INSTRUCTOR S MANUAL
FOR
UIC INSPECTOR TRAINING COURSE
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
HEADQUARTERS-WASHINGTON, D.C.
ENGINEERING
ENTERPRISES, INC.
WATER RESOURCES SPECIALISTS
LOE CONTRACT NO. 68-03-3416
WORK ASSIGNMENT NO. 3-0-7-3
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INSTRUCTOR'S MANUAL
FOR
UIC INSPECTOR TRAINING COURSE
PREPARED FOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
HEADQUARTERS - WASHINGTON, D.C.
UIC CONTRACT NO. 68-03-3416
WORK ASSIGNMENT NO. 3-0-7-3
PREPARED BY
SIMON-EEI
NORMAN, OKLAHOMA
$PRIL, 1990
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TABLE OF CONTENTS
SECTION PAGE
1 USE OF THE INSTRUCTOR'S MANUAL 1-1
2 PRESENTATION OF THE COURSE 2-1
3 WELCOME AND OVERVIEW OF COURSE MATERIALS 3-1
4 INTRODUCTION TO TRAINING 4-1
5 INSPECTOR CERTIFICATION PRETEST 5-1
6 REGULATIONS OF INTEREST 6-1
Clean Water Act (CWA) 6-4
Safe Drinking Water Act (SDWA) 6-11
Resource Conservation and Recovery
Act (RCRA) 6-24
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA).. 6-46
Outline of Regulations Pertinent to the
UIC Program (For Instructor Review Only).. 6-51
7 UIC PROGRAM 7-1
Program Overview 7-2
Well Classification System 7-4
8 UIC INSPECTIONS 8-1
Inspections and the SDWA 8-2
Role of the Inspector 8-2
Inspector Responsibilities 8-4
Kinds of Inspections 8-8
Typical Observations to Make During
Inspections 8-9
Actual Inspection Cases 8-10
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TABLE OF CONTENTS
PAGE TWO
SECTION PAGE
9 FACILITY ACCESS 9-1,
Statutory Considerations 9-4
Constitutional Considerations 9-4
Case Studies 9-5
Denial of Entry 9-6
10 GENERAL FIELD SAFETY 10-1
Personal Protective Equipment 10-3
Other General Considerations for
Personal Safety 10-4
Drilling and Workover Safety 10-5
Safety During Routine Inspections 10-6
Safety During Mechanical Integrity
Testing 10-8
Sampling 10-9
Initial Hazard Assessment 10-12
Levels of Personal Protection 10-13
Decontamination 10-15
11 MECHANICAL INTEGRITY TESTING 11-1
Well Construction Types 11-2
Newly Constructed Wells 11-8
Internal Mechanical Integrity Test
Methods 11-9
External Mechanical Integrity Test
Methods 11-24
12 CASED HOLE LOGGING 12-1
Wireline Logging of Injection Wells 12-2
Well Logging Methods and Their Uses 12-6
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TABLE OF CONTENTS
PAGE THREE
SECTION PAGE-
13 PLUGGING AND ABANDONMENT 13-1
Basic Considerations for Plugging Job
Design 13-2.
Plugging Materials 13-3
Cement Plug Placement 13-5
Plugging Job Execution 13-6
14 INSPECTIONS OF CLASS V INJECTION WELLS 14-1
Types of Inspections 14-4
Preparing for Class V Inspections 14-6
Conducting Class V Inspections 14-7
Activities Subsequent to Inspections 14-9
Class V Well Types/Inspection Tips 14-10
15 SAMPLING OF CLASS V INJECTION WELLS 15-1
Lab Selection 15-2
Sampling Point Selection 15-3
Sampling Equipment 15-4
Sample Containers 15-5
Basic Sampling Methods and Procedures 15-6
Quality Assurance/Quality Control 15-8
Sample Collection 15-9
Types of Samples and Analyses 15-10
Sample Documentation and Shipment 15-17
Field Modifications 15-18
Health and Safety SOP 15-18
Typical Sampling Event 15-21
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TABLE OP CONTENTS
PAGE FOUR
SECTION PAGE
16 HYPOTHETICAL INSPECTION SITUATIONS - CLASS II
INJECTION WELLS 16-1
17 HYPOTHETICAL INSPECTION SITUATIONS - CLASS V
INJECTION WELLS 17-1
18 FIELD WORK REQUIREMENT - SUGGESTIONS 18-1
« Clarksville, Indiana 18-2
San Francisco, California 18-2
Dallas, Texas 18-3
19 INSPECTOR CERTIFICATION TEST 19-1
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SECTION 1
USE OF THE INSTRUCTOR1S MANUAL
The Instructor's Manual for the UIC Inspector Training
Course is designed so that (unless otherwise noted) the
instructor may read directly from the manual while teaching the
course. Guidance for the instructor is denoted by use of a full
margin (see the top of page 3-1). Discussions to be led by the
instructor are denoted by indented, blocked text (see the bottom
of page 3-1). References made for the use of slides and video
cassette tapes are found in the left hand margin of the text (see
page 4-2 for an example). Slides are numbered by section and
sequence.
l-l
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I COURSE PRESENTATION
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SECTION 2
PRESENTATION OF THE COURSE
The UIC Inspector Training course has been presented on
three separate occasions by the L.O.E. contractor under UIC
Contract No. 68-03-3416. The agenda has been altered for each:
presentation in order to emphasize the specific information
requested by the host EPA Region. The major difference in the
presentations has been with regard to the amount of Class II and
Class V information presented during each course.
Portions of the UIC Inspector Training course may be
effectively presented in the following order:
Overview of Handout Materials
Introduction to Training Requirements
Inspector Certification Pretest
Presentation of Course Materials
Field Work Requirement
Inspector Certification Test
2-1
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| OVERVIEW OF MATERIALS
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SECTION 3
WELCOME AND OVERVIEW OF COURSE MATERIALS
The instructor should introduce himself/herself and welcome
the class participants. Mention should be made in regard to the
various Regions and States represented by attendees. The?
instructor should make sure that all participants have a name-
tag. Any other course instructors should be briefly mentioned at
this time.
The instructor should refer the class to the handout
materials from which much of the course presentation will be
drawn. It is important that, while discussing handouts, the
instructor allow plenty of time for the class members to briefly
review the course materials.
DISCUSSION The handout materials include two notebooks,
entitled:
UIC Inspector Training; and
UIC Inspector Training - Class V Addendum.
The large notebook entitled UIC Inspector
Training, contains two bound documents:
UIC Inspection Manual; and
Technical Assistance Document - Cementing for
the Plugging and Abandonment of Injection
Wells.
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The UIC Inspection Manual is divided into five
sections. It is suggested that the class
familiarize themselves with the appendices. These
sections contain information which may be useful
to the inspector while conducting inspection
duties.
The cementing document has been included to
provide the inspector with guidance in regard to
proper plugging and abandonment procedures, and
important items to consider while witnessing a
plugging operation. NOTE: The instructor may
wish to credit the authors of both manuals at this
time.
The notebook also contains:
Region VIII memorandum written by Mr. Jim
Ellerbe;
Packet on Plugging and Abandonment;
Packet on Well Logging; and
Packet on Well Construction Types.
The second notebook, entitled Class V addendum,
contains information specific to the Class V
program. The notebook is divided into four major
sections, and contains the following:
An Overview of Class V Injection Wells;
How to Inventory and Investigate Class V
Injection Wells;
Inspection Tips for Class V Injection Wells;
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Documenting and Reporting Class V Inspection
Activities;
Standard Operating Procedures for Injectate
and Sediment Sampling at Class V Facilities;
Site-Specific Sampling Plan; and
Site-Specific Health & Safety Plan.
The Addendum also includes handouts, entitled:
Preparing for Inspections; and
In-Depth Inspection Checklist.
Other reference materials distributed to supple-
ment the course are provided by the National
Enforcement Investigation Center. These materials
include:
NEIC Policies and Procedures Manual; and
A Description of Automated Information Sys-
tems Accessible by NEIC
3-3
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INTRO. TO TRAINING
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SECTION 4
INTRODUCTION TO TRAINING
This section presents a basic discussion of EPA's Inspector
Training Requirements.
4-1
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DISCUSSION It is the policy of the Environmental Protection
Agency to ensure that those who lead environmental
compliance inspections/field investigations be
properly trained to perform those functions in a:
legally and technically sound manner.
EPA Order 3500.1, approved in June of 1988, estab-
lishes a consistent agency-wide training and
development program for employees leading
environmental compliance inspections/field inves-
tigations .
SLIDE #4-1 EPA's training program consists of three parts:
Occupational Health and Safety Curriculum;
Basic Curriculum; and
Program-Specific Curriculum.
The Occupational Health and Safety Curriculum
consists of a 40-hour course that is approved by
the Occupational Safety and Health Administration
(OSHA). An 8-hour refresher course is required
annually. The courses are available through
numerous sources nationwide.
The Basic Curriculum has been developed by the
Office of Enforcement and Compliance Monitoring
(OECM) to provide a comprehensive overview of
knowledge and skills needed to perform compliance
inspections/field investigations under EPA
statutes.
4-2
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UIC Inspector Training will constitute the third
part of EPA training requirements, the Program-
Specific Curriculum.
The effective date of the training order is June
29 of 1988, the issuance date; the following dates
also apply:
New Inspectors are those inspectors newly
employed by EPA subsequent to the issuance
date. Beginning October 1, 1989, new
inspectors shall not conduct inspections
unless they have completed the Basic
Curriculum and have completed or been
excepted from the Program-Specific Training
Curriculum.
Experienced inspectors are those inspectors
employed on or previous to the issuance date.
Beginning October 1, 1991, experienced
inspectors shall not conduct inspections
unless they have completed or been excepted
from the Basic and Program-Specific Training
Curricula.
First Line Supervisors supervise the day-to-
day work of an individual who leads
compliance inspections/field investigations.
A first-line supervisor may be new or
experienced. Beginning October 1, 1989,
first-line supervisors shall meet the
requirements of the training order within one
year of appointment to the supervisory
position, if they have not already done so.
