the lack of common definition
of the various injection well categories. Moreover, it is
difficult to distinguish between some of the well practices
solely on the basis of use and construction of the wells.
-------
II-5
For convenience in estimating numbers, the injection wells
were first grouped into the two broad categories, disposal wells
and recharge wells, in order to separate wells receiving con-
sistently poor quality water from those receiving water of a
generally better quality. The wells were grouped, therefore,
according to the purpose of the well and, to some extent, ac-
cording to the expected quality of the injected fluid. This
distinction is difficult to define sharply, however, because
most of these wells are capable of accepting fluids of all qual-
ities. For example, many of the recharge wells are drainage
wells receiving urban or agricultural storm-water runoff. The
fluids entering those wells are typically of very poor quality
during the "first flush"9 and then of relatively good quality.
Also, some air conditioning return flow wells in Oregon typi-
cally transmit water of relatively good quality, but these wells
may also receive some sanitary sewage intermittently. Further
investigation was conducted to estimate total well populations
for Classes IV and V. More recently, the study was extended to
develop a better estimate of the number of wells in Class IV.
Due to a lack of data, the present analysis of injection
wells only partly examines the issues related to the volumes
injected by each of the various well categories. Several states
have made preliminary estimates of the number of injection wells
in some well categories. However, the studies by the states did
not place much emphasis on the volume and toxicity of injected
fluids. Preliminary estimates of volumes have been made during
this study, but only to assess the general magnitude of the
problem and to compare the contamination threat with that posed
by injection wells covered under the other Classes of the UIC
regulations.
Methodology
Information for the estimate of disposal wells and recharge
wells was obtained primarily through: (1) a literature survey;
(2) telephone interviews; (3) a mail survey; and (4) visits to
state and county offices.
In performing the literature survey, the EPA library was
used to obtain relevant publications, as were the consultants'
libraries and technical files. Major sources are included in
the bibliography at the end of this report.
The significance of "first flush" was decribed in Character-
ization and Treatment of Urban Land Runoff, Chapt<
670/2-74-096, December,1974~
;er VI, EPA-
TIBISI
-------
II-6
Officials with various federal, state, and county agencies
were contacted, including the U.S. Environmental Protection
Agency, U.S. Geological Survey, U.S. Bureau of Census, state
departments of environmental protection and of natural resources,
state and county departments of health, and state oil and gas
conservation boards. In all, 22 states were contacted--14 states
through personal visits and the remaining 8 by telephone. Per-
sonal and telephone contacts were also made with trade and indus-
trial associations that might be concerned with Class IV and V
well practices. These included the Metal Finishers Foundation,
the American Mining Congress, the American Water Works Associ-
ation, the American Petroleum Institute, and the Manufacturing
Chemists Association.
Most of the states that were contacted in the telephone
interviews also received a mail survey and a copy of relevant
Subparts of the September 23, 1977, draft of the proposed UIC
regulations. The response to the mail survey was generally
favorable.
Fourteen states (Arkansas, California, Colorado, Florida,
Illinois, Indiana, Kansas, Maryland, Mississippi, New York,
Ohio, Pennsylvania, Texas, and Washington) were visited by the
consultants. These visits generally included personal inter-
views with state officials in several agencies as well as col-
lection of relevant state regulations, case study materials,
and available permit information.
Findings—Disposal and Recharge Wells
The states varied substantially in the amount of informa-
tion which they possessed regarding the wells covered by Classes
IV and V. A few had actually conducted inventories of wells in
selected categories, such as air conditioning return flow wells,
cesspools, or conventional cased disposal wells. Many state
officials who lacked formal inventories did offer other esti-
mates for selected well categories. Still other states either
had no data or, in some cases, believed that none of these wells
exists in their states. A detailed summary of the responses of
each of the states is presented in Appendix A.
In three states reporting Class IV and Class V disposal
wells and recharge wells, 10,000 or more wells per state were
reported. These estimates, which were 13,000 for California,
12,000 for Pennsylvania, and 10,000 for Florida, represent the
best professional judgment of state officials and the results
of the literature and mail surveys. In several other states,
estimates for wells were determined for only certain categories
T|B|S|
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II-7
or certain parts of a state. These states and the respective
estimated well numbers are: Maryland, 3,000; Idaho, 5,000;
Oregon, 7,000; Ohio, 5,000; and Kansas, 5,000.
States that estimated they had only a few wells injecting
into or above freshwater aquifers and that could not supply
numbers included: Arkansas, Louisiana, Mississippi, and
Oklahoma. In Arkansas and Mississippi, cesspools and septic
tanks were cited by state officials as a cause of groundwater
pollution. However, most cesspools in those states are gener-
ally used by private residences, and the UIC regulations do not
include control of private residence septic systems and cess-
pools.
About 60,000 disposal wells and recharge wells were re-
ported in the eight states that had the most complete data.
About two-thirds of these wells are in the disposal well cate-
gory, and about one-third are in the recharge well category
(see Table II-l). Even these data are incomplete, as noted
earlier, because most states did not have data on all types of
Class IV and V wells, and, in some cases, the reported data
do not represent all counties within the state.
i Table II-l
!
REPORTED NUMBER OF CLASS IV AND CLASS V
! WELLS IN EIGHT STATES1
| Type of Vlel Is Number of Wells?
|Disposal Wells:
:• Non-Residential Cesspools,
Dry Wells, and Septic-System Wells 25,000
i
t Conventional-Cased Wells 15,000
i
i Recharge Wells:
j
1 • Drainage Wells 15,000
]
i* Other Recharge Wells 5,000
Total 60,000
; The states included are California, Florida, Idano,
Kansas, Maryland, Ohio, Oregon ana Pennsylvania.
The reported figures are incomplete counts of the wells
in these states, but they do represent the -information
currently available to state officials. For most states,
these figures represent three or fewer of the four cat-
egories listed. For some states, the estimate 1oes not
represent all counties.
Source: State and local officials. See Appendix A
for details.
TBS
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II-8
The national implications are significant, even though the
data are incomplete. First, even the 60,000 reported wells
constitute a widespread practice and, as will be shown later,
account for a significant volume of contamination entering the
nation's underground drinking water sources.
Second, when these wells are studied more carefully, there
will undoubtedly be many more than the 60,000 already identi-
fied. Even in the eight states, the total number should be
higher because other categories will be identified, full geo-
graphic coverage will be attained, and the estimates presented
above are only conservative minimum estimates provided by the
states. It is likely that the final number in these states will
exceed 60,000 by a wide margin.
Finally, the other 42 states and the federal territories
which are covered by these regulations are also expected to
identify significant numbers of Class IV and Class V wells. In
this connection, it is believed that the eight states may be a
fairly representative sample of the 50 states with respect to
injection well practices endangering freshwater aquifers for
the following reasons:
• These eight states account for a significant
share of the population and business establish-
ments in the country. Since the well practices
studied here are considered to be related to
both population and business activity, these
states constitute a significant sample. In
combination, they account for 28 percent of
the country's population and 30 percent of
the manufacturing and service establishments.
• These states contain an average, or slightly
lower than average, percentage of population
and business establishments which are not served
by sewer systems. Since the use of wells inject-
ing into or above underground sources of drinking
water is thought to be most prominent in unsew-
ered areas, these states should present a typi-
cal or even slightly low estimation of the na-
tional incidence of these wells. According to
EPA statistics, 22 percent of the 1975 popula-
tion of these eight states were not served by
sewer systems, while the national figure was 27
percent for all 50 states. The range in these
eight states was from a low of 10 percent in
Ohio to a high of 46 percent in Idaho. The
-------
II-9
other 42 states account for just over three-
quarters of the national population which was
not served by sewers in 1975.
• In terms of hydrogeology, these states make up
a sample of the major physical characteristics
which determine the suitability of an area for
such wells and the availability or lack of alter-
native means of disposal. These states repre-
sent all 10 of the groundwater regions in the
United States, as described by H. E. Thomas.10
As a group, these states are neither the most
nor the least conducive areas for such wells
and, except for approximately 10 mountain
states which are geologically not favorable
for such wells, constitute a fairly represen-
tative sample of the country.
Findings—Class IV Wells
There exist considerable variations among state inventories
of Class IV wells. Generally, more extensive information is
available in states that issue permits for the practice than in
states where the practice is not allowed. The few states that
do regulate Class IV well practices generally do so under the
authority of environmental protection programs such as the NPDES
program. Even states that issue permits for Class IV wells, how-
ever, do not consider their estimates highly reliable. Depend-
ing on local hydrogeologic conditions, the use of illegal wells
can be extensive and difficult to detect. In addition, Class IV
wells do not usually constitute a separate category in state
inventories of disposal permits. Rather, these wells are incor-
porated with other forms of groundwater discharge such as leach-
ing fields, and hazardous and nonhazardous wastes are not
differentiated.
It is even more difficult to identify the extent of the
practice in states that do not issue permits for Class IV wells.
Such wells are usually identified only in response to specific
complaints of groundwater contamination. Thus, it is difficult
to project the number of Class IV wells on the basis of partic-
ular complaints.
Thomas, H. E. , The Conservation of Ground Water, McGraw-Hill
Book Co., Inc., New York: 1951.
JTlBlsl
-------
11-10
A preliminary total estimate of 5,000 to 10,000 Class IV
wells, with a midpoint estimate of 7,500 wells, has been de-
veloped by projecting national estimates from more localized
areas of the country that have relatively extensive information
concerning the practice. These figures account for both esti-
mates by officials in these areas of the number of existing
Class IV wells which are not included in their inventories and
for the results of extensive field work in Nassau County, New
York. Until more extensive state survey data become available,
however, more precise estimates cannot be developed. This
midpoint figure, 7,500 wells, will be used in developing the
total cost estimates for industry and state impacts.
Findings—Class V Wells
Class V wells far outnumber Class IV wells. An estimate
can be developed based on data from the eight states cited
earlier which provided the most detailed information on Class
IV and V practices. These states are: California, Florida,
Idaho, Kansas, Maryland, Ohio, Oregon, and Pennsylvania. The
estimate must be based on three factors: (1) these eight
states' share of the nation's population and business establish-
ments (28 percent and 30 percent, respectively); (2) the rela-
tive degree of population without sewer service considered
more likely to utilize these forms of disposal (22 percent for
the eight states versus 27 percent nationally); and (3) the
eight state estimate of the present number of Class IV and V
wells (60,000). Combining these factors, and allowing for
5,000 to 10,000 Class IV wells nationally as estimated above,
yields an estimate of over 250,000 Class V wells nationwide.
This estimate will be refined after the assessment programs
are conducted by the states.
POTENTIAL FOR GROUNDWATER POLLUTION
Determination of Pollution Potential
The quality of injected fluid can vary from poor quality
wastewater injected by municipal, commercial, and industrial
dischargers by means of disposal wells, to good quality water
used in some recharge wells. The volume and toxicity of the
injected fluid, along with the proximity to underground sources
of drinking water, and the permeability of an aquifer, are among
the principal factors that determine the groundwater pollution
potential of the well practices. The limited capacity of the
TIBISI
-------
11-11
aquifer to attenuate the injected fluid by adsorption and dilu-
tion of the fluid by mixing are also important factors. Since
the great majority of the injection wells in Classes IV and V
inject into or above underground sources of drinking water,
these two Classes pose a significant threat to groundwater
quality.
Disposal wells generally inject waste fluids of a poorer
quality than the fluid in the receiving aquifer. For example,
these wells are used to inject raw, primary, and secondary sew-
age, industrial wastes, extremely acidic and alkaline wastes,
floor washings, spent soaps, synthetic detergents, bleaches,
and dirt and grease. The pollution potential is great because
these wastes may contain large amounts of putrescible organic
matter, nitrates, chlorides, pathogenic bacteria and viruses,
and toxic heavy metals.
Drainage wells inject fluids of highly variable quality
into underground sources of drinking water. For example, urban
storm water varies in composition, and sometimes contains organ-
ic and toxic materials such as heavy metals. Agricultural run-
off generally has a high content of organic chemicals resulting
from the use of fertilizers. Air conditioning and cooling water
return flow wells inject heated water that can raise the temper-
ature of the ambient groundwater. Also, such water may contain
rust inhibitors that can cause contamination of groundwater.
Saltwater barrier wells and subsidence control wells inject
fluids that may be of marginal or unusable quality. Fluids in-
jected through recharge wells may contain suspended solids,
organics, toxic metals, oil and grease, road de-icing salts,
pathogenic bacteria and viruses, and fertilizers. Therefore,
the groundwater pollution potential is high.
Class IV wells present the greatest pollution threat to
underground sources of drinking water, on a per well basis.
This fact is implicit in the definition of "hazardous waste"
that is used to distinguish Class IV wells from Class V wells.
This definition is given in Section 1004(5) of RCRA:11
"The term 'hazardous waste' means a solid waste, or combi-
nation of solid wastes, which because of its quantity, concentra-
tion, or physical, chemical or infectious characteristics may--
CD cause, or significantly contribute to an increase
in mortality or an increase in serious irrevers-
ible, or incapacitating reversible, illness; or
11 P.L. 94-580, 42 USC 6903.
ITIBIS
-------
11-12
(2) pose a substantial present or potential hazard
to human health or the environment when improper-
ly treated, stored, transported, or disposed of,
or otherwise managed."
The range of materials covered by this definition includes the
primary contaminants of the Safe Drinking Water Act, toxic heavy
metals, pesticides, organic chemicals, bacterial and viral
pathogens, and similar wastes.
Class V wells present an as-yet-undetermined degree of
hazard to health and the environment. These wells account for
the majority of wells listed as disposal wells, and for nearly
all of the recharge wells. Wastewater quality can be extremely
variable, both between wells and for the same well at different
points in time. Therefore, some Class V wells may present a
minimal threat to groundwater quality while others, after in-
vestigation, may be found to present a significant threat to
groundwater quality. Further research is needed to develop an
extended and intensive study of these wells' capacity for ground-
water pollution.
Patterns of Contamination
Class IV and Class V injection wells are sources of contam-
ination from which plumes of contaminated water extend down-
gradient for tens of feet to thousands of feet. Plumes of con-
taminated water emanating from seepage from dry wells or from
wells that penetrate the upper part of the water table aquifer
for a few feet generally lie at or just below the water table.
In contrast, injection wells with long open sections that pen-
etrate a large part of a shallow aquifer may result in the de-
velopment of plumes that occupy almost the full thickness of
the aquifer at and near the wells.
Plumes of wastes from injection wells can contaminate
water-supply wells that are along the line of flow and down-
gradient from the injection well. In addition, small plumes
from numerous individual injection wells can merge downgradient
and create an areally extensive body of contaminated ground-
water. Finally, contaminated water from shallow injection wells
in recharge areas may move vertically downward into underlying
artesian aquifers and, ultimately, cause contamination of deep
public-supply wells.
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11-13
Hydrogeologic Factors
Class IV and Class V injection wells are commonly used in
hydrogeologic settings characterized by a shallow zone with good
infiltration characteristics such as beds of permeable sand and
gravel. Another favorable characteristic for these injection
wells is a moderate depth to the water table (25 feet to 50 feet
or more), which helps prevent a quick rise of the water table
during injection and possible flooding at the land surface.
Deposits of sand and gravel and cavernous rocks, such as lime-
stone, or rocks, such as lava, with large bedding plane and
other openings, are generally suitable for construction of
shallow injection wells. In contrast, rocks of low permeabil-
ity, such as granite, gneiss, and schist, and sediments, such
as silt and clay, are generally of little or no use as sites
for construction of shallow injection wells.
Relative Volumes of Contamination
Very little information on the volumes of liquids injected
from Class IV and Class V disposal and recharge wells is avail-
able from the literature or from state officials contacted dur-
ing this study. Volumes for individual cases can be identified,
and judgmental estimates are sometimes offered by local and state
officials, but almost no statistically supportable data exist.
