UNDERGROUND INJECTION CONTROL PROGRAM ------- TABLE OF CONTENTS • CONGRESS ESTABLISHES STATUTORY FRAMEWORK FOR THE UIC PROGRAM • SDWA/RCRA INTERFACE • BASIC CONCEPTS • THE UNITED STATES DEPENDS ON GROUND WATER FOR DOMESTIC USE • TO PROTECT GROUND WATER, EPA AND STATES CONTROL WELLS USED TO INJECT FLUIDS UNDERGROUND • CLASS I: HAZARDOUS WASTE INJECTION WELLS • CLASS I: NONHAZARDOUS WASTE INJECTION WELLS • CLASSE: INJECTION WELLS ASSOCIATED WITH OIL AND GAS PRODUCTION • CLASS HI: INJECTION WELLS ASSOCIATED WITH SOLUTION MINING OF MINERALS • CLASS V INJECTION WELLS • UIC RESOURCE SUMMARY (1978-1992) • EPA REGIONS WITH UIC PROGRAMS FOR INDIAN TRIBES • NUMBER OF REGULATED INJECTION WELLS IN THE U.S. • MECHANICAL INTEGRITY TESTING ------- CONGRESS ESTABLISHES THE STATUTORY FRAMEWORK 4llll CONSWaS AUTMOMZB 9AT0 nOTCCT USOW MOM CONTAMINATION BY INJECTION WQU I I, 'l. 27MAYEXTB0IONPOR 9TATE8 TO APPLY TOR . 1977 PTOIAACY; PEDEHAL isas 80WA AflOiCW SUBJECT TO SOMA 4| AMEND. JCREQUUTION AMEMX DEVELOPMENT OF UIC PROGRAM UNDER THE SAFE DRINKING WATER ACT EMAUTHONZEDTD: QIVBUICPWMACY TO SJOIBLe IfOAN TWflBh ASSESS IMPACT OP CUM VWBXB: INCORPORATE ACOmONM. HAZWOOUt WWTC RamcTIONa in uc rem; ano impose stippbr POMLTW AOAlNirr VtOLATOra. 4 FINANCIAL AND TBCHNCAl ASSISTANCE TO STATES extend© Tones t OIL AND OAS STATO OVEN PHMAOf OPTION* B»ATO AS8BS IMPACT OF INJECTION (» NATUWLOM FOR STORAGE Bsoni neauAimo uNoa uc Vw : i^b^e»iy jp^Ni; istn'«»v«^9! >: :xigwiiiiijifr i:: In 1974, Congress amended the Public Health Service Act to ensure that the public would be provided with safe drinking water. The amended Act, thereafter known as the "Safe Drinking Water Act" called directed the U.S. Environmental Protection Agency (EPA) to establish minimum requirements for effective State programs to prevent underground injection which endangers groundwater resources of public water supply systems. 'Underground Inaction endanger* drinking water sources It auch Injection may reeult In the presence In underground water which auppllea or can reasonably bo expected to aupply any public water system of any contaminant, and K the pretence 0/ tuch con- taminant may reeult In such sys- tem's not complying with any national primary drinking water regulation or may otherwise ad- vendy affect the health 0/ persons.' (PartC of the SDWA) The 1974 Safe Drinking Water Act (SDWA) laid down the statutory framework for the national Underground Injection Control program. ------- STATUTORY FRAMEWORK FOR THE UIC PROGRAM The national Underground Injection Control (UIC) program requirements tor State programs MUST: o prohibit underground injection not authorized by permit or rule; o require permit applicants to demonstrate that underground injection will not endanger drinking water sources; and, o include inspections, monitoring, record- keeping and reporting requirements, o recognize varying geologic, hydrologlcal or historical conditions among the different States or areas within a State. The national Underground Iniection Control (UIC) program requirements for State programs MAY NOT: o interfere or Impede the underground injection of brine or other fluids which are brought to the surface in connection with oil or natural gas production; or, o Interfere or impede underground injection in connection with the enhanced recovery of oil or natural gas, unless essential to protect USDWs. When EPA approves a State's program, the State shall have primary enforcement responsibility for underground water sources. In cases where a State cannot or will not adopt its own program and assume primary enforcement responsibility, EPA shall prescribe a UIC program. EPA may make grants (not to exceed 75 per- cent of the recipient's