DRAFT - FOR REVIEW AND COMMENT INSPECTION TIPS FOR CLASS V INJECTION WELLS Prepared for USEPA Region V Chicago, Illinois Under Contract No. 68-03-3416 Work Assigimtent No. 5-12 Respectfully Submitted By Engineering Enterprises, Inc. Norman. Oklahoma August, 1987 ------- TABLE OF CONTENTS SECTION PAGE NO. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1— 1 PURPOSE .. .... . .. .. . 1— 1 BACKGROUND. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1— 1 CONTENT OF REPORT.............................. 1— 9 TYPES OF INSPECTIONS . . . . . 1— 9 2 INSPECTION TIPS BY CLASS V WELL TYPE ........... 2- 1 GENERAL 2— 1 DRAINAGE WELLS...... .......... ..... ...... ...... 2— 2 GEOTHERMAL WELLS............................... 2— 7 DOMESTIC WASTEWATER DISPOSAL WELLS.. .... 2-11 MINERAL AND FOSSIL FUEL RECOVERY RELATED WELLS.. .................. . . . .. ..... .... 2—15 OIL FIELD PRODUCTION WASTE DISPOSAL WELLS...... 2-19 INDUSTRIAL/COMMERCIAL/UTILITY DISPOSAL WELLS... 2-21 RECHARGE WELLS . . . . . . . . . . . . . . . . . . . . 2—25 M ISC LANEOUS WELLS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 2—26 3 GENERAL CLASS V WELL INSPECTION TIPS.. 3- 1 4 VARIOUS CLASS V INJECTION WELL INSPECTION CHECKLISTS 4— 1 RECONNAISSANCE-LEVEL INSPECTION CHECKLISTS..... 4- 2 Field InspectionReport 4—3 USEPA Region IX UIC Program Reconnais sarice—Level Field Inspection Report...... . . . . . . . . . . . . . . . . . . . .4— 5 ------- Table of Contents Page Two SECTION PAGE NO. VERIFICATION, ASSESSMENT, OR ENFORCEMENT- LEVEL INSPECTIONCHEC 1ISTS.................... .4—7 USEPA Region IX LJIC Program In-Depth Inspection Report Low Tech Wells...........4- 8 USEPA Region IX UIC Program In-Depth Inspection Report High Tech We].ls..........4-12 UIC Program Site Inspection (Low Tech Wells).. ..... . .. ... . .... .. .. .. . ..4—18 UIC Program Inspection Report (High—Tech Wells) ................4—27 LIST OF TABLES 1 CLASS V INJECTION WELL TYPES.........................l— 4 ------- SECTION 1 INTRODUCTION PURPOSE The following information has been compiled to assist Underground Injection Control (UIC) field inspectors with Class V injection well site investigations. Because the Class V injection program is relatively new and field efforts have not been extensive, this information package should not be considered absolute or exhaustive. As new information is accumulated, well— type specific guidelines can be developed along with United States Environmental Protection Agency (USEPA) approved inspection practices. The USEPA will also be developing federal regulations and designating regulatory programs for many types of Class V wells in the coming years (after reporting to Congress in September 1987). This guide should only be used as a supplement to previously developed operating procedures for inspections. It is not intended to and does not encompass all aspects of inspection protocol. BACXGROUND On December 14, 1974, the Safe Drinking Water Act became law (PL-93-523). Part C of the Act mandates development of regulations for state and federal UIC programs. The intent of these regulations is to provide protection of underground source(s) of drinking water (USDW) from contamination resulting 1—1 ------- from underground injection or emplacement of fluids through wells. The USEPA has promulgated regulations which are published in the Code of Federal Regulations (CFR). The UIC regulations establish requirements for five classes of injection wells. These well classes are: Class I: Class I wells are municipal, hazardous, and industrial disposal wells which inject below the lowermost formation containing, within one-quarter mile of the well bore, an underground source of drinking water. Class II: Class II wells inject fluids associated with oil or gas production or liquid hydrocarbon storage. These wells include brine waste injection, enhanced oil or gas recovery wells, and wells for storage of liquid hydrocarbons. Class III: Class III wells inject fluids for the extraction of minerals and, are used in conjunction with solution mining of minerals. Class IV: Class IV wells inject hazardous or radioactive wastes into or above an underground source of drinking water (banned nationally). Class V: Class V wells are wells which do not meet the criteria listed for Classes I — IV. 1—2 ------- Precise definitions of the five injection wells classes are found in 40 CFR 144.6. A complete list of Class V injection well types is presented in Table 1. Class V injection wells can be divided into two general types of wells based on construction. “Low-tech” wells 1) have simple casing designs and well head equipment and 2) inject into shallow formations by gravity flow or low volume pumps. In contrast, “high—tech” wells typically 1) have multiple casing strings, 2) have sophisticated welihead equipment to control and measure pressure and volume of injected fluid, and 3) inject high volumes into deep formations. Low-tech well types include agricultural drainage wells (5F1), storm water and industrial drainage wells (5D2, 5D4), improved sinkholes (5D3), heat pump/air conditioning return flow wells (5A7), some aquaculture return flow wells (5A8), raw sewage disposal wells and cesspools (5W9, 5W10), septic systems (5Wll, 5W31), 5W32), some mine backfill wells (5X13), some cooling water return flow wells (5A19), sane industrial process water and waste disposal wells (5W20), automobile service station waste disposal wells (5x28), and abandoned water wells (5X29). High-tech well types include geothermal wells used for electric power or for direct heat (5A5, 5A6), some aquaculture return flow wells (5A8), domestic wastewater treatment disposal wells (5W12), mining or backfill wells (5X13) , solution mining wells (5X14), in—situ fossil fuel recovery wells (5X15) , spent 1—3 ------- TABLE 1 CLASS V INJECTION WELL TYPES WELL CODE NANE OF WELL TYPE AND DESCRIPTION DRAINAGE WELLS (a.k.a. DRY WELLS) 5F1 Agricultural Drainage Wells — receive irrigation tailwaters, other field drainage, animal yard, feedlot, or dairy runoff, etc. 5D2 Storm Water Drainage Wells - receive storm water runoff from paved areas, including parking lots, streets, residential subdivisions, building roofs, highways, etc. 5D3 Improved Sinkholes - receive storm water runoff from developments located in karst topographic areas. 5D4 Industrial Drainage Wells - are wells located in industrial areas which primarily receive storm water runoff but are susceptible to spills, leaks, or other chemical discharges. 5G30 Special Drainage Wells — are used for disposing water from sources other than direct precipitation. Examples of this well type include: landslide control drainage wells, potable water tank overflow drainage wells, swimming pool drainage wells, and lake level control drainage wells. GEOTHERMAL REINJECTION WELLS 5A5 Electric Power Reinjectiori Wells — reinject geothermal fluids used to generate electric power - deep wells. 5A6 Direct Heat Reinjection Wells - reinject geothermal fluids used to provide heat for large buildings or developments - deep wells. 5A7 Heat Pump/Air Conditioning Return Flow Wells — reinject groundwater used to heat or cool a building in a heat pump or air conditioning system - shallow wells. 5A8 Groundwater Aquaculture Return Flow Wells - reinject groundwater or geothermal fluids used to support aquacul ture. Non-geothermal aquacul ture disposal wells are also included in this category (e.g. Marine aquariums in Hawaii use relatively cool sea water). 1—4 ------- TABLE 1 (CONT.) CLASS V INJECTION WELL TYPES (CONT.) WELL CODE NAME OF WELL TYPE AND DESCRIPTION DOMESTIC WASTEWATER DISPOSAL WELLS 5W9 Untreated Sewage Waste Disposal Wells - receive raw sewage wastes from pumping trucks or other vehicles which collect such wastes from single or multiple sources. (No treatment) 5W10 Cesspools - including multiple dwelling, community, or regional cesspools, or other devices that receive wastes and which must have an open bottom and sometimes have perforated sides. Must serve greater than 20 persons per day if receiving solely sanitary wastes. (Settling of solids) 5W11 Septic Systems (Undifferentiated disposal method) — are used to inject the waste or effluent from a multiple dwelling, business establishment, community, or regional septic tank. Must serve greater than 20 persons per day if receiving solely sanitary wastes. (Primary Treatment) 5W31 Septic Systems (Well Disposal Method) — are used to inject the waste or effluent from a multiple dwelling, business establishment, community or regional septic tank. Examples of wells include actual wells, seepage pits, cavitettes, etc. The largest surface dimension is less than or equal to the depth dimension. Must serve greater than 20 persons per day if receiving solely sanitary wastes. (Less treatment per square area than 5W32) 5W32 Septic Systems (Drainfield Disposal Method) - are used to inject the waste or effluent from a multiple dwelling, business establishment, community or regional septic tank. Examples of drainfields include drain or tile lines and trenches. Must serve more than 20 persons per day if receiving solely sanitary wastes. (More treatment per square area than 5W31) 5W 12 Domestic Wastewater Treatment Plant Effluent Disposal Wells - dispose of treated sewage or domestic effluent from small package plants up to large municipal treatment plants. (Secondary or further treatment) 1—5 ------- TABLE 1 (CONT.) CLASS V INJECTION WELL TYPES (CONT.) WELL CODE NAME OF WELL TYPE AND DESCRIPTION MINERAL AND FOSSIL FUEL RECOVERY RELATED WELLS 5X13 Mining, Sand, or Other Backfill Wells - are used to inject a mixture of fluid and sand, mill tailings, and other solids into mined out portions of subsurface mines whether what is injected is a radioactive waste or not. Also includes special wells used to control mine fires and acid mine drainage wells. 5X14 Solution Mining Wells - are used for in—situ solution mining in conventional mines, such as stopes leaching. 5X15 In—situ Fossil Fuel Recovery Wells — are used for in— situ recovery of coal, lignite, oil shale, and tar sands. 5X16 Spent—Brine Return Flow Wells - are used to reinject spent brine into the same formation from which it was withdrawn after extraction of halogens or their salts. OIL FIELD PRODUCTION WASTE DISPOSAL WELLS 5X].7 Air Scrubber Waste Disposal Wells - inject wastes from air scrubbers used to remove sulfur from crude oil which is burned in steam generation for thermal oil recovery projects. (If injection is used directly for enhanced recovery and not just disposal it is a Class II well.) 5X18 Water Softener Regeneration Brine Disposal Wells - inject regeneration wastes from water softeners which are used to improve the quality of brines used for enhanced recovery. (If injection is used directly for enhanced recovery and not just disposal it is a Class II well.) INDUSTRIAL/COMMERCIAL/UTILITY DISPOSAL WELLS 5A19 Cooling Water Return Flow Wells - are used to inject water which was used in a cooling process, both open and closed loop processes. 1—6 ------- TABLE 1 (CONT.) CLASS V INJECTION WELL TYPES (CONT.) WELL CODE NAME OF WELL TYPE AND DESCRIPTION 5W20 Industrial Process Water and Waste Disposal Wells - are used to dispose of a wide variety of wastes and waste- waters from industrial, commercial, or utility processes. Industries include refineries, chemical plants, smelters, pharmaceutical plants, laundromats and dry cleaners, tanneries, laboratories, petroleum storage facilities, electric power generation plants, car washes, electroplating industries, etc. 5X28 Automobile Service Station Disposal Wells - inject wastes from repair bay drains at garages, service stations, n s car dealerships, motorpools, etc. RECHARGE WELLS 5R21 Aquifer Recharge Wells — are used to recharge depleted aquifers and may inject fluids from a variety of sources such as lakes, streams, domestic wastewater treatment plants, other aquifers, etc. 5B22 Saline Water Intrusion Barrier Wells - are used to inject water into fresh water aquifers to prevent intrusion of salt water into fresh water aquifers. 5S23 Subsidence Control Wells - are used to inject fluids into a non-oil or gas producing zone to reduce or eliminate subsidence associated with overdraft of fresh water and not used for the purpose of oil or natural gas production. MISCELLANEOUS WELLS 5N24 Radioactive Waste Disposal Wells — include all radioactive waste disposal wells other than Class IV wel 1 s. 5X25 Experimental Technology Wells - include wells used in experimental or unproven technologies such as pilot scale in-situ solution mining wells in previously unmined areas. 1—7 ------- TABLE 1 (CONT.) CLASS V INJECTION WELL TYPES (CONT.) WELL CODE NAME OF WELL TYPE AND DESCRIPTION 5X26 Aquifer Remediation Related Wells - include wells used to prevent, control, or remediate aquifer pollution, including but not limited to Superfund sites. 5X29 Abandoned Drinking Water Wells - include abandoned drinking water wells which are used for disposal of waste. 5X27 Other Wells - include any other unspecified Class V wells. 