Accordingly, conservative estimates were developed for the
purpose of determining how significant a contamination threat
is posed by the wells injecting into or above freshwater aqui-
fers in comparison with the threat posed by the other practices
covered by the UIC regulations.
The major conclusions arising from this investigation are
as follows:
• The volume of fluids actually entering the
nation's drinking water aquifers is greater for
the wells included in Class V than it is for all
the wells covered under Classes I, II, and III
combined; however, the fluids injected by Class
V wells are generally of a higher water quality
than that injected by other well classes.
• Class IV wells are estimated to inject 660 mil-
lion gallons to 1.7 billion gallons of hazardous
wastes annually into or above strata containing
underground aquifers
ITIBIS
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11-14
• An exact estimate for the volume injected
through Class V wells cannot be made; however,
the data from the eight states suggests that
recharge volumes alone may exceed 30 billion
gallons annually and that disposal into other
Class V wells would increase that number.
These conclusions are discussed more fully below.
A minimum estimate of total annual volume discharged from
or above freshwater aquifers was developed. In only the eight
states that provided the best data on disposal and recharge
wells and using a conservatively low assumption of 1,000 gal-
lons per week for estimating average daily volumes discharged,
these wells are estimated to discharge nine billion gallons or
more per year directly or indirectly into underground sources
of drinking water. The actual volume could be greater in these
states if less conservative assumptions for average daily vol-
umes are used, and several times higher if extrapolated for
the whole country.
In contrast, the estimate for the total volume of fluid
leakage and migration into underground sources of drinking
water from deep waste-disposal wells (Class I), oil and gas
injection wells (Class II), and mining and related wells
(Class III) is lower. Information on annual total injection
volumes for wells in Classes I, II, and III were obtained from
recent EPA reports.12 Together, the wells in these categories
are estimated to inject approximately 850 billion gallons of
fluids annually. If as much as one percent of the injection
fluids migrate eventually into drinking water sources (which
would be a high rate by industry standards), then the total
volume of fluids actually entering underground sources of
drinking water from these well practices would be eight billion
gallons per year. If the leakage rate were lower and only
one-tenth of one percent of the injection fluids in these wells
12
For Class I wells, the number of wells and daily injection
volumes were taken from Compilation of Industrial and Munici-
pal Injection Wells in the United States. Volume 1, U.S. En-
vironmental Protection Agency, October 1974.For Class II
wells, the number of wells and annual injection volumes were
taken from the report on Class II wells, Preliminary Analysis
and Findings, Estimated Cost of Compliance^Arthur D.Little,
Inc., February 15, 1979. For Class III wells, the number of
wells was taken from Analysis of Costs: Underground Injec-
tion Control Regulations, Class I and III WellslTemple,
Barker & Sloane, Inc., May 1979.
BEDS
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11-15
migrate into drinking water sources, then the total estimate
would be reduced proportionately, to less than one billion
gallons per year. Other leakage rates would alter the total
figure proportionately.
Data from Maryland, Florida, and Nassau County, New York,
were used to develop a national profile of volumes injected by
Class IV wells. As may be seen in Table II-2, 660 million to
1.7 billion gallons of hazardous wastes may be disposed of
yearly by these wells into or above underground sources of
drinking water. A "best" estimate of discharged volume would
be approximately one billion gallons yearly.
Table II-2
CLASS IV WELLS - NATIONAL PROFILE
I
I
I
•SIZE CATEGORIES
! I: Wells injecting less than 100 gallons per day (gpd)
I II: Wells injecting between 100 and 1,000 gpd
| III: Wells injecting over 1,000 gpd
I
'.WELL POPULATION
I: 4,000 to 8,000; best estimate - 6,000 wells
II: 500 to 1,000; best estimate - 750 wells
I III: 500 to 1,000; best estimate - 750 wells
| TOTAL: 5,000 to 10,000; best estimate - 7,500 wells
'ANNUAL WELL INJECTION VOLUMES—MILLION GALLONS PER YEAR (MGY)
i I: 15 MGY to 50 MGY; best estimate - 30 MGY
II: 19 MGY to 62 MGY; best estimate - 38 MGY
III: 625 MGY to 1,625 MGY; best estimate - 938 MGY
, TOTAL: 659 MGY to 1,737 MGY; best estimate - 1,006 MGY
j 1
It also appears that a few high volume facilities account
for a disproportionate percentage of the hazardous waste volume
discharged. High volume facilities, i.e., facilities injecting
over 1,000 gallons per day (gpd), represent approximately 10
percent of the national Class IV well population. However,
these facilities appear to discharge over 90 percent of the
hazardous waste volume attributable to Class IV wells. Small
volume facilities, representing 80 percent of all Class IV
wells, appear to inject only 3 percent of Class IV well hazard-
ous waste volume.
A national estimate of Class V injection volumes cannot be
developed without data which is to be collected during the state
TIBISI
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11-16
assessment activities. Specifically, the volumes of fluid in-
jected in these wells is uncertain and expected to vary widely
from one type of well and location to another. The greatest
volumes in Class V are expected to derive from recharge wells,
which often are drainage wells for the disposal of storm water.
In the eight states described earlier, approximately one-third
of the wells and perhaps as much as three-quarters of the in-
jected volume was in this category. Some drainage wells are
estimated to discharge 10,000 gallons per minute during periods
of high precipitation. Taking into account the intermittent
nature of rainfall and the variation in watershed areas served
by individual wells, one might conservatively estimate a range
of average daily volumes exceeding 1,000 gallons per well. If
one-third of the nation's Class V wells are of this type, as
they were in the eight states, then the annual injection volume
from these wells nationally would be approximately 30 billion
gallons or more. The volumes injected through other forms of
Class V wells would increase that number by an undetermined
amount. It is significant to note that the fluids injected
underground from recharge wells are generally of a higher water
quality than that injected from other underground injection
wells.
EXAMPLES OF GROUNDWATER CONTAMINATION
BY CLASS IV AND CLASS V WELLS
The following case histories are provided as examples of
the types of groundwater pollution problems associated with
Class IV and Class V wells.
Class IV Wells—Case Studies
In some states, many small industrial and commercial plants
illegally use cesspools and dry wells for the disposal of waste
fluids. Small cheese manufacturers are an example of an indus-
try that uses this type of disposal process. The states are
aware of this problem and would be interested in investigating
this type of pollution if federal funding were available through
the UIC program. At the present time, state resources are not
adequate to enable regulators to implement a more comprehensive
enforcement program.
On Long Island, New York, a cardboard box manufacturer was
discharging process wastewater containing glue chemicals to a
cesspool. Upon the suggestion of the Suffolk County Department
of Environmental Control, the box manufacturer recycled his
process wastewater, and is now using it in the manufacture of
itS ED
-------
11-17
glue. This method of recovering process wastewater has dimin-
ished operating costs of the plant and has eliminated the waste-
water discharge as a source of groundwater pollution.
Endangerment of a Protected
Groundwater System
A West Coast firm specializing in the disposal of liquid
wastes, such as acids and caustics, was discharging 15,000
gallons per day (gpd) into a well about 40 feet deep. From the
well, the wastes percolated into the underlying strata. This
firm was operating under a Class I industrial waste disposal
permit issued by the City of Los Angeles in December 1963 and
July 1965. On July 29, 1976, the firm was notified by the
California Regional Water Quality Control Board (RWQCB) that
the site no longer met the state requirements because the
disposal site was in hydraulic continuity with underlying
groundwater, which, in turn, was in hydraulic continuity
with waters of the Pacific Ocean and the saltwater intrusion
barrier system operated by the Los Angeles County Flood Control
District. The groundwater underlying the disposal site was
already subject to saltwater intrusion, indicating that the
acid wastes of the firm could migrate and damage the operation
of the saltwater intrusion barrier system and contaminate the
protected groundwater system on the other side.
The firm proposed to treat the wastes at another of its
facilities prior to their disposal at the original site. The
Board countered this proposal with requirements that were much
stricter than the standard Ocean Plan effluent limitations be-
cause the Flood Control District had notified the RWQCB that
the sink seaward of the saltwater barrier was filling and that
the firm's disposal wells may have an adverse effect on the
barrier operation. The firm found it impossible to meet the
requirements; therefore, it ceased disposal of the wastes and
completed construction of a sewer connection to the Los Angeles
community sewer system. The cost of compliance was not released
for use in this study.
Disposal of Pesticide Waste
Water in a Bore HoFe"
The owner of an aerial pesticide spraying and dusting ser-
vice, located in a small town in Texas, applied to the Texas
Water Quality Board (TWQB) in May 1974 for a permit to dispose
of pesticide-contaminated waste water in a 40-foot bore hole.
TBS
-------
11-18
The facility was located at the local airport about one
mile north of town. A domestic water well was located about
200 feet from the disposal bore hole. Other water wells, used
for irrigation and domestic purposes, were located in the sur-
rounding area. The underlying material is composed of sand
and clay to a depth of 300 to 430 feet, with a static water
level of 165 to 190 feet from the surface.
The owner disposed of insecticides, herbicides, and fungi-
cides, from the clean-up of aerial spray planes, into a bore
hole. The bore hole was located under a 50 foot square concrete
slab sloped to drain into the hole. Approximately 3,000 gallons
of water were used each operating season from early spring until
late fall.
The remaining chemicals in the tanks on the planes were
dumped into the bore hole, and the systems were flushed with
clean water to remove any residue.
The director of field operations for the Texas Water Qual-
ity Board examined the site and surrounding area and recommended
that the permit be denied. In his opinion, the process led to
disposal of a hazardous waste into an unlined bore hole, and, if
the waste had not yet migrated into ground water, it probably
would in the near future. The owner was told to plug the bore
hole to prevent surface water from passing through the zone and
possibly carrying the contaminants into ground water. The owner
was told to develop a suitable method for the disposal of the
hazardous waste and submit his plans to the TWQB.
One year later, the owner informed the TWQB that he had
not been able to develop plans for a new disposal facility,
but that he was no longer using the bore hole. Instead, he
was allowing the washwater to run into an open pit lined with
drillers' mud and protected with a lock and chain-link fence.
He was informed by the TWQB that this method was not approved
either.
During the summer of 1975, the TWQB pursued the problem
by obtaining sediment and water samples in the area to be used
as evidence in possible litigation against the aerial sprayer.
A pamphlet entitled "Aerial Applicator Pesticide Waste Control,"
developed by TWQB in consultation with various aerial applica-
tors and the Aerial Applicators' Association "of Texas, was
delivered to the aerial sprayer to provide guidance in select-
ing an approved method of solving his wastewater problem.
According to the owner of the spray service, he continued
as of mid-1978, to use the open pit. No action had been taken
by TWQB on this case or on similar cases within this industry.
-------
11-19
Recently the board was reorganized, and all outstanding spray
applicator cases were turned over to the Texas Department of
Agriculture. State Department of Agriculture sources report
that staff and budget limitations prohibit a more aggressive
approach to discouraging potential contamination from disposal
of spray applicator wastewater.
Contamination of Fresh Water Aquifer
from Metallic Waste Stream
This case history involves a precision and specification
electroplating job shop in Huntingdon Station (Long Island),
New York. The firm employs 13 people and has a gross income
of approximately $500,000 per year.
Several metals are used in the electroplating process in-
cluding nickel, cadmium, copper, tin, zinc, silver and others.
The process waste water is high in heavy metals.
During the first 80 years of business, wastes were chan-
neled to leaching pools and allowed to percolate in the ground.
In 1962 the company installed a chromate treatment facility to
destroy cyanide in the waste stream. There was no capital cost,
and the incremental operating cost was about $300 per month.
This was less than 1 percent of total operating costs.
The early 1970s brought greater ecological awareness to
the Long Island counties. More stringent guidelines were set
for allowable discharge of heavy metals, and the Suffolk County
Department of Environmental Control recommended that this firm
upgrade its treatment facility. It was difficult to find a
treatment process which could detoxify a heterogeneous waste
stream. Reverse osmosis, precipitation, and evaporation were
considered; however, these processes were not technically
feasible. The company worked on the problem for a few years,
together with members of the Metal Finishers Foundation and
local electroplaters. The amount of time invested was con-
siderable; yet these small operators could not afford to hire
extra personnel to study the waste-disposal problem as this
industry is characterized by low profit margins and intense
competition.
Late in 1976 the company contracted for the services of a
liquid hauler at a cost of 10 cents per gallon. Operating cost
for use of the hauling service was $2,000 per month, or approxi-
mately 7 percent of total sales. As a result of this cost, the
firm reduced its use of water from 13,000 gpd to 1,000 gpd.
Four hundred gpd of non-contact cooling water were discharged
IrlBlsl
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11-20
through a leaching field and eventually recharged the underly-
ing aquifer. The hauling cost had been passed on directly to
customers with an explanation that it was due to pollution-
control requirements. The customers were sympathetic, as they
were experiencing the same environmental protection pressures.
However, the president of the firm believed that additional
costs would not be accepted readily and would impact on his
ability to compete in the marketplace.
The president of the firm was contacted again in January
1979 to see whether his costs had risen recently. The services
of the liquid hauler are now about 13.5 cents per gallon, and
the firm has reduced its volume to 7,200 gallons every two
weeks—720 gallons per day. The firm president said that he
could not reduce his water use further and maintain the quality
of his finish. It was not clear whether his recent reduction
in volume resulted from a lower level of production or from
further economies in water use. Future regulations may add
administrative costs to cover manifest handling, labeling,
incident reporting, and general administration. These addi-
tional costs have been estimated to bring total hauling costs
up to slightly more than 20 cents per gallon.113
Class V Wells—Case Studies
Injection of rendering wastes associated with slaughter-
houses in Illinois, Indiana, and Ohio has caused ground-water
contamination. In eastern Ohio, a slaughterhouse injects
rendering wastes into a dug well. This type of waste generally
has a high concentration of biochemical oxygen demand (BOD).
The Ohio Environmental Protection Agency is aware of this prac-
tice but allows it to continue because the wastes are being
injected into an aquifer with low specific capacity of wells in
the aquifer and because it is not considered an important source
of groundwater that needs to be protected. When this type of
disposal is investigated in areas underlain by valuable ground-
water resources and in other states, it is generally banned.
Under the currently proposed UIC regulations, this practice
would be banned in all states.
In Pennsylvania, sewage is discharged to abandoned mines
through wells. The water in the mines is believed to have
13
Draft Economic Impact Analysis: Subtitle C, Resource Conser-
vation and Recovery Act of 1976. Arthur D. Little, Inc.,
January 1979.
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11-21
less than 10,000 mg/1 of total dissolved solids (TDS) concen-
tration. In addition, fly ash slurry is injected into wells
to control subsidence. The State Department of Environmental
Resources indicates that it has not received complaints of
groundwater pollution regarding this practice.
Groundwater contamination has occurred in Bellevue, Ohio,
as a result of the use of sewage disposal wells. In the City
of Bellevue, there are appoximately 1,400 residential and com-
mercial disposal wells and 200 municipally operated sewage
disposal wells. The area is underlain by a limestone aquifer
that has a high transmissivity. This type of aquifer is charac-
terized by a high rate of groundwater movement. Between 1953
and 1960, approximately 80 disposal wells were drilled. In the
middle 1960s a sewage collection and treatment system was com-
pleted. This system greatly reduced the use of disposal wells;
however, storm water runoff is still injected through drainage
wells.
Injection of runoff into highway and street drainage wells
in Streeter, Illinois, and Modesto, California, has caused
groundwater contamination. Modesto has approximately 3,000
wells of this type. The city has requested funds from the state
to study and design an alternative disposal system.
In Tallahassee, Florida, thermal pollution of groundwater
has been reported as a result of injection of air-conditioning
cooling water. The majority of large air-conditioning systems
in this area use ground water for condenser cooling. Ground-
water is heated in the cooling process and is returned to the
aquifer that is being pumped. Generally, cooling water supply
wells and disposal wells are completed in the same zone of the
aquifer. Due to the high temperature of injected water, ground-
water temperature in the area has increased by 2°C to 3°C (5°F
to 6°F). Three supply wells completed in the same zone as the
disposal wells recorded temperatures as high as 32.2°C (90°F).