Experienced first-line supervisors may be
excepted from the Basic Curriculum, but new
ones may not. There may be limited
exceptions to program-specific requirements
for new and experienced first-line
supervisors.
Training requirements for Contract Inspectors
and others shall be phased into future
contracts.
4-3
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SECTION 5
INSPECTOR CERTIFICATION PRETEST
The inspector certification test is to be administered, to
the class participants before the course materials are presented.
This pretest serves as a tool to emphasize the important pointa
which will be covered during the training course. It is not
necessary to grade and return the pretest; however, the
instructor may find pretest results helpful in indicating the
level of knowledge exhibited by class participants. Depending
upon pretest results, the instructor may choose to place more
emphasis on certain subjects presented throughout the training
course.
5-1
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UIC INSPECTOR CERTIFICATION PRETEST
REGULATORY STRUCTURE
1) The National Pollutant Discharge Elimination Systems was
established by which environmental act?
a) Safe Drinking Water Act
b) Clean Water Act
c) Resource Conservation and Recovery Act
d) Toxic Substance Control Act
e) Solid Waste Disposal Act
2) Point source discharges to waters of the U.S. are
authorized by the:
a) Safe Drinking Water Act
b) National Pollutant Discharge Elimination Systems
c) Resource Conservation and Recovery Act
d) Toxic Substance Control Act
e) Solid Waste Disposal Act
3) Spill Prevention Control Countermeasure regulations were
established by which of the following?
a) Resource Conservation and Recovery Act
b) Safe Drinking Water Act
c) Clean Water Act
d) Toxic Substance Control Act
e) 40 CFR
4) Which program was established to protect USDWs from
endangerment by subsurface emplacements of fluids?
a) Underground Injection Control
b) National Pollutant Discharge Elimination System
c) Superfund
d) Wellhead Protection Program
5) The Underground Injection Control program was established
under which of the following?
a) Resource Conservation and Recovery Act
b) Clean Water Act
c) Safe Drinking Water Act
1
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6)
Management of hazardous waste falls under Subtitle C of
the:
a) Safe Drinking Water Act
b) Federal Water Pollution Control Act
c) Resource Conservation and Recovery Act
d) Comprehensive Environmental Response, Compensation and.
Liability Act
7) Listed hazardous wastes are contained in:
a) Resource Conservation and Recovery Act
b) Solid Waste Disposal Act
c) Federal Water Pollution Control Act
d) Comprehensive Environmental Response Compensation and
Liability Act
e) 40 CFR
8) Which act mandated a study to be performed to determine the
effects of drilling fluids, produced water and other wastes
associated with production of crude oil and natural gas?
a) Federal Water Pollution Control Act
b) Safe Drinking Water Act
c) Resource Conservation and Recovery Act
d) Clean Water Act
9) List the four criteria by which a waste can be considered
characteristically hazardous as defined by RCRA.
1.
2.
3.
4.
10) Oil Pollution Prevention Regulations are established in:
a) Federal Water Pollution Control Act
b) Resource Conservation and Recovery Act
c) 40 CFR
d) Safe Drinking Water Act
e) Solid Waste Disposal Act
2
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11) The National Priorities List refers to which of the
following?
a) 40 CFR
b) Resource Conservation and Recovery Act
c) Safe Drinking Water Act
d) Comprehensive Environmental Response Compensation and
Liability Act
12) Name three of seven containment systems acceptable to
prevent discharged oil from reaching navigable waters.
1.
2.
3.
13) 40 CFR Part establishes criteria and standards, for
underground injection wells.
a) 144
b) 145
c) 146
d) None of the above
14) The Land Disposal Restrictions Program regulates liguid
hazardous wastes or free liguids associated with treatment
of hazardous wastes.
a) True b) False
15) Transporters of listed hazardous wastes may store the wastes
for up to...
a) 5 days
b) 10 days
c) 15 days
d) 30 days
16) Dilution of wastes is allowed as a method of treatment in
the Land Disposal Restriction regulations.
a) True b) False
17) Name three areas that are prohibited for use as disposal
sites by the Land Disposal Restrictions Program.
1.
2.
3.
3
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UIC STRUCTURE
1) UIC Regulations are found in 40 CFR Part(s)...
a) 144
b) 146
c) 144, 145, 146
d) 144 through 148
e) None of the above
2) States which have primary enforcement responsibility for the-
UIC program are called states.
3) States which have Federally administered UIC programs are
called states.
4) Match each well to its class of well type.
1. Class I A. Oil and gas enhanced recovery
injection well
2. Class II B. All other well types
3. Class III C. Hazardous waste injection well
4. Class IV D. Mineral extraction well
5. Class V E. Radioactive waste injection well
injecting above the USDW
5) Which of these is not a well according to the EPA
definition?
a) 24-inch casing driven 10 feet deep
b) A pit with surface dimensions 4' by 41 by 6' deep
c) A hole that is 4 feet deep and 6 feet in diameter
d) A drilled hole 12 feet deep and 6 inches in diameter
6) A well completed with casing, tubing, and packer is an
example of a completion.
7) Name three types of unconventional completions.
1.
2.
3.
4
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8) Which of these is not a Class III well type?
a) Frasch sulfur mining well
b) Enhanced recovery well
c) In-situ leaching well
d) Solution mining well
5
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CLASS V WELLS
1) How many subclasses of Class V wells have been identified to
date?
a) 16 b) 24 c) 32 d) 48
2) Which of the following represents a high-tech Class V well?
a) Improved sinkhole (503)
b) Cesspool (5W10)
c) Automobile service station disposal well (5X28)
d) Radioactive waste disposal wells (5N24)
e) None of the above
3) A 4* by 4' by 3' deep rock-filled pit located at an
industrial facility and accepting only storm-water runoff is
classified as a:
a) Storm-Water Drainage Well (5D2)
b) Industrial Drainage Well (5D4)
c) Special Drainage Well (5G30)
d) None of the above
4) A drainage well located in a parking lot of an industrial
facility, designed to accept stormwater, appears to be
accepting spills (stains on asphalt) from a chemical storage
area located up-gradient. The well should be classified as
a:
a) Storm-Water Drainage Well (5D2)
b) Industrial Drainage Well (5D4)
c) Industrial Process Water and Waste Disposal Well (5W20)
d) Special Drainage Well (5G30)
e) None of the above
5) Which of the following items should be noted at each
inspection site?
a) The facility is connected to sanitary and/or storm
sewer
b) The injectate is treated prior to injection
c) The construction date of the well
d) Only a and b
e) All of the above
6
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6) When an oil/water separator, located in a service bay, is
piped directly to a septic tank and drainfield system, -the
well should be designated as a:
a) Automobile Service Station Disposal Well (5X28)
b) Septic System - drainfield disposal method (5W32)
c) Septic System - undifferentiated disposal method (5W11)
d) Industrial Process Water and Waste Disposal Well (5W20)
e) None of the above
7) It is common to discover information that changes a well
classification during a facility tour.
a) True b) False
8) Which of the following is not essential to rate an injection
well for follow-up investigations?
a) Approximate horizontal distances to nearest public or
private water supply well
b) Frequency of injection or volume being injected
c) Years of operation
d) All are essential
9) Which of the following is not a Class V well?
a) Drainage well accepting stormwater which is 21 in
diameter and 35* deep
b) Septic tank accepting solely sanitary waste and serving
45 people per day that is discharging to a drainfield
3' below surface and 25' long
c) Septic tank accepting solely sanitary waste and serving
10 people per day that is discharging to a well 1* in
diameter and 101 deep
d) Rock-filled retention pit accepting stormwater with
surface dimension of 4' by 4" and is 6' deep.
7
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10) Which scenario would most likely pose the greatest
environmental threat?
a) Service bay waste, treatment prior to injection,
nearest water supply well <1 mile, low permeability
injection zone, 100* vertical distance between
injection zone and currently used USDW
b) Electroplating waste, treatment prior to injection, 1/2
mile to water supply well, moderate permeability, 25*
vertical distance between injection zone and USDW
c) Silkscreening shop waste, no treatment, 3/4 mile to
water supply well, high permeability (karst), 751
vertical distance between injection zone and USDW.
11) During a site inspection, the facility operator informs you
that all waste fluids generated are discharged to the city
sewer, except for storm water which is handled by drainage
wells. Therefore, you
a) only inspect the drainage wells and ignore a sump in
the service bay and a floor drain in the painting
booth.
b) inspect all drainage wells, sump, and floor drain.
c) verify that the facility is hooked into the city sewer
system.
d) a and c
e) b and c
12) What two well types appear to pose the greatest threat to
USDWs?
a) Industrial Drainage Wells (5D4) and Industrial Process
Water and Waste Disposal Wells (5W20)
b) Industrial Drainage Wells (5D4) and Automobile Service
Station Disposal Wells (5X28)
c) Industrial Process Water and Waste Disposal Wells
(5W20) and Automobile Service Station Disposal Wells
(5X28)
d) Industrial Process Water and Waste Disposal Wells
(5W20) and Untreated Sewage Waste Disposal Wells (5W9)
8
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SAMPLING
1) When sampling a Class V system, the preferred sampling point
is:
a) as near to the potential contaminants as possible
(drainage sump)
b) at an intermediate stage between the point of
origination and injection (septic tank)
c) as near to the injection point as possible (monitoring
tube)
d) none of the above
2) To avoid sample contamination due to equipment materials,
fluid sampling equipment should be constructed out of these
materials:
a) Teflon
b) PVC
c) Glass
d) Stainless steel
f) a, c, and d
g) All are preferred materials
3) Fluid samples collected for a Volatile Organics Analysis
should be transferred to the following container type:
a) 2-40 ml. glass vials
b) 1-80 ml. glass vial
c) 2-500 ml. glass bottles
d) 1-1 liter glass bottle
4) All sampling equipment should be decontaminated...
a) before each sampling event.
b) after each sampling event.
c) prior to each day's sampling.
d) following each day's sampling.
e) a and b
9
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5) Equipment blanks are:
a) supplied by the lab to assure no cross contamination in
transport.
b) supplied by the lab to assure contamination is not
present in their lab equipment.
c) prepared in the field to assure proper sampling
techniques.
d) prepared in the field to assure proper equipment
decontamination.