1—8 ------- brine return flow wells (5A26) , air scrubber and water softener regeneration brine disposal wells (5X17, 5X18) , some cooling water return flow wells (5M9) , some industrial process water and waste disposal wells (5W20), sane aquifer recharge wells (5R21), salt water intrusion barrier wells (5B22), subsidence control wells (5S23), radioactive waste disposal wells (5N24), experimental technology wells (5X25), and aquifer remediation wells (5X26). CONTENT OF REPORT Section 2 of this report contains inspection tips for each type of Class V injection well. After the well—type listing and description, potential inspection contacts or information sources are presented. Also given are well—type specific questions and peculiarities or potential programs associated with each well type. Section 3 provides general questions and information which could be used when an inspector has no knowledge of site activities or of the type(s) of Class V injection wells on site. Section 4 contains several inspection checklists which could be used (or modified for tailored use) during site inspections. TYPES OF INSPECTIONS Several types of injection well inspections can be conducted, depending on the Agency’s objectives: enforcement, routine, witness mechanical integrity testing, witness plugging and abandonment, reconnaissance, assessment-level, etc. The 1—9 ------- primary types of inspections conducted at Class V facilities have historically included: reconnaissance—level inspections (basic information gathering); verification—level (verify info given in state or local permit applications); assessment—level (gather info necessary to assess groundwater contamination potential); and enforcement—level (gather info necessary to prove Class IV hazardous waste injection or Class V endangerment). The simplest type of inspection is the reconnaissance-level inspection. Very few details about the injection operation are recorded at this type of investigation. These inspections are conducted when the purpose is to find out “what’s out there.” Examples include initial (multi-purpose/multi-program) inspections at federal facilities and area-wide drainage well surveys (primarily to build inventories and look for potential misuse). The first two inspection checklists in Section 4 of this report are examples of reconnaissance-level forms and present the types of data which should be collected. Also note that both forms have space for the inspector to note if a follow— up inspection is necessary. An intermediate level of data are collected at verification- level inspections. This type of investigation is possible when the injection facility is operating under a permit (e.g. state agency permit) and considerable data is on file with the facility permit application. Similar to routine Class II well inspections, the inspector should review the facility permit 1 — 10 ------- application information prior to inspecting the facility. The main intent of inspection would then be to verify the previously submitted information and look for compliance with permit specifications. Although inspection checklists have not been developed specifically for verification level investigations the third and fourth checklists in Section 4 (one for low-tech wells and one for high-tech wells could be used (may need some modification). The inspector should fill out the form to the degree possible before inspection and complete the form during inspection, noting any differences in the application information and the actual facility operation. Both assessment and enforcement-level inspections entail collecting, verifying, or generating extensive information about Class V facilities during inspections. Assessment-level inspections are conducted when nothing is known about a certain well type or facility and the impact of the well’s or well type’s discharges on groundwater quality must be determined. Enforcement-level inspections are conducted when a facility is suspected of injecting hazardous waste (Class IV enforcement) or may present endangerment to USDW (although hazardous waste is not injected). Injectate (or groundwater or soil) sampling and analysis may be necessary to determine the impact of such injection practices on groundwater quality. Site investigations at this level, and especially those including sampling, must be well prepared and coordinated in advance, including preparing 1 — 11 ------- sample and safety plans, planning with legal counsel, etc. The last four checklists in Section 4 of this report are examples (for both high and low-tech wells) which present the type and amount of data needed during an assessment or enforcement-level inspection. Depending on the facility, it may not be possible to obtain all listed information, at least not from the facility. It may be necessary to gather missing data from state or local agencies or through extensive site investigations. 1 — 12 ------- SECTION 2 INSPECTION TIPS BY CLASS V WELL TYPE GENER.AL This section presents several general questions or tips which are applicable to most or all of the Class V well types. These should be asked at each inspection site. In addition, tips, questions, and problems are presented for each specific well type. General Questions/Tips - Are there any nearby potable water, industrial, or irrigation water supply wells, (including abandoned wells)? [ If so, determine if they are completed in the same formation as any identified Class V wells.] Are there any kind of injection wells nearby? Is the facility connected to sanitary and/or storm sewers? If so, is the use of sewers available or all wastes generated? Are septic systems or cesspools used? How is storm water handled? (Obtain all available details concerning well construction including depth, date of construction, casing and screen type, all logs, etc.) What are injection rates and volumes? How often does injection occur? Is injectate treated or filtered prior to injection? (If yes, obtain a description of the treatment or filtration process.] Have there been any problems with the wells (clogging, caving, etc.)? If yes, please describe. What type of maintenance, if any, does the owner/operator perform or performed on the well ? At what frequency? What is done with any debris removed from the well(s) during maintenance? Are any of the injection wells permitted? If so, by what agency? 2—1 ------- DRAINAGE WELLS 5F1 Agricultural Drainage Wells — receive irrigation tailwaters, other field drainage, animal yard, feedlot or dairy runoff, etc. Inspection Contacts — Farmer (Owner/Operator), SCS County Agent, County Health Department Sanitariari or Inspector, State Agriculture Department, State University (A&M). Well—T ’pe Specific Questions/Tips — Does the agricultural drainage well receive surface and/or subsurface drainage (subsurface drainage is collected by a buried tile field)? How deep are the supply wells, if present? What kind of nutrients and pesticides are used, and what are the application rates? Do surface drainage waters flow over land which could contribute high levels of microbial contaminants (e.g., feed lots, barnyards, dairies, etc.)? Has the drainage well ever been used for direct disposal of wastes (such as pesticide rinsate, etc.)? Are septic systems or cesspools used? If yes, continue questions for septic systems and cesspools since effluent from these wells could enter a nearby agricultural drainage well. Peculiarities/Potential Problems — Finding an inspection contact may be difficult if not impossible. Getting information from the inspection contact may be difficult. Because these wells are often shallow, owners/operators may not consider them “real wells”. These wells are also known 2—2 ------- as dry wells, pits, s mtps, drains, and other local “pet” names. Construction and operation details along with other specific information may not be readily available. 5D2 Storm Water Drainage Wells — receive storm water runoff from paved areas including parking lots, streets, highways, residential subdivisions, building roofs, etc. Inspection Contacts — city engineer or planner, highway department or department of transportation, building inspector, maintenance supervisor, developer, land owner or tenant, well driller. Well—Type Specific Questions/Tips — Are storm water drainage wells utilized? May I inspect the storm water drainage wells? (Note location of wells (with respect to sources of contamination such as chemical storage and handling areas, note condition of wells, figure apparent drainage area and land use, tag bottom of well.] Is the measured depth equivalent to total depth of the well, or is the well backfilled with rock or gravel below casing? [ Look for inflow or outflow pipes and associated settling chambers (catch basins) or wells hooked up in series (overflow), look for evidence of illicit disposal or disposal of materials other than storm water.] Have any spills or leaks flowed to the storm water drainage wells? Is there a spill containment/contingency plan? What is done with the debris collected after cleaning/maintaining the wells? 2—3 ------- Peculiarities/Potential Problems — Finding an inspection contact may be difficult. Getting information from the inspection contact may be difficult. Shallow wells like these may not be considered “real wells’ t and are also known as dry wells, pits, sumps, and drains. Construction and operation details and other specific information may not be readily available. If you don’t already know that this is a storm water drainage well, it may look just like a storm sewer from the surface. Look for inflow/outflow pipes and riser pipes (top of injection casing) in the settling chamber under the grate or manhole cover and nearby connected chambers. Depending on what has drained into the well, materials collected in the settling chamber or the well may be dangerous or toxic. If the well does not drain properly, mosquitoes and other insects may be thriving in the well or settling chamber. Access to the well may require special grate or lid removal tools; these can usually be obtained from the city maintenance division. 5D4 Industrial Drainage Wells — are located in industrial areas and primarily receive storm water runoff but are susceptible to spills, leaks, or other chemical discharges. Inspection Contacts — see description above for 5D2 wells. Well Specific Questions/Tips — see above for 5D2 wells. Peculiarities/Potential Problems — see above for 5D2 wells. Industrial operators or land owners may be reluctant to 2—4 ------- provide information, especially if they have discharged materials other than storm water runoff to the well. 5G30 Special Drainage Wells - are used for disposing fluids from sources other than direct precipitation. Examples of this well type include landslide control drainage wells, potable water tank overflow drainage wells, swimming pool drainage wells, lake level control drainage wells, and construction dewatering drainage wells. Inspection Contacts — city engineer, planner, construction department (potable water tank overflow or construction dewatering), developer, owner/operator, maintenance super- visor (pool drainage), highway department or department of transportation (landslide control or construction dewater- ing). Well— ’pe Specific Questions/Tips — Specific questions are difficult to list due to the variable nature of this well type. During inspections the inspector must initially determine use of wells, type and volume of injected fluids, and construction details of wells to correctly subcategorize well (see examples of well types listed above). Peculiarities/Potential Problems — The inventory database for these wells is very limited at present and needs to be developed further. Because of this, inspection tips other than routine procedures are limited - use common sense! intuition. Use and location of these wells will not gener— 2—5 ------- ally be obvious or often talked about. Swimming pool owners may not know whether their pool drains to the sewer system or a well. 5D3 Improved Sinkholes — receive storm water runoff from developments located in karst terrain and may also receive any other fluid (e.g. agricultural drainage, industrial waste fluids, etc.) Inspection Contacts — city engineer or planner (and others listed for 5D2 wells), farmer or county SCS agent (and others listed for 5F1 wells), local sanitarian or land owner (and others listed for 5W9—l1, 31, 32 wells), plant manager, environmental coordinator, or maintenance supervisor (and others listed for 5W12 and 5W20 wells). Well—Type Specific Questions/Tips — What has been done to improve the sinkhole(s) (e.g. put pipe in sinkhole throat, installed grate to restrain debris, etc.)? What fluids are disposed in the sinkhole? Are there any interconnected sinkholes in the area (other sinkholes may back up and flood due to this sinkhole’s improvements)? Has there been any rapid development of other sinkholes or further development of this sinkhole since it has been improved? Are any nearby surface water bodies connected to the sinkhole or sinkhole system? 2—6 ------- Peculiarities/Potential Problems - the Agency has not defined precisely what constitues an improved sinkhole. The inspector should be aware of this but still maintain keen observation for intentional discharge of fluids into sinkholes. Hopefully, this gray area will be better defined as more site specific data is gathered and reported. The owner or operator may not consider the improved sinkhole to be a well and, thus, without direct questioning, may not provide useful information. For more information on improved sinkholes, please contact Ms. Lorraine Council at Engineering Enterprises, Inc.’s Norman, Oklahoma office. GEOTHERMAL REINJECTION WELLS 5A5 Electric Power Reinjection Wells — reinject geothermal fluids used to generate electric power - deep wells. Inspection Contacts — operator, company environmental coordinator, state agency (e.g., Division of Oil & Gas), Bureau of Land Management (BLM) (operations on federal land), department of minerals and energy (state level). Well—Type Specific Questions/Tips — What type of electric power generation process is used at this facility (e.g., binary method, dry steam, or dual flash system)? Could a synopsis of the operation be provided, especially with regard to the injection facilities and what changes the geothermal fluids are subject to before injection? Is injection into the same geothermal reservoir as production? 