costs) to States to carry out underground water source protection programs. Finally, States have the option of developing regulations that are more stringent than the Federal UIC program requirements. Congress has amended the SOWA four times: IN 1977 - Congress extended its deadline for EPA to institute national standards for injection practices. The States, in turn, received more time to apply for primary enforce- ment responsibility (primacy). Congress extended grant and technical assistance to States for primacy development modified the statutory language pertaining to oil and gas related injection practices and clarified the extent of SDWA authority over injection activity conducted by Federal agencies and Indian Tribes. IN 1979 - Congress extended SOWA authorities and appropriations for three years. IN 1980- Congress exempted underground Injection of natural gas for purposes of storage from the definition of underground Injection. Congress added Section 1425 to the SDWA ' so that a State with an existing underground injection control program for injection of fluids associated with petroleum production can _ assume primacy by demonstrating its program is protective of USDWs according to the SDWA in lieu of adopting the Federal UIC program. IN 1986- Congress directed EPA to assess the Impact of injection practices not usually associated with large Industries (non-residential septic systems, for example) and recommend Federal UIC stan- dards. Congress also directed EPA to treat eligible Indian Tribes as States delegate UIC primacy where appropriate. Finally, Congress required Injection wells to meet hazardous and solid wast* requirements under the 1984 Hazardous Wast* Amendments to the Resource Conservation and Recovery Act ------- UNDERGROUND INJECTION CONTROL PROGRAM BASIC C0MCEPT8 The regulations define: WELL as any bored, drilled or driven shaft or dug hole whose depth is greater than the largest surface dimension. USDW as any aquifer or part thereof which contains less than 10,000 mg/1 TDS and serves, (or contains a sufficient quantity of water to serve) a public water supply system, and which has not been exempted. Injection wells are divided into five Classes: (1992 inventory figures in parenthesis) Class I: wells used to inject municipal or industrial waste including hazardous waste) below the lowermost USDW. (170 hazardous waste wells; 347 nonhazardous Class I wells) Class IX* wells used to inject fluids related to oil and gas production including enhanced recovery, disposal of produced waters, and hydrocarbon storage. (176,768 class II wells) Class IZZt wells used to inject fluids for the extraction of minerals. (35,668 Class III wells) Class XV: wells used to inject hazardous or radioactive waste into or above an underground source of drinking water; banned by regulation unless they are used as part of an approved RCRA or CERCLA ground-water clean-up operation. Class ~: all other injection wells. Regulatory standard for Class I, II and III wells is no fluid movement into USDW, however there are exceptions such as construction requirements for Class II and closure for Class III. ------- SDWA/RCRA INTERFACE Class I hazardous waste (HW) wells must comply with both SDWA and RCRA. Under certain conditions a UIC permit is a pennit-by-rule under RCRA. The 1984 RCRA amendments contained specific provisions subjecting HW wells to the requirements of the Land Ban. In order to continue to inject hazardous wastes beyond certain dates specified in the statute or subsequent regulations, an operator must either: treat the wastes to levels or by methods specified in regulations (BDAT); or, demonstrate to a reasonable degree of certainty that there will be no