6) A fluid is considered RCRA hazardous based on pH if the pH
is...
a) < 1
b) <2
c) <3
d) <4
or > 11.5
or > 12.5
or > 13.5
or > 10
7) All waste fluids generated during the sampling process...
a) can be dumped back into the disposal well.
b) must be containered and put in the trash.
c) must be containered and stored on-site until analysis
is complete for further determination of proper
handling.
d) must be containered and always treated as hazardous
waste.
8) Site health and safety plans should contain the following
information:
a) Material Safety Data Sheets
b) Route map to nearest hospital emergency room
c) Police and fire department phone numbers
d) a and b
e) All of the above
10
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FIELD SAFETY
1) Name the four basic routes of entry to the human body
relative to exposure of harmful substances:
1.
2.
3.
4.
2) Which level of protection provides maximum protection from
potentially hazardous contaminants?
a) 1
b) 4
c) A
d) D
3) Which route of entry is the most common accidental form of
exposure and most likely cause of systemic illness?
4) Which four body parts should be afforded protective
equipment to prevent injury during regular inspection
activities?
1.
2.
3.
4.
11
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MECHANICAL INTEGRITY TESTING
1) Wells completed with a small tubular string cemented to
surface are completions.
a)
packerless
b)
slimhole
c)
tubingless
d)
dual
e)
annular disposal
2) Wells which injected between the surface casing and long
string casing are completions.
a) packerless
b) slimhole
c) tubingless
d) dual
e) annular disposal
3) When witnessing the cementing of a well, it is important to
record all volumes of cement pumped, pressures exerted, and
sizes of casings.
a) True b) False
4) Name three types of internal mechanical integrity tests:
1.
2.
3.
5) When conducting the standard annular pressure test, the
pressure in the tubing has no bearing on the test pressure
used for the test.
a) True b) False
6) Which of the following is a viable method of pressuring up
the annulus for the standard annular pressure test?
a) Pump truck
b) Hand pump
c) Nitrogen bottle
d) Injection line pressure
e) All of the above
12
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7) It is good operating practice for the inspector to witness,
and record the amount of fluid returned from a- pressure
test.
a) True b) False
8) Which of the following is allowed by regulations, to
demonstrate external mechanical integrity?
a) Casing bond log
b) Noise log
c) Cement evaluation log
d) Temperature log
e) b and d
13
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UXC INSPECTIONS
1) Which section of the Safe Drinking Water Act provides
authority for inspectors to enter upon and inspect any
facility subject to the UIC program?
a) 1422
b) 1425
c) 1445
d) 1545
2) When conducting an on-site field inspection it is important
to...
a) present proper credentials to the operator before
conducting the inspection.
b) gain entry unnoticed and identify yourself only when
noticed by the operator.
c) identify yourself to the operator before conducting the
inspection.
d) a and c
e) All of the above
3) A notice of inspection form needs to be completed for every
inspection.
a) True b) False
4) Operators must always be notified when an inspection is
going to take place at their facility.
a) True b) False
5) Which of the following is not information that should be
recorded at a Class II well inspection?
a) Injection pressure
b) Evidence of surface discharge
c) Evidence of recent workover
d) Annulus pressure
e) Color of the wellhead sign
6) Inspection reports should be completed....
a) within 24 hours
b) within a week
c) by the end of the month
d) All of the above
e) None of the above
14
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7)
Name three types of well inspections.
1.
2.
3.
8) Name three situations in which warrantless facility access
is legally justified.
1.
2.
3.
9) When gaining entry into a facility, it is acceptable for the
inspector to allow the operator to make a copy of the
inspector's credentials.
a) True b) False
10) Specific information regarding the planned activities during
the inspection should be written on the notice-of-inspection
form prior to presentation to the operator.
a) True b) False
11) Inspection notes should be written in a:
a) spiral notebook
b) any pad of paper
c) bound notebook
d) bound notebook with numbered pages
12) Corrections to field notebooks should be handled by:
a) tearing out page and throwing away
b) correcting by copying on a separate sheet and
discarding initial notes
c) marking out and putting initials near correction
d) erasing mistake and making correction
13) Interviewing employees at a facility that you are inspecting
is a waste of time since they will not give you any good
information due to their company loyalty.
a) True b) False
15
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During a sampling inspection, when the owner/operator of the
facility requests split samples, you should:
a) give the operator samples in the containers which he
provides you with
b) give the operator samples in spare containers brought
along for the inspection
c) refuse the operator samples
d) None of the above
16
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PLUGGING AND ABANDONMENT
1) Produced water is suitable for mixing cement,
a) True b) False
2) When setting multiple plugs, each plug should be allowed to
set for how long before the hole is recirculated and another
plug sets?
a) 2 hours
b) 4 hours
c) 8-24 hours
d) Until the test cement at the surface hardens
e) None of the above
3) Removal of equipment (tubing, packer, etc.) in the well is
the first operational step in plugging and abandoning the
well.
a) True b) False
4) List 3 activities or considerations that can ensure cement
plug quality:
1.
2.
3.
17
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WELL LOGGING
1) Because planned procedures are always altered at the well
site, it does no good to be familiar with the well or
procedure before you arrive on location.
a) True b) False
2) How long should a well be' shut in before running a base
temperature log?
a)
0 hours
b)
at
least
3 hours
c)
at
least
8 hours
d)
at
least
12 hours
e)
at
least
24 hours
3) The cement bond log depends on sonic energy traveling
through the casing fluid, casing, cement, and formations and
returning to the sensor to give an indication of cement bond
to the casing and formation.
a) True b) False
4) Cut off frequencies for the noise log output are (in Hz):
a) 10; 100; 1000; 10,000
b) 1; 5; 10; 20
c) 200; 600; 1000; 2000
d) 100; 500; 1000; 2000
5) The primary advantage of the Cement Evaluation Tool over the
Cement Bond Log is that:
a) it investigates radially
b) it is a newer generation tool
c) it is less expensive
d) it is standardized
18
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REGS. OF INTEREST
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SECTION 6
REGULATIONS OF INTEREST
This section contains material associated with regulations
pertinent to the UIC program. Particular topics discussed
include:
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Resource Conservation and Recovery Act (RCRA)
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA)
- Outline of Regulations- Pertinent to the UIC Program
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DISCUSSION EPA has no single authority by which it is
charged to protect ground water. Virtually every
major piece of environmental legislation addresses
the need to protect ground water.
SLIDE #6-1 There are six major legislative Acts contributing
to the protection of ground water:
Clean Water Act (1972)
Safe Drinking Water Act (1974)
Resource Conservation and Recovery Act (1976)
~ Comprehensive Environmental Response, Compen
sation, and Liability Act (1980)
Federal Insecticide, Fungicide, Rodenticide
Act (1972)
Toxic Substance Control Act (1976)
National standards have been established by these
statutes that control the handling, discharge, and
disposal of potentially harmful substances. The
programs that seek to ensure compliance with these
standards are either implemented directly by the
EPA or may be delegated to the States.
In most cases, permit programs control the release
of pollutants into the environment. The EPA
establishes the Federal standards and
requirements, and approves State programs for
permit issuance. Some of the larger programs
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which have been delegated by the EPA to qualifying
States are:
The Clean Water Act (CWA)
- Water Quality Standards
- NPDES
Safe Drinking Water Act (SDWA)
- Drinking Water
- UIC Program
The Resource Conservation and Recovery Act
(RCRA)
- Hazardous Waste Program
Developing the ability to recognize the existence
of UIC violations may be acquired from familiari-
zation with applicable portions of the SDWA and 40
CFR. UIC inspectors also need to become familiar
with other regulatory structures since other
violations which are not enforceable through the
UIC program may exist at injection facilities.
With this in mind, let's discuss the provisions of
the various environmental regulatory Acts as they
may apply to UIC inspections.
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We will look at the Clean Water Act (CWA); The
Safe Drinking Water Act (SDWA); the Resource
Conservation and Recovery Act (RCRA); and the
Comprehensive Environmental Response, Compensa-
tion, and Liability Act (CERCLA). We will also
refer to 40 CFR to become more familiar with
regulations concerning production facilities and
injection wells.
THE CLEAN WATER ACT
In 1972, The Federal Water Pollution Control Act
was significantly amended. The changes emphasized
a new approach combining water quality standards
and effluent limitations. The amendments of 1972
were enacted primarily to control point source
discharges into United States waters.
In 1977, the Federal Water Pollution Control Act
was further amended and renamed the Clean Water
Act.
The objective, as stated by the Act, is to restore
and maintain the chemical, physical, and
biological integrity of the nation's waters. The
Clean Water Act consists of six titles.
Title III of the Clean Water Act is entitled,
"Standards and Enforcement."
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SLIDE #6-2 We will now summarize some of the highlights of
Title III.
Section 301 of Title III establishes that the
discharge of any pollutant by any person shall be
unlawful, except as in compliance with Title IV of
the Act. Discharge includes spilling, leaking,
pumping, pouring, emptying, or dumping, but
excludes discharges in compliance with Section 402
of this Act, the National Pollutant Discharge
Elimination system.
Section 304 of Tile III is important because it
calls for the development of:
Criteria for water quality;
Information identifying conventional pollu-
tants ;
Guidelines for effluent limitations; and
Methods to control pollution resulting from
the disposal of pollutants in wells.
Section 311 addresses oil and hazardous substance
liability. This section declares that there shall
be no discharges of oil or hazardous substances to
the navigable waters of the United States.
Penalties are established for discharges up to
$500,000 onshore and $5,000,000 from a vessel.
The legislation requires that operators
immediately notify the appropriate agency in the
event of a discharge. Failure to immediately
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notify the proper authorities may result in a
$10,000 fine.
Section 311 calls for preparing and publishing a
National Contingency Plan for the removal of oil
and hazardous substances. The plan shall provide
for effective action to minimize damage through
containment, dispersal, and removal. Section 311
also calls for the development of substances
designated as hazardous. The list of hazardous
substances are found in 40 CFR, Part 116.4.
Whenever a maritime accident has created a
substantial threat of pollution, the United States
may coordinate all public and private efforts
directed at the removal of such a threat.