The disposal wells were redesigned to inject into a deeper zone
which is isolated from the shallower zone by thick beds of
dolomite.
-------
III. COSTS TO INDUSTRY
CLASS IV WELLS
INTRODUCTION
The continued operation of Class IV wells poses a serious
threat to the quality of the nation's freshwater aquifers. Each
year these wells discharge an estimated one billion gallons of
hazardous wastes into or above underground sources of drinking
water. The materials injected possess toxic, reactive, corro-
sive, and similarly harmful properties. Moreover, these sub-
stances may persist in the groundwater for years after injection.
However, regulation by permit does not appear to be a vi-
able protective approach. The very nature of Class IV wells,
i.e., injection of hazardous wastes into or above underground
drinking water sources, frustrates any attempt to control their
pollution potential through the use of rigorous construction and
operating standards. Therefore, the reproposed federal UIC
regulations have called for closure of all Class IV wells within
three years of the effective date of the applicable state UIC
program.
Upon closure of a well, the hazardous wastes formerly dis-
charged therein must be disposed of elsewhere. If the waste
generator cannot recycle these materials, then the hazardous
wastes must be stored, treated, or disposed of at a RCRA-approved
on-site or off-site hazardous waste management facility. If more
than 100 kilograms of hazardous waste are to be transported off-
site, then the generator is to participate in the RCRA manifest
tracking system.
In any event, the UIC regulations for Class IV wells will lead
to the following incremental activities for the well operator:
• Notification
• Monitoring of well injection and nearby well-
water quality
• Submittal of quarterly reports to the program
director
• Use of alternative disposal methods
• Participation in the RCRA manifest tracking
system.
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III-2
Each of these activities will be explained and discussed
more fully in the next section.
OPERATOR REQUIREMENTS
The federal UIC regulations explicitly require the operator
of a Class IV well to participate in the first three major
activities mentioned above: apply for temporary authorization
to operate an injection well, monitor injection well parameters
and nearby well-water quality, and report quarterly to the pro-
gram director. Furthermore, the operator must close his well
when ordered to do so by the state UIC program director.
However, the UIC regulations do not require the hazardous
waste generator to dispose of the displaced wastes in an approved
hazardous waste management facility—this is entirely a RCRA re-
quirement. Instead, the UIC regulations require that a Class
IV well user turn to alternative disposal means. RCRA then
stipulates that the disposal alternative must be at a RCRA-
permitted hazardous waste management facility. Furthermore, if
more than 100 kilograms of hazardous wastes are to be transported
off-site, then the generating facility must participate in the
RCRA manifest tracking system.
Costs for disposal of the displaced hazardous wastes at an
approved facility and the cost of participating in the manifest
tracking system have been included in this analysis because the
UIC Class IV program is the direct cause of these activities.
But it should be kept in mind that RCRA regulations play a large
part in the costs shown here for these post-closure tasks.
Notification
All Class IV well operators must formally notify the pro-
gram director of the existence of their practice. The notifica-
tion information must include the name, location, and principal
activity of the place of operation as well as a description of
the types of hazardous wastes handled. Moreover, the well oper-
ator must submit information similar to that required on Part A
of the RCRA permit application for hazardous waste management
facilities: for example, a description of the types and amounts
of hazardous wastes handled and a description of the manner in
which the hazardous wastes are treated, stored, or disposed of
at the facility.
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III-3
Since the task requires only a few hours' work, it is esti-
mated that formal notification will cost approximately $30 to
$35 per well. Submission of further information on the contam-
ination potential of the facility is estimated to cost $120 per
well, on the average. Class IV wells appear to be, on the whole,
small operations, and it is unlikely that completion of this
latter task will take up more than a day and a half of the
operator's time. The complete notification process has been
assigned an average cost of $150 per well.
Monitoring
One of the conditions of temporary authorization is a
requirement for periodic monitoring of injection well para-
meters and nearby well-water quality. The federal UIC regula-
tions require, at a minimum, the following monitoring activi-
ties:
• Daily monitoring of variable injection
flows for volume and hazardous characteris-
tics
• Weekly monitoring of constant injection
flows for volume and hazardous characteris-
tics
• Weekly monitoring of existing water supply
wells within the vicinity of the operation for
parameters determined by the injection.
This study assumes that well operators will try to equalize
injection flows or reduce disposal frequency in order to mini-
mize monitoring costs. Furthermore, it has been assumed that
facilities practicing variable injection would tend to dispose
of their hazardous wastes on a periodic basis, following imple-
mentation of a state UIC program. This analysis assumes that
facilities practicing variable injection would, on the average,
dispose of their wastes on a weekly basis. Yearly costs of
monitoring injection flows would then be similar for comparable
facilities practicing either constant or variable injection.
The incremental cost of monitoring injection volume and
its hazardous characteristics would depend also on factors
other than the frequency of monitoring, i.e., the operator's
present level of monitoring, the relative homogeneity of the
injected hazardous waste stream, and the level of reporting
detail required by the program director in identifying the
hazardous characteristics of the waste stream. At present,
TIBISI
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III-4
this information is unavailable. The analysis must proceed
instead from reasonable assumptions about the typical hazard-
ous waste generator and expected UIC monitoring requirements.
Most, if not all, persons using or operating Class IV
wells as disposal means will have a fair degree of knowl-
edge on the chemistry and hazardous characteristics of the
waste streams injected--if only because such information
was required in the RCRA permit application. It is also
likely that Class IV wells will have flowmeters or volumetric
meters as part of their existing equipment in order to ensure
injection flow rates maintained within the limits of well
capacity.
The incremental cost of monitoring injection flows would
arise, then, from the task of reading the meter weekly and
logging the value read. There could be an incremental cost
associated with the logging of the hazardous characteristics
of the waste stream, but for small operations it is likely
that only one waste stream is injected, while for larger
operations handling several waste streams it is likely that
a record of the substances injected is already being kept.
In either case, the incremental cost of logging the waste
streams' hazardous characteristics would be negligible or
nonexistent.
An average weekly monitoring cost of $3.50 per well has
been used in this study. This estimate is, of course, subject
to the limitations of the assumptions made in the preceding
paragraphs.
Class IV injection wells located near existing water
supply wells are required to monitor the water quality
on a weekly basis. However, little usable data exist on
this subject, largely because few data exist on Class IV
well practices in general, but partially because there
is no objective definition of what constitutes a critical
proximity between Class IV injection wells and nearby
existing water supply wells. To be conservative, this
analysis assumes that, on the average, one existing water
supply well is located near each Class IV well.
The federal UIC regulations state that monitoring of
water quality shall be for "parameters determined by the
injection." The present analysis assumes that the monitor-
ing test shall be for only one hazardous waste contaminant,
e.g., the contaminant produced in greatest quantity or the most
toxic contaminant produced. The costs of laboratory analysis
would make a more comprehensive requirement prohibitively
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III-5
expensive for small operators. Furthermore, unless the hazard-
ous substances discharged in the well have different diffusion
properties, test results for one substance may indicate the
relative concentrations of other substances injected in the
same waste stream. Using the above stated assumption, weekly
monitoring costs for water quality are estimated to average
$20 per water supply well.
Quarterly Reporting
The results from both types of monitoring are to be
submitted by the well operator to the program director each
quarter. The present analysis assumes that the typical well
operator will require a half-day of effort to compile, pre-
pare, and submit this report, at a cost of $37.50 per report.
GENERATOR REQUIREMENTS
Alternative Disposal Methods
It is expected that the majority of Class IV well operators
will respond to the proposed regulations by transporting their
wastes to an approved hazardous waste disposal site. Firms
injecting less than 1,000 gallons per day will probably find it
economical to reduce waste streams through adjustments in their
production process and to dispose of their entire remaining
waste streams at an off-site facility.14 Larger plants, with
daily wastewater flows of over 1,000 gallons, will generally
apply treatment to separate out the hazardous components of
their waste streams and remove treatment sludges to off-site
facilities. For these firms, treatment would reduce the volume
of wastes requiring disposal to approximately 2 percent of the
original waste stream.
Local conditions will strongly influence the costs of
treatment and disposal. For purposes of arriving at a national
cost estimate, however, this study has used typical standard
costs for all plants within a given category. The cost of
hauling/disposal has been estimated to be $.22 per gallon based
14
Experience with NPDES permits has demonstrated a move toward
volume reduction prior to hauling wastes to deep disposal wells,
-------
III-6
on figures developed for EPA's Office of Solid Waste.15 The
costs of treatment will vary by industry. Because many of the
affected plants will be electroplating operations, the costs
for an electroplating plant generating 11,000 gallons per day
of waste and requiring both clarification and cyanide removal
were assumed to be typical. Based on data from EPA's Office of
Water Planning and Standards, the annual capital and operating
and maintenance costs for such a plant would be in the range of
0.9 to 1.5 cents per gallon. TBS has used the upper end of
this range to obtain a conservative estimate of the total
national cost.16
Table III-l summarizes the annual costs of compliance with
UIC regulations for Class IV wells based on the estimates of
the number of wells and the volumes of flow developed earlier
Table III-l
CLASS IV WELLS
ANNUAL COSTS OF TREATMENT AND DISPOSAL
Volume
Injected
Total
Annual Volume
(mill ion
Number gallons per
of Wells year)
More than 1000
gallons per day
Less than 1000
gallons per day
Total
750
6,750
7,500
938
Cost of
Treatment/
Disposal
(millions of
1977 dollars)
Treatment: $14a
Disposal: 4b
58
1,006 MGY
Disposal:
15C
$33
aAssumes pretreatment cost of $.015 per gallon applied to total
flow.
bAssumes hauling/disposal cost of $.22 per gallon applied to
treatment sludges which are estimated to be 2 percent of the
total wastewater volume.
cAssumes hauling/disposal cost of $.22 per gallon applied to
entire wastewater stream.
15
Draft Economic Impact Analysis of Subtitle C, Resource Conser-
vation and Recovery Act of 1976, Arthur D. Little,
1979.
Inc., January
16
It should be noted that this cost is also conservative in
that it is based on a plant requiring cyanide removal, which
is required only in certain electroplating processes.
TIBISI
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III-7
in this report. Although small and medium-sized firms will
tend to reduce the volume of their waste streams, no estimate
can yet be made of the level of reduction that can be expected.
Therefore, the cost analysis has taken a conservative approach
and has assumed no reduction in waste stream volume for firms
injecting less than 1,000 gallons per day. The total annual
national treatment and disposal cost would be $33 million.
Over one-half of this cost ($18 million) would be borne by the
largest plants, which represent 10 percent of the total number
of plants, at an average cost of $24,000 per plant. Plants
injecting less than 1,000 gallons per day would incur an
average cost of $2,200.
Manifests
One of the major components of the RCRA program for regula-
tion of hazardous wastes is the manifest tracking system. Off-
site shipments (greater than 100 kilograms per month) are re-
quired to be accompanied by a manifest describing the wastes.
As the wastes are transported to their ultimate disposal site,
all persons to whom responsibility is successively allocated
are required to sign the manifest, retaining copies for their
files. Moreover, these copies are to be stored for three years,
This report assigns an average cost of $2.67 to the gen-
erator's task of completing the manifest. Additionally, a cost
of $68 per facility has been used as the annual cost of storage
and filing for these manifests.^
METHODOLOGY
Total costs to industry were developed by identifying
incremental activities necessitated by the Class IV regulations
and estimating unit costs for the implementation of these ac-
tivities. In this, the industry cost analysis for Class IV
wells is consistent with earlier TBS cost analyses for Class I
and Class III wells.
However, there are two major differences between the
present analysis and the earlier analyses. These differences
arise from the uncertainty of the Class IV well population
17
Manifest costs are from Draft Economic Impact Analysis of
Subtitle C, Resource Conservation and Recovery Act of 1976,
Arthur D. Little, Inc., January 1979.
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III-8
estimate and from the unique regulatory approach to be used
for Class IV wells. First, total manpower and cost estimates
will be developed for well populations of 7,500 wells, 5,000
wells, and 10,000 wells. These represent the midpoint estimate
and the lower and upper bounds, respectively, on the range of
well population. Second, since all Class IV wells will be
closed within three years of the effective date of the appli-
cable state program, the relative mix of active program ele-
ments will change throughout the lifetime of the program.
For example, the number of well operators engaged in monitoring
and reporting activities declines while the number of waste
generators using alternative disposal means increases as the
program progresses. An economic analysis of this program must
postulate a reasonable time pattern of well closure before
costs can be computed.
This analysis assumes that all Class IV wells will be
identified in the first six months and assessed in the second
six months of program operation. Fifty percent of these wells
are assumed to be closed in the second year and the remaining
50 percent are assumed to be closed in the third year. In
other words, if 7,500 Class IV wells are identified in the
first year of program operation, this analysis assumes that
3,750 of these wells will be closed by the end of the second
year and that the remaining 3,750 active well operations will
be closed by the end of the third year of program operation.
The average active well population in the second year of pro-
gram operation would be 5,625 wells, while in the third year,
the average active well population would be reduced to 1,875
wells. Furthermore, it was assumed that all wells identified
in the first six months of program operation would begin moni-
toring their operations and nearby supply wells soon after
authorization and that each well operator would submit two
quarterly reports to the program director during the latter
half of the first year. These assumptions result in the task
chronology and average well populations shown in Table III-2.
Operator program tasks and their estimated average costs
are summarized in Table III-3. The information contained in
Tables III-2 and III-3 has been used to compute expected indus-
try expenditures for the three years of program operation and
two years thereafter.
RESULTS
Total five-year costs to industry resulting from imple-
mentation of the Class IV regulatory program may be seen in
Table III-4.
IrlBlsl
-------
III-9
2b
3C
Table III-2
CLASS IV WELLS
CHRONOLOGY OF INDUSTRY TASKS AND WELL POPULATION
One-Time
Task
Average
Class IV
Year Well Population^- Notification Monitoring
Recurring Tasks
Quarterly
Reports
7,500
(0)
5,625
(1,375)
1,875
(5,625)
0
(7,500)
0
(7,500)
I/well
n/a
n/a
n/a
n/a
1/wk/well
for 26 weeks
1/wk/well
for 52 weeks
1/wk/well
for 52 weeks
n/a
n/a
2/well
4/well
4/well
n/a
n/a
Alternative
Disposal
n/a
As necessary
for each
closed well
As necessary
for each
closed wel1
As necessary
for each
closed well
As necessary
for each
closed well
Manifests
n/a
1/wk/
closed
wel 1
1/wk/
closed
well
1/wk/
closed
well
1/wk/
closed
well
Class IV well operators conduct monitoring and reporting activities only during the
last half of the year, since the first half of the year is devoted to the one-time
task of notification.
3,750 wells closed during this year.
3,750 wells closed during this year.
For each year, the first number shows the total population of active wells remaining
at the midpoint of that year. The second number, in parentheses, shows the number of
wells already closed by the program at the midpoint of that year.
n/a = not applicable.
TIBIS
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111-10
Table III-3
CLASS IV WELLS
UNIT COSTS FOR INDUSTRY EXPENDITURES
Program Element
Unit Cost
One-Time
Notification
Recurring
Monitoring
• Injection parameters
• Water quality
Quarterly Reports
Alternative disposal^
• Large-volume generators
• Medium- and small-volume generators
Manifests
• Filling out forms
t Storage and filing
$150/well
$3.50/monitoring i
$20/monitoring incident3
$37.50/report/quarter
$24,000/well/year
$2,200/well/year
$2.67/manifest
$68/facility/year
A "monitoring incident" refers to a single occasion in which read-
ings are taken or analytic tests are performed for one well in
order to satisfy the monitoring requirements of the UIC regulations.