migration of hazardous constituents from the injection zone for as long as the waste remains hazardous. Pan 148 regulations (July 26, 1988) require HW operators to submit petitions to continue disposal of untreated hazardous waste and demonstrate that hazardous constituents will not migrate out of the injection zone at hazardous levels for 10,000 yean. These regulations were challenged and successfully defended. (OSW's proposed petition rule still at OMB) ------- EPA 1992 AM. SAMOA MARIANAS ISL. Odc- GUAM INDIAN TRIBES PALAU PUERTO RICO VIRGIN ISL. 50 % of pop. or moR rdj cm 30ftto«% ~ 30% THE UNITED STATES DEPENDS ON GROUND WATER FOR DOMESTIC USE O AM. SAMOA MARIANAS ISL. Odc- 0GUAM Q INDIAN TRIBES QPALAU PUERTO RICO Q VIRGIN ISL. . - - , , SpfitUICProgram Control (UIC) Program ^ TO PROTECT GROUND WATER, EPA AND STATES CONTROL WELLS USED TO INJECT FLUIDS UNDERGROUND ------- EPA 1992 O AM. SAMOA O MARIANAS ISL. Od-c. O GUAM Q INDIAN TUBES Opalau O PUERTO RICO O VIRGIN ISL. 70-123 Ciwlwdb K3 11 - 39 Qw I wdk ~ Onetotm Omi I wtfli CLASS I: NONHAZARDOUS WASTE INJECTION WELLS • Class I wells inject nonhazardous industrial or municipal fluids into underground formations which are not now nor expected to be used for drinking water. • Twenty-one State and EPA UIC PROGRAMS regulate 347 Class I nonhazardous injection wells. Florida injects all of its treated municipal waste into Class I wells because of its stringent surface water discharge requirements and has die largest inventory, 123 wells. ------- EPA 1992 CLASS I: HAZARDOUS WASTE INJECTION WELLS Sixty percent of all hazardous wastes that are land disposed are injected into 170 Class I hazardous waste wells that are regulated by the UIC PROGRAM. Each year, Gass I hazardous waste wells inject 9 BILLION GALLONS of fluids into confined formations below underground sources of drinking water (USDW). Thirteen State and EPA UIC PROGRAMS regulate Class I hazardous waste wells. Texas has the largest inventory: 73 wells. ------- EPA 1992 O AM. SAMOA O MARIANAS ISL. Odc. O GUAM g) INDIAN TRIBES Opalau O PUERTO RICO O VIRGIN EL. 54,446 Class n wells m 10,000 - 25.000 122 Class Dwells 101 - 1,000 L^1 Clus II weOs r——j 1»100 L—1 Class OweUs CLASS O: INJECTION WELLS ASSOCIATED WITH OIL AND GAS PRODUCTION * The petroleum industry produces ten gallons of brine for every gallon of domestic oil. Three hundred billion gallons of brine are discharged into salt water formations through Class II wells each year. * Class II wells are used for salt water disposal, enhanced recovery and for hydrocarbon storage. 9 Thirty-six State and EPA UIC PROGRAMS regulate 176,768 Class II wells. Texas has the largest inventory, 54,446 Class II wells. ------- EPA 1992 mam 29,903 _ 4.699 n 51-500 r-, 1-50 — riaaa m weOs ™ Class m weOs Class m wells 1 Class DI wells CLASS m: INJECTION WELLS ASSOCIATED WITH THE SOLUTION MINING OF MINERALS * Solution mining techiques account for more than 50 % of salt and 80 % of uranium production in the U.S. * Class ED wells inject water-based fluids into formations which cause minerals such as salt, sulfur or uranium to go into solution in the ground water. The fluid is then pumped to the surface where the mineral is stripped from the fluid. In most operations, the fluid is treated and recycled into the injection well. * Sixteen State and EPA UIC PROGRAMS regulate 202 facilities with 35,668 Class m wells each year. Class II wells are used for salt water disposal, enhanced recovery and for hydrocarbon storage. * Thirty-six State and EPA UIC programs regulate more than 177,000 wells. ------- EPA 1992 O AM. SAMOA O MARIANAS ISL. Odc- O GUAM O INDIAN TRIBES O palau O PUERTO RICO O VIRGIN ISL CLASS IV: INJECTION WELLS THAT DISPOSE OF HAZARDOUS OR RADIOACTIVE WASTES INTO A FORMATION WHICH WITHIN ONE-QUARTER MILE OF THE WELL CONTAINS AN UNDERGROUND SOURCE OF DRINKING WATER * EPA prohibits Class IV injection wells unless they are authorized under RCRA or CERCLA to reinject contaminated ground water that has been treated and is being reinjected into the same formation from which it was drawn. ------- EPA 1992 O AM. SAMOA O MARIANAS ISL. Od.c. GUAM O INDIAN TRIBES 0 PALAU ® PUERTO RICO O VIRGIN ISL. 15,001 - 29,000 Class V wells rv, 1,001 -15,000 ^ Class V wells .