Except where the operator can prove that the
discharge was caused solely by an act of God, an
act of war, negligence on the part of the United
States government, or a third party, the operator
shall be liable to the government for the full
amount of incurred costs not to exceed 50 million
dollars.
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The Administrator is authorized to establish
reasonable classifications of those onshore
facilities having a total fixed storage capacity
of less than 1,000 barrels. These regulations are
found in 40 CFR, Part 113, entitled "Liability
Limits for Small Onshore Storage Facilities."
Regulations, consistent with the National
Contingency Plan shall be issued, establishing
procedures, methods, and equipment necessary to
prevent the discharge of oil and hazardous
substances, from vessels and onshore facilities,
and to contain such discharges.
40 CFR, Part 112, entitled "Oil Pollution
Prevention," satisfies the requirement of this
portion of Section 311.
Spill Prevention Control and Countermeasures
40 CFR, Part 112.3 states that operators are
required to prepare Spill Prevention Control and
Countermeasure (SPCC) plans for non-transportation
related facilities in areas where spills can
potentially enter waters of the United States.
The SPCC program sets minimum standards for
certain aspects of facility design and operation.
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The guidelines for preparing and implementing an
SPCC Plan are found in 40 CFR, Part 112.7 (as
mandated by the CWA, Section 311). Part 112.7(c)
states that appropriate containment and/or
diversionary structure or equipment to prevent oil
discharge from reaching a navigable water course
should be provided.
SLIDE #6-3 One of the following preventative systems or its
equivalent should be used as a minimum:
- Dikes, berms or retaining walls sufficiently
impervious to contain spilled Oil;
Curbing;
Culverting, gutters, or other drainage
systems;
Weirs booms or other barriers;
Spill diversion ponds;
Retention ponds; or
Sorbent materials.
Familiarity with such containment structures may
be valuable when performing Class II inspections.
SLIDES #6-4 These slides illustrate examples of the kinds of
THRO #6-6
containment structures you might see in the field.
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In addition to the containment requirements, the
Spill Prevention Control and Countermeasure Plan
must also address:
Facility drainage;
Bulk storage tanks (excluding production
facilities);
Facility transfer operations;
Tank truck loading/unloading rack;
Oil production facilities;
Oil drilling and workover facilities
(onshore and offshore);
Inspections and records;
Security of facility; and
Personnel training and spill prevention
procedures.
Section. 402 of Title III of the Clean Water Act is
entitled, "National Pollutant Discharge
Elimination System (NPDES)." NPDES is defined as
the national program for issuing, revoking,
reissuing, terminating, and monitoring permits for
discharge of pollutants within the effluent
limitations of previous sections in the act.
NPDES allows for State administration of a permit
program.
40 CFR, Part 122 contains all the provisions for
the NPDES program established under Sections 318,
402, and 405 of the Clean Water Act.
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In accordance with Part 122.21, applicants for
NPDES permits must provide the following
information:
Activities conducted by the applicant which
require it to obtain an NPDES permit;
Name, address, and location of the facility;
and
A listing of all permits or construction
approvals received or applied for under any
of the following programs;
- Hazardous waste management (RCRA)
- UIC program (SDWA)
- NPDES program (CWA)
and others
The NPDES program requires permits for the
discharge of pollutants from any point source into
waters of the United States.
Surface discharge is frequently encountered.
Familiarization with the contents of 40 CFR, Part
122 as mandated by Section 402 of the Clean Water
Act, may make identification of violations under
this Act more easy to recognize during UIC
inspection activities.
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THE SAFE DRINKING WATER ACT
Part A of the SDWA includes definitions.
Part B of the SDWA is entitled, "Public Systems"
and includes Sections 1411 through 1417. Of
particular interest is Section 1412, which calls
for the establishment of Maximum Contaminant Level
goals and National Primary Drinking Water
Regulations for each contaminant listed by the
Administrator.
40 CFR, Part 141 establishes Primary Drinking
Water Regulations pursuant to Section 1412 of the
Safe Drinking Water Act.
40 CFR, Part 142 sets forth regulations for the
implementation and enforcement of the National
Primary Drinking Water regulations contained in
Part 141.
Part C of the Safe Drinking Water Act is entitled
"Protection of Underground Sources of Drinking
Water."
SLIDE #6-7 Part C of the SDWA consists of:
Section 1421 - Regulations for State Programs
Section 1422 - State Primary Enforcement
Responsibility
Section 1423 - Enforcement of Program
Section 1424 - Interim Regulation of Under-
ground Injection
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Section 1425
- Optional Demonstration by
States Relating to Oil and
Natural Gas
Section 1426 - Regulation of state Programs
Section 1427 - Sole Source Aquifer Demon-
stration Program
Section 1428 - State Program to Establish.
Wellhead Protection
Section 1445 - Records and Inspections
Section 1451 - Indian Tribes
In order to fully comprehend mandates set forth by
the SDWA, it is important to define an underground
source of drinking water (USDW). Let's turn to
page 2-3, Section 2:7 of the UIC Inspection
Manual.
40 CFR, Part 146.3 defines a USDW as:
Any aquifer or its portion
- Which supplies any public water system;
or
- Which contains a sufficient quantity of
ground water to supply a public water
system; and
Currently supplies drinking water
for human consumption; or
Contains fewer than 10,000 mg/1 TDS
dissolved solids; and
- Which is not an exempted aquifer.
Let's see how the act sets out to protect USDWs.
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Section 1421 of the SDWA
As described in 40 CFR, Part 144.1, Section 1421
of the SDWA requires the Administrator to
promulgate regulations establishing minimum
requirements for effective State UIC programs.
The regulations set forth in Section 14 21
call for the publishing of proposed
regulations for State UIC programs by the
Administrator within 6 months after enactment
of the Act.
Any regulation must be in accordance with
Section 553 of Title 5 (relates to rule
making), and must provide the opportunity for
a public hearing.
The regulations shall contain minimum
requirements for effective programs. The
regulations:
- Shall prohibit injection unless a permit
is issued by the State (rule-authorized
exceptions);
- Must satisfy the State that underground
injection will not endanger drinking
water;
- Shall include inspection, monitoring,
recordkeeping, and reporting require-
ments ; and
- Shall apply to Federal agencies and
other persons associated with under-
ground injection.
Regulations of the Administrator of State
programs may not prescribe requirements which
impede:
- The underground injection of brine
brought to surface by oil and gas
production; or
- Any underground injection for the
recovery of oil and gas.
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The regulations of the Administration shall
provide for consideration of varying
geological, hydrological, or historical
conditions in different regions.
The Administrator shall avoid requirements
which would disrupt programs which are being
enforced in a substantial manner. A
regulation is considered to disrupt if it
would be infeasible to comply with both the
regulation and the State UIC program. A
regulation shall be deemed unnecessary only
if, without such regulation, USDWs will not
be endangered by injection.
No part can be construed to affect the duty
to assure that USDWs will, within Section
1421, not be endangered by any underground
injection.
The Administrator may, upon application of
the Governor of a State, authorize temporary
permits for injection effective for 4 years
if:
- The Administrator finds that the State
is unable to process all permit
applications within the time available;
- The Administrator determines that the
adverse environmental effect is not
unwarranted;
- Such temporary permits may only be
issued to active wells at the time of
approval of State program; and
- The Administrator determines that the
temporary permits require safeguards.
The Administrator may upon application of the
Governor of a State which authorizes
injection by means of permits, authorize a
State to issue temporary permits, after
reasonable notice and hearing, effective for
4 years if the State finds, on the record of
such hearing;
- That technology to permit safe injection
in accordance with the applicable UIC
program is not available;
- That injection would be less harmful to
health than other methods of disposal;
and
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- That available technology or other means
have been employed to minimize the
potentially adverse effect of the
injection on the public health.
For the purpose of this part:
- Underground injection means the
subsurface emplacement of fluids by
injection; it does not include storage
of natural gas.
- Underground injection "endangers" if
such injection may result in the
presence in underground water which
supplies or can be expected to supply
any public water system of any
contaminant.
Section 1422 of the SDWA
Section 1422, "State Primary Enforcement," states
that within 6 months, the Administrator shall list
in the Federal Register the States that require a
UIC program.
Any State listed must, within 270 days,
submit an application satisfactory to the
Administrator that the State:
- Has adopted a program that meets the
requirements of the regulations; and
- Will keep records and make reports as
required by the regulations.
States must submit a notice to the
Administrator of any revisions or added
requirements
Within 90 days, the Administrator will
approve or disapprove the State program.
If the Administrator approves the program,
then the State shall have primary enforcement
responsibility.
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The Administrator shall provide opportunity
for a public hearing. If the program is
disapproved, the Administrator will, within
90 days, prescribe a program. Such a program
may not impede:
- The injection of brine brought to the
surface in connection with oil and gas
production; and
- Any injection for the secondary or
tertiary recovery of oil.
Section 1423 of the SDWA
Section 1423, "Enforcement of the Program," states
that whenever the Administrator finds that any
person is violating a requirement of the UIC
program in a primacy State, he shall notify both
the state and the party in violation. After 30
days, if the State has not commenced enforcement
action, the Administrator shall commence civil
action.
When the State does not have primary enforcement,
the Administrator shall issue an order to comply,
or the Administrator shall commence a civil
action.
Civil and Criminal Actions - Civil actions
referred to shall be brought into the
appropriate U.S. District Court. Any person
who violates a requirement of an applicable
UIC program or order:
- shall be subject to a civil penalty of
not more than $25,000 for each day of
violation;
- if such violation is willful, such
person may in addition to or in lieu of
the civil penalty be imprisoned for not
more than 3 years.
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Administrative Orders
- For cases in which the Administrator is
authorized to bring civil action for
violation other than those relating to:
the underground injection of brine
brought to the surface in
connection with oil and gas
production; or
~ any injection associated with the
secondary or tertiary recovery of
oil and gas, the Administrator may
issue an order assessing a civil
penalty of not more than $10,000
for each day, up to a maximum
administrative penalty of $125,000.