Monitoring injection flow for volume and hazardous characteristics.
Analytic test for one contaminant.
See Table III-l.
TIBISI
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III-ll
Table III-4
CLASS IV WELLS
CHRONOLOGY OF INDUSTRY EXPENDITURES
(mi llions of 1977 dollars)
Year
1
2
3
4
5
Total
One-Time
Task Recurri nc
Quarterly
Notification Monitoring Reports
1.1 4.6 0.6
6.9 0.8
2.3 0.3
-
-
1.1 13.8 1.7
Tasks
Alternative
Disposal
8.2
24.8
33.0
33.0
99.0
Tnf al
Yearly
Manifests Costs
6.3
0.4 16.3
1.2 28.6
1.55 34.55
1.55 34.55
4.7 120.3
Total five-year costs to industry are estimated to be $120
million. The average yearly cost to industry is $24 million,
and the average yearly cost per well is $3,200. Range estimates
for these costs can be obtained by using population estimates of
5,000 and 10,000 wells. Total five-year costs may range from
$80 million to $160 million. The average yearly cost to indus-
try ranges from $16 million to $32 million, and the average
yearly cost per well remains the same, $3,200.
Total yearly costs to industry increase quickly from $6.3
million in the first year of program operation to $35 million
in the fourth year. Average industry expenditures in the first
year are $840 per well, but in the fourth year average industry
expenditures are $2,200 to $24,000 per well, or the cost of
alternative disposal methods.
Recurring program tasks account for 99 percent of total
program costs. The task generating the greatest cost impacts
is alternative disposal. Alternative disposal costs, together
with manifest costs, account for over 86 percent of the total
five-year cost to industry. These are costs borne by the gen-
erators. If these costs had not been included in the analysis,
total costs to industry would be $16.6 million, or an average
yearly cost to well operators of $740 per well in the first
three years of program operation.
TBS
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IV. INCREMENTAL MANPOWER REQUIREMENTS AND COSTS
TO THE STATES-CLASS IV WELLS
INTRODUCTION
The currently proposed UIC regulations call for all states
and territories to develop Class IV well programs meeting mini-
mum federal requirements. The primary requirement is formula-
tion of an enforcement strategy that will close all Class IV
wells within three years of program operation. Supplementary
to this are requirements concerning program structure, criteria
and administration.
The purpose of this analysis is to estimate the incremental
manpower requirements and program costs to the states arising
from regulation of Class IV wells. The labor and cost figures
presented here are the best estimates available to date, though
several simplifying but well-considered assumptions have been
made in the estimation of labor and cost requirements for par-
ticular program elements.
PROGRAM ELEMENTS
The requirements for the states in the UIC program may be
viewed as a series of related tasks. This study has grouped
these tasks to form the following major program elements:
• Program development
• Program hearings
• Semi-annual report to EPA
• Closure notification
• Quarterly review of operator reports
• Quarterly reports to EPA
• Annual reports to EPA
• Enforcement
TBS
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IV-2
The components of and estimated manpower needs for each
program element are discussed briefly below.
Program Development
States designated by EPA as those states for which an
underground injection control program "may be necessary" must
develop a UIC program and submit it to EPA within 270 days.
EPA may extend this deadline for any state by an additional 270
days. Eventually, 57 states and territories will be listed.
Section 1421 of the Safe Drinking Water Act determined
the minimum requirements for a state program to be as follows:
• Prohibition of any underground injection not
authorized by permit (under certain circum-
stances a state may be allowed to regulate
by rule)
• Protection of underground sources of drink-
ing water
• Satisfaction of inspection, monitoring,
recordkeeping, and reporting requirements
• Coverage of underground injections by
federal agencies and by any person on
property leased or owned by the United
States.
The consolidated regulations describe the elements of an ap-
provable state program in greater detail (40 CFR Part 123). In
40 CFR Part 146, minimum criteria and standards are set out for
the state underground injection control programs which are to
regulate injection wells. Subpart E of Part 146 describes
specific responsibilities of the state and of the well opera-
tors regarding Class IV wells.
An initial survey of state underground injection control
legislation and hazardous waste legislation has indicated wide
variation among the states in their degree of control over
Class IV well practices. The manpower estimate for program
development used in this analysis, 15 man-days per state, is an
estimate of the incremental manpower needs of a "typical" state,
i.e., a state already possessing a limited degree of regulatory
authority over Class IV well practices.
-------
IV-3
Program Hearings
The federal UIC regulations stipulate that a state UIC
program can only be adopted following "reasonable notice and
public hearings." Public participation requirements ,u'e ex-
plained in 40 CFR Part 124 of the consol i ' :ii o.i regulations.
An estimate of five man-days per state has been allocated to
the task o" holding public hearings and responding to public
comments on Class IV wells.
Semi-annual Report to EPA
States are to submit semi-annual reports to EPA during the
time they are develop Lag their application for primacy. Theso
reports will provide EPA with information on the states' pro-
gress in formulation of an approvable program for those well
classes currently operating within each state. It is estimated
that a typical state would submit one semi-annual report, util-
ising five man-days of effort, to EPA during its 270-day program
development period.
Closure Notification
Well operators must supply formal notification of their
existence as well as provide information on the types and
quantities of hazardous wastes handled. The program director
will review these documents and notify the operator of the
time by which closure must be accomplished and, if appropriate,
of a compliance schedule leading to closure.
The director is to consider a number of criteria in re-
viewing these documents, including: the population affected
or potentially affected by the injection, local geology and
hydrology, toxicity and volume of the injected fluid, and in-
jection well density. Review of the information contained in
these documents is estimated to require two man-hours per appli-
cation. Small operations would submit documents requiring less
time to review, but large operations would undoubtedly supply
documents requiring several days' review. These different
review times are averaged in the present estimate.
Quarterly Review of Operator Reports
Each quarter, Class IV well operators will submit reports
to the program director on the results of periodic monitoring
-------
IV-4
required by the UIC regulations. Most reports should be rela-
tively short, containing 26 weekly items: 13 records of the
volume and hazardous characteristics of the injection stream
and 13 records of nearby well-water quality.1®
An average review time of two man-hours per report has been
used in this study, and is intended to include time spent in
following up on reports with incomplete or confusing data. It
does not include time spent on site visits to wells with reports
indicating contamination of groundwater. Such visits are to be
included instead in the manpower requirements for enforcement.
Quarterly Reports to EPA
The state program director is to submit quarterly reports
to EPA on the compliance status of Class IV wells within the
state. It is expected that these reports will take the form of
organized summaries of data obtained from quarterly operator
reports and from enforcement visits. Less than one-half man-
hour per well has been estimated as the quarterly manpower re-
quirement for this task.
Annual Report to EPA
The annual report sent by the state program director to
EPA will summarize the regulatory activities undertaken during
the year and is expected to include an assessment of the status
and progress of the Class IV well program. The information con-
tained in the quarterly reports to EPA will probably form the
database from which an intensive self-evaluation would proceed.
Also, it is expected that during this time of evaluation, con-
siderable effort will be devoted to the review and possible
reformulation of a closure strategy for the upcoming year and
that these plans will be included in the annual report to EPA.
A labor estimate of 1.2 man-hours per existing Class IV well
has been allotted to this effort.
Enforcement
Each state program must demonstrate adequate enforcement
capabilities prior to approval by EPA. A plan of regular sur-
veillance and inspection of operating facilities is required,
1 8
As was explained in the previous chapter, this analysis
assumes that nearly all well operators will be monitoring
injection well parameters and nearby well-water quality on a
weekly basis.
TBS
-------
IV-5
in addition to a range of enforcement tools such as civil
alties, criminal penalties, and injunctive relief.
pen-
One man-day per operating site has been chosen as the
level of annual enforcement effort. This represents two half-
day site visits to each operating facility every year. Time
constraints and the inherent uncertainty of the subject matter
precluded investigation into an estimate of manpower needs for
correction of extended cases of noncompliance. These circum-
stances have therefore not been included in the present analysis,
METHODOLOGY
The unit manpower requirements given for each program
element discussed above will be used to generate an estimate
of total incremental manpower needs for the 57 states and
territories. Table IV-1 below is a summary of those unit
estimates.
Table IV-1
CLASS IV WELLS
ESTIMATED STATE MANPOWER REQUIREMENTS
Program Element
One-Time:
Program development
Program hearings
Semi-annual report
Closure notification
Recurring:
Quarterly review
Quarterly report
Annual report
Enforcement
Manpower Estimate
15.0 man-days/state
5.0 man-days/state
5.0 man-days/state
2.0 man-hours/wel1
1.0 man-hours/welI/quarter
0.3 man-hours/welI/quarter
1.2 man-hours/wel I/year
1.0 man-days/welI/year
The program timing assumptions employed in the Class IV
industry cost analysis will also be employed in this analysis.
Table IV-2 shows the effects of these timing assumptions on
the chronology of state program tasks and on the size of the
Class IV well population. Approximately one year will be
required to develop a state program. After the program is
approved, all Class IV wells are to be closed within three
years of the effective date of the program. In all, there
will be four years of regulatory costs to the states. Tables
IV-1 and IV-2 display the information used to develop estimates
of total manpower needs for four years for the states.
TBS
-------
IV-6
Total state costs were computed by using an estimate of
the weighted average state staff wage and fringe benefit level
to convert total manpower needs into total budgetary needs.
The manpower wage estimate is in 1977 dollars, and the value
used, $22,500, is the same estimate used in the analysis of
state costs done by TBS for well Classes I and III. A 15
percent overhead charge has been added to the $22,500 manpower
wage estimate to cover direct expenses such as office supplies
and travel.
Tahlp IV-?
CUSS IV WELLS
CHRONOLOGY Of STATF TASKS AND WE 1.1. POPULATION
One-Time Tasks Rprurrinq Tasks
Average
Class IV Program Program Semi-annual
Closure
Year Well Population Development Hearings Report Notification
** 7,500 I/state I/state I/state
(5,000 - 10,000)
lb 7,500 n/a n/a n/a
(5,000 - 10,000)
2C 5,625 n/a n/a n/a
(1,750 - 7,500)
3d 1,875 n/a n/a n/a
(1,250 - ?,500)
4 0 n/a n/a n/a
(0)
5 0 n/a n/a n/a
(0)
fl"*" refers to the 270-day period during which the state programs
period may be extended an additional ?70 days with the approval
n/a
I/well
n/a
n/a
n/a
n/a
arc to be
of EPA.
Quarterly rev lews and enforcement visits are assumed to he conducted dur inq
the ful 1 year for the second and third years.
C1,750 wplls closed during this year.
3,750 wells closed during this year.
'The frequency of enforcement act ions 15 not spec) f t ed tn the MIC
with state sources .
requlat ion
Quarterly Quarter 1 v Annual Enforcement
Reviews Reports Reports Visitse
n/a n/a n/a n/a
?/welt 4/state I/state 1/welt
4/well 4/state 1/sUfe ?/well
4/well 4/state I/state ?/wpll
n/a n/a n/a n/a
n/a n/a n/a n/a
developed and program h^arinqs held This
the last half of the first year, and during
s but was estimated by TBS based on discussions
RESULTS
The discussion of total manpower requirements and costs
will concentrate on results based on a starting Class IV well
population of 7,500 wells, with limited reference to total re-
source needs expected for Class IV well populations of 5,000
and 10,000.
TBS
-------
IV-7
Total Manpower Requirements
A total of 112 man-years of effort, shown in Table IV-3,
is estimated to be used by the states in carrying out the
federal UIC regulations for Class IV wells. Each state will
expend an average of 2.0 man-years of effort in developing
and fully implementing program requirements.
For a Class IV well population of 5,000 wells, total man-
power requirements are estimated to be 84 man-years of effort,
or an average of 1.5 man-years per state. A Class IV well popu-
lation of 10,000 would lead to total state manpower requirements
of 161 man-years, or 2.8 man-years per state.
Tabli; IV-t
(I ASS IV WllI S
CHRONOLOGY OF S1ATI MANCOWIR RFO.UIRLWNTS
(man-years of effort)
(5/ slates and territories)
One- f nne Tasks
Program Program Semi- annual Closure Ouartetly
Year Development Hearings Report Notif nation Revtows
* 39 1.3 1 3
1 H.5 8.5
/ - - - - 12.8
3 - 4.3
4
5 - - -
39 1.3 13 8. 5 ?5.6
Rerur(
Quarter ly
Reports
-
5 1
1 H
1 1
-
10.2
inq Tasks
Annua 1
Repoi ts
5 1
3.H
1 3
-
-
10.?
Fnf or( ernent
Visits
l/.O
2b f>
8 5
-
51.1
Tot a 1 Year 1 y
Manpower
Requir einents
6 5
41 ?
1fi 0
15 4
-
U?.l
Recurring program tasks will take up the most time. Total
recurring labor needs amount to 97 man-years, or 87 percent of
total manpower needs. Total one-time labor needs for the states
are estimated to be 15 man-years. For the three years of program
operation, each state will employ, on the average, less than one
full-time person to carry out program tasks.
Enforcement visits and quarterly reviews of operator re-
ports will be the program elements employing the most manpower.
Together, these two program elements account for over 68 percent
of total state manpower needs for the Class IV well regulatory
program.
TBS
-------
IV-8
The first and second years of program operation will be
the most costly program years for the states in terms of man-
years expended. The first year will require over 39 percent
of the total state manpower budget for the program; the second
year will require 41 percent of the total state manpower budget
The first year of program operation may also be the most
difficult year to administer. Five different program tasks
will be carried out at this time: closure notification, quar-
terly reviews, quarterly reports, an annual report, and en-
forcement. Furthermore, all of these tasks will be performed
for the first time in this year.
Total State Costs
As shown in Table IV-4, total state costs will be $2.9
million for all 57 states and territories. Each state will
expend, on the average, approximately $51,000 in this effort
to close down all Class IV wells.
For a Class IV well population of 5,000 wells, total state
costs are estimated to be $2.2 million, or an average cost of
$39,000 per state. A 10,000 Class IV well population is esti-
mated to lead to total state costs of $4.2 million, or an
average cost of $73,700 per state.
lable IV-4
CLASS IV WILLS
CHRONOLOGY OF STATE EXPENDI HIRES
(thousands of 1977 dollars)
(57 states and territories)
Une-Tiute Tasks Recurrinc
Program Program Semi-annual Closure Quarterly Quarterly
Year Development Hearings Report Notification Reviews Reports
* 101 34 34
1 220 220 132
2 331 9U
3 111 34
4
5
Tasks
Annual Enforcement
Reports Visits
132 440
>JU 662
31 220
Yearly
Costs
169
1,144
1 , 1H9
399
101
662
264
264
1,322
2,901
T
BS
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V. GUIDELINES FOR AN ASSESSMENT
CLASS V WELLS
INTRODUCTION
The assessment of Class V well practices is designed to
aid state officials in determining the statewide impact of these
well practices and to indicate regions within the states that
may require special attention. The data and interpretations
generated by the assessment will be used as the basis for an
advisory report and, therefore, should be detailed enough for
use in making general and specific regulatory decisions.
The major objectives of the assessment in a state are:
(1) to identify the scope of injection well practices; (2) to
develop a detailed description of the hydrogeologic environment;
and (3) to identify the magnitude of potential contamination
threats. It is expected that the assessment process will dif-
fer from state to state, depending upon the level of present
state action and the availability of information in this area.
In most states the process is expected to be an iterative one
in which the early stages are focused on conducting a prelim-
inary analysis of the problem and in which the later stages are
devoted to improving the accuracy and depth of the assessment.