2—7 ------- Note: This line of questioning could be continued to cover many more aspects of geothermal injection. For more specific guidance, please contact Mr. Gary Cipriano or Mr. Mike Quillin at Engineering Enterprises, Inc.’s Norman, OK office. Peculiarities/Potential Problems — Chances are that there will not be many, if any, 5A5 wells in EPA Region V because it is not a thermally active area (most wells are in the western U.S.). Many operators (and state regulatory agencies holding records) will claim confidentiality of information, especially geologic data. Most injection wells are regulated, along with rest of the facility, under state programs or the BLM (federal leases). Regulation and information required by permits will vary from agency to agency (so will cooperation). A considerable amount of data and information should generally be available for 5A5 wells where they exist. 5A6 Direct Heat Reinjection Wells — reinject geothermal fluids used to provide heat for large buildings or developments - deep or shallow wells. Inspection Contacts — operator or maintenance supervisor, utility representative or state utility board, developer or local planner/engineer, BLM (federal leases). Well-Type Specific Questions/Tips — Does the direct heat system use downhole or surface heat exchangers? Is the 2—8 ------- geothermal, fluid piped to a central facility or to many buildings! facilities? Is information available on analyses of geothermal fluids, etc? Note: As for 5A5 wells, this line of questioning could be continued to cover many more aspects of geothermal injection. Please contact Mr. Gary Ciprianb or Mr. Mike Quillin at EEl’s Norman, OK office. Peculiarities/Potential Problems — Some direct heat facili- ties are considered by the state to be utilities. Regula— tiori of these wells varies from state to state and may be dependent on volumes of heat-spent fluid injected. Where these wills are actively regulated (e.g., permitted), a large information database should exist. None of these wells has been inventoried in EPA Region V yet, and future use of these wells in Region V is expected to be limited or non—existent. 5A7 Heat Pump/Air Conditioning Return Flow Wells - reinject groundwater used to heat or cool a building by a heat pump or air conditioning system. Inspection Contacts — home owner (residential systems), developer, local planner or engineer, maintenance supervisor (large systems like in shopping malls), heat pump installer or contractor. Well— ’pe Specific Questions/Tips — Does the groundwater pump utilize an open-loop system or a closed-loop system? (Note that some heat pump systems are installed with 2—9 ------- subsurface closed—loop circulation systems. Injection wells are not utilized with systems such as this, since water is recirculated.] Does the system have an injection well for fluid discharge (as opposed to surface discharge or drain tile systems)? Are additives used in the system? Is injection into the same formation as withdrawal? Peculiarities/Potential Problems — Closed-loop, earth- coupled heat pumps are not injection wells. The closed-loop exchanger is filled just one time with water or some other fluid which is continuously circulated in the buried vertical loop. Many states may have well construction standards such as requiring surface grouting around both production and injection wells. Water may be injected into a zone other than the supply zone. 5A8 Aquaculture Return Flow Wells - reinject groundwater or geothermal fluids used to support aguaculture. Non- geothermal aquacu].ture disposal wells are also included in this category (e.g., marine aquariums in Hawaii use rela- tively cool sea water). Inspection Contacts — owner/operator (fish farms and hatcheries), state department of land and natural resources or health department (many facilities are state operated — DNR in Indiana owns/operates fish hatcheries), state fish and game or recreation departments. The U.S. Fish & Wildlife Service also owns and operates fish hatcheries. 2 — 10 ------- well—Type Specific Questions/Tips — What is the source of water used in the aquaculture operation? Is the water system a continuous once-through system or is the water recycled several times before disposal? What is the specific disposal method (via injection wells, surface disposal, or sewer system)? Are additives used in the aquarium water and, if so, what is used, how much, etc.? Peculiarities/Potential Problems — Commercial aquaculture facility owners may be leery of inspectors and may think you are a competitor trying to find out his operational secrets (this has happened before). Surface water disposal is much easier than injection because the wastewater can easily clog the injection well and/or formation. In the absence of surface water, aquaculture wastewater may be injected to the subsurface or percolated in ponds. The only inventoried 5A8 wells are located in Hawaii where the injection zones are extremely permeable. DOMESTIC WASTEWATER DISPOSAL WELLS 5W9 Untreated Sewage Waste Disposal Wells — receive raw sewage wastes from pumping trucks or other vehicles which collect such wastes from one or more sources; also receive wastes directly injected from facilities (e.g., injection into abandoned mines, lava tubes, cavern systems). 5W10 Cesspools — include multiple-family dwelling, community, or regional cesspools, or other devices which receive wastes and which must have an open bottom and sometimes have 2 — 11 ------- perforated sides. Must serve more than 20 persons per day if receiving solely sanitary wastes. 5W11 Septic Systems (undifferentiated disposal methods) — receive waste or effluent from a multiple—family dwelling, business establishment, community, or regional establishment septic tank. Must serve more than 20 persons per day if receiving solely sanitary wastes. 5W31 Septic Systems (Well disposal method) — include, for example, actual wells, seepage pits, cavitettes, etc. which inject effluent from septic tank(s). The largest surface dimension of the well is less than or equal to the depth dimension. Must serve more than 20 persons per day if receiving solely sanitary wastes. 5W32 Septic Systems (drainfield disposal method) — include, for example, drain or tile lines, absorption mounds, and trenches. Horizontal dimension(s) are greater than vertical dimensions. Must serve more than 20 persons per day if receiving solely sanitary wastes. Inspection Contacts — Owner or property manager, maintenance supervisor, city or county sanitarians (health department), plant manager, maintenance supervisor, or environmental coordinator (if large industrial facility). Well - rpe Specific Questions/Tips — How are sewage wastes disposed? (If a septic system is used, ascertain what kind 2 — 12 ------- of disposal system is used (e.g., drainfield, cavitette, etc.).] Is the septic tank or cesspool pumped out periodically? Who pumps out the facility, and where do the pumping wastes go? Are any chemicals used to “treat” the septic system? Does the system receive any wastes other than sanitary wastes? (Find out all sources of waste, e.g., lab drains, toilets, etc.] Have there been any problems with the system? What is the capacity of the system? Peculiarities/Potential Problems — Many owners may not have a clue as to what kind of sewage disposal system they have, and any records may have “disappeared.” Sewage waste disposal wells may receive wastes other than sanitary wastes, especially at industrial or commercial facilities. Owner/operators may be hesitant to tell you about this or may even lie about it (this has happened). Access to the wells may be difficult or impossible without exhuming the systems. Sampling to detect wastes other than sanitary wastes may be difficult because of construction features. If cesspools or septic systems are exhumed for sampling, dangerous levels of gases such as methane or hydrogen sulfide may be present. 5W12 Domestic Wastewater Treatment Plant Effluent Disposal Wells — dispose of treated sewage or domestic effluent from small package plants up to large municipal treatment plants (treatment should be secondary or further). 2 — 13 ------- Inspection Contacts — plant operator or manager, city public works department, local or state health department. Well—Type Specific Questions/Tips — Please describe the plant’s treatment process and operation. (Try to get a tour of the plant as the contact describes the processes.] What level of treatment is provided and does the plant consistently achieve this treatment level? Are effluent analyses available? Have any problems occurred injecting this volume? (Continue on with questions as per the high- tech inspection checklists (Section 4 of this report).] Peculiarities/Potential Problems — Sewage treatment plant (STP) effluent disposal wells may serve a secondary purpose of recharging depleted aquifers or acting as a hydraulic barrier to salt water intrusion. In some cases, disposal may be the secondary purpose and recharge may be the primary purpose. Sewage treatment plants generally experience periods where treatment processes are not adequate to treat wastes as designed. Many such injection facilities may hold monitoring data on the injectate and possibly on the groundwater quality; these data should be obtained if possible. Some STP disposal wells need periodic maintenance (e.g., acidizing wells). Maintenance records and descrip- tions should be noted. 2 — 14 ------- MINERAL AND FOSSIL FUEL RECOVERY RELATED WELLS 5X13 Mining, Sand, or Other Backfill Wells — inject a mixture of fluid, and, mill tailings, or other solids into mined out portions of subsurface mines. Also includes special wells used to control mine fires and acid mine drainage wells. Inspection Contacts — mine operator/supervisor, environ- mental coordinator or mine engineer, plant supervisor (sand and gravel quarries). Well—Type Specific Questions/Tips — What is the composition of material injected? How are the wells plugged and abandoned? Does the state mining, minerals, or energy department permit the wells, perhaps as part of an overall mining project permit? (Obtain permit application data, or note type of information and where it is available for review.] Peculiarities/Potential Problems — Some backfill wells have a very short lifetime (2 — 3 days). Backfill wells can be used for subsidence control, mining waste disposal, acid mine drainage, and mine fire control. 5X14 Solution Mining Wells — are used for in situ solution mining of conventionally mined areas, such as stopes leaching. Inspection Contacts — mine operator, supervisor, or process engineer, company environmental coordinator, state bureau of mines, BLM (federal leases). 2 — 15 ------- Well-Type Specific Questions/Tips — What minerals are you producing and what isthe lixiviant used in the mining process? What zones are being mined? How many wells are used to inject lixiviant? Are analyses of injected fluid available? What percent of fluids are recovered (e.g., 90%)? Are there any aquifers in the mining vicinity, and is there a groundwater monitoring network? If so, are analyses available? (Proceed with questions from the high-tech well inspection forms in Section 4 of this text.] Peculiarities/Potential Problems — Solution mining opera- tions may use both Class III and V injection wells. Class V wells are those used in previously mined areas (by conven- tional methods) or pilot—scale experimental projects. Solution mining operations typically use several injection wells, on the order of hundreds of wells. Often, these operations will recover over 100% of fluids injected, which indicates the mine is acting as a groundwater sump. Opera- tors generally know exactly what they are injecting (part of the process) and will reuse the lixiviant until it is totally spent. Lixiviant chemistry will vary with the mineral product to be mined but is typically a very acidic or basic solution. - 5X15 In Situ Fossil Fuel Recovery Wells — are used for in Situ recovery of coal, lignite, oil shale, and tar sands. 2 — 16 ------- Inspection Contacts — plant supervisor or operator, company environmental coordinator or process engineer, state depart- ments of energy or minerals, BLM (federal leases). Well—Type Specific Questions/Tips — What energy-related product is the operation producing, and by what method is it produced? [ If the operation is confidential or patent— pending status, ask for at least a brief overview. Items to note are: 1) what is produced, 2) what is injected, 3) how many wells over what three-dimensional area are used, 4) what is left in the burn zone, 5) whether the project has a groundwater monitoring network in place, 6) whether the project (as a whole) is permitted or regulated by some federal or state agency and 7) what was required for a permit application (should review permit material).] Peculiarities/Potential Problems — Very few, if any, of these type of projects are currently operating, due to the economic situation. Other federal agencies, such as the Department of Energy (DOE) or Bureau of Land Management (BLM) may be more involved in regulating projects such as these; however, these agencies probably are regulating the entire project and not just the injection well part of the project. Development of coal and lignite appears to be more likely than development of oil shale or tar sand in Region V (in situ processing). 