- For cases in which the Administrator is
authorized to bring civil action
relating to:
the underground injection of brine
brought to the surface in
connection with oil and gas
production; or
any injection for the secondary of
tertiary recovery of oil and gas,
the Administrator may issue an
order assessing a civil penalty of
not more than $5,000 for each day
not to exceed $125,000.
- An order shall be issued after opportu-
nity for a hearing.
- The Administrator shall provide public
notice and opportunity for comment.
- Any citizen who comments on any proposed
order shall be given notice of any
hearing and of any order.
- Any order issued will become effective
30 days following its issuance.
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Section 1425 of the SDWA
Section 14 25, "Optional Demonstrations by States
Relating to Oil and Gas" establishes an
alternative method for a State to obtain primary
enforcement for those portions of its UIC program
related to the recovery and production of oil and
gas.
Remember that Section 1422 specifies that, in
order for a State to obtain approval for its UIC
program, it must make a satisfactory showing that
it has adopted and will implement a program that
meets the requirements of regulations issued by
the Administrator. Such regulations have been
promulgated in 40 CFR, Parts 122, 123, 124, and
146.
In 1980, Congress amended the SDWA by adding
Section 1425. Effective May 19, 1981, this
section allows States to demonstrate the
effectiveness of their in-place regulatory
programs for Class II (oil- and gas-related) wells
in lieu of demonstrating that they meet the
minimum requirements specified in the UIC
regulations. In order to be deemed effective,
State Class II programs have to meet the same
statutory requirements as the other classes of
wells, including prohibition of unauthorized
injection and protection of USDWs. All Class II
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programs currently approved by EPA were approved
under Section 1425 of the SDWA.
Because of the large number of Class II wells, the
Federal regulations allow for authorization-by
rule for existing enhanced recovery wells (i.e.,
wells that were injecting at the time that a State
program was approved or prescribed by EPA). Wells
authorized by rule are subject to requirements
similar to those of permitted wells, but are not
subject to the administrative difficulties
associated with obtaining a permit. During the
first 5 years of the program, EPA and the States
have been conducting file reviews on all wells
authorized by rule to ensure that injection wells
not subject to permitting are technically adequate
ahd will not endanger USDWs.
In approving programs under Section 1425, the
Agency has accepted variations among States. This
is consistent with the requirements of the SDWA.
However, the program has been in place for several
years now and the Agency has acquired experience
in implementation of the regulations. Based on
this experience, the Agency began to look at the
adequacy of the current requirements. As a matter
of fact, EPA's Office of Drinking Water has
recently concluded the Class II Mid-Course
Evaluation.
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Section. 142 6 of the SDWA
Section 1426, "Regulation of State Programs,"
states that, 18 months after enactment of the 1986
SDWA amendments, the Administrator shall modify
the regulations for Class I wells, including
groundwater monitoring, to provide the earliest
possible detection of fluid migration.
The Administrator shall issue a report to Congress
by September of 1987. It shall include the
following items of information:
Class V (nonhazardous) well inventory,
numbers, and categories;
Primary contamination problems associated
with these Class V these wells; and
- Recommendations for design, construction, and
installation requirements that should be
applied to protect USDW from contamination.
Section 1428 of the SDWA
Section 1428, "State Programs to Establish
Wellhead Protection Areas," states that within 3
years of the 1986 SWDA amendments, States shall
adopt and submit a State program to protect
wellhead areas public supply wells). The States
were to submit wellhead programs by June of 1989.
In the program, States were required to:
Specify the duties of State agencies, local
government entities, and public water systems
in developing and implementing wellhead
protection;
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For each wellhead, identify the protection
area. As used in this section, "wellhead
area" means the surface and subsurface area;
Identify within each area, all anthropogenic
or man-related contaminants;
Describe a program that protects the water
supply within the wellhead protection area;
Include contingency plans for alternate
drinking water in the event contamination
occurs; and
Include a requirement that consideration be
given to all potential sources of contami-
nants within the wellhead area of a new water
well.
Each State must establish technical and citizen
advisory committees to encourage public partici-
pation.
The Administrator may disapprove of a program if
he deems it unsatisfactory in protecting public
water systems.
The State may, within 6 months after receipt
of disapproval, submit a modified program
based on the Administrator's comments.
Federal assistance must be received by the State
within 3 years of inception of this Section 1428.
Each State should implement the program within 2
years of program submission. Status reports shall
be submitted once every 2 years.
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Any governmental branch having jurisdiction over a
contaminant source is subject to and must comply
with the established State provisions.
Section 1445 of the SDWA
Section 1445, "Records and Inspections,n> states
that all persons who are suppliers of water or
operators of injection wells subject to primary
drinking water regulations must maintain records,
make reports, and conduct monitoring.
Eighteen months after enactment of the 1986 SDWA
amendments, the Administrator shall promulgate
regulations requiring monitoring, by every public
water system, of unregulated contaminants. These
regulations shall include a list of unregulated
contaminants, and criteria for addition or
deletion from the list.
Monitoring results must be submitted to the
primary enforcement authority.
Notification of the availability of the results
shall be given to those served by the system and
the Administrator.
The Administrator may waive the monitoring
requirements for a system which has conducted a
consistent program.
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For public water systems serving less than 150,
the system shall be in compliance if sampled in
accordance with rules established by Administra-
tor.
No entry of facilities in a State with primary
enforcement responsibility may be made without
notice first being given to the State by the
Administrator.
Refusal of entry may result in a civil penalty not
to exceed $25,000
Part of this section addresses the topic of
confidentiality of information. The Administrator
shall consider the applicant and give 30 days
notice of an unsatisfactory showing before
releasing information.
Information may be disclosed to other authorized
representatives of the United States.
We will now discuss the Resource Conservation and
Recovery Act.
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RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
The Resource Conservation and Recovery Act of 1976
completely replaced the previous language set
forth in the Solid Waste Disposal Act.
As. defined, it is an act to provide technical and
financial assistance for the development of
management plans and facilities for the recovery
of energy and other resources from discarded
materials and for the safe disposal of discarded
materials, and to regulate the management of
hazardous waste.
SLIDE #6-8 The Resource Conservation and Recovery Act
includes:
Subtitle A
Section 1004 - Definitions
Subtitle C
- Section 3020 - Interim Control of Hazard-
ous Waste Injection
- Section 3003 - Standards Applicable to
Transporters of Hazardous
Waste
- Section 3004 - Standards Applicable to
Owners/Operators
Section 3007 - Access Entry
Subtitle H
- Section 8002 - Special Studies
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Subtitle A - General Provisions
Section 1004 of Subtitle A is entitled,
"Definitions". In simplest: terms, a solid waste
is- any material that is discarded or is intended
to be discarded. According to RCRA, solid wastes
may be either solid, semi-solid, liquid, or
contained gaseous material.
Specifically excluded are point source discharges
subject to NPDES permits under the Clean Water
Act.
Commercial products are not wastes unless and
until they are discarded. Commercial products are
regulated under other statutes such as FIFRA,
TSCA, SARA, and OSHA.
The term hazardous waste means a solid waste, or
combination of solid wastes which because of its
quantity, concentration, or physical, chemical, or
infectious characteristic may:
Cause or significantly contribute to an
increase in serious irreversible illness; or
Pose a substantial present or potential
hazard to human health when improperly
handled.
EPA has also determined that produced water
injected for enhanced recovery is not a waste for
purposes of RCRA, Subtitle C or D, since produced
water, as used in enhanced recovery, is
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beneficially recycled and is an integral part of
some crude oil and natural gas production
processes.
Subtitle C - Hazardous Waste Management
Management of hazardous waste falls under Subtitle
C of RCRA. Subtitle C calls for the identifica-
tion and listing of hazardous wastes. As listed
in 40 CFR, Part 261.30, the regulations contain
four lists of hazardous wastes:
Hazardous wastes from non-specific sources;
Hazardous wastes from specific sources;
Commercial chemical products considered
acutely hazardous when disposed of; and
Commercial chemical products considered toxic
wastes when disposed.
Listed hazardous wastes are assigned generic
identification numbers. A solid waste is
hazardous if it exhibits any of the
; characteristics in this subpart.
SLIDE #6-9 The characteristics of this subpart are:
Ignitability;
Corrosivity;
Reactivity; and
Toxicity.
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RCRA regulations contain a rule that provides that
the commingling of any listed hazardous waste with
a nonhazardous wastes stream renders the entire
mixture a hazardous waste. The intent of the rule
is to prevent avoidance through dilution.
Section 3020 under Subtitle C is entitled,
"Interim Control of Hazardous Waste Injection" and
was added in 1984.
This section abolishes all hazardous waste
injection (into or above USDWs) 6 months after
enactment of the Hazardous and Solid Waste
Amendments of 1984.
This shall not apply to the injection of
contaminated ground water into the aquifer from
which it was withdrawn if:
Such injection is:
- A response action taken under 104 or 106
of CERCLA; or
- Part of corrective action required under
this title.
In addition to enforcement under the provisions of
this Act, the prohibitions established shall be
enforceable under the SDWA.
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Section 3003 under Subtitle C is entitled,
"Standards Applicable to Transporters of Hazardous
Waste" (established eighteen months after
enactment).
The standards include:
Recordkeeping, source, and delivery points;
Proper labeling;
Compliance with manifest system referred to
in Section 3002; and
Transportation to the facility designated on
the manifest.
Regulations under this act should be consistent
with the Hazardous Materials Transportation Act.
Section 3004 under Subtitle C is entitled,
"Standards Applicable to the Owners and Operators
of Hazardous Waste Treatment, Storage, and
Disposal Facilities.'
The standards include:
Maintaining records of treated, stored or,
disposed hazardous waste;
Satisfactory reporting, monitoring and
inspection, and compliance with manifest
system;
Operating technigues and practices satisfac-
tory to the Administrator;
Location, design, and construction of
facilities;
Contingency plans;
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Maintenance of operation and qualification
requirements; and
Compliance with requirements of Section 3005
regarding permits.
Section 3 007 under Subtitle C is entitled, "Access
Entry." Representatives are authorized:
To enter at reasonable times; and
To inspect and obtain samples, providing a
portion of the sample to the facility owner.