The following discussion presents the structure, content,
and schedule of a hypothetical state assessment effort. These
guidelines are meant to serve as a basis for cost estimation
and should not be viewed as being prescriptive. The sections
below describe the process generally and then in more detail
for each phase. It is envisioned that there will be three
major phases in the assessment process: (1) Phase I, program
planning, data assembly, and preliminary review of operator-
submitted and existing data; (2) Phase II, collection of field
data; and (3) Phase III, analysis and interpretation of data,
documentation of the findings of the state assessment, and
formulation of a set of recommendations to EPA. These recom-
mendations will form the basis for a national regulatory
strategy for Class V well practices.
Phase I is estimated to take six months. During this
time, operators of Class V wells are to submit information on
their operations and on alternative disposal means open to
them. The state will use these data and existing well and
industry data to identify geographical areas where Class V
injection wells are most likely to be numerous. Toward the end
TBS
-------
V-2
of the six months the results of both data-gathering efforts
compared to determine the expected need for state action
ing non-reporting facilities.
will
in
1 be compared to determine tl
locating non-reporting facil:
Phase II is also expected to take six months. Its objec-
tives are to confirm the existence of Class V injection wells
indicated by the results of Phase I, including locating non-
reporting individual Class V wells to the extent feasible,
and to continue work begun in Phase I identifying the scope
of practices and evaluating the hydrogeologic environment.
Phase III will last about 12 months. During this phase,
the results of Phases I and II will be interpreted to determine
actual and potential threats to underground sources of drinking
water. The feasibility of technological alternatives will be
studied, and priorities for regulatory action will be developed
Lastly, a formal set of recommendations, or advisory report,
will be submitted to EPA at the conclusion of the assessment.
The components of each phase are briefly described in Figure
V-l.
Figure V-l
GENERAL STRUCTURE OF THE STATE ASSESSMENT PROCESS
Phase I
Scope of Practices
• Review operator-submitted data
and existing data in state
and local files
t Map significant charac-
teristics (e.g., unsewered
areas, population, and busi-
ness establishments)
t Determination of areas for
further investigation
Scope of Practices
• Field work to confirm
existence of wells and
to identify alternatives
Hydrogeology
• Map aquifer charac-
teristics (location,
yield, quality, and
movement)
• Map groundwater use
Hydrogeology
• Limited water quality
sampling
Phase
III
Combined Analysis
Data analysis and interpretation
Establishment of priorities
Evaluation of technological alternatives
Documentation of results for use in advisory report
Submission of advisory report
TBS
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V-3
PHASE I: DATA COLLECTION AND REVIEW
Scope of Injection Well Practices
The key factors in assessing the scope of Class V injec-
tion well practices are: (1) the number of disposal and
recharge wells; (2) the location and depth of wells; (3) the
use of wells; and (4) the volume and toxicity of injected
fluids. Owing to the lack of readily available information
from existing sources, both direct and indirect methods will
be used to determine the scope of the practices. The informa-
tion from indirect methods will be useful in determining the
inferred regional concentration of facilities, whereas the
information from direct methods will be particularly useful in
determining the specific numbers of wells. In Phases I and II,
the hydrogeologic environment investigation will be carried
out simultaneously with the scope of the practices investiga-
tion, and these investigations will be mutually dependent.
At the conclusion of Phase I, it is envisioned that these
methods of investigation will provide information that can be
shown on transparent maps. A preliminary indication of the
likely areas of Class V well concentrations can be obtained
by overlaying maps from the effort to identify the scope of
well practices and by overlaying maps from the effort to de-
scribe the hydrogeologic environment.
Many injection well practices covered under the term
"disposal wells" in Class V violate existing state water-
pollution control rules and regulations, especially those
containing non-degradation clauses. Nevertheless, public
information on the location and use of such facilities is
generally not readily available because most of these prac-
tices have never been specifically investigated. The wells
involved in these practices generally discharge fluids that
have a poorer quality than that of the water in the receiving
aquifers. Under certain locations and conditions, however,
these practices are considered to be the best and most eco-
nomical methods of disposal of wastes and may be under some
type of regulation by state and local agencies. Similarly,
some of the well practices covered under the term "recharge
wells" in Class V are regulated to some extent by state and
local agencies. Most wells in this category discharge fluid
of relatively good quality; drainage wells, however, discharge
relatively large volumes of water whose quality ranges from
poor to good, depending on local conditions.
TBS
-------
V-4
Direct Methods
Although the UIC program will require operators of
Class V wells to identify themselves to the program director,
not all operators will comply. The state will then have to
use other direct methods to compile data on Class V wells,
i.e., through the use of databases that have been developed
for different government programs and purposes. There are
numerous ways to compile such data; this section suggests
some of the more obvious methods of securing the information.
One direct method of defining the scope of the Class V
practices is through a review of federal, state, and local
agency files. Various federal programs, for example, have
peripherally involved the study of and the need for regulating
some of the Class V practices. Federal agencies that have
made studies involving some aspects of the use of Class V
wells include: the EPA, the Department of Interior, the
Department of Housing and Urban Development, the Department
of Health, Education, and Welfare, and the Department of
Transportation.
The EPA National Pollutant Discharge Elimination System
(NPDES) might be a source of information. This program has
extensive permit files that primarily describe specific indus-
try methods of surface-water discharge and require annual in-
spection of individual industrial sites. It might be possible,
through contact with regional EPA field inspection personnel
and by examination of permit files, to ascertain the use of
Class V wells in certain industry categories.
Several of the states that have assumed primacy for the
NPDES program also have compiled more detailed information
than that required by EPA. Some of these states have already
made preliminary counts of the number of disposal and recharge
wells. In New York and California, for example, a number of
well practices, such as those covered under recharge wells,
are already regulated through state programs. In addition,
the California State Water Resources Control Board has made
a preliminary count of the number of wells injecting into or
above underground sources of drinking water in the state.
Also, in California, numerous studies, funded by the federal
and state governments, have focused on areas where these well
practices have caused or could cause groundwater problems.
Some state and local departments of health already regulate
some types of disposal wells such as cesspools, sumps, and
septic system wells. Consequently, much information is avail-
able for these well practices, but an extensive file search
would be required to compile the data.
TBS
-------
V-5
Many of the Class V wells are constructed by well-
drilling firms and designed by consulting engineering firms.
Presumably, records of such injection facilities might be
available in the files of such companies; however, this
information may not be readily available for inspection.
Various published reports of federal and state agencies
on general hydrogeologic studies, river basin studies, and
Section 208 water-quality management studies also commonly
contain well data and descriptions of discharge facilities
that may include Class V wells.
Indirect Methods
The purpose of the indirect approach is to identify,
within a particular state, geographic areas and industrial
and commercial establishments that would be likely to have
Class V wells. This information will be used later in Phase
II to focus on areas and establishments to be investigated
by field visits.
There are numerous indirect methods of determining the
scope of injection well practices through examination and
interpretation of information not specifically developed for
this purpose. For example, some states require the use of a
manifest system for industrial facilities that haul solid and
liquid wastes. This system requires detailed record keeping
of solid and liquid wastes from a production site, through
hauling, to a disposal site. Knowledge of recorded quantities
of wastes at a site could be helpful in determining potential
volumes of waste generation in different industries.
Another indirect method of determining the number of wells
in Class V is to map various physical and economic development
features believed to be associated with the use of Class V
wells. Examples of these features are: (1) unsewered areas
within states; (2) population and concentration of industrial
establishments; and (3) hydrogeologic characteristics which
are conducive to the existence of Class V wells.
Hydrogeologic Environment
Evaluation of the hydrogeologic environment will be based
on collecting existing data from various governmental and other
sources. The key factors that are relevant to the UIC program
are: (1) location of aquifers that are potential underground
sources of drinking water; (2) quality of groundwater: (3)
location of mineral, oil, or geothermal energy-producing zones;
TBS
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V-6
(4) economic and technological limitations which may make re-
covery of groundwater impractical; and (5) areas where ground-
water is so contaminated that it would be impractical to
render the water fit for human consumption. Very general
information about these subjects is available either in raw
form, such as well logs and laboratory analyses, or in compiled
form, such as published reports. Raw data are available from
such agencies as the U.S. Soil Conservation Service, U.S.
Geological Survey, state geological surveys, and state depart-
ments of health, water resources, natural resources, and en-
vironmental protection. Published reports are available from
federal agencies, such as the EPA, the Army Corps of Engineers,
and the U.S. Geological Survey, and from various state agencies.
Technical journals of professional associations are also im-
portant sources of pertinent hydrogeologic data.
It is suggested that information concerning the key factors
be represented in the form of hydrogeologic maps. Maps of this
type may be used to summarize the broad lithologic and hydro-
geologic characteristics of the sites. It is assumed that
the general direction of groundwater flow can be deduced from
these maps or other sources. The first level of effort of
development of these maps will be a small scale compilation,
covering an entire state. Larger scale maps can be developed
in Phase II to provide more detailed information concerning
local groundwater conditions.
Location and Yield of Aquifers
The usability of an aquifer as a continuing source of
drinking water is dependent on its geologic structure and hydro-
logic characteristics, the amount of water in storage, and rate
of recharge. The amount of water in storage can be determined
from the dimensions of the aquifer and the porosity of the
aquifer materials.
The rate of recharpe is dependent on the annual average
precipitation over an area, minus water losses due to evapo-
transpiration and runoff. In humid regions of the United
States, groundwater recharge rates vary from several inches
to over 20 inches per year. In arid regions of the United
States, however, where evapotranspiration losses are equal to
or exceed precipitation, little or no recharge occurs.
Groundwater Quality
Natural groundwater quality can range from poor to excel-
lent, both areally and with depth. Generally, under natural
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V-7
conditions, the shallowest aquifers contain good water in
almost all parts of the country. In places, however, the
natural quality has been degraded by man's activities.
There are numerous methods for describing groundwater quality
which generally involve the determination of the distribution
and concentration of selected chemical and biological constitu-
ents and physical characteristics. A convenient measure of the
potability of groundwater is concentration of the total dis-
solved solids expressed in milligrams per liter. Water with a
TDS content of up to 10,000 mg/1 is considered to have a poten-
tial to be a usable source of drinking water. Water quality
conditions by areas and aquifers can be illustrated on maps and
sections. The basic data consist of chemical analyses of water
samples from either published reports or agency files.
Groundwater Movement
Most groundwater is in continuous movement in aquifers.
The rate and direction of movement are dependent on the perme-
ability and thickness of the aquifer materials, the relative
heads, and the hydraulic gradients. The relation of these
factors is expressed in Darcy's law.
In a groundwater system, there are regions where perco-
lating water from precipitation or from surface-water bodies
moves downward to recharge the aquifer, and in other parts,
water discharges upward or laterally to surface streams, to
oceans, or to other aquifers. In still other places, water
is lost from the shallow parts of the system by evapotranspi-
ration.
Groundwater Use
The dependence of a population on groundwater for public
water supply is reflected in the ratio of groundwater use to
total public water supply use in an area. Present as well as
future groundwater use is important in assessing the vulnerabil-
ity of the hydrogeologic environment to contamination. Major
public water supply wells should be located on a map, noting
quantity of pumpage and location and depth of the supply
aquifer.
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V-8
Determination of Areas for
Further Investigation
A comparison of the results of the several data-gathering
efforts should be done prior to entry into Phase II. The
objective will be to identify geographical areas hypothesized
to contain high concentrations of non-reporting Class V well
operations. This early analysis will serve as the basis for
much of the fieldwork agenda planned for Phase II.
PHASE II; FIELD VERIFICATION
The objective of this phase of the assessment is twofold:
to locate non-reporting Class V operations and to improve the
quality of data on the scope of practices and the hydrogeologic
environment obtained in Phase I. It will require extensive
field work, not only to locate non-reporters, but to verify
and support the analysis and interpretation behind the state
advisory report.
Location of Non-Reporting Class V
Well Operations
Not all Class V well operators will have identified them-
selves by the conclusion of Phase I, either through ignorance or
misinterpretation of the UIC requirements. The state will have
to devote time and effort to the problem of locating these
facilities using means such as direct mailings, telephone calls,
and site visits.
Some states may choose to levy fines or take court action
against Class V facilities that did not identify themselves
during Phase I. These punitive actions would serve to decrease
or increase the costs of locating the non-reporting Class V
operations during the assessment period. Although penalties are
allowed, this study has not included estimates for them in the
manpower and cost analysis. Instead, only estimates for the
general assessment effort shall be included.
Scope of Injection-Well Practices
Significant progress in identifying the scope of Ciass V
well practices in a state could be made by switching from
indirect methods of identification to direct methods in Phase
II. Instead of attempting to infer the likely existence of
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V-9
wells based upon levels of business activity and other charac-
teristics, direct contacts will be made with county and local
officials, industry associations, and business leaders. On a
limited basis, selected site visits will also be conducted.
The site visits will be focused on high priority areas.
They will be directed toward identifying three types of infor-
mation regarding Class V wells: (1) the scope of the prac-
tices (i.e., the number of wells, their uses, and relative
volumes of wastes); (2) the significance of the wells to the
user (i.e., whether they are used to dispose of primary pro-
cess wastes or merely to clean wastes, spills, or other types
of fluid); and (3) the feasibility and costs of environmental-
ly superior alternatives to well disposal.
These topics cannot be addressed with statistical signi-
ficance—the numbers and uncertainty in each category and the
constraints of budgets and time preclude a rigorous statisti-
cal approach. Therefore, this effort will be directed toward
nonstatistical validation and refinement of the Phase I esti-
mate of the scope of the problem. The field work should also
identify some relevant case studies. Finally, it will improve
the understanding on the part of the state project staff of
the issues surrounding the feasibility, costs, and environment-
al effects of alternative methods of disposal at some sites.
Hydrogeologic Environment
One important thrust in Phase II will be to attempt to
substantiate that some contamination occurs from these wells
by performing limited water-quality sampling. Sampling could
be performed on water from existing water supply wells and, even
then, only on a limited basis due to the cost and time required
for thorough analyses of water samples.
Chemical analyses for many constituents, including trace
metals and organics, will have to be performed because the
state staff will be investigating problems about which little
may be known. On the other hand, samples taken near specific
industrial sites may be analyzed only for those constituents
thought to originate from the industrial source.
While this sampling effort may have limited significance
due to the small sample size, it is likely to enhance the
understanding of the problem and, through documentation of
some case histories, to lend credence to the state assessment.
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V-10
Other efforts in the hydrogeologic area are mainly exten-
sions of the Phase I effort. One such task will be to intro-
duce quantitative projections of future groundwater use.
That evaluation should be developed on the basis of state
population projections, and the water resource plans and the
results should be plotted on a series of maps.
Two issues which must be studied but not necessarily
illustrated on maps or overlays are the hydrogeologic fac-
tors of aquifer depth and groundwater movement. Both should
be examined, particularly in areas with a high degree of
groundwater vulnerability, in order to interpret and use the
other information in any final state advisory report.
PHASE III; EVALUATION AND RECOMMENDATIONS
Phase III is the final phase of the state assessment and
will involve analysis and interpretation of data collected in
Phases I and II and the documentation of the findings and
recommendations from the state assessment.
The quantitative data from Phase II will be at least par-
tially in the form of improved Phase I overlay maps. Minor
improvements in hydrogeological data should be incorporated.
The biggest change, though, should be in the quality of the
data on business concentrations and the expected numbers and
types of Class V injection wells.
The results from Phases I and II should provide Phase
III with: (1) an improved quantitative estimate of the scope
of Class V wells and their coincidence with significant hydro-
geological conditions; (2) better qualitative understanding
of the problem posed by Class V wells; and (3) some limited
understanding of feasible solutions for Class V problems.
The state must then establish some priorities based on a
ranking of the problems by geographic locations, type of
industry, type of well, volume and toxicity of substances
being injected, and other factors where needed.
Finally, the state must organize and document all of the
information and analyses which it collected during the assess-
ment. This must be compiled in such a way that it can form
the basis for the development of a formal set of recom-
mendations to be submitted to EPA. The results of the assess-
ment and the recommendations will be used to help formulate
a national regulatory plan of action.