2 — 17 ------- 5X16 Spent Brine Return Flow Wells — reinject spent brine into the same formation from which it was withdrawn after extrac— tion of halogens or their salts. Inspection Contacts — operator or company environmental coordinator, state agency (e.g., oil and gas division, corporation commission). Well—Type Specific Questions/Tips — Which halogens or salts are being extracted? Is injection into the same horizon from which production is occurring? [ Examine production volumes and injection volumes. Be wary of high injection volumes which would indicate other fluids (e.g., process wastewater) may be injected in the spent brine stream. Proceed with either the high—tech well inspection form (Section 4 of this text) or with a verification-type Class II inspection (once the permit application data has been examined) .1 Peculiarities/Potential Problems — These wells are very similar in construction and operation to Class II wells and most are permitted by state agencies. Some states regulate 5X16 wells as either Class I, II, or III wells and require permits for operation. In such a case, permit application records should be reviewed before inspection, and the inspection should be verification or routine level. Some Arkansas 5X16 operators have been discovered to dispose of other process wastewater along with the spent-brine, a practice which, according to USEPA HQ, is illegal. Casing, 2 — 18 ------- tubing, and other construction features are susceptible to corrosion from the brines disposed. OIL FIELD PRODUCTION WASTE DISPOSAL WELLS 5X17 Air Scrubber Waste Disposal Wells — inject wastes from air scrubbers used to remove sulfur from crude oil which is burned in steam generation for thermal oil recovery / projects. (If injection is used directly for enhanced recovery and not just for disposal it is a Class II injection well.) 5X18 Water Softener Regeneration Brine Disposal Wells — inject regeneration wastes from water softeners which are used to improve the quality of brines used for enhanced oil recovery. (If injection is for enhanced oil recovery and not just disposal it is a Class II injection well.) Inspection Contacts — well operator or company environmental coordinator, state oil and gas regulatory agency. Well—Type Specific Questions — For air scrubber wells, what are the approximate relative percentages of scrubber liquor, regeneration brine, and produced water that are commingled for injection? Are injectate analyses available? Similar- ly, for regeneration brine disposal wells, what are the approximate relative percentages of regeneration brine and produced water? Is cogeneration a part of the overall oper- ation? If so, what processes are involved? (This is impor- tant primarily for inventory purposes.) Is the system fired 2 — 19 ------- by crude oil or natural gas? (This will aid in determining air scrubber waste constituent types and concentrations.) Is the injection zone hydrocarbon productive? (This may be important for future aquifer exemptions.) What is the cation exchange medium used in the water softener, and how of ten is it replaced? Is there a plot available showing origins and holding facilities for all wastes that are commingled prior to injection? Peculiarities/Potential Problems — Reclassification of 5X17 and 5X18 injection wells to Class II wells is currently being considered by USEPA Headquarters. However, these wells will be treated as Class V wells until notification otherwise by USEPA HQ. Waste streams will be commingled either at the welihead or at a central storage facility. This is important to note if waste stream sampling is anticipated. If wastes are commingled at a central holding tank, sampling can be conducted under low pressure conditions. However, if commingling occurs at the wellhead, accurate characterization of the waste stream will require sampling at the welihead. This may involve the use of high pressure welihead sampling equipment. One strategy behind injection of these wastes may be for enhanced oil recovery purposes, which would make such injection Class II. It is important to identify the operator’s intentions so that differentiation between Class II and V disposal practices can be made. 2 — 20 ------- INDUSTRIAL/ COMNERCIAL/UTIL ITY DISPOSAL WELLS 5A19 Cooling Water Return Flow Wells — inject water which has been used in a cooling process and include contact systems and open- and closed—loop processes. Inspection Contacts — plant manager, supervisor, or environ- mental coordinator (large industries), plant maintenance supervisor, owner/operator, building safety inspector. Well-Type Specific Questions/Tips — What products are manufactured at this facility? What processes are employed to make the products? What wastes are generated from each process? What is done with the wastes? Which processes require the use of cooling water? Are any of the waste streams commingled with the spent-cooling water? What type of cooling water system is used (e.g., contact, open-loop, or closed-loop)? What is the source of supply water? Are any chemical additives used? Is there a scale problem and, if so, how is it removed? If so, what is used, for what reason, and how much is used? (Inspect the entire cooling system and return flow well(s). Look for any pipes which do not originate from the cooling system but lead to the circulation system or return flow well, and ask for the source of each pipe. Ask to see all waste handling/storage areas.] Does the facility have a spill containment! contigency plan?. Peculiarities/Potential Problems — Wastes other than spent cooling water may be injected along with cooling water. If 2 — 21 ------- a contact system or open-loop system is used, there is a possibility that contaminants may enter the spent cooling water. The type of system and its integrity should be checked during inspection. Water may be injected into a zone other than the supply zone. 5W20 Industrial Process Water and Waste Disposal Wells — dispose of a large variety of wastes and wastewaters from industri- al, commercial, and utility processes. Examples of indus- trial, commercial, and utility facilities include refin- eries, chemical plants, smelters, pharmaceutical plants, laundromats, dry cleaners, tanneries, laboratories, petro— leum storage facilities, electric power generation plants, car washes, electroplating shops, funeral homes, etc. Inspection Contacts — plant supervisor or manager, environ- mental coordinator (large industries), plant supervisor or owner/operator (small industries), maintenance supervisor, building safety inspector. Well—Type Specific Questions/Tips — What products are made or what services are provided? What processes are employed to make the products? What wastes are generated from each process? What is done with these wastes? May I see the waste storage/handling areas? Is there a spill containment! contingency plan? Are there any floor drains in the process areas or waste handling/storage areas? Are any wastes, other than sanitary wastes, discharged into the sewage 2 — 22 ------- disposal system (e.g. lab chemicals, etc.)? Are any wastes discharged into or could any waste potentially enter the storm water runoff drainage wells? Is equipment (such as trucks, heavy machinery, etc.) washed at the facility? If so, what types of cleaners are used, and how is the rinsate disposed? Are any storm water drainage wells susceptible to injection of rinsate? Is there an aquifer remediation project on site? If so, does it utilize injection/recharge wells as part of the system? Is a cooling water system used? If so, is the spent cooling water injected? Is there a groundwater or vadose zone monitoring system on site? If so, is any monitoring data available? Is any waste discharged to pits, wells, or leach lines? Are any injectate analyses available? Peculiarities/Potential Problems - Many owner/operators will be hesitant to provide such information on their waste dis- posal wells. Many industries mix their waste streams. Many industries use dual purpose wells (e.g., sewage waste dis- posal or storm water runoff wells). Some of these wells may actually be Class IV hazardous waste disposal wells. Appropriate sampling and analysis is required to determine if Class IV waste disposal is practiced. Keen observation is warranted at all industrial site inspections. This is especially important for facilities where the inspection contact is hesitant to provide information. 2 — 23 ------- 5X28 Automobile Service Station Disposal Wells — inject wastes from repair bay drains or other floor drains at service stations, garages, car dealerships, etc. Inspection Contacts — manager of station (gas stations and garages), maintenance or repair supervisor (automobile dealers). Well—Type Specific Questions/Tips — Does the facility have a recycling/reuse or waste management system in place? If so, please describe. How are the repair bay wastes managed or disposed? Is an oil/water separator, or other grease trap device used to remove oils before disposal of wastes into the injection well? What type of injection well is used (e.g., dry well, septic system, cesspool, drainage well, etc.)? Are there any plumbing plans for the disposal system? May I see the plans? Does the facility have a car wash? If so, how is the car wash effluent disposea and what cleaners are used? Is the station area hosed down? If so, where does the floor/lot drainage water go? How many cars are serviced daily? Specifically name all wastes and describe the associated disposal practice. [ Observe setting and determine if any other wastes can be or have been injected into the on—site disposal well(s).] Peculiarities/Potential Problems — Many gasoline station and garage owners may not have knowledge or records on their disposal systems. Intensive detailed questioning may pro- vide some answers which were not easily answered before. 2 — 24 ------- Many facilities may use dual purpose wells (e.g., cesspools, septic systems, and storm runoff drainage wells). The inspector may have to check city records to determine if the station is sewered or not. This may be a tedious task. All legal implications of inspecting such facilities, especially at stations owned or leased by major oil companies, should be reviewed before any inspections are conducted. Some wastes injected by such facilities may be Class IV hazardous wastes. All such sampling and analysis must be carefully undertaken, especially if enforcement actions are anticipa- ted. RECHARGE WELLS 5R21 Aquifer Recharge Wells — recharge depleted aquifers arid may inject fluids from a variety of sources such as lakes, streams, domestic wastewater (sewage) treatment plants, other aquifers, etc. 5B22 Saline Water Intrusion Barrier Wells — inject water into fresh water aquifers to prevent intrusion of salt water into fresh water aquifers. 5S23 Subsidence Control Wells — inject fluids into a non-oil or gas producing zone to reduce or eliminate subsidence associated with overdraft of fresh water. Inspection Contacts — owner/operator (e.g., flood control district), state agency (e.g., Water Resources Division), consulting engineer. 2 — 25 ------- Well—Type Specific Questions/Tips — What is the source and quality of injected •fluids? Do these wells serve a secondary purpose such as sewage treatment plant effluent disposal? Which aquifer is being recharged? What is the injection zone? Please present an overview of the recharge project including specific details on the injection portion of the project. Is there a groundwater monitoring and/or injectate monitoring system on site? If so, may I review the periodic/continuous analyses? Is this project regulated by a local or state agency? Peculiarities/Potential Problems — Define the purpose of the injection project (e.g., recharge, salt water barrier, or subsidence control). Determine any secondary uses of system. Many of these projects are under jurisdiction of a local or state agency. This is primarily due to the fact that most such projects inject directly into USDW. Some of these projects may be operated irresponsibly with regard to injectate water quality. MISCELLANEOUS WELLS 5N24 Radioactive Waste Disposal Wells — include all radioactive waste disposal wells other than Class IV wells (Class V radioactive disposal wells include those injecting deeper than the lowermost USDW). Inspection Contacts — environmental coordinator, company process engineer, or waste disposal supervisor, Department 2 — 26 ------- of Energy (DOE), Nuclear Regulatory Commission (NRC), or Department of Defense (DOD) official. Well—type Specific Questions/Tips — What specifically is injected and what is the fluid quality and quantity? Please delineate all aquifers (USDW) nearby with respect to the injection zone (to determine if this is a Class IV or V well). Peculiarities/Potential Problems — Very little is currently known about 5N24 wells. Any 5N24 site inspection should be conducted only after careful planning and coordination with USEPA and the facility owner/operator or other representative. Although USEPA’s motive would be to obtain all site specific assessment level information, the health and safety of field inspectors is paramount. Coordination with other regulatory agencies such as DOE and NRC is crucial. More details on inspecting 5N24 wells will be developed as more is understood about these wells. 