Any information shall be available to the public
unless it would divulge information entitled to
protection. Any person who divulges information
entitled to protection is subject to fine or
imprisonment ($5,000).
The State may make annual inspections of Federal
facilities and make information available to the
public.
The administrator shall annually inspect every
permitted facility which is operated by a State or
local government.
The Administrator, in cooperation with the States,
shall compile an inventory of all wells which
inject hazardous wastes.
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Subtitle H - Research, Development, Demonstration,
and Information
Section 8002(m) of Subtitle H mandates a study to
be performed to determine the effects of drilling
fluids, produced water, and other wastes
associated with the production of crude oil, or
natural gas and geothermal energy. The study was
to be completed within 2 years of the enactment
date of PL 96.482 (October 21, 1980). The
Administrator was to prepare a summary of the
findings, and submit a plan for research,
development, and demonstration to the Committee on
Environment and Public Works of the U.S. Senate,
and the Committee of Interstate and Foreign
Commerce of the U.S. House of Representatives. As
a result of that mandate, EPA published the
"Regulatory Determination for Oil and Gas and
Geothermal Exploration, Development, and
Production Wastes." The following lists are
excerpted from the Federal Register notice of the
determination, dated July 6, 1988.
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EPA'S List of Exempt Exploration and Production
Wastes
The following wastes are listed as exempt, in EPA's
Regulatory Determination submitted to Congress in
June of 1988:
Produced water;
Drilling fluids;
Drill cuttings;
Rigwash;
Drilling fluids and cuttings from offshore
operations disposed of onshore;
Well completion, treatment, and stimulation
fluids;
Basic sediment and water, and other tank
bottoms from storage facilities that hold
product and exempt waste;
Accumulated materials such as hydrocarbons,
solids, sand, and emulsion from production
separators, fluid treating vessels, and
production impoundments;
Pit sludges and contaminated bottoms from
storage or disposal of exempt wastes;
Workover wastes;
Gas plant dehydration wastes, including
glycol-based compounds, glycol filters,
filter media, backwash, and molecular sieves;
Gas plant sweetening wastes for sulfur
removal, including amine, amine filters,
amine filter media, backwash, precipitated
amine sludge, iron sponge, and hydrogen
sulfide scrubber liquid and sludge;
Cooling tower blowdown;
Spent filters, filter media, and backwash
(assuming the filter itself is not hazardous
and the residue in it is from an exempt waste
stream);
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Packing fluids;
Produced sand;
Pipe scale, hydrocarbon solids, hydrates, and
other deposits removed from piping and
equipment prior to transportation;
Hydrocarbon-bearing soil;
Pigging wastes from gathering lines;
Wastes from subsurface gas storage and
retrieval, except for the listed nonexempt
wastes;
Constituents removed from produced water
before it is injected or otherwise disposed
off-
Liquid hydrocarbons removed from the
production stream but not from oil refining;
Gases removed from the production stream,
such as hydrogen sulfide and carbon dioxide,
and volatilized hydrocarbons;
Materials ejected from a producing well
during the process known as blowdown;
Waste crude oil from primary field operations
and production; and
Light organics volatilized from exempt wastes
in reserve pits, impoundments, or production
equipment.
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EPA's List of Nonexempt Exploration and Production
Wastes
EPA's Regulatory Determination for Exploration and
Production Wastes lists the following wastes as
nonexempt. It appears that the EPA concluded that
production equipment maintenance wastes, as well
as transportation (pipeline and trucking) related
wastes, are nonexempt. While the following wastes
are nonexempt, they are not necessarily hazardous.
Unused fracturing fluids or acids;
Gas plant cooling tower cleaning wastes;
Painting wastes?
Oil and gas service company wastes, such as
empty drums, drum rinsate, vacuum truck
rinsate, sandblast media, painting wastes,
spent solvents, spilled chemicals, and waste
acids;
Vacuum truck and drum rinsate from trucks and
drums transporting or containing nonexempt
waste;
Refinery wastes;
Liquid and solid wastes generated by crude
oil and tank bottom reclaimers;
Used equipment lubrication oils;
Waste compressor oil, filters, and blowdown;
Used hydraulic fluids;
Waste solvents;
Waste in transportation pipeline-related
pits;
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Caustic or acid cleaners;
Boiler cleaning wastes;
Boiler refractory bricks;
Incinerator ash;
Laboratory wastes;
Sanitary wastes;
Pesticide wastes;
Radioactive tracer wastes; and
Drums, insulation, and miscellaneous solids.
Operators should consider testing nonexempt wastes
whenever there is reason to believe they exhibit
one of the hazardous waste characteristics.
There is no requirement for testing of a
nonexempted waste to determine if it is hazardous;
civil and criminal penalties may be imposed if the
waste .is not managed in a safe manner and
according to regulations.
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Additional Exempt Wastes
It should be noted that EPA's lists of exempt and
nonexempt wastes are not all-inclusive and that
determinations will need to be made on a number of
other incidental wastes. In deciding which wastes
were exempt, it appears that EPA focused on wastes
necessary to conduct so-called "primary field.
operations" (including centralized facilities and
gas plants). Using this approach, the following
wastes, although not specifically listed as exempt,
appear clearly exempt:
Excess cement slurries and cement cuttings;
Sulfur contaminated soil or sulfur waste from
sulfur recovery units;
Gas plant sweetening unit catalyst;
Produced water contaminated soil;
Wastes from the reclamation of tank bottoms
and emulsions when generated at a production
location;
Production facility sweetening and dehydra-
tion wastes;
Pigging wastes from producer operated
gathering lines;
Production line hydrotest/preserving fluids
utilizing produced waster; and
Iron sulfide.
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Land Disposal Restrictions Program (Land Ban)
The Land Disposal Restrictions Program regulates
the disposal of liquid hazardous wastes or free
liquids associated with treatment residues of
hazardous wastes, as well as non-liquid
halogenated organic compounds.
Applicable regulations are found in 40 CFR, Parts
146 and 148, as well as Parts 268 and associated
portions of 260 through 266.
State requirements for land disposal restrictions
(UIC program) are found in 40 CFR, Parts 148.10
through 148.16.
The regulations prohibit land disposal in:
Landfills;
Surface impoundments;
Waste piles;
Injection wells;
Land Treatment;
Salt domes;
Salt beds;
Underground caves or mines; and
Concrete vaults or bunkers.
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Land disposal of restricted wastes can continue
if:
No migration petition (40 CFR, Part 148)
Two year national capacity variance (40 CFR,
Part 148)
Case-by-case extension (40 CFR, Part 268.5)
Exemption (40 CFR, Part 268.5)
Contaminated soil or debris from CERCLA or
RCRA clean-up (generally until 11/8/90)
Small quantity generator
less than 100 kg/month of non-acute
hazardous waste, or
- less than 1 kg/month of acute hazardous
waste
Farmers disposing of pesticides in accordance
with 262.51
The dilution of wastes as a substitution for
treatment is prohibited (40 CFR, Parts 148.3 and
268.3).
Solvent wastes include:
F001 through F005, except:
- Chlorinated fluorocarbons
1,1,2-trichloroethane
- Benzene
- 2-ethoxyethanol
- 2-nitropropane
The waste must be used as a solvent-cleaning
agent, paint remover, degreaser, etc., where
the substance is not chemically altered.
The wastes are "restricted" above and below
treatment standards.
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Constituents on the California list include liquid
hazardous wastes containing:
Free cyanides > 1000 mg/1;
Corrosives with pH < 2.0;
PCBs >50 ppm; and
Certain metals.
The list also includes hazardous wastes containing
halogenated organic compounds (HOCs) in Part 268,
Appendix III:
Dilute wastewaters-primarily water and HOCs
> 1,000 mg/1, but < 10,000 mg/1;
Other liquid HOCs > 1,000 mg/1; and
Nonliquid HOCs > 1,000 mg/1.
Metals, as elements or compounds, include:
Arsenic > 500 mg/1
Cadmium > 100 mg/1
Chromium VI > 500 mg/1
Lead > 500 mg/1
Mercury >20 mg/1
Nickel > 134 mg/1
Selenium > 100 mg/1
Thallium > 130 mg/1
6-38
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Land Disposal Restrictions - First Third
157 high volume, high hazard wastes
Treatment standards established for approxi-
mately 25% by August 8, 1988
Treatment standards for "soft hammer" wastes,
approximately 75% were not established
Soft Hammer Wastes
Disposal in a landfill or surface impoundment if:
Facility is in compliance with technical
requirements; and
Prior to disposal, the generator must certify
to the Regional Administrator that
alternative treatment capacity is not
available and that landfill or surface
impoundment is the only available practical
alternative.
Effective Dates Related to Injected Wastes
Effective Aucrust 8. 1988
40 CFR, Part 148.10:
F001-F005 wastes, unless the solvent wastes
is a solvent-water mixture or sludge
containing less than 1% total F001-F005
constituents
Part 148.11:
F020-F023 and F026-F028 wastes, unless the
wastes have been treated to meet standards in
268.41; an exemption has been filed under
148.20 (no migration standard); and extension
of the effective date under 148.4 or granted
a treatability variance under 268.44
Part 148.12:
Wastes listed in 268.32 containing PCBs > 50
ppm of HOCs > 10,000 mg/kg
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Effective August 8. 1990
Part 148.10:
All spent F001-F005 solvent wastes containing
<1% total F001-F005
Same exceptions, extensions, variances a&
above
Part 148.12:
Liquid hazardous waste including free liquids
associated with any solid or sludge
containing free cyanides > 1,000 mg/1
Liquid hazardous waste including free liquids
associated with, any solid or sludge
containing the following metals (or elements)
or compounds of these metals (or elements) at
the following concentrations:
- Arsenic > 500 mg/1
- Cadmium > 100 mg/1
- Chromium (VI) > 500 mg/1
Lead > 500 mg/1
- Mercury >20 mg/1
- Nickel >134 mg/1
Selenium > 100 mg/1
- Thallium > 130 mg/1
Liquid hazardous waste with pH < 2
Hazardous waste containing HOCs in total
concentration > 1,000 mg/1, but < 10,000 mg/1
Same exceptions, extensions, variances as
above
Part 148.14:
K049, K050, K052, K062, K071, K104
Same extensions, exemptions, variances as
above
6 40
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Effective June 8. 1989
Part 148.14:
F006 (Cyanide), F008, F009, F019
K004(nw), K036(ww)
P030, P039, P041, P063, P071, P089, P094,
P097
U221, U223
Part 148.15:
F010, F011, F012, F024
K027, K028, K029(nw)/ K038, K039, K040, K043,
K095(nw), K096(nw), K113, K114, K115, K116
P029, P040, P04 3, P044, P062, P074, P085,
P098, P104, P106, Pill
U028, U058, U107, U235
Part 148.16:
K002(nw), K003(nw), K005(nw), K006(nw),
K007(nw), K023, K093, K094
P013, P021, P099, P109, P121
U069, U-87, U088, U102, U190
Effective Date August 8. 1990
Part 148.14:
F007
K011, KOI3/ K014
nw - nonwastewaters
ww - wastewaters
6 41
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Effective Date June 8. 1991
Part 148.15:
K009, K010
Generator Requirements
~ Determine if waste is restricted (262.11(h)
and 268.7(a)).