T
B
s
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V-ll
At the conclusion of the assessment effort, the state
director must submit the following to EPA19:
• "An assessment of the contamination potential of
the Class IV wells using information supplied by
the operator and hydrogeologic data available to
the State";
• "An assessment of the available corrective alter-
natives where appropriate and their environmental
and economic consequences"; and
• "Recommendations both for the most appropriate
regulatory approaches and for remedial actions
where appropriate."
The recommendations could suggest a combination of regu-
latory forms such as a permit program for a small number of
very serious practices; a set of rules for the construction and
use of many wells which could constitute a ban on some forms;
and no action at all on certain wells. The form of the national
regulatory program will depend upon the sum of the 57 states' and
territories' assessment of the scope of the practices, the
magnitude of the potential contamination threat, and the feasi-
bility of technical alternatives to the Class V wells. It is
that eventual use to which the entire assessment process will be
directed.
19
"State Underground Injection Control Regulations," Federal
Register, Vol. 44, No. 78, April 20, 1979, p. 23766.
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VI. STATE PROGRAM MANPOWER AND COSTS-
CLASS V WELLS
INTRODUCTION
An important element in developing the UIC program is
estimation of the level of staffing and funding required by
state agencies to carry out the assessment and use its results
to form a set of recommendations for future regulatory action.
The previous section described the steps of the assessment
process. This section presents personnel and cost estimates
for the entire Class V assessment program and is based on
discussions held in 1978 with state officials in 22 states.
All these states have regulatory requirements to protect
underground sources of drinking water, but the regulations in
these states range from broad, general statements to specific
requirements. Likewise, there is wide variation from state
to state regarding the number of existing practices, the
amount of available data describing those practices, and the
level of detail of hydrogeologic data.
STAFFING
In the previous chapter, three phases were described in
the guidelines to conducting an assessment. Phase I is char-
acterized by program planning and assembling and reviewing
existing data; Phase II by developing new sources of data to
supplement and validate existing information; and Phase III
by analyzing these data, determining technological alternatives
to existing practices, setting priorities for a regulatory
approach, and preparing an advisory report containing a set
of recommendations for the most appropriate regulatory approach
and for remedial actions where needed.
The number of persons required for an assessment and pre-
paration of an advisory report is dependent on the scope of the
well practices, the status of information, and the extent of
regulations that currently exist in each state. Three general
levels of effort have been identified during discussions with
state officials. These are shown in Table VI-1 and are labeled
minimal, moderate, and extensive. Each level of effort would
TBS
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VI-2
enable the states included within the category to fulfill the
UIC requirements for states in evaluating Class V wells.
Table VI-1
STAFFING REQUIREMENTS
ASSESSMENT AND ADVISORY
Phase I
FOR
REPORT
Phase II
Time: 6 months Time: 6 months
Minimal Effort
Supervisor
Professional Staff
Support Staff
Total
Moderate Effort
Supervisor
Professional Staff
Support Staff
Total
Extensive Effort
Supervisor
Professional Staff
Support Staff
Total
.1
.3
.6
1.0
.2
.5
1.0
1.7
.5
1.5
1.0
3.0
.1
.3
.6
1.0
.2
.5
1.0
1.7
.5
1.5
1.0
3.0
Phase III
Time: 12 montns
.2
.3
.6
1.1
.3
.5
1.2
2.0
1.0
1.5
1.5
4.0
The level of effort required during the first six months
of the assessment process would range from one full-time person
in each of the states requiring minimal effort, to 1.7 full-time
persons in those states needing moderate effort, to three
full-time persons where extensive effort would be required. In
each of these cases, a supervisor would be needed to coordinate
the effort. He would be assisted by other professional and
support staff.
The supervisor would be a senior staff person who would
be responsible for both the assessment and advisory report. He
would provide continuity and leadership for the program and
would coordinate the activities of the professional and support
staff, other contributing agencies, and state legislative
resources. An academic background consisting of an advanced
degree in groundwater hydrology, geology, environmental or
water-resources engineering, or a similar field of study,
T|B|S|
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VI-3
or the equivalent, would be a prerequisite, along with at
least five years of experience in related fields. This posi-
tion requires a wide range of administrative ability coupled
with practical and theoretical experience. State officials
indicated that such a supervisor could be drawn from existing
state personnel, and may have other UIC program responsibili-
ties simultaneously.
The prerequisites for the professional staff positions
would be a B.S. degree in the areas of groundwater hydrology,
geology, or perhaps environmental or water-resources engi-
neering, and two or more years of field experience, preferably
within the same state. Some state officials believe that
professional staff would be readily available. In other states,
there was some doubt about the ability to successfully fill
these positions.
The required level of effort for the states and terri-
tories was based on the following criteria: 1) industrial
concentration; 2) population concentration; 3) hydrogeologic
conditions; 4) extent of regulation; and 5) physical size of
state. It was determined that, of the 22 states contacted
during this study, approximately 8 would require a minimal
level of effort, 7 would require a moderate level of effort and
7 would require an extensive level of effort. Of the remaining
35 states and territories, approximately 23 are expected to
require a minimal level of effort, 11 are expected to require a
moderate level of effort, and 1 is expected to require an
extensive level of effort. Table VI-2 shows the aggregate
staffing needs for all Class V requirements.
Table VI-2
AGGREGATE STAFFING REQUIREMENTS
FOR TWO YEARS OF PROGRAM ASSESSMENT
Level of Effort
Minimal
Moderate
Extensive
Total
Note: Total is for
territories.
and support
Man-Years
Per State
3.1
5.4
10.0
the two years of
It is based on
staff.
Estimated
Number of States Total
31
18
8
57
assessment and for all 57 states
a mix of supervisor, professional
Man-Years*
96.1
97.2
80.0
273,3
and
staff,
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VI-4
STATE COSTS
The levels of effort discussed above form the basis for an
estimate of costs for each state. During interviews with state
officials in 1978, prevailing salary ranges for state employees
were identified. These wages were for 1977 and are expressed
in terms of 1977 dollars. Their salaries included fringe
benefits and other direct overhead items which were estimated
to range from 35 to 100 percent of base salary. Supervisory
salaries and overhead expenses ranged from $28,000 to $38,000
per year. The salary and overhead for professional staff
ranged from $20,000 to $28,000 per year. Supporting staff
salary and overhead costs ranged from $14,000 to $20,000 per
year. Direct expenses for travel, per diem, supplies, and
other items were estimated at $1,000 per man-year. This $1,000
figure is an average of field staff, who would spend more than
this amount, and office staff and the supervisor, who would
spend less.
The analysis of state program costs for Class V injection
wells differs from the analysis of costs for Class I, II, and
IV. In the latter analyses, an average annual salary of
$22,500 was used to evaluate the costs to states. The $22,500
amount represented the NPDES staffing experience of a mix of
supervisory, technical and clerical personnel required to carry
out that program. In addition to the $22,500, direct expenses
of $3,500 per man-year were budgeted to cover office supplies
and travel. The salary ranges for Class V staffing are equiva-
lent to the NPDES program but the mix of personnel differs. In
NPDES, experience has shown the mix to be approximately 70/30
supervisory and technical to clerical; in Class V administra-
tion it is anticipated to be approximately 40/60 for a minimal
effort and 2/1 for a maximum effort. These are shown in
greater detail in Table VI-1.
Another determinant of costs discussed during the inter-
views with state officials was the method that would be used
to acquire personnel to carry out these tasks. The alterna-
tives discussed were: 1) hiring individuals on a contractual
basis; and 2) hiring permanent staff under civil service or
other state government personnel systems. The general prefer-
ence was for contractual hirees to fill professional and sup-
port staff positions, because the state personnel systems were
considered to be rigid and frequently constrained by personnel
ceilings, and because employees would have to be hired for the
long term. Contractual hirees, however, might be more expen-
sive and less likely to be accepted by existing state staff
and, perhaps, by plant personnel in the industries visited.
The final decision apparently would be determined to a large
extent by the prevailing state legislative climate towards
hiring.
TBS
-------
VI-5
Table VI-3 shows the estimated cost requirements for a
single state based on minimal, moderate, and extensive levels of
effort during the assessment and state plan phases. These costs
reflect the range of salary levels supplied by state officials
and the mix of personnel shown in Table VI-1, and cover eighteen
months of assessment work and six months of advisory report
development. Individual state costs for the first six months
range from $18,000 to $84,000. Costs for the program range from
$57,000 to $282,000 per state, depending upon the level of
effort required in the state.
Table VI-3
COSTS OF ASSESSMENT AND ADVISORY REPORT
(per state*)
(thousands of 1977 dollars)
Level of
Effort
Phase I
Minimal $18-$25
Moderate $31-$43
Extensive $61-$84
Two-Year
Phase II Phase III Total
$18-$25 $21-$29 $57-$79
$31-$43 $37-$51 $99-$137
$61-$84 $83-$ 1H $205-$282
Based on a mix of supervisor, professional staff, and
support staff, as shown on Table VI-2.
Table VI-4 shows the estimated cost requirements for the 22
designated UIC states for the first year of the program. These
costs are developed for three estimated levels of effort based
on the status of existing inventories, regulatory approach, and
level of industrial concentration. Total costs for two years
range from $2.7 million to $3.7 million.
Table VI-5 shows the average total costs for assessment
and state plan for 57 states and territories. On a national
basis, the total program cost range is $5.2 million to $7.2
million for the two years.
T|B|S
-------
VI-6
Table VI-4
ASSESSMENT AND ADVISORY REPORT COSTS
FOR 22 DESIGNATED UIC STATES
(thousands of 1977 dollars)
Level of
Effort
Minimal
Moderate
Extensive
Total
Number of
States
22
Total Cost
for Two Years
S 456-S 632
$ 594-$ 822
$1,640-52,256
$2,690-$3,710
Table
VI-5
ASSESSMENT AND ADVISORY REPORT C
FOR 57 STATES AND TERRITORIES
Level of
Effort
Minimal
Moderate
Extensive
Total
(thousands of
Average
Cost Per
State
$ 57-$ 79
$ 99-S137
$205-5282
1977 dollars)
Number of
States
31
18
3
57
OSTS
Total Cost
for Two Years
$1,767-12,449
$1,732-12,466
$1,640- $2, 256
SS/SQ-S?,!/!
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Appendix A
SUMMARY OF CONTACTS WITH
STATE OFFICIALS
IT
B
S
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Appendix A
SUMMARY OF CONTACTS WITH STATE OFFICIALS
Information for this appendix was obtained by Geraghty
& Miller, Inc. and Temple, Barker & Sloane, Inc. during the
period July 1977 - March 1978.
Source:
ARKANSAS
Mr. Bill Wright
Geologist (interview)
Oil and Gas Commission
El Dorado, Arkansas
November 3, 1977
ARKANSAS
Mr. Hugh Hanna, Chief
Mr. Chuck Crawson,
Geologist
(interview)
Department of Pollution
Control and Ecology
Little Rock, Arkansas
November 3, 1977
CALIFORNIA
Mr. Thomas E. Bailey,
Assistant Chief
(written response)
Division of Planning
and Research
State Water Resources
Control Board
Sacramento, California
July 27, 1977
Comments;
The Oil and Gas Commission regulates
injection wells and only permits in-
jection into a zone in which TDS con-
centration is greater than 20,000 mg/1.
It was estimated that excluding oil
and gas related injection wells,
there are: one sulfuric acid in-
jection well and two cooling water
blowdown injection wells.
Class V wells are not considered a
major threat to groundwater; however,
leaky septic tanks have caused ground-
water contamination in several cities.
There are a few industrial septic tanks,
but a dense concentration of household
and municipal septic tanks have caused
groundwater contamination. In addition,
some older brine injection wells are
completed in sources of groundwater.
Estimates were obtained from knowl-
edgeable officials in State
Regional Water Quality Control
Boards. These officials gave
gross estimates of the number of
shallow disposal and recharge wells of
each type. It was indicated that de-
velopment of detailed information
would require many man-years, and in
the case of drainage wells, the in-
formation is physically impossible to
obtain. The responses he submitted
from his inquiry are summarized in
Table A-l.
TlBlSl
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A-2
CALIFORNIA
Mr. Alvin Franks,
Supervising Engineering
Geologist
(interview)
Division of Planning
and Research
State Water Resources
Control Board
Sacramento, California
November 28, 1977
COLORADO
Mr. Frank J. Rozich,
Director
Water Quality Control
Board
Mr. George A. Prine,
Chief
General Services Section
Colorado Department of
Health
Denver, Colorado
Mr. Carrol G. McDowell,
Petroleum Engineer
Oil and Gas Conservation
Board
Mr. John Romero, Chief
(interview)
Water Resources Engineer
Division of Water Resources
Department of Natural
Resources
Denver, Colorado
July 28, 1977
CONNECTICUT
Mr. Bob Moore (telephone
interview)
Division of Water
Compliance and
Hazardous Substances
Department of Environmental
Protection
Hartford, Connecticut
December 15, 1977
The city of Modesto is about 75
percent sewered. In non-sewered
areas there are numerous wells in-
jecting into or above freshwater
aquifers. The Modesto Health
Department tried to document the
number of septic tanks being used
in the city, but was not successful
There are probably some Class IV
and V wells, but the state has
adopted rules to control subsurface
disposal and feels that the issue is
being properly addressed. There
may be perhaps 25 illegal industrial
discharges to Class IV and V wells
by small industries.
There are no known nor allowed
wells injecting into or above fresh-
water aquifers in the state. Most
industries discharge their waste to
municipal sewage systems.
T
B
S
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A-3
FLORIDA
Mr. Ralph H. Baker, Jr.,
Chief
Bureau of Drinking Water
and Special Programs
Mr. Nick Mastro,
Assistant Enforcement
Administrator
(interview)
Division of Environmental
Permitting Department
of Environmetnal
Regulation
Tallahassee, Florida
July 12, 1977
FLORIDA
Mr. Frederick Meyer
(telephone interview)
U.S. Geological .Survey
Miami, Florida
July 22, 1977
FLORIDA
Mr. Mohammad Husain
(telephone interview)
Department of
Environmental
Regulation
Tallahassee, Florida
March 1, 1978
IDAHO
Jack Sceva, Geologist
(interview)
U.S. EPA-Region X
Seattle, Washington
September 8, 1977
It was indicated that wells in-
jecting into or above freshwater
aquifers are numerous and that
partial inventory of these wells
has documented 6,080 such wells.
(See interview with Mr. Husain
below.)
There may be about 8,r)00 drainage
wells in Dade County. In Orange
County, a study by the U.S. Geological
Survey indicated that a total of 419
such wells are in operation. In ad-
dition, it was indicated that there
could be as many as 10,000 drain-
age wells in the state.
Information in a reoort entitled
Inventory of Drainage Wells, July 21,
A-2).
1977, was
All wells
are under
verified
recorded
permit.
(see Table
in this
In Idaho, there are several hundred
drainage wells. In addition, there
are approximately 5,000 Class IV and
V wells in industrial, agricultural ,
and municipal categories.
TBS
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A-4
ILLINOIS
Mr. Rauf Pi skin
Environmental Geologist
Division of Land and
Noise Pollution Control
Mr. Thomas E. McSwiggin
Manager, Field Operations
(interview)
Division of Water Pollution
Control
Illinois Environmental
Protection Agency
Springfield, Illinois
July 27, 1977
INDIANA
Mr. Joe Stallsmith,
Chief
(written response)
Enforcement Branch
Division of Water
Pollution Control
Indiana State Board
of Health
Indianapolis, Indiana
August 17, 1977
KANSAS
Mr. Bruce Latta, Chief
Oil Field and
Environmental Geology
Section
Mr. Marvin f. Glotzbach
Geologist (interview)
Bureau of Water Quality
Division of Environment
Department of Health and
Environment
Topeka, Kansas
Mr. Alan Me FarIan
EPA—Region VII
UIC Coordinator
Kansas City, Missouri
November 28, 1977
KANSAS
Mr. Herman Jansen
(interview)
Department of Health and
Environment
Topeka, Kansas
November 28, 1977
There are at least several hundred
shallow industrial disposal wells.