5X25 Experimental Technology Wells — are used in experimental or unproven technologies such as pilot scale in Situ solution mining wells in previously urimiried areas, tracer studies, secondary water recovery, thermal storage, etc. Inspection Contacts — site specific (will have to play by ear), project supervisor or environmental coordinator. 2 — 27 ------- Well—type Specific Questions/Tips - Please explain project ‘and the specific usage of injection wells. What type and quality of fluids are injected? Does the facility have a groundwater or injectate quality monitoring. system on site? (Proceed with assessment level inspection questions (see checklists in Section 4 of this text).] Peculiarities/Potential Problems — This is an unlimited, diverse class of injection wells which require specific questioning to determine use and purpose, threat to groundwater quality, etc. If the wells are associated with in situ solution mining, aquifer remediation, underground coal gasification, or in situ oil shale/tar sands retorting, proceed with reviewing tips presented for these well types, respectively. Some owner/operators may consider these associated technologies as experimental. Very little is known about other experimental technologies using injection wells; thus, assessment level inspections are warranted. 5X26 Aquifer Remediation Related Wells — inject fluids to prevent, control, or remediate aquifer pollution, including but not limited to wells at Superfund sites. Inspection Contacts’ — company environmental coordinator, plant manager, or project engineer, state agency (e.g., Departments of Water Resources, Health, etc.). Well—type Specific Questions/Tips — What contaminant(s) is(are) being recovered by the remediation system? Please 2—28 ------- detail the remediation system specifics. Are any treatments used before the recovered groundwater is reinjected? If so, please detail. What is the source, quality, and quantity of injected fluids? Is there a groundwater or injectate monitoring system on site? May I review the system reports and periodic analyses? How effective has the system been to date? Is the project under regulatory authority of any federal, state, or local agency? If so, please detail. [ A tour of the system and each component, complete with explanation, is in order.] Peculiarities/Potential Problems — Each system is site specific. Inspection questions should be developed for each facility to compensate for site specific conditions. Any federal, local, or state regulatory agency overseeing the remediation system should be identified and coordinated with during site investigations. Depending on the site and the stage of remediation in place, it may not be practical or necessary to treat recovered groundwater before injection. This is true for facilities where hydrocarbon contamination is being remedjated; at such sites, the “free hydrocarbon” (source) is first removed before further groundwater treatment can effectively be conducted. 5X29 Abandoned Drinking Water Wells - include those abandoned water wells which are used intentionally for the disposal of wastes. 2 — 29 ------- Inspection Contacts — owner/operator (including land owner), SCS county agents, local or county sanitarians. Well—Specific Questions/Tips — Are there any other abandoned water supply (potable, irrigation, or process water) wells on site? Are the wells properly plugged and abandoned? If not, are any wastes, intentionally or unintentionally, discharged to the wells? If so, please specify type, quantity, and quality of fluids injected. How long and by whom has this injection been occurring? Have any nearby water wells have been affected or have had any water quality changes? (Inspect all wells, including the abandoned water wells, on or near site.] Peculiarities/Potential Problems — Finding out about such wells is difficult. Most cases of abandoned wells being used for waste disposal come from citizen complaints or anonymous telephone calls. The state or local water resources agency or health departments may be aware of such practices. 5X27 Other Wells — any other unspecified Class V wells. Well type/purpose and injected fluids must be specified. Use your best judgment on inspections, based on above listed suggestions. 2 — 30 ------- SECTION 3 GENERAL CLASS V WELL INSPECTION TIPS This section is intended to provide some guidance for inspection situations where the inspector has no prior knowledge of the type of Class V well(s) which might be present and little or no information about the type of activities or manufacturing processes occurring at a given inspection site. In this case the initial step in the inspection process is to obtain a description of the type of activities occurring on-site from the contact person. This should include descriptions of processes and wastes generated from each process. The inspector should ask the general questions listed below to help determine what wastes or fluids are generated on site, keeping in mind what the facility business is. What is the nature of business at this facility? What L hat i 4c trca. ’j ic. pr.cJu J 4 products or services are provided?fl (Have contact person list each waste stream and its ulitmate fate (e.g., well disposal, sewer disposal, recycled, etc.).] How is storm water handled on site (e.g., by storm sewer disposal, by drainage well disposal, etc.)? Is this facility connected to a sanitary sewer system? Does the facility dispose of sewage wastes in the sewer or by an on—site system like a cesspool or septic system? Is the use of sewers available for all wastes generated? If not, are wastes other than sanitary wastes disposed in the on-site systems or by some other means? Please specify for each waste stream. Is an aquifer remediation (clean—up) project operating at the facility? 3—1 ------- If so, are injection wells used in the system? Does the facility heating/air conditioning system utilize groundwater and, if so, does the system have reinjection wells associated with it? Are there any nearby potable water, industrial, or irrigation water supply wells (including abandoned water wells)? (At this point it may be worthwhile to review the listing of Class V injection well types.] Are there any other kind of injection wells known to operate nearby? Once this information has been obtained and as many of the general questions have been answered, the inspector should ask for a tour of the facility and to see the wells. A facility tour is very important. During this tour, the inspector has the opportunity to see any waste management facilities, examine general site conditions, and to look for possible violations such as sinks or floor drains plumbed into the wells. The inspector should ask about anything that appears to have any potential to contaminate the wells including chemicals stored nearby, floor drains, catch basins, waste disposal practices, etc. It is not uncommon to discover information that changes a well’s classification during a facility tour (e.g., presence of floor drains connected to a septic system which might result in reclassification to a 5W20 industrial waste disposal well). It is also not uncommon to discover additional wells, particularly drainage wells, which were not originally declared by the inspection contact. 3—2 ------- After all wells have been located and classified by type, the inspector should attempt to obtain the information specific to each well type identified (see Sections 2 and 4). 3—3 ------- SECTION 4 VARIOUS CLASS V INJECTION WELL INSPECTION CHECKLISTS Six example, inspection checklists are presented in this section. The first two inspection forms could be used or modified for use during reconnaissance-level inspections. The last four checklists could be used or modified for use during verification, assessment, or enforcement-level inspections and reflect the generally greater amount of details needed for such inspections. The third and fourth checklists (one for high-tech and one for low—tech wells) ask for relatively less detail than the fifth and sixth checklists and could be used for verification—level inspections. 4—1 ------- RECONNAISSANcE-LEVEL INSPECTION CHECKL ISTS 4—2 ------- FIELD INSPECTION REPORT Field Inspectors Previous Inspections yes no If yes, date(s) _______________ Date of Inspection: _____ Type of Well: ________ L ation of Well: ______ rber of Wells: _______ G P DA FAcThI’IY INF R’1M’ION s-rk< r ____________ a’wis’rizi P E m: ___ CX)N AC PERSON: Type of Inspection: rrective ?ction Ca plaint _______ Capliances ______ Mech. mt. _______ nstruction _____ Re-Work _________ Reconnaissarxe L AL QER PRE P ‘z?/s’r/zIP O E : ___ CDN AC PERSON: LOCATED IN NS P OR LATITUDE _____ _____ SECrION _____ Q1’R S TION ________ z r FR 4 THE ________ LD E ND ________ FRQI THE ________ LINE LO ’I ]DE P&A ______ Misc. (ecplain) , , 4— -, ------- ‘1’Y S ?ND Nt ERS OF P 1 SS V ECI’ION WELLS OPERATED: DRAfl GE W JLS A icult .zal Drainage Wells ____ Storm Water Drainage Wells ____ Im ro ,ed Sinkholes _____ Iniustrial Drainage Wells ____ Special Damage wells (specify) _________________ GEDTHE tP.L REDUEC ICN WELLS .ectric P r Reinjection Wells ____ Direct Heat Reinjection Wells _____ Heat P inp/AC Return Fl Wells ____ Pquaculture Return Floe. Wells ____ ric WPISTEWATER DIS S L W TJ- Untreated Sewage Waste Disposal Cesspool s Septic Syst ns (TJr i fferentiated) Septic Systens (Well Disposal) Septic Systans (Drainf ield Disposal) Waste ater ‘frea ent Plant fluent I’DNERNJ ND FOSS J FUEL RELATED ____ Mining, Saixi , or Other 3 ) ill ____ ____ Solution Mining Wells ____ ____ In Situ FOssil Fuel Recovery Wells ____ ____ Spent Brine Return Flo Wells 0Th FIELD JC1’ION WASTE DIS SAL Air Scrtbber Waste Disposal Water Softener Regeneration Brine ______ fl WSTP IN / a?L/TJr rr’f oling Water Return F1o i ____ Irdus trial Process Water/Waste _____ (specify) ____________________________ Autanthile Service Station Waste R.EOiA E WELLS ) uifer Recharge Wells Saline Water Intxusion Barrier Subsiderce Control Wells MISC LLANEaJS Radioactive Waste Disposal E çerinental Technolo (spec.fy) _______ ?q ñ fer Ranediation ) bd. Drinid.ng Water Other Fa. r -uP NE SSARY (‘ SfNO): ? NY NON— 1 I?N I NirrJ u : E O’IOS TA L G NUb SER WI’fli DES IPPION OF OT : SI2 A’IURE OF D SPECflR: (spec.fy) 4—4 ------- USEPA REGION IX UNDERGROUND INJECTION CONTROL PROGRAM RECONNAISSANCE LEVEL FIELD INSPECTION REPORT FACILITY INFORMATION Inverztory/Pemnit ID: ________________ Other ID ________ Facility Nait : ____________________ Contact Person: ______ _________________________________ Title: ______________ Facility Mdress: __________________ Contact’s Address: ____ Inspection tate (N, D, CY): ____ - - N es ai Affiliations of Field Inspector(s): ________________ W L i TION DNrA: ________ Type ________ *S s ________ Years of Cper. ____ to ____ Ni. ±er ________ Type ________ *St ________ Years of Oper. ____ to ____ N rber ________ Type ________ *Status ________ Years of Oper. ____ to ____ N’m’ber ________ Type ________ * 5 a ________ Yeaxs of Oper. ____ to ____ *1= Proposed 2=Urxier Constxuction 3=Existing/Active 4=Tezpararily Aarx1on i 5=Pez:mariently Abarxb ied 6=Pexinanently ?baxx oned ar t bt Approved Any rbn-Ca liarce rbted? (YIN) _______ (List possible violations on back) Folla -Up edai? (YIN) _______ Recar rerx ed Fol l r-up Action*: __________________________________________ ENF=fliergerey R ponse/ ifoxc nt SMP=S pling PLG=Plug Well RT Routine/Periodic Inspections RFIi=Ra uest for ?Mitional Inforsation PI to(s) Taken? (YIN) ________ Roll M . ________ Fraz s. ________ Attac rents? List: _____________________________________________________ 4—5 (Comments on Reverse Side) ------- G 4ERAL co * rrs (Operator c ments, weather, surrounding land use, susceptibility to spills, appearance of wells, security, etc.) Signature(s) of Inspector(s): — 4—6 ------- VERIFICATION, ASSESSMENT, OR ENFORCEMENT-LEVEL INSPECTION CHECKLISTS 4—7 ------- USEPA. REGION IX UNDERGROUND INJECTION CONTROL PROGRAM IN-DEPTH INSPECTION REPORT LOW TECH WELLS GENERAL FACILITY INFORMATION Inventory/Permit ID _____________ Other ID No. — Operator/Facility: Name ___________________________ Address: City: __________ Ccxinty: __________ State: — Zip: _____ Phone: Legal Contact: Name ______________________________ Company: Address: City: __________ Ccunty: __________ State: Zip: _____ Phone: Owner: Name __________________________________ Company:. Address: City: __________ C nty: __________ State: — Zip: _____ Phone: Parent Company: _____________________________________________ vnership Stat is: 1 = F 2 = TE 3 = PRIVM’E 4 = JRTi C 5 = (Cix 1e e) Nature of Business: ________________________________________ RC A Facility? (Y/N/M) Y = Yes N = 1.b M = MAYBE, ADDITIO L RMM’ION Insp tion Date: CM, D, C ): ____/ /___ NanEs ai Affiliations Inspectors: _____ Signature(s) of Inspector(s): ______ Date Inspection Report Car leted: — 4—s ------- Inventory/Permit ID ___________ Operator/Facility Inspection Type: _________________, ! CT = Witness z a’r = flrergercy Response/ orc nent = Witness ,struction PLC = Witness Plugging RTN = Routine/Periodic Inspection SMP = Saspling EPA Project Officer: _____________________________________________ Mditional Participants: ______________________________________________ 1 11 C.assi.ficatiai t ta Mmber _______ Type ________ *Status ________ Years of Oper. ____ to _____ Niunber _______ Type _______ *Sta ________ Years of Oper. ___ to ____ I4 i urber _______ Type _______ *S t tus ________ Years of Oper. ___ to ____ N i unber _______ Type _______ *Sta ________ Years of Oper. ___ to ____ *j=p posed 2=Ur er c nstxuction 3=E dsting/Active 4=’1 xporarily bar or 5=Pexmanently Abandoned 6=Pexrlax3ently Abandoned az bt Approved Well O on ta1 D th (ft) Dia. (in) Casing? (Y/N) Well Type ____ _______ _______ __________ Well Type _____ __________ _________ _____________ Well e ____ _______ _______ _________ Well Type ____ _______ _______ _________ Describe any prcviois prthlaz with the wells: ___________________________ Describe injection well peintits that this facility has applied for or cbtained: List substances stored on-site: ____________ List possible RC a rdc,is Waste(s) on—site: - h_fl ------- Inventory/Per nit ID ___________ Operator/Facility crxa FIDID n ai Describe Injectate Source/Pre-trea nt Pr esses: ________ Inj ec tate Cai Osi tiOrl:__________________________________________________ Eossible Q ritaninants:____________________________________________________ Averaqe Voltzie Inject :____________________________ (gallons/day/well) Specify periodicity of injection voltme ai of injectate caiçosition: Describe pot tial sanpi irig points: _________________________________________________ cricz i A C ____ ____ General i ntS (appearar e of ll Cs), susc ti i1ity to spills, sec ity, etc.): Any bn-Cpliance Ibted? (YIN) ____ Foll -Up Needed? (YIN) ____ Recar rerded Foll v up ? tion: ________ PLG= Plug Well J=Routine/Periodic Inspections =Saup1 ing ENF=E xergency Respnse/ forceu ent RFI=R uest for Mditional Thfornatian 4-10 ------- Inventory/Permit ID __________ Operator/Facility __________ 1 . 1ST (P M’rA i1’S — bte as follovs: X if atP ) i. A if available l it rxt att 1 vi, if r t available o Map of Facility Grouix1s: ____ o Well or Sat ling Point Plxtos: (Y/N) Roll . ____ Fraie ,. o Well Log(s) for Injection Well(s): ____ o As—built Dia9ran of Injection Well(s): ____ o risultant R orts for Injection Well (s): ____ o orts on Well Construct ion/Workov-ers: ____ o nitorthg Data for Injection Well: - records of injectate arialysis(es): ____ — records of injection voitme (s) /rate Cs): _____ o nitoring Well Data: - .mber of M,nitoring Wells: ____ - Location: Vertical and Horizontal Distance and Direction of bnitoring Well Cs) Fran Injection Well: ____ — D th of Ca pletion and S rp1ing Interval: ____ — nical and Physical Analyses: _____ o Water Supply Wells (within a one-quarter mile r ius of the injection well): - Nimber of walls: ____ - Location: Vertical xi Horizontal Distance and Direction of Supply Well (s) fran Injection Well: ____ — n r ical and Physical Analyses: _____ - Status of Wells (operating, abarx1oned, etc.): ____ - Status of Any Nearby Surface Waters (possibly affect by injection well operation): ____ - Fl Diagr of ocesses, waste neration and disposal: _____ o Operator Interview tes: ____ o Manifests: ____ o R orts on Site Hydro ology: ____ £ —l 1 ------- us ’A, K11uc11 D C UN DurX fl 1 Dfl I -D rH P Ic J i cr HI j w yz..g GE2 AL FACImY X1 Irwentory/Pennit ____________ Other tb. ________ Operator/Facility: Nane ______________________________ Address: City: ___________ Cc1znty: __________ State: — Zip: _____ P1x ,ne: Legal Contact: Name ______________________________ Company: Address: City: __________ Cainty: __________ State: — Zip: ____ Pl cne: Owner: Name __________________________________ Company: Address: City: __________ CQinty: __________ State: — Zip: _____ P1x ne: Parent Company: _____________________________________________ nership Sta as: 1 = F 2 = S’ E 3 = PRIVM’E 4 = YHLIC 5 = (Cix 1e One) Nature of Business: ________________________________________ RCRA Facility? (Y/NIM) Y = Yes N = t b M = ? BE, P W ADDITIO L ]2 FO1 a’IoN ]] P D F Inspection Date: CM, D, CY): ____/ /____ Names az Affiliations Inspectors: - Signature(s) of Inspector Cs): _______ Date Inspection R ort Capleted: — 4—12 ------- Inventory/Permit ID __________ Operator/Facility Inspection T ype: _________________, Z T = Witness ‘Tr = E ergerry Response/ forc t nt = Witness i5tniction PLC = Witness Plugging R = Routine/Periodic Inspection = Saupling PA Project Officer: __________________________________________________ .Mditional Participants: ________________________________________________ Wel]. CJ .assi.ficatiai Deta Ninrber _______ Type ________ *Status ________ Years of Cper. ____ to ____ Nunber _______ Type ________ *St JS ________ Years of Oper. ____ to ____ Nurber _______ Type _______ *Status ________ Years of Cper. ____ to ____ Ntm ber _______ Type ________ *St 1S ________ Years of Cper. ____ to ____ *l=Pruposed 2=Ur er Cons txuction 3 cisting/Active 4=Teiporarily Abardoned 5=Perrnanently Abarx cned 6=Perxnanent] .y Abaix1oned ar Isbt Approved Describe injection well pe xtits that this facility has applied for or cbtained: List substances stored on-site: ___________________________________________ List possible RC A Hazaxdcus Waste Cs) on-site: _____________________________ flU Describe lxii ectate S jrce/Pre—trea ent Prccesses: ___________________________ lxii ectate Ca position __________________________________________________ Fossible itaninants ____________________________________________________ Average Volt Injected ____________________________ (gallons/day/well) Specify periodicity of injection voh e ard of irijectate caxpositiori: Describe potential sanp]. ing points: _____________________________ 4—13 ------- Inventory/Permit ID __________ Operator/Facility L OATh API NLmiber: ________________________ Date Drilled: _______________________ Surface Elev: Date Converted: ____________________ Pli ged Back To: _________ Date Abathoned: ____________________ Well Stab.is*: __________________ *1 = Proposed 2 = Urger Construction 3 = cisting/ tive 4 = Tarporarily ?tbai ned 5 = Permanently Abar oned 6 = Permanently Abarxioned Not Approved 1e, Casing/Li r, C m-rit, Packer, Tubii ThfuuIkttiCXl Hole Casing Wt./ Cai nt Top of Size Depth (a)) Grade Depth C.ass h3d . Sacks Caent Packer Type: ________________ Tubing Size/Wt.: Packer Depth: _______________ Tubing Depth: — Ar i 1 r Fluid: ______________ Inhibitors: FluidSeal: Yes/No pl etixi Type Perforations (sk ts/ft) Depth _________ to _____ Depth _________ to _____ Depth _________ to _____ Screened Interval (Sq. in/LF) Depth_____ to___ Depth_____ to___ Depth to _____ Open Hole Depth _________ to _____ Note: If the facility has i re thai one injection well, attach a carpleted Page 3 for each. 4—14 ------- Inventory/Permit ID Operator/Facility IM E !I ZQ E AN OP TflG D Fran ________to ________ Fruit ________to ________ Fran ________to ________ Fran ________to ________ Above fruit ________ to Be1 fran ________ to Cai rents: _________ ha a1 Iut ity 1 stirq Litbolo r Litbolo ’ Date Of Last T: ____________ Results: __________________________ cVeraHt 1 jt ii of hxjecti Well Type of MIT: Injection Rate ______ Injection Pressure ______ Anxn. lar Pressure Fluid T iperature _____ Athient Tesiperature _______ pH ____ Daily Voltm (average) __________ Daily Voltni (maxini n) — ?txtthly Vo1t ne (avg) _____________ kxithly Voluzze (max) ____ Pressure Gauge Type _______ Pressure Range ________ Ir reient Calibration Date _________ Recorder Type ________ L ation Any Previous Prthlare with ll Cs)? cribe: _____________ Geologic YL ’.. flt Nate(s) of Injection fl it/Interval(s): Geologic Age of Injection fin(s):___ Depth(s) to p of Fornation: _____ Depth(s) to Base of Formation: ____ Depth(s) of Injection Zone(s): Lithology Lithology Lithology Lithology ‘IDS IDS ‘IDS IDS Confining Fornation Nazie(s): Geologic Age of Confining fin(s): Depth of First Confining Zone(s): s._i c ------- Inventory/Per nit ID __________ Operator/Facility _________ List Records intained ath Re’iewe:I. Also, Describe any Inad uacies in Record Ke ing: PE I I LTS AN) I A1 List Results: Any M n-caTIp1iar1ce t i? (YIN) Follow-Up Ne ed? (Y/N) List RecaT rer ations: ReCcn IX1e Follow-Up P ction: * * =Plug Well R itthe/Pericdic Inspections =S pling ‘=E rergency R ponse/ foxcer it RFI=R iest for ? 1 dditional Info. 4—16 ------- Inventory/Permit ID __________ Operator/Facility _________ LIST AT a* EM’S — te as fol1c s: X if attack , A if available but r t atP r h d, Z if zr t available o Map of Facility Gr irds: ____ o Well or Sarrpling Point P1 tos (YIN) Roll l b. ____ Frane lb. _____ o Well Log(s) for Injection Well(s): _____ o As-built Diagran of Injection Well(s): ____ o nsultant R orts for Injection Well Cs): ____ o R ts on well const ction/workovers: _____ o Z’bnitoring Data for Injection Well: - records of injectate analysis (es): ____ - records of injection vol me (s) Irate Cs): _____ o rbnitorfng Well Data: - Nurber of rLitOrthg Wells: ____ - L ation Map or Coordinat : ____ - D th of Caxpletion ath Saupling Iiiterval: ____ — thanical and Physical z,alyses: _____ o Water Supply Wells (within a one-quarter mile rwthis of the injection well): — N mber of wells: _____ - L ation Map or Coordinates: ____ - Chenical ai Physical Analyses: _____ - Status of Wells (operating. abardoned, etc.): _____ - Status of Any axby Surface Waters (possibly affected by injection well operation): ____ - Flc v Dia -aui of processes, waste generation ard disposal: _____ o Operator Interview Ibtes: ____ o Manifests: _____ o R orts on Site Hydrogeology: ____ 4—t i ------- UNDERGROUND INJECTION CONTROL PROGRAM SITE INSPECTION SECTION I — General Information Name of Facility: Address: Telephone: Owner Address and Telephone (if different from above) Nature of Business: Use of Injection Well Cs) (drainage, direct disposal, etc.) : Identification, Permit or EPA Number (s): Injection Well (s) Location (township, range and section, latitude and longitude, verbal description, land marks, etc.): Type of Injection Well Cs): Industrial Drainage: Storm—runoff: Agricultural Drainage: Improved Sinkhole: Beat Pump Air Conditioning Return: Aquaculture: Cesspool Septic Tank: Domestic Wastewater Treatment Plant Effluent: Sand/Mining Backfill: Cooling Water Return Flow: Industrial. Waste Disposal: Service (Gas) Station: Other (specify): Injection Well (s) Currently Operating: Yes _______ No _______ If No, Last Date of Operation: Date of Construction of Injection Well Cs): Years Injection Well in Operation: 4—18 ------- SECTION II — Hydrogeo]ogic Information Injection Formation — Name: — Description: — Extent of tnjection Zone Cs) Below Land Surface (or elevation above Mean Sea Level): — Minimum Distance from Injection Well to Underground Source of Drinking Water (U.S.D.W.): Location (depth below land surface, areal extent, etc.) and description (thickness, lithology, etc.) of Any Relatively Impermeable Strata (aquitard Cs)) Present: Underground Sources of Drinking Water: Confined: Unconf ined: Depth to Perched Water Table (if present): Depth to Water: Saturated Thickness: Description and Characteristics: Extent of Use of U.S.D.W. (extensive, moderate, municipal, domestic, potential, etc.) Comments: 4—19 ------- SECTION II — Hydrogeologic Information, Continued Attach the Following Information (note if unavailable) — Map of Facility Grounds: — Well Log Cs) for Injection Well Cs) — As—built Diagram of Injection Well (s) (may use attached general schematic if necessary): — Consultant Reports for Injection Well Cs) and/or Site Hydrogeology: — Monitoring Data for Injection Well: — Monitoring Well Data: — Number of Monitoring Wells: — Location: Vertical and Horizontal Distance and Direction of Monitoring Well Cs) From Injection Well: — Depth of Completion and Sampling Interval: — Chemical and Physical Analyses: — Downgradient Water Supply Wells (up to a two mile radius of the injection well): — Number of wells: — Location: Vertical and Horizontal Distance and Direction of Supply Well (s) from Injection Well: — Chemical and Physical Analyses: — Status of Wells (operating, abandoned, etc.) — Status of Any Nearby Surface Waters (possibly affected by injection well operation): 4-20 ------- SECTION III — Operating Data Injection Rate, Frequency, and Volume (drainage area, precipitation, etc, for drainage wells): Description of Injection Operation (including brief history): Fluid Source: Fluid Composition/Characteristics (including any treatment process): Contaminant Cs) and Potential Source Cs) of Contamination: Method of Disposal (transport to well): Previous Problems with Well (clogging, overflowing, etc.): No ________ Yes _______ Description of Problem: Operating Records Attached: Yes ________ No ________ Injection Fluid Analyses Attached: Yes ______ No _______ 4—21 ------- SECTION IV - SITE INSPECTION SPECIFICS Name and Affiliation of Inspectors: Name and Affiliation of Facility Contact: Date: Time: Reason for Inspection: Number of Injection Wells: Number of Injection Wells Inspected: Site Conditions: Inspection Comments: 4—22 ------- SECTION V Primary Contact Information Sheet Name: Phone: Address: Affiliation (local, state, federal, etc.): Notes: 4—23 ------- WELL COMPLETION SKETCHES .11 LftATOR HYDROGEOLOGIC D T FACILITY