If waste does not meet treatment standard,
notification.
If waste does meet treatment standards,
notification and certification.
May store wastes for up to 90 days for
accumulation; if stored for more than 90
days, the facility must have interim status
or a permit.
Treatment, Storage, and Disposal (TSD) Requirements
General
- Obtain detailed waste analysis (264.13
or 265.13).
- Update waste analysis plan including:
analyses to be performed (a)(1) and
methods for analyses (b)(6).
For surface impoundments (b) (7) ,
schedule for sampling, analysis and
annual removal or residue.
Storage Requirements (268.50 (2))
Container storage
- Mark each drum/container identifying
contents and the date accumulation
begins.
Tank storage
- Mark each tank with contents and date
accumulation begins, or keep the same
information in the operating record.
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Transporter may store waste up to 10 days.
TSD may store waste up to one year for accu-
mulation purposes. Beyond 1 year, the facil-
ity must prove storage is for accumulation
purposes.
Treatment Facilities (268.7(b))
Keep a copy of generator notification/certi-
fication in operating record.
Test treatment residues or extract at the
frequency specified in waste analysis plan.
Determine if restricted wastes have been
treated to appropriate concentrations.
- If waste required further treatment, send
notification with each shipment.
If waste or residue meets the treatment
standards, send notification and certifica-
tion with each shipment.
Disposal Facility Requirements
Keep generator notification/certification in
operating record.
Record quantities of waste disposed under an
exemption.
Test the waste or an extract to assure that
wastes comply with treatment standards
according to the frequency in the waste
analysis plan.
Treatment, Recovery, or Storage Facility Require-
ments
Must keep copies of the generators demonstra-
tion (if applicable) and certification in the
operating record.
Must certify (using text in 268.8(c)(1) that
the waste has been treated in accordance with
the generators demonstration.
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Must send a copy of the generators demonstra-
tion (if applicable), and certification under
268.8(a)(2) and certification under 268.8(c)
(1) (if applicable) to the facility receiving
the waste or treatment residues.
Disposal Facility Requirements
Must ensure that the wastes prohibited under
258.33(f) are subject to a certification
prior to disposal.
Units receiving wastes must meet the minimum
technological requirements of 268.5(h)(2).
Additional requirements for disposal in landfills
or surface impoundments - 40 CFR, Part 268.8
Disposal in a landfill/surface impoundment may
continue if the unit is in compliance with the
requirements in 268.5(h)(2), provided that:
Prior to disposal, the generator makes a good
faith effort to contract with treatment/
recovery facilities which provide the
greatest environmental benefit.
Generator submits a demonstration and
certification that an attempt was made to
meet the above requirement and the
demonstration includes a list of the
facilities contacted, names of contacts,
addresses, telephone numbers, and contact
dates.
If the generator determines that there is "no
practically available" treatment:
Indicate so in the demonstration and use the
certification in 268.8(a)(2)(i). Submit the
package to the Regional Administrator.
Submit a copy of the demonstration and
certification with the first shipment to the
receiving facility.
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With each subsequent shipment, submit only
the certification, as long as the conditions
have not changed.
Generator must retain a copy of the
demonstration and certification (for each
shipment) for at least 5 years, onsite.
Record retension extended if enforcement
action.
Generator must immediately notify the
Regional Administrator of any change in
conditions which formed the basis of the
certification.
If the generator determines that there is "practi-
cally available" treatment:
Indicate so in the demonstration and use the
certification in 268.8(a)(2)(ii). Submit the
package to the Regional Administrator.
Submit a copy of the demonstration and
certification with the first shipment to the
receiving facility.
With each subsequent shipment, submit only
the certification, as long as the conditions
have not changed.
Generator must retain a copy of the demon-
stration and certification (for each
shipment) for at least 5 years, onsite.
Record retension extended if enforcement
action.
Generator must immediately notify the
Regional Administrator of any change in
conditions which formed the basis of the
certification.
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Treatment, Recovery, or Storage Facility Require-
ments :
Must keep copies of the generator's demon-
stration (if applicable) and certification in
the operating record.
Must certify (using text in 268.8(c)(1) that
the waste has been treated in accordance
with the generator's demonstration.
Must send a copy of the generator's demon-
stration (if applicable), certification under
268(a)(2), and certification under 268.8(c)
(1) (if applicable) to the facility receiving
the waste or treatment residues.
Disposal Facility Requirements
Must ensure that the wastes prohibited under
258.33(f) are subject to a certification
prior to disposal.
- Units receiving wastes must meet the minimum
technological requirements of 268.5(h)(2).
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSA-
TION, AND LIABILITY ACT (CERCLA)
It was felt that a Federal law was needed to
protect U.S. citizens against the dangers posed by
hazardous waste abandoned at sites throughout the
nation, both the short-term threat that became all
too apparent during emergencies and the long-term
threat, often requiring years of cleanup action.
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The Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980 (CERCLA) was the
first major response to the problem on a national
level. CERCLA had several key objectives:
To develop a comprehensive program to set
priorities for cleaning up the worst existing
hazardous waste sites;
To make responsible parties pay for those
cleanups, wherever possible;
To set up a $1.6 billion Hazardous Waste
Trust Fund, popularly known as "Superfund,"
for the twofold purpose of performing
remedial cleanups in cases where responsible
parties could not be held accountable, and
responding to emergency situations involving
hazardous substances; and
To advance scientific and technological
capabilities in all aspects of hazardous
waste management, treatment, and disposal.
Superfund was to be funded with taxes on crude oil
and 42 different commercial chemicals. State
governments were to pay 10 percent of the cost of
Superfund work at privately owned sites and 50
percent at those that were publicly owned.
The United States seemed ill-prepared to deal with
the problem of hazardous waste prior to the
creation of Superfund.
In the Clean Water Act of 1972, Congress had
provided for the regulation of hazardous waste
discharged into all navigable waters of the United
States. A $35 million trust fund (an ancestor of
6-47
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Superfund) was set up to deal with problems
stemming from such discharges. However, no
provision was made to deal with damage to land
resources resulting from contamination by
hazardous waste.
CERCLA, commonly known as Superfund, became law in
December of 1980. Superfund established a program
to identify sites from which hazardous releases
had occurred. This program was designed to assure
that the releases are cleaned up by responsible
parties or the government, to evaluate damages to
natural resources, and to create a claims proce-
dure for parties who have cleaned up sites or
spent money to restore natural resources. Under
CERCLA, releases of hazardous materials at levels
above the reportable quantity must be reported to
the National Response Center.
Under CERCLA, EPA has broad enforcement authority
to require Potentially Responsible Parties (PRPs)
to undertake cleanups (Section 106) or to recover
costs incurred in conducting remedial actions from
PRPs (Section 107).
Courts have interpreted the statute to be
retroactive in its application, to provide for
strict liability without regard to fault, and, in
appropriate circumstances, to impose joint and
6-48
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several liability. CERCLA provides owners/
operators with a significant economic incentive to
properly manage deposition of solid wastes at both
on-site and off-site locations to avoid being
involved in expensive cleanup activities.
For example, it would be financially unsound to
knowingly allow hazardous waste to contaminate a
nonhazardous exploration and production waste site
making it a potential CERCLA site, and be named as
a PRP by EPA. EPA has taken the position that
non-petroleum "special wastes", although exempt
from RCRA Subtitle C hazardous waste regulations,
may nevertheless result in CERCLA liability if any
of the constituents are "hazardous substances", as
otherwise listed under CERCLA.
CERCLA provides for the exclusion of petroleum,
including crude oil or any fraction thereof, from
the definition of hazardous substance, pollutant,
or contaminant. EPA has interpreted the petroleum
exclusion to include, in their entirety, pure
petroleum and pure petroleum fractions even though
they contain substances that are otherwise listed
as hazardous substances. Thus, EPA interprets the
term "petroleum" to encompass crude oil, crude oil
fractions, and refined products, such as gasoline.
This includes any indigenous hazardous substances.
6-49
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National Priorities List (NPL)
One important product of the 1972 Clean Water Act
was the formation of a National Contingency Plan
for dealing with emergencies involving hazardous
waste. The plan has undergone many changes and is
the guiding principle behind the implementation of
Superfund.
The plan was originally published for the removal
of oil and hazardous substances pursuant to
Section 311 of the Clean Water Act in order to
reflect and effectuate the responsibilities and
powers created by the Act.
The revisions of PL499 (Oct. 17, 1986), found in
Section 105 of CERCLA, include the National
Hazardous Substance Response Plan which
established procedures and standards for
responding to releases of hazardous substances,
pollutants, and contaminants.
The revisions established a list of national
priorities among the known releases or threatened
releases throughout the United States. The list
is revised at least once annually.
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OUTLINE OF REGULATIONS PERTINENT TO THE UIC PROGRAM
The instructor may find the following outline useful for
review.