Some estimates run as high as sev-
eral thousand wells injecting into
or above freshwater aquifers.
There is no accurate count avail-
able of the number of
jecting into or above
aquifers. '?hen these
are identified during
field investigations,
we 11 s i n -
freshwater
•practices
routine
steps are
are taken to eliminate them.
Industrial and municipal waste
water is not being discharged
through shallow wells to under-
ground sources of drinking water.
In 1973, the state started permit-
ting air-conditioner and cooling-
water return-flow wells.
The number of septic systems in
the state is estimated to range
from 50,000 to 100,000; 95% are
believed to be residential systems.
Therefore there could be 5,000
Class V wells.
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A-5
KENTUCKY
Mr. Michael McCann, Geo-
logist (written response)
Division of Water Quality
Department of Natural
Resources and Environ-
mental Protection
Frankfort, Kentucky
January 24, 1978
LOUISIANA
Mr. Charles E. Bishop,
Assistant Director
(written response)
Bureau of Environmental
Sciences
Office of Health Services
and Environmental Quality
Department of Health and
Human Resources
New Orleans, Louisiana
December 15, 1977
MARYLAND
Mr. Arnold Schiffman,
Chief
(written response)
Permits Division
Water Resources
Administration
Department of Natural
Resources
Annapolis, Maryland
December 15, 1977
MISSISSIPPI
Mr. John Harper, Chief
Law Enforcement
Mr. Charles Branch
Industrial Waste-Water
Section
(interview)
Air and Water Pollution
Control Commission
Jackson, Mississippi
November 4, 1977
No data have been compiled for
information concerning wells
injecting into or above under-
ground sources of drinking water,
No known wells injecting into or
above freshwater aquifers in
state.
There are between 2,500 and 3,500
non-domestic septic system wells
in the state.
There are some brine injection
wells discharging into underground
sources of drinking. It was
indicated that there are a few
wells injecting into or above
freshwater aquifers in the state
and are not a cause of groundwater
contamination.
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A-6
NEW MEXICO
Ms. Maxine Goad, Program
Manager (written response)
Water Quality Division
Permits and
Regulation Section
Environmental Improvement
Agency
Department of Health and
Social Services
Santa Fe, New Mexico
January 24, 1978
NEW YORK
Mr. Robert O'Reilly
Principal Engineering
Technician (interview)
Department of
Environmental
Conservation
Stony Brook, New York
November 9, 1977
NEW YORK
Mr. James Pirn, Chief
(interview)
Water Pollution Control
Section
Suffolk County Department
of Environmental
Control
Hauppauge, New York
November 9, 1977
NEW YORK
Mr. Francis Pader,
Assistant Deputy
Commissioner
(interview)
Nassau County Department
of Health
Mineola, New York
November 10, 1977
OHIO
Mr. Russell B. Stein
Geologist
Public Water Supply
Department
Mr. John Noyes, Geologist
(interview)
It was indicated that the practice
of waste disposal through wells exists
in several well categories defined in
this report, but little information
is available. In addition, if the
definition of drainage well is
interpreted broadly the count could
represent a very large number.
It was estimated that there are
approximately 1,000 air-conditioning
return-flow wells, based on the num-
ber of state permits. No information
is available for other wells injecting
into or above underground sources
of drinking water.
In Suffolk County, most industries
inject wastewater through leaching
beds. The major industries in this
county that discharge to ground-
water are metal finishing, pharma-
ceutical, and food processing. No
estimate of the number of wells
injecting into or above freshwater
aqui fers.
In Nassau County there are ap-
proximately 3,000 industrial
firms discharging organic
chemicals. A large percentage
of these firms discharge to
groundwater through cesspools.
Probably 200 air-conditioning
return-flow wells are concentrated
in the cities of Dayton, Columbus,
and Cincinnati. In addition, in
the City of Zanesville conventional
cased wells are used to dispose of
waste fluids into mines. Based on
-------
OHIO (continued)
Ohio Environmental
Protection Agency
Columbus, Ohio
July 14, 1977
A-7
the population of Zanesville, there
may be at least 5,000 conventional
cased wells. A report to the Ohio
Water Commission indicated there
may be 1,600 conventional cased
city of Bellevue. This
diminished since the
of a sewer system in the
reported that the State
wells in the
practice has
installation
city. It was
Board of Health believes there may be
as many as 200 floor drain dry wells
being used for industrial waste
disposal.
OREGON
Jack Sceva, Geologist
(interview)
U.S. EPA-Region X
Seattle, Washington
September 8, 1977
OREGON
Mr. R. Nichols
Mr. W. W. Bartholomew
(written response)
Water Resources Division
Department of
Environmental Quality
Portland, Oregon
January 10, 1978
PENNSYLVANIA
Mr. Carlyle Westlund,
Chief
Division of Water Quality
Mr. John Osgood, Chief
(interview)
Ground-Water Quality
Management Unit
Ground Water Section
Bureau of Water Quality
Management
Department of Environ-
mental Resources
Harrisburg, Pennsylvania
September 23, 1977
In Oregon there are approximately
3,000 wells injecting into or above
underground sources of drinking
water, including street drainage
wells.
There are at least 5,000 non-domestic
septic system wells and at least
2,000 drainage wells that are limited
to Central Oregon. In addition, it
is estimated that there are at least
20 air-conditioning and cooling return-
flow wells. No estimate is available
for the number of sumns, cesspools
and dry wells, located primarily in
Multnomah County.
There are an estimated 10,000 con-
ventional cased wells injecting sewage
into deep mines, 2,000 abandoned water
wells receiving wastes, and at least
500 highway drainage wells. An esti-
mated 55,000 sand-backfill wells have
been drilled to inject Ely ash slurry;
however, there is no estimate of the
present number in operation. There-
fore, the number of these wells and
their volume of injected fluid are
not included in the inventory.
TBS
-------
A-8
TEXAS
Mr. Bob Kent, Geologist
(interview)
Department of Water
Resources
Austin, Texas
November 21, 1977
TEXAS
Mr. W. Fred Rogers,
Director
(interview)
Environmental Health
Services
Austin-Travis County
Health Department
Austin, Texas
November 21, 1977
VIRGINIA
Mr. E. W. Ramsey,
Geologist
(written response)
State Water Control Board
Richmond, Virginia
January 18, 1978
WASHINGTON
Mr. Michael Palko
Division Supervisor
(interview)
Office of Field
Operations
Department of Ecology
Olympia, Washington
September 9, 1977
There are approximately 300 conven-
tional recharge wells in the High
Plains area of the state.
Non-domestic septic systems are
generally used by restaurants,
with approximately 2,000 of these
systems in Austin and a total of
2,500 in Travis County. Dallas,
Fort Worth, Houston, and San
Antonio have extensive sewer sys-
tems .
There are approximately 120
drainage wells in the state.
Only a few wells injecting into
or above freshwater aquifers are
known to exist. Due to the
large number of streams and
rivers, much of the waste that
might otherwise be injected is
discharged to surface water under
NPDES permit.
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A-9
Table A-l
ESTIMATED NUMBER OF WELLS INJECTING INTO OR ABOVE FRESHWATER
AQUIFERS IN THE STATE OF CALIFORNIA^
Category
Disposal
Conventional Cased Wells
Cesspools, Sumps, and Orywells
Total
Recharge
Conventional Recharge Wells
Drainage Wells
Air-Conditioning and Cooling-Water
Return-Flow Wells
Salt-Water Intrusion Wells2
Subsidence Control Wells^
Total
Grand Total
Count
500
2,120 (! 20%)
2,620
170 (! 5%)
8,850 (t 10%)
1,300 (t 40%)
300
300
10,920
13,540
2
3ased on estimated count from Regional Water Quality Control
Boards, Thomas E. Bailey, Assistant Chief, Division of Planning
ana Research, State Water Resources Control Board, Sacramento,
California, September 2, 1977.
Based on count in EPA-Preliminary Evaluation of Well-Injection
Practices, Geraghty & Miller, Inc., April 1977.
TlBlSI
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A-10
Table
INVENTORY OF DRAINAGE WELLS IN THE
Storm Water
Runoff
County Wells
Alachua 2
Bradford
Brevard
Broward 31
Citrus 1
Clay 1
Collier
Columbia
Oade 145
Ouval 1
Escornbia
Hamilton 4
Hardee 5
Hernando
Hillsborough 3
Jackson 2
Jefferson 1
Lake 1
Leon 5
Levy 5
Madison 6
Manatee
Marion 12
Nassau
Orange 19
Palm Beach 11
Pasco
Pinel las
Polk
Putnam 1
Sarasota 1
Seminole 1
Sumter
Suwanee 55
Taylor
Volusia
Washington 1
Total 314
Surface Water Laundry
and Lake Level Waste
Control Wells Wells
2
1
1
1
259 54
1
1
4
5
1
13
1
154 2
1
4
1
3
1
451 60
No wells counted in 28 counties.
Includes wells used for disposal of swimming pool
A-2
STATE OF FLORIDA BY COUNTY 1, 3
Air-Cond. Effluent Industrial
Return-Flow Sewage Waste
We 1 1 s We 1 1 s We 1 1 s
5
. .
7
7 1
4
1
2,637 6 146 1
2
3
1
2
100 1
1
3
37
10
15 1
2
21 4 1
10
9
68
7 1 6
1
14
1
1
44
3,009 15 156 2
water, wastes from water softener
Other
Wells2
.
1
4
1
,955
4
1
2
5
8
58
1
2
25
1
5
1
1
,075
Total
9
2
8
43
2
2
5
1
5,205
3
3
5
6
2
108
2
3
9
47
5
9
10
46
3
209
79
10
70
40
7
21
5
1
57
1
44
1
6,080
equipment, and other wastes.
Source: Mohammad Husain
, Florida Department of Environmental Regulation, 1977.
T
B
S
-------
Appendix B
REGULATORY HISTORY--
WELL CLASSES IV AND V
-------
Appendix B
REGULATORY HISTORY-
WELL CLASSES IV AND V
As part of this investigation, federal and state laws and
regulations were reviewed to: (1) provide background informa-
tion on regulatory authority and (2) determine the extent of
present state programs. Based on this information, four alter-
native methods of regulation were formulated. The alternatives
are compared briefly in this study. One regulatory approach
stands out as superior and serves as the basis for the cost
estimates presented in the body of this report.
FEDERAL PrtOGKAMS
Safe Drinking Water Act
The purpose of the Safe Drinking 'Water Act of 1974 (PL 93-
523, referred to as "the Act") is to protect water quality of
public water-supply systems, which are defined in Part B of the
Act as systems having at least 15 service connections or regu-
larly serving at least 25 individuals. The Act prescribes two
methods of meeting this goal: (1) establishment of drinking-
water standards, and (2) establishment of a system of assuring
compliance with these standards
sources of drinking water.
and protecting underground
method of
means of a
of the Act,
following
injection
Act; (2)
of assuring
(3) assur-
Part C (Sec. 1421-1424) of the Act calls for a
protecting underground sources of drinking water by
state system of regulation. Under the requirements
state regulatory programs must provide at least the
items: (1) prohibition of unauthorized underground
effective within three years after enactment of the
requirement of applicant to bear the responsibility
protection of underground sources of drinking water;
ance that no regulation would allow endangerrnent of underground
drinking water sources; (4) inspection, monitoring, record-
keeping, and reporting; (5) control over injection by federal
agencies, whether or not the injection occurs on property owned
or leased by the federal government; and (6) non-interference
with oil and gas production, unless such requirements are
essential to assure protection of underground sources of drink-
ing water.1
ipart C, Section 1421, PL 93-523, 93rd Congress,
December 16, 1974.
. 433,
TIBISI
-------
B-2
Committee Report
The House of Representatives Committee Report (Report No.
93-1185) that accompanied the Act broadly defines "underground
injection" to include the underground emplacement of any con-
taminant, but not be limited to injection of wastes or injection
for disposal. Single-family septic tanks and other residential
waste-disposal systems are, however, specifically excluded from
the regulatory program.
The Committee Report also broadly defines "underground
injection which endangers drinking water sources" to cover any
contaminant which may be put below ground level and which flows
or moves, whether the contaminant is in semi-solid, liquid,
sludge, or any other form or state that would prevent a public-
supply system from complying with any primary water standard,
or otherwise pose a threat to public health. The Committee
Report indicates that all subsurface water with less than
10,000 mg/1 of total dissolved solids should be designated as
an underground source of drinking water, regardless of whether
or not it is presently being used as such.
Previously Proposed UIC Regulations
On August 31, 1976, proposed regulations for the State
Underground Injection Control Program (40 CFR Part 146) were
published in the Federal Register by EPA. In the proposed
regulations, Subpart C covered industrial and municipal waste-
disposal wells, subsidence control wells, barrier wells, re-
charge wells, mining wells, storage wells, and geothermal wells;
Subpart D covered oil and gas related wells; and Subpart E
covered drainage wells.
Wells that were listed in Subpart C are used to inject
fluids that range in water quality from relatively clean water
(recharge wells) to industrial wastewater (disposal wells).
In addition, these wells range in depth from a few feet to
several thousand feet. Under Subpart C of the August 31, 1976,
proposed regulations, these wells would have been regulated by
permi t.
That set of the proposed regulations separated wells into
categories based on their function and design rather than on
their depth and the quality of water in tue zone of injection.
Classification based on function, however, produced major dif-
ficulties. For example, wells to be permitted in Subpart C
were required to have a casing cemented from the injection zone
ITIBIS
-------
B-3
to the land surface to protect water containing 3,000 mg/1 or
less of total dissolved solids. This requirement would have
prohibited the use of most subsidence control wells and salt-
water intrusion wells because these wells are usually designed
to inject into water of this quality. Due to the permitting
requirement, wells covered in Subpart C that inject into under-
ground sources of drinking water would have been subject to
stricter control than wells covered in Subpart E, which also
may inject into underground sources of drinking water.
In 1977, EPA drafted another set of UIC regulations for
internal review. These regulations separated injection wells
into four categories that were described under Subparts C, U,
E, and F. Subpart C covered wells used for disposal of munici-
pal or industrial wastes into saline aquifers. Subpart D
regulated wells used for oil and gas production. Subpart E
covered wells used for mining, geothermal wells, and in situ
gasificaton wells. Subpart F was involved with all wells in-
jecting into or above freshwater aquifers.
CURRENT STATE REGULATORY PROGRAMS
All states have regulatory requirements to protect under-
ground sources of drinking water. The coverage in each state
ranges from broad, general statements to very specific in-
structions for banning, permitting, monitoring, and reporting
requirements.
According to state officials who were contacted in the 22
states surveyed during this study, several states currently
ban all practices which inject into or above freshwater sources.
These states include Arkansas, Connecticut, Illinois, Kentucky,
Louisiana, ana Mississippi. The remaining states allow certain
practices by rule or permit.
Control of these practices is typically the responsibility
of more than one agency in each state. For example, in Cali-
fornia, multi-unit septic systems serving greater than five
units and saltwater barrier injection wells are the responsi-
bility of the Regional Water Quality Control Boards, while other
practices are regulated by the Division of Oil and Gas and
Department of Health. In Texas, practices are regulated by the
Texas Department of Water Resources, county health departments,
city health departments, and the Department of Agriculture. No
state currently has centralized responsibility for all practices
that would be covered by an Underground Injection Control program,
T|B|S|
-------
B-4
The following table (Table B-l) summarizes current regu-
latory programs for states where information was available.
The description of state programs in the table gives the
appearance of more comprehensive protection from the effects
of these types of wells than actually exists in most states.
The major reason for this variance is the lack of a comprehen-
sive state-level approach to regulation of these wells. Also,
most state programs are limited to responding to individual
complaints on a case-by-case basis.