FIELD WELL CLASS TYPE ORIGiNAL COMP OATE CONVERSION DATE WELL COMPLETION DAT I 4—24 ------- NOTES 4—25 ------- NOTES 4—26 ------- Cover Page UNDER ROVND I? JECTION CONTROL PROGRAM INSPECTION REPORT FACILIT! NAME: ______________________________ NAME AND PERMIT/EPA NUMEER OF INJECTION W L (S): NATURE OF BUSINESS: DATE(S) OF INSPECTION: ___________________________________ TIME: ______________ INSPECTOR(S): Name(s): Affiliation(s) Phone Number(s) ADDITIONAL PARTICIPANTS Name(s): Affiliation(s) Phone Number(s): GENERAL SITE CONDITIONS DURING INSPECTION [ weather; well(s) operational status. ease of entry, general housekeeping etc.]: PURPOSE OF INSPECTION: INSPECTION RESULTS (SUMMARIZED) • COMMENTS AND REMAP.FZS: I certify that I conducted the inspection described in the attached report and that, to the best of my knowledge, this report is accurate. Signature of Inspector Name, Title and Affiliation of Inspector Date of Completed Report 4—27 ------- UIC INSPECTION REPORT SECTION I - C ERAL INFORMATION 1. Facility Name, Address and Telephone Number: Name Address Telephone Number _____________________________________________________________ 2. Facility Contact: Name Title/Affiliation ____________________________________________________________ Telephone Number _____________________________________________________________ 3. Injection Well(s) Identification: Injection Well(s) Identification ________________________________________ 4. Location of Injection Well(s): Latitude/Longitude ________________________________________________________ Township/Range. Section _________________________________________________ Street Address _______________________________________________________________ Other 5. Name and Address of Legal Contact (if different from above): ______________ 6. Types of Permits Issued for this Facility (include permit numbers and names of federal, state and local agencies and programs which regulate the facility): 7. Number and Operational Status of Injection Well(s): Well Class/Type Active Under Abandoned Idle Other Construct. Conments/Remarks (include reasons for abandonment): 8. Visual Appearance of Injection Well(s) (Attach photographs if available): 4—29 ------- UIC flISPECTION REPORT SECTION III - OPERATIM DATh 1. Description of Injection Opera tion (including brief history): 2. Surface Facilities/Treatment Processes: 3. Industrial/Wastewater Sources (processes by vhich the injected fluid is produced) 4. Generalized fluid/Waste Category (les) /Composition: 5. Method of Delivery of Fluid to the Injection Well(s): 4—29 ------- UIC INSPECTION REPORT SECTION II - ETDROGEOLOGIC ENVIRONM IT AND INJECTION W IL INFORMATION 1. Well(s) Construction Details (complete attached diagram for simple Class V well(s) and/or provide sketch of well(s); sketch or provide photograph of well, head): a. Total Depth _____________________________________________________________ b. Casing: Diameter: _____ Grade: _____ We. (#/ft) _____ Depth: _____ to ________ Diameter: _____ Grade: _____ Wt. (f/ft) _____ Depth: _____ to ________ Diameter: _____ Grade: _____ Wt. (0/fe) _____ Depth: _____ to ________ Diameter: _____ Grade: _____ Wt. (0/fe) _____ Depth: _____ to ________ Diameter: _____ Grade: _____ Wt. (0/fe) _____ Depth: _____ to ________ c. Tubing: Diameter: _____ Grade: _____ Wt. (#/ft) _____ Depth: _____ to ________ d. Cement (also indicate drilling mud): Depth ______ to ______ Grade _______ Additives _______________________ Depth ______ to ______ Grade _______ Additives _______________________ Depth ______ to ______ Grade _______ Additives _______________________ Depth ______ to _______ Grade _______ Additives ________________________ Depth ‘ to ______ Grade _______ Additives _______________________ e. Annular fluid Type: ____________________ Inhibitors: _________________ f. Packer Type: _________________________ Depth: _____________________ g. Fluid Seal: Tes No h. Copletion Type: Perforated Openings (holes/f t) Depth ______ to ___________ Depth ______ to ___________ Depth ______ to ___________ Screened Openings (sq in/LF) Depth ______ to ___________ Depth ______ to ___________ Depth ______ to ___________ Open Mole ________________________________________________________ 4-30 ------- UIC INSPECTION REPORT SECTION II — HYDROGEOLOGIC INFORXAI”ION (continued) 2. Geologic Environment: a. Name of Injection Formation/Interval ________________________________ Geologic Age of Injection Formation ________________________________ Depth (Subsea) to top of Formation ____________________________________ Depth (Subsea) to 3ase of Formation ___________________________________ Depth (Subsea) of Injection Zone(s): ______________________________ From To _________ L.ithology ____________ TDS ________ From To __________ Lithology ____________ TDS ________ From To _________ Lithology ___________ TDS ________ From To __________ Lithology ____________ TDS ________ Additional Information: ________________________________________________ b. Confining Formation Name(s): _____________________________________ Geologic Age of Confining Formation: ________________________________ Depth of Confining Zone(s): From __________ To __________ Lithology __________________________ From To Lithology _________________________ Additional Information: ______________________________________________ c. Recent Geologic History Including Seiamic/Volcanic Activity 3. Subsurface Geology and Hydrology for Well Site: Attach the following information or note that the information is to be requested at the time of inspection. Where applicable, information on an area within a 1/2 mile radius of the well bore should be included. a. Map of facility grounds with well locations shown. b. Indicate the depth to the base of the lowest USDW. c. Well logs on Injection Wells. d. As—built diagram of inj ection well Cs). e. Location (horizontal and vertical) and data (water quality and availability) for public drinking water supply wells and for monitoring wells which are part of the injection project. f. Geologic cross section(s) through injection well(s) down to at least the base of the lowest injection zone. g. Regional hydraulic gradient within the injection zone (direction and quantity). h. Bibliography of information used in preparing Section II. parts 2 and 3. 4—31 ------- UIC INSPECTION REPORT SECTION III — OPERATDG DATA (continued) - 6. Mechanical Integrity Testing (include copy of pressure recording charts/records): Date of Last MIT Type of KIT _____________________________________ Results _____________________________________________ 7. Operational Monitoring of Injection Well (at time of inspection): Injection Rate Injection Pressure Annular Pressure Fluid Temperature Ambient Temperature pH Daily Volume (average) Daily Volume (maximum) Monthly Volume Cave) Monthly Volume (max) Pressure Gauge Type Pressure Range Increment ________________ Calibration Date ________Recorder Type Location ___________________ 8. Any Previous Problems with Well(s): If yes, describe 9. Attach the following information (note if unavailable): 1. All Appropriate Analyses of Injectate 2. All Appropriate Operating Records 3. Date and Report of Last Major Workover SECrION I V — SAI1PLDG INFORMATION (if applicable) 1. Sample Data Sample ID ________________________________ Date _____________________________ Time Sampling Point ___________________________ Sample Type Analyses Requested Preservatives Used Name(s) of Collector(s) 2. Field Data Temperature pH Specific Conductance 3. Chain of Custody Identify Analytical Laboratory to be Used Indicate Chain of Custody Form and field data form are attached to sample(s) by circling YES 4—32 ------- UIC DISPEC’rION REPORT SECTION V — RE ORD PDIG 1. List Records Reviewed and Reasons for their Review (reference all docuzents that were borrowed or copied): 2. Describe any Inadequacies in Record Keeping Procedures (Note if any required information was unavailable or incomplete or inaccurate with special attention paid to pressure and flow measurement records and construction schedules if relevant): SECTION VI — FINDI)GS MID 4 NauSIONS 1. Describe all Findings and Remarks: 2. List Conclusions: 3. List Rec mendations: 4—33 ------- WELL COMPLETION SKETCHES WELL CLASS WELL FACILITY flPE ORIGINAL OPERATOR FIELD COMP DATE CONVERSION __________________________________ DATE HYDROGEOLOGIC WELL. COMPLETION D T A DATA 4—34 ------- NOTES 4—35 ------- NOTES 4 36 ------- PREP 2XNG POR INSPECTIONS Choose folder containing positive questionnaires with prioritized well type. Separate questionnaires by location. Choose priority locations. Call facilities. Record information on telephone correspondence record. Note: - date - time - who you are - who you are talking to - that information on questionnaire is correct or otherwise — date inspection will be conducted - who will conduct inspection — who inspectors should ask for (facility contact) — directions to facility from major road. Follow up phone call with letter of notification. Include: - date of phone call — who you spoke with, and who inspectors will contact — date inspection will be conducted - who will conduct inspection - your name and phone number — EPA representative name and phone number — list of items that facility rep should make available Prepare inspection file, including: - copy of questionnaire — copy of letter of notification — Notice of Inspection form — map with arrow indicating facility location - Inspection Summary Report form - copy of telephone correspondence record - rating system form ------- CONDUCTING INSPECTIONS - EVERY FACILITY (Fill out form in ink) — Sit down with facility representative - fill out questions from inspection report form in its entirety or in field notebook. Verify info on questionnaire. — Walk through facility, noting locations of all Class V systems, drains to systems, potential contaminants, sampling points, etc. Keep notes in field notebook. — Photograph all Class V systems, drains processes, etc. Record description of each photo (by number) on photo log. — Indicate what kind and number of wells were inspected and any necessary follow up (e.g., mail MSDSs) on Notice of Inspection form. Sign form. Have facility rep sign form. Leave one copy of form with facility rep. — Call project coordinator every other day (minimum) to report number of wells inspected, any problems encountered, and to get any messages concerning inspections. — If inspection has been scheduled but, for some reason, date cannot be kept, facility should be called as soon as possible for rescheduling or to confirm that inspection has been canceled, then follow up in writing. ------- POLLOW UP ACTIVITIES (Fill out forms in ink, neatly printed, or type) (All files should be reviewed by Project Coordinator prior to sending to Region) - Fill out Inspection Summary Report form — Fill out rating system for follow up activities - Do ument photos - Write one- to three-page summary report on facility. Type. — Submit completed file to project manager or project coordinator for review. — Send one set of inspection files to Region. Keep duplicate set of files in—house. (See database management). - Update UICDB with new inventory information. All follow up activities should be completed within two weeks after completing inspections. ------- UNDERGROUND INJECTION CONTROL PROGRAM IN-DEPTH INSPECTION CHECKLIST General Information 1. Facility Contact Name(s) 2. Facility Address, Phone # 3. Contact Address, Phone # (if different than above) 4. RCRA Facility: ID # 5. Inspection Date 6. Names and Affiliations of Inspectors 7. Additional Participants 8. Parent Company, Address Nature of Business 1. Products or Services Offered? 2. Brief Description of any Process, Operation, or Maintenance that Produces Waste 3. What Chemicals are Stored On Site? 4. Describe Waste Disposal Practices 5. Site History - Years of Occupation, Past Owners and Uses of the Facility Class V Injection Well Information 1. Numbers and Types of Class V Wells 2. Current Status and Years of Operation 3. Construction Details - TD, Diameter, Casing 4. Are the Injection Wells Regulated by a State or Local Program? Permit? ------- INJECTION FLUID INFORKATION 1. Describe the Source of Injectate 2. Describe any Pre-Treatment Processes 3. Describe Possible Contaminants 4. What Volume is Injected? 