—i 1-1,000 1—1 Class V wells CLASS V: INJECTION WELLS THAT ARE MOSTLY SHALLOW WELLS Class V wells are injection wells that are not Class I, II, in, or IV wells. They are mostly shallow wells that inject industrial waste present a great danger to underground sources of drinking water. Class V wells threaten surface and underground sources of drinking water, because they are shallow and geographically dispersed with the population - where there are drinking water supplies there are people, where there are people, there are Class V wells. Current Class V inventories total 190,443 but are incomplete. Estimates range firom 500,000 to over 1,000,000. The proposed regulatory scheme for Class V injection wells requires permits for certain high priority wells to include: municipal waste disposal wells, (wells used to inject POTW effluent) more than 1,000 wells, where there are people, there are Class V wells. Current Class V inventories total 190,443 but are incomplete. Estimates range from 190,000 to over 1,000,000. ------- UIC RESOURCE SUMMARY (1978-1992) FY Total Regional Total Funda Claaa II Other Claaa FTE'a Allotted Well Funda Well Funda 1978 25.0 $6,000,000 $3,060,000 $2,940,000 1979 47.0 $7,600,000 $3,876,000 $3,724,000 1980 46.2 $4,395,000 $2,241,450 $2,153,550 1981 66.9 $6,574,500 $3,352,995 $3,221,505 1982 110.8 $6,574,500 $3,352,995 $3,221,505 1983 118.6 $7,074,500 $3,607,995 $3,466,505 1984 120.8 $7,500,200 $3,825,102 $3,675,098 1988 129.5 $8,500,200 $4,335,102 $4,165,098 1986 173.5 $9,100,200 $4,641,102 $4,459,098 1987 173.4 $9,500,000 $4,845,000 $4,655,000 1988 195.3 $11,500,000 $6,345,000 $5,155,000 1989 191.1 $10,500,000 $5,595,000 $4,905,000 1990 190.2 $11,177,800 $5,190,678 $5,987,122 1991 190.5 $10,500,000 $5,355,000 $5,145,000 1992 181.7 $10,500,000 $5,355,000 $5,145,000 TOTAL 1960.5 S126.996,900 S64.978.419 S62.018.481 ------- EPA Regions With UIC Programs For Indian Tribes O* 66 Indian Tribes Have Federafly- Administered (EPA) Programs Wefl» Grants zy Region II Region V Region Vi Region VIII Region IX Region X 12 152 3,601 567 637 246 $5300 $57,500 $219,900 $88,800 $44,200 $32,tOO Indian Tribe Injection Well Universe v •% Omq* 69% Distribution by Tribe Ml 92% Distribution by Class ------- National Overview Mechanical Integrity Testing (MIT) By Type (Classes l-lll) 33% TEST TYPE # OF TESTS PASS FAIL ¦ Annulus Pressure Monitoring 4,591 4*43* 152 ! 2 J Casing/Tubing Pressure 29,092 27,806 1,286 [|] Monitoring Record 5,481 5,451 30 HI Other Leak Tests/Evaiuations 8,959 8,783 176 Q Cement Record 34,382 28,196 6,186 0 Temperature/Noise Log 214 208 6 [Tj Radioactive Tracer/Cement Bond 5,178 = 66 Q Other Fluid Migration Tests 1,260 K-:V 59' * Injection wells which faded an MIT in 1991 and did not undergo re- medal action, have ceased Injection TOTAL 89,157 81,196 7,961 • Total Remedial Actions 1,451 and may be subject to plugcing and abandonment. Total Plugging & Abandonment 464 ------- MIT Testing History (CL l-ll) EPA and State Programs 150,000 " 133,500 13M00 140,500 140,500 147,300 141,300 133,200 1983-85 1986 1987 1988 1989 1990 1991 Year * Totals rounded to nearest multiple of 100 Tested rzz. Untested ------- |