Table B-l
EXISTING STATE PROGRAMS FOR WELLS WHICH
INJECT INTO OR ABOVE DRINKING WATER SOURCES
FOR 17 STATES REPORTING INFORMATION
State
Arkansas
Cali fornia
Colorado
Connecticut
Florida
I1linois
Indiana
Regulatory Program
No new wells allowed. Existing wells
closely regulated by Oil ana Gas
Commission and Department of Pollution
Control and Ecology.
State Water Resources Control Board,
Department of Health, and Division
of Oil and Gas have extensive permit,
monitor, and report requirements.
Regulation by rule and permit by Depart-
ment of Health, Water Quality Control
Commission, and Oil and Gas Conservation
Board.
No wells allowed.
Most wells under permit and controlled
by the Department of Environmental
Regulation.
Most practices banned by state laws.
Illinois EPA has authority.
All practices banned by the State Board
of Health, Division of Water Pollution
Control.
(continued)
T|B|S
-------
B-5
State
Kansas
Kentucky
Louisiana
Maryland
Mississippi
New Mexico
New York
Ohio
Pennsylvania
Texas
Table B-l (continued)
Regulatory Program
No practices allowed.
No practices allowed.
No practices allowed.
Extensive regulations under authority of
Department of Natural Resources.
Most practices not allowed, regulated by
Air and Water Pollution Control Commission.
New injection practices after June 1977
are required to have an "approved discharge
plan." For practices in use before June
1977, a discharge plan may be required by
the director^ of the agency on a case-by-
case basis.
Regulation by rule and permit by Depart-
ment of Environmental Conservation and
Department of Health. Some practices
banned, especially industrial wastewater
disposal.
Municipal waste disposal permitted by
Department of Health. Industrial disposal
banned. Permits required for cooling
water and air conditioning return flow
wells by the Ohio EPA.
The Department of Environmental Resources
issues permits for the injection of sec-
ondary treated effluent through disposal
wells until an alternative method of dis-
posal is completed.
Regulations are extensive and enforced by
several agencies including city and county
health departments, Texas Department of Water
Resources, and Department of Agriculture.
'In this report, director refers to the state official who is
responsible for regulation of wells injecting into or above
underground sources of drinking water.
TlBlSl
-------
B-6
SELECTION OF REGULATORY ALTERNATIVES FOR WELLS
INJECTING INTO OR ABOVE FRESHWATER AQUIFERS
In determining a method of regulating these wells,
the following factors were considered:
• Degree of drinking water protection
• Federal and state regulatory concerns
—consistency with intent of the Safe Drinking
Water Act
—internal consistency with UIC program
—consistency with other current EPA programs
—consistency with states' current levels of
technical data and support
—likelihood of acceptance of primacy by states
—ease of administration
--level of federal, state, and industry costs
--technical feasibility of alternatives
• Industry concerns
--technical feasibility of alternatives
--costs to industry
The most important consideration and the purpose of the
entire UIC program is the protection of underground sources of
drinking water. However, all factors must be addressed when
comparing regulatory alternatives and in choosing the best
option that can be reasonably implemented.
Alternative Regulatory Approaches
Four alternative approaches were formulated for regulation
of wells which inject directly into or above underground sources
of drinking water:
1. Within the UIC regulations, require a permit
program for at least some of these practices
2. Within the UIC regulations, require the states
to assess the threat of contamination from these
wells and submit a detailed state plan to the
administrator^
In this report, administrator refers to the federal EPA offi-
cial who is responsible for administration of the UIC program,
TBS
-------
B-7
3. Withdraw consideration of these wells from the UIC
regulations and study them in a separate national
assessment
4. Within the UIC regulations, require state assess-
ment of these wells coupled with regulatory control
over the most potentially harmful practices.
The following is a discussion of each alternative and a
presentation of recommendations for the most appropriate
regulatory approach.
Alternative 1; Permit Program for
at Least Some Practices
Disposal wells and recharge wells are numerous and would
be difficult to permit on an individual or group basis, which
a permit-program approach would require. Many disposal wells
are illegal, hidden from view, and impossible to detect except
by a detailed field inspection. For example, a small commercial
laboratory may dispose of chemical waste fluids through a well
in the basement of the building. Even where such polluters
are aware of the illegality of their practice, they may prefer
to remain anonymous as alternative waste-disposal methods would
be costly or infeasible due to physical and geological condi-
tions. In extreme cases, marginal industrial operations could
be forced out of business should expensive waste treatment
facilities be mandated by the state agency.
A permit program is a compromise between a ban and study
approach because a total, immediate ban of shallow waste-disposal
wells would be economically disruptive, administratively dif-
ficult, and practically impossible.
The following are the suggested major components of a
permit program:
• The director would have the discretion to ban
immediately those categories of practices which
present an unreasonable risk to health, and to
ban, after an appropriate period of time, all
categories of practices for which economically
feasible alternatives exist
• The state director would determine, for those
practices not banned, which practices in his
state should be regulated by permit rather than
by rule
TIBISI
-------
B-8
• For those practices to be regulated by permit
the state director would determine when and
where to allow exemptions based on criteria such
as low toxicity and/or low volume, hydrogeologic
characteristics, and population in the area
relying on the affected underground sources of
drinking water
• Some means would be allowed by which the director
could group wells for area permits, thereby
reducing the administrative burden
• Permits would be issued for practices over a
period of a few years with priorities established
for issuing permits for wells requiring greatest
control first
• The director would impose monitoring, record-
keeping, and reporting requirements for each per-
mit as would be necessary to protect public health
In addition, the director would require public
notification for each permit before its issuance
and require that the injector periodically show
that his well continues to be the best environ-
mental means of disposing of the waste.
Pros and Cons of a Permit Program
A permit program would provide maximum protection of un-
derground drinking water sources within the shortest time
frame. It would be consistent with other Subparts of the UIC
regulations.
An effective permit program would be costly, however, as
substantial effort would be required to locate individual wells
that are typically hidden from view. Operators probably would
not come forward voluntarily unless they were convinced that
they would be caught, and that they would receive an exemption
anyway. State officials have expressed a lack of support for
a permit program due to a belief that a response to complaints
of contamination is more effective and a belief that their ad-
ministrative burden would be excessive. In fact, some states
would probably reject primacy if many of the wells injecting
into or above potable aquifers were required to be regulated by
permit.
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Additionally, it is impossible to argue with certainty that
technological alternatives to current practices are economically
feasible for all shallow disposal and recharge well practices.
Case histories indicate that several years' time and the cooper-
ation of several groups, including state agencies, universities,
trade groups, and operators, may be required to solve one in-
dustry's problem. Alternatives to some practices that occur
in vast numbers would be prohibitively expensive. Given the
current, incomplete characterization of wells, it is likely
that some permit requirements may be inappropriate in that they
may be established without a thorough understanding of all ele-
ments of operations, such as volumes, toxicity, alternatives,
costs, and available resources.
Alternative 2; Within the UIC Regulations,
an Assessment and Submission of State Plan
The previous chapters of this report described the types
of wells that inject into or above underground sources of drink-
ing water and discussed the problems of developing an exact
inventory of these practices. A related problem, expressed by
state officials during visits to 13 states and during telephone
conversations and mail surveys with 9 other states, is the per-
ception of the extent of the threat of contamination from these
wells. Seven states, California, Florida, Kansas, Maryland,
New York, Pennsylvania, and Texas, say they are actively regulat-
ing problem areas and industries on a selected basis, but they
may be interested in additional federal support. Six states,
Illinois, Indiana, Kentucky, New Mexico, Ohio, and Oregon, say
there is a problem but only in selected industries and/or local-
ities, and they would like to have federal support to study
these wells, but they are not yet ready to formulate or enforce
a permit program. Nine states, Arkansas, Colorado, Connecticut,
Kentucky, Louisiana, Mississippi, Oklahoma, Washington, and West
Virginia, say these wells either aon't exist or create no prob-
lem, and therefore no regulatory program is necessary.
At this time, and for several reasons, it is impossible
to demonstrate that the states are not in control of these
injection practices. Reported cases of contamination are few
and relatively isolated. Where cases have corne to the atten-
tion of state regulators, careful study and constructive
action have followed to discourage any further contamination.
Characterization of well types and industries is still not
detailed enough to provide convincing evidence of the potential
for contamination to the states. This evidence would require
state-specific facts about industries, hydrogeology, and case
histories. This task is far beyond the scope of studies
undertaken to date.
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With the realization that data are sparse, the following
have been suggested as major components of an assessment and
state plan approach:
• The state director would compile an inventory,
including number, location, and use of these
well practices, and determine the toxicity and
volume of the injected fluids
• The director would develop and compile hydro-
geologic data, including information about
geology and location of the aquifers, aquifer
yield, groundwater quality, groundwater move-
ment and groundwater use
• The director would develop data on present and
future population and industrialization within
the state, emphasizing the study of dependence
on groundwater resources and the protection of
the quality of public health
• The director would consider the technological
alternatives available to existing practices,
including injection into a deeper well, dis-
charge into surface water (subject to Section
402 of the FWPCA), disposal in a sanitary
landfill under RCRA, disposal into a municipal
treatment facility, or injection after addi-
tional treatment
• The director would assess the risk to under-
ground sources of drinking water based on the
above data and would submit a state plan to
cover new and existing injection wells. The
plan would address the issues of regulatory
priorities (i.e., substances, geographic areas,
types of wells), time frame for implementation,
rule vs. permit programs, and prohibitions.
Pros and Cons of an Assessment and State Plan
An assessment approach would allow time to study the
least understood and most numerous practices of the VIC
program. It would lead to an increased awareness at state,
local, and industry levels of the risk of those practices
while avoiding the costs and problems of a mandatory permit
requirement. This approach would lead to a state plan that
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is consistent with the intent of the Safe Drinking Water Act
and consistent with the approach toward the formulation of
other pollution-control programs within EPA. The assessment
approach would make acceptance of primacy by the states more
likely than a permit program would, thereby decreasing the
federal administrative burden.
On the negative side, the time lag between acceptance of
primacy and submission of a state plan would delay ultimate
action and therefore allow the threat of pollution to go
unchecked for a time. Relative to the strict framework within
which other practices are to be regulated in the UIC program,
an assessment approach places the least immediate emphasis on
the most serious contamination problems.
Alternative 3; Withdraw These Practices
from UIC Program and Study in Separate
National Assessment
As discussed in the previous paragraphs, little specific
information is available about the practices which inject into
or above underground sources of drinking water. A national
assessment could be conducted outside the UIC regulations to
obtain the following information:
• Scope of practices including number, location,
toxicity, and volume of waste materials
• Documented cases of contamination
• Evaluation of potential for groundwater con-
tamination
• Existing state programs
• Level of resources expended and required
• Needed additional regulations at the state level
• Recommended role of the federal government.
The UIC regulations could then be amended to incorporate
conclusions reached as a result of conducting a national assess-
ment, or a separate regulatory package could be formulated, as
is intended for surface impoundments.
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Pros and Cons of a National
Assessment Outside the UIC Program
The other well categories of the UIC regulations cover
practices for which a great deal of information is known, in-
cluding specific location, count, and construction of those
wells. Removal of wells that inject into or above underground
sources of drinking water from the regulations would leave the
package internally consistent. States would evaluate their
willingness to accept primacy based on known practices and
administrative requirements rather than unknown practices and
hypothetical administrative burdens.
A separate national study would be consistent with the
approach taken to the nationwide study of surface impoundments.
The results of both these studies could lead to a coordinated
regulatory approach.
A study approach would appear to be the least aggressive
attack on the problem because groundwater experts have argued
that these wells are a greater threat to water quality than
any of the practices covered. A wait-and-see attitude may not
be consistent with the intent of the Safe Drinking Water Act.
As part of the Act, grants will be made available to the
states accepting UIC primacy to aid them in carrying out admin-
istrative responsibilities. There is no certainty that money
would be available for an assessment of wells outside tne UIC
program.
Alternative 4: Within the UIC Regulations,
Assessment with Regulatory Control Over the
Most Potentially Harmful Practices
To repeat major points stated earlier, it appears that
there exist substantial numbers of wells throughout the country
that discharge fluids of variable quality into or above fresh-
water aquifers. Furthermore, there seems to be a general
scarcity of data concerning the exact number, locations, and
injection fluids of these wells. It is clearly not economic to
attempt to permit all these wells, but it is just as clearly
unsafe to take no action against these practices until an
assessment has been completed.
Under these circumstances, it is worthwhile to separate
the set of wells injecting into or above underground sources of
drinking water into two subsets: (1) wells posing a serious
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threat to human health and the environment and (2) wells posing
an as-yet-undetermined threat to human health and the environ-
ment. Wells of the former group may be regulated immediately
by permit, by rule, or through bans, while wells of the second
group may undergo assessment prior to formulation of a regu-
latory strategy.
The following are the suggested major components of a
state regulatory program for wells injecting hazardous wastes
into or above underground sources of drinking water:
• The director would determine the identifying
characteristics of harmful materials and/or
list such substances. Alternatively, a national
list of hazardous substances, such as RCRA's,
could be used for nationwide consistency
• Operators of facilities injecting hazardous sub-
stances into or above freshwater aquifers would
identify themselves and describe their opera-
tions to the state director
• These wells would be granted temporary
authorization to operate by the program di-
rector, with the understanding that they
would be closed as soon as possible in order
to protect public health and the environment
• New wells injecting harmful materials into
potable groundwater sources could be banned
• Monitoring, record-keeping and reporting
requirements for the operator would be a
necessary condition of the temporary authori-
zation granted by the state director
• Disposal of harmful materials formerly
injected into wells would be coordinated
with the requirements of other programs
dealing with hazardous substances.
The suggested regulatory approach for wells injecting ma-
terials of indeterminant hazard into or above freshwater aqui-
fers would be similar to the approach suggested in Alternative
2, assessment and submission of a state plan. In condensed
form, the major components of this approach would be as follows
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• Compilation of well inventory
• Compilation of hydrogeologic database
• Assessment of state groundwater dependency,
present and future
• Evaluation of acceptable disposal alternatives
• Analysis of accumulated data and formulation
of state plan.
Before embarking on this program, EPA and the states
should make sure the program's requirements will mesh with
those of other programs dealing with waste disposal, i.e.,
RCRA and the NPDES permitting program of FWPCA. A consolidated
permitting system would avoid duplication of effort for both
the operators and program directors.
Pros and Cons of Assessment with Regulatory
Control Over the Most Potentially Harmful Practices
This approach addresses both the need for immediate action
in the instances where public health is endangered and the need
for additional information prior to comprehensive regulation.
In protecting the health of the public, the states will impose
the greatest restraints primarily on the well operators doing
the greatest harm. Furthermore, the task of regulating only
the potentially dangerous well practices at first will be far
less of an administrative burden than requiring all wells to be
permitted.
As the states conduct assessments, there will arise two
benefits: (1) better databases on the pollution potential of
wells injecting into or above freshwater aquifers, and (2) an
increased likelihood that states will accept primacy for a
future regulatory program due to their heightened awareness
of these wells' contamination potential. Moreover, the federal
government will benefit by delegating the task of gathering
data to the states, whose files will be better starting points
for such an investigation.
The problems with this approach center on two points:
identification of hazardous wastes and identification of wells
injecting hazardous wastes. RCRA defines identifying charac-
teristics of hazardous substances in addition to supplying a
list of hazardous wastes. However, this information has to be
circulated to all well operators in order to be useful.
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Second, even if the information were to be widely circulated,
there is little incentive for well operators injecting hazardous
waste to come forward and identify themselves. A penalty for
noncompliance would probably need to be imposed to encourage
operators to report their activities.
Findings
The last of these regulatory approaches stands out as
superior to the other three. It is aggressive in protecting
the welfare of persons near wells demonstrating the greatest
pollution potential while also being realistic about the lack
of data regarding these wells in general.
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