5. Specify Periodicity of Injection Volume and of Injectate Composition 6. Describe Potential Sampling Points GENERAL OBBERVATIONB 1. Measure Dimensions of Well(s) 2. Susceptibility to Spills 3. Security 4. G nera1 Appearance of Well(s) 5. Take Photographs, Record Roll #, Frame # 6. Surrounding Land Use Documents to Request if Available 1. Map of Facility 2. Drillers Logs or Wireline Logs 3. As-built Diagrams 4. Reports on Well Performance or Maintenance 5. Monitoring Well Data 6. Water Supply Well Location and Ownership 7. Flow Diagram of Processes, Waste Generation, and Disposal 8. Manifests - Waste Disposal 9. Reports on Site Hydrogeology, Other Regulatory Agency Investigations 10. Records of Injectate Composition and Volume 11. Obtain Necessary Material Safety Data Sheets ------- E El ENGiNEERING ENTERPRISES, INC. WATER RESOURCF.S SPECIALISTS 1225 We Main Nonnan, Oklahoma 73069 Phonie (4051 329 8300 T Iex 333666 (ENG ENT INCI FAX. t4C5) 366.S7 2 March 15,, 1989 Mr. Dennis Minnick Stauffer Chemical Company 2300 S. Pennsylvania Avenue Morrisville, PA 19067 Re: Confirmation of Inspection Arrangements Dear Mr. Minnick: As I indicated to you during our telephone conversation, the U.S. Environmental Protection Agency and/or Engineering Enterprises, Inc. plan to conduct an inspection of Class V injection wells at the above mentioned facility on March 21 or 22, 1989. EPA and its contractors are authorized to inspect records and facilities under Section 1445 of the Safe Drinking Water Act. Requested information cannot be withheld from EPA on the basis that it is considered proprietary or confidential. For any portions of the information submitted during the inspection which you believe are entitled to confidential treatment, please indicate during the inspection that you consider the information to be confidential. If EPA determines that the information designated as confidential meets the criteria set forth in 40 C.F.R. 2.208, the information will be disclosed only to the extent, and by means of the procedures specified in 40 C.F.R. Part 2, Subpart B. EPA will construe the failure to indicate confidentiality as a waiver of confidentiality claim, and the information may be made available to the public by EPA without further notice. Please inform your facility manager or other on-site representatives of this notice. If any authorized representative will not be available at the facility during regular business hours, please contact me at 1—800—777—8300, or Mark Nelson, Region III EPA, at (215) , 97—9031. Sincerely, • ‘/i 11;- /- , /// Sharron B. Moore Class V Specialist S BM: kh Enclosure Norman Oklahoma Long Beach. California Martinez. California Philadelphia. Pennsylvania ------- MEW ENCLOSUR.E The following items may be reviewed by an EPA inspector or EEl personnel during the inspection of your facility. This enclosure is intended to prevent confusion and wasted time during the inspection. Please prepare the following information for review during the forthcoming inspection.. 1. Facility map showing well, locations, 2. Flow diagram showing flow of waste fluids and their final destination, 3. As—built diagrams of the injection wells (if available), 4. Material safety data sheets, 5. Waste disposal manifests (if applicable), and 6. Any permits obtained for operation of the Class V system (dry well, drainfield, etc.) on site. ------- US EPA UNDERGRQJND INJECtION CONTROL PROGRAM (LASS V W ..L Il PECfION AND SAMPLINC REPORT FACILITY INPORMA F ION UIC Inventory/Permit No.: - Other ID No. (SPDES. RCRAII etc.): Facility Name: ______________________________ Contact Person: ____ ____________ ____________________ — ____________ — Title: ——__________________________ Facility Address: ___________________— Contact’s Address: _______________ Facility Telephone: —____________________________ Contact’s Telephone: ________________________________ Nature of Business: __________________________ No. of Employees: — — SIC Code(s): — ——_____________________ Ownership (circle): FED STATE PRIVATE FUBLIC OTHER I1 PECrION INFORM ION Inspection Date (H. D, CY): — — _____ Inspection Report Completed (Date): Names and Affiliations of Field Inspector(s): _________________________________________________ Number of Wells — Well Types Inspected (i—type): _________________________ _________________ Any Non—Compliance Noted? (Y/N) ________ Photo(s) Taken**? (YiN) —____________ Follow-Up Needed? CT/N) ________ Roll No. ________ Frame Nos. Recommended Follow—Up Action*: _________________________________________ Response/Enforcement SMPSampling PLGP1u 8 Well RTtI=Routine/Periodic Inspection RFI=Requeat for Additional Information **DescriptIon of photographs should be included on the photo log. ------- Inventory/Permit No.: _________________________ Operator/Facility: Wfl.L CLASSIFICATION AND CONSTIWCFION DATA Well Well Location (or Number Years of Opec. Total Gravel Pack! Casing Cement/ Tubing! Type Well No.)** of Wells Status* From To Depth Cf t) Dia (in) Backfill (YIN) Mud Packer *1=Proposed 2=Under Construction 3=Fxistfng/Active 4 Temporarily Abandoned 5Permanently Abandoned 6=Permanently Abandoned and Not Approved ‘ **Attach map or sketch of facility grounds with well locations, floor drains, plumbing associated with wells, and chanical/waste storage areas. INJRCrION FLUID INFOR}W ION Average Volume and Well - Frequency of Injection Type Injectate Source/Composition Possible Contaminants (e.g.. gal/day) ------- Inventory/Permit No.: Operator/Facility: HYDROGEOLOGI C I NFORMAT ION 1 General Composition of injection zone: — Depth to currently used USDW: ___________ Distance to nearest public water supply: Distance to nearest private water supply: Distance to nearest surface water: — Other notes: PROXIMITY TO GRWNDW ER USE 1 (check all that apply) Area Remote to Groundwater Use: — Class I or II Recharge Area: ______ Sole Source Aquifer Recharge Area: Karat Area: _______________________ High Density Use Area: _________— Zone Contribution of PWS: ________ Other (describe): liater Supply Wells (on—site): — Number of wells: — Location; Vertical and Horizontal Distance and Direction of Supply Well(s) from Injection Well (to include well seal depth and screened interval): _____ ____________________________ — Chomical and Physical Analyses Available?: — Status of Any Nearby Surface Waters (possibly affected by injection well operation): — — Depth of Completion and Sampling (screened) Interval: _______ — Chemical and Physical Analyses Available?: ______ As described by the facility representative. Note here if source of information differs. ADDITIONAL WU.L DATA (as available) Monitoring Wells (on—site): — Number of Monitoring wells: ______ — Location: Vertical and Horizontal Distance and Direction of Monitoring Well(s) from Injection Well (to include well seal depth): _____________ ------- Inventory/Permit Ho.: Operator/Facility: LIST OF M7ACIINENTS — Note as follows: I if attached 1 A if avaiable but not attached, NA if not available _____ o Well Log(s) for Injection Well(s): ______ o As—built Diagram of Injection Well(s): ______ o Consultant Reports for Injection Well(s): —— ______ o Reports on Well Construction/Workovers: ______ o Monitoring Data for Injection Well: — records of injectate analyais(es): ______ — records of injection volume(s)/rate: — o Reports on Site Hydrogeology: ______ INSPECUON R ULTS AND RECOMHENDATIONS Inspector’s comments (appearance of well(s), pretreatment processes, susceptibility to spills, security. involvement of other agencies. etc.): ______________________________________________ —- - -- Recommendations (including description of potential sampling points): o Location Hap: ______ o Map of Facility Grounds: — o Well or Sampling Point Photos: (Y/N) Roll No. Frame No. ______ o Fl s Diagram of processes, waste generation and disposal: ___— o Operator Interview Notes: ______ o Manifests: Other notes: ------- Inven Permit No.: perator/Facility: SAMPLING INFORMATION (Complete one sheet for each Sample Station and/or Sample Matrix) Data Samples Collected CM. D, CY): — — Date Samples Sent to Lab: Names and Afflillationa of Samplers; —— — — Drainage Sump/ Catch Basin _____ Leachf i eld/ Drainf teld Other (describe): _____ Air Water Laboratory Name: Contact Person: Add teas: Telephone: Statute(s) Under Which Sample Was Collected: Sample Station: (Check only one) Sample Matrix: (Check only one) Septic Tank/ Oil/Water Separator Monitor Well Seepage Pit/Well Raw Injectate — Liquid Sediment/sludge/soil • Other (describe): Total Metals (Series 200) Ignitsbility (Method 1010) . EP Toxicity (Method 1310) Conductivity (Note results here if measured in the field) Reactivity Corroaivity (pH) (Note results here if measured in the field) Analyses Requested: _____ VOA (Check all that apply) (Method 624) _____ VOA (Method 8240) Semi—VOA (Method 625) Other (describe); ------- Inventory/Permit lb.: ______________________________ Operator/Facility: SAMPLING R ULTS* (Complete one sheet for each Sample Station and/or Sample Matrix) Sample Station: __________________________________ Sample Matrix: ___________________________________ Value RCU Haz. Value RCRA Has. Parameter (units) MQ Substance Parameter (units) MCL Substance ( ) (YIN) (______ (Y/N) VOLATILE ORGANI(S MEFALS Acetone Arsenic Benzene Barium ____ 2—Butanone (M () _____ ____ _____ Cadmium ____ tl—Butylbenzene Chr nium ____ Chloroform Lead Ethylbenzene Mercury Merhylene Chloride • Selenium ____ 4—Methyl 2—Pent anone (1IThK) _____ ____ _____ Silver ____ Tetrachloroetliene (PCE) o Toluene Trichioroethane (TCA) _____ ____ _____ METALS (EP TOX) ( ) Trichloroethylene (TCE) Arsenic _____ Trimethylbenzene Barium (1.3.5 & 1.2.4) Cadmium _____ Xylene Chromium ________________________ Lead _______________________ Mercury Selenium Silver SF111 VOLATILE ORGANICS ( ) ______________ Aidrin MISC LANEWS. ( ) Dieldrin Endrin Nitrate Napihalene Sulfate TDS Pentachiorophenol pH Ignit ability Reactivity Conductivity *At additional sheets for parameters not listed. ------- U.S. ENVIRONMENTAL PROTECTION AGENCY NOTICE OF INSPECTION Firm To Be Inspected Inspection Contractor 1225 W 1 Main, Nonnw , OK 730w (406) 329 63O0 MX (406) 366-8722 Date Notice of inspection is hereby given according to Section 1445(b) of the Hour Safe Drinking Water Act (42 U.S.C. §300 f et seg.). Reason For Inspection For the purpose of inspecting records, files, papers, processes, controls and facilities. and obtaining samples to determine whether the peison subject to an applicable underground injection control program has acted or is acting in compliance with the Safe Dnnking Water Act and any applicable permit or rule. Section 1445(b) of the SDWA 1 42 U.S.C §300 j-4 (b) is quoted on the reverse of this fonn ipt of this Notice of Inspection is hereby acknowledged. rirm Representative Date Inspector ------- Section 1445 * .* S S (b) (1) Except as provided in paragraph (2), the Administrator, or representatives of the Administrator duly designated by him, upon presenting appropriate credentials and a written notice to any supplier of water or other person subject to (A) a national primary drinking water regulation prescribed under section 1412, (B) any applicable underground injection control program, or (C) any requirement to monitor an unregulated contaminant pursuant to subsection (a), or person in charge of any of the property of such supplier or other person referred to in clause (A), (B), or (C), is authorized to enter any establishment, facility, or other property of such supplier or other persons in orderto determine whether such SuDplier or other person has acted or is acting in compliance with this title, including for this purpose, inspection at reasonable times, of records, files, papers, processes, controls, and facilities, or in order to test any feature of a public water system, including its raw water source. (C) Whoever fails or refuses to comply with any requirement of. subsection (a) or to allow the Administrator, the Comptroller General, or representatives of either, to enter and conduct any audit or inspection authorized by subsection (b) shall be subject to a civil penalty of not to exceed $25,000. ------- dotes: (1) Express Time in 24 hour clock notation; (2) Focal Length is of lens used. Signature of Photographer________________________ E EI d or Witness Camera____ Roll No. — Film Type_ ASA Number RECORD OF PHOTOGRAPHS Project Code [ HOTo I NO. DATE 2 TINE FOCAL LENGTH WEATHER CONDITIONS LOCATION DESCRIPTION OF PHOTOGRAPH . 3 4 5 6 7 8 9 10 11 1 2 ‘3 14 15 16 17 18 19 20 21 22 21 24 25 ------- USEPA REGION V CLASS V INJECTION WELL RATING SYSTEM FOR FOLLOW-UP (ENFORCEMENT) INVESTIGATIONS Pg 1 of 2 FACILITY NAME: I NSPECTOR: CITY. STATE: ____________________________ NUMBER. TYPE. & STATUS OF CLASS V WELL(S):, _____ DATE: ____________ Response Points (1) Does/did the well(s) discharge into, above, or below (with potential for fluid migration into) a currently used USDW? (2) Approximate vertical distance between the injection zone and currently used USDW. (3) Approximate horizontal distance to the nearest public or private water supply well or surface discharge. (4) General permeability (composition) of the injection zone. - (5) Probability that this is/was a Class IV hazardous waste ?njectlon well(s). — Into 15 - Above 10 - Below 5 - Unknown 5 — 0-25ft 15 - 25-75 ft 10 - 75- l5Oft 5 - > lSOft 0 - Unknown 5 — < 1/4 ml 15 — 1/4 - 1/2 mi 10 — 1/2 — 1 ml 5 - > lmi 0 - Unknown 5 - High (e.g., karat, basalt, coarse gravel. highly fractured bed- rock, etc.) 15 - Moderate (e.g.. fine to coarse sand/sand- stone, highly frac- tured shale, etc.) 10 - Low (e.g., clay, silt- stone, shale, igneous and metamorphic rocks, etc.) 0 - Unknown 5 - High - Moderate to High - Low to Moderate - Low Score .45 .30 .15 .0 ------- Reaponse Pointa Pg 2 of 2 Score (6) Probability that the injectate exceeds/exceeded the Safe Drinking Water Act maximum contaminant levels or poses/posed signficant endangerment to USDW. (7) Volume of fluids currently injected (or frequency of injection if the volume is unknown). (8) Years of operation. (9) Additional items: - High 45 - Moderate to High 30 - Low to Moderate 15 - Low 0 - > 1500 GPD (or ) 2.5 hra per day injection at 10 gpm) 25 - 600-1500 GPD (or 1- 2.5 bra per day injection at 10 gpm).. . .15 - 1-6 0 0GPD(orupto 1 hr per day injection at 10 gpm) S - Incidental. 5 - 0 CPD - not operating... 0 - 20 yrs 15 - S-2øyrs 10 - 0-Sirs 5 - Discretionary 0 - 10 Indicate ease or ability to sample: TOTAL POINTS _____ Describe involvement of any other agency: Evaluators recommendations and comments: ------- |