Federal Water Pollution Control Act (1972)/Clean Water Act (1977)
Introduction
Statement of Amendment
Title III - Standards and Enforcement
Section 301 - Effluent Limitations
- Section 304 - Information and Guidelines
Section 311 - Oil and Hazardous Substance Liability
Title IV - Permits and Licenses
Section 402 - National Pollutant Discharge Elimination
Systems
Safe Drinking Water Act (1974)
Part C - Protection of Underground Sources of Drinking Water
- Section 1421 - Regulation for State Programs
- Section 1422 - State Primary Enforcement Responsibility
- Section 1423 - Enforcement of Program
Section 1424 - Interim Regulation of Underground In-
jection
Section 1425 - Optional Demonstration by States Relat-
ing to Oil and Natural Gas
- Section 1426 - Regulation of State Programs
Section 1427 - Sole Source Aquifer Demonstration Pro-
gram
Section 1428 - State Program to Establish Wellhead
Protection
- Section 1445 - Records and Inspections
Section 1451 - Indian Tribes
6-51
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40 CFR, Part 144 (1980) - Underground Injection Control Program
Subpart A - General Provisions
- Section 144.1 (a),(b),(e),(f)(1),(f)(2)
- Section 144.3 - Definitions
- Section 144.8 - Noncompliance
Subpart B - General Requirements
- Section 144.11
- Section 144.12
- Section 144.13
- Section 144.14
Subpart C - Authorization by Rule
- Section 144.21
- Section 144.22, .24
- Section 144.25
- Section 144.26
- Section 144.28*
Subpart D - Authorization by Permit
Subpart E - Permit Conditions
40 CFR, Part 145 - State UIC Program Requirements
40 CFR, Part 146 - Underground Injection Control Program:
Criteria and Standards
Subpart A - General Provisions
- Section 146.3 - Definitions
- Section 146.8 - Mechanical Integrity Testing
- Section 146.10 - Plugging and Abandonment
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Subpart B - Criteria and Standards Applicable to Class I
Wells
- Section 146.12 - Construction Requirements
- Section 146.13 - Operating, Monitoring, and Reporting
Subpart C - Criteria and Standard Applicable to Class II
Wells
- Section 14 6.22 - Construction
- Section 146.23 - Operating, Monitoring, and Reporting
Subpart D - Criteria and Standards Applicable to Class III
Wells
Section 146.32 - Construction
- Section 14 6.33 - Operating, Monitoring, and Reporting
Subpart F - Criteria and Standards Applicable to Class V
Wells
40 CFR, Part 147 - state Underground Injection Control Program
Resource Conservation and Recovery Act (1976)
Introduction
Section 1004 Definition
Subtitle C
- Section 3020 - Interim Control of Hazardous Waste In-
j ection
Section 3003 - Standards Applicable to Transporters of
of Hazardous Waste
Section 3 004 - Standards Applicable to Owners/Operators
- Section 3 007 - Access Entry
Subtitle D
- Section 4001 - Objective of the Subtitle
Section 4002 - Federal Guidelines for Plans
- Section 4003 - Requirements for Approval of Plans
- Section 4007 - Approval of State Plan; Federal Assist-
ance
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- Section 4008 - Authorization of Federal Financial
Assistance
- Section 4010 - Adequacy of Certain Guidelines and
Criteria
Subtitle H
- Section 8002 - Special Studies
EPA. List of Exempt E&P Wastes
EPA List of Nonexempt E&P Wastes
Toxic Substance Control Act
Title I - Control of Toxic Substances
- Section 2 - Findings
- Section 3 - Definitions
- Section 6 - Regulation of Hazardous Chemicals and
Mixtures [(3) placarding]
- Section 8 - Reporting and Retention of Information
- Section 9 - Laws Administered by the Administration
- Section 11 - Inspections and Subpoenas (Requirement for
Written Notice)
Comprehensive Environmental Response, Compensation, and Liability
Act
Introduction
Federal Insecticide, Fungicide, Rodenticide Act
6-54
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SECTION 7
UIC PROGRAM
This section contains material associated with the UIC
program- Particular topics discussed include:
Program Overview
Well Classification System
7-1
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DISCUSSION This section provides an overview of the EPA*
Underground Injection Control Program, commonly
referred to as the UIC program. The purpose of
the program will be discussed, as well as the
classification system used to designate the
various well types regulated under the program.
PROGRAM OVERVIEW
On December 14, 1974, Congress enacted the Safe
Drinking Water Act to protect the public health
and welfare of persons, and to protect existing
and future underground sources of drinking water
SLIDE #7-1 (USDWs). In 1980, USEPA promulgated these
regulations under 40 CFR, Parts 144 though 146.
The "Act also mandated the development of a
Federally approved Underground Injection Control
(UIC) program for each State, Possession, and
Territory. Approval of a particular program is
based on a finding that the program meets minimum
standards and technical requirements of SDWA
Section 1422 or Section 1425 and the applicable
provisions set forth in 40 CFR, Parts 144 through
146. States whose programs were submitted to and
approved by USEPA are known are Primacy States.
These States have primary enforcement responsibil-
ity for the regulation of injection wells in their
States. In those instances where a State has
7-2
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opted not to submit a program for approval or
where the submitted program does not meet the
minimum standards and technical requirements, the
program is promulgated and administered by USEPA.
States with Federally administered programs are
known as Direct Implementation (DI) States and are
subject to the regulations set forth in 40 CFR,
Parts 144 through 146.
Under 40 CFR, Section 144.3,. a "well" is defined
as a bored, drilled, or driven shaft, or dug hole,
whose depth is greater than its largest surface
dimension. "Well injection" is defined as the
subsurface emplacement of fluids through a bored,
drilled, or driven well; or through a dug well
where the depth of the dug well is greater than
its largest surface dimension.
SLIDE #7-2 An underground source of drinking water (USDW) is
defined as:
An aquifer which presently supplies a
public water system; or
Which contains sufficient water to supply a
public water system; or
Which contains less than 10,000 mg/1 total
dissolved solids; and
Is not an exempted aquifer.
7-3
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SLIDE #73 WELL CLASSIFICATION SYSTEM
The UIC regulations define and establish five
classes of injection wells. These are listed on
page 1-2 of the UIC Inspection Manual.
Class I wells receive hazardous and non-hazardous
wastes from industrial and municipal generators;
the wastes are injected below USDWs.
Class II wells include oil and gas enhanced
recovery, salt water disposal, and hydrocarbon
storage wells.
Class III wells include mineral extraction wells.
Class IV wells receive hazardous and radioactive
wastes which are injected into or above USDWs.
Class V wells include all other wells not included
in Classes I through IV.
Now we will review each well class in a little
more detail. First, let's discuss Class I wells.
SLIDE #7-4 Class I wells are:
Wells used by generators of hazardous waste
or owners/operators of hazardous waste man-
agement facilities containing, within one
quarter mile of the well bore, an underground
source of drinking water; and
Other industrial and municipal disposal wells
which inject fluids beneath the lowermost
formation containing, within one quarter mile
of the well bore, an underground source of
drinking water.
7-4
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Bethlehem steel, Dupont, and Parke-Davis are
examples of companies that operate Class I wells
at their facilities.
SLIDE #7-5 This slide illustrates the number of States which
contain Class I wells. As you can see, there are
quite a few states with Class I wells.
SHOW DUPONT Now we will show you a video put together by
VIDEO
Dupont for a Class I well they are constructing in
Louisiana.
SLIDE #7-6 Now we will discuss Class II wells.
Class II wells are wells which inject fluids:
Which are brought to the surface in connec-
tion with conventional oil or natural
gas production and may be commingled with
waste waters from gas plants which are an
integral part of production operations,
unless those waters are classified as a
hazardous waste at the time of injection;
For enhanced recovery of oil or natural gas?
and
For storage of hydrocarbons which are liquid
at standard temperature and pressure.
SLIDE #7-7 This slide illustrates the number of States which
contain Class II injection wells.
7-5
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SLIDE #7-8
SLIDE #7-9
SLIDE #7-10
SLIDE #7-11
SLIDE #7-12
SLIDE #7-13
SLIDE #7-14
This is a typical Class II well. Class II
injection wells can be constructed in a variety of
ways. These various completion types can have a
bearing on the inspections and types of MITs.
conducted in the field. Class II well completion
types include:
Conventional completion
Packerless completion
Slimhole completion
Tubingless completion
Dual completion
Annular disposal well
SLIDE #7-15
THRU #7-18
Here are a few examples of actual Class II wells
found in the field.
SHOW
CALIFORNIA
VIDEO
We'd now like to show a short video put together
by the California Division of Oil and Gas.
SLIDE #7-19
Now let's talk about Class III wells.
Class III wells are wells which inject for
extraction of minerals, including:
Mining of sulfur by the Frasch process;
In-situ production of uranium or other
metals; and
Solution mining of salts or potash.
7-6
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In-situ wells includes only in-situ production
from ore bodies which have not been conventionally
mined. Solution mining of conventional mines such
as stopes leaching is included in Class V.
SLIDE #7-20 This slide illustrates the number of States in
which Class III wells are operated.
SLIDE #7-21 This is a typical Class III salt or potash
solution mining well. Salt solution mining wells
can be operated as single wells or by the gallery
system.
The decision on which type of field design to use
is dependent on the type of salt formation.
SLIDE #7-22 Salt domes are mined by use of the single well
field design. Wells are drilled deep into the
salt dome where there are the fewest impurities.
They inject fresh water, usually down the annulus,
and produce saturated brine up the tubing.
SLIDE #7-23 The gallery method of salt solution mining is used
in bedded salt formations. Bedded salt formations
consist of salt layers too thin for single well
brine production. The gallery method involves
injecting into one well while producing from
another well. The salt formation is fractured
initially to allow flow between the wells. Fresh
water is injected into one well and saturated
-------
brine is produced from the other well. Additional
wells can be added to create a system of channels.
Salt solution mining wells are completed in many
of the same ways as Class II wells.
They can be tested for mechanical integrity using
the Standard Annular Pressure Test and by the use
of the Radioactive Tracer Survey (RTS).
The MIT Workgroup is looking into approving the
gallery test method. The gallery test involves
pressuring up the entire well field system as one
and approving the mechanical integrity of all the
wells should it pass the test.
SLIDE #7-24 Another type of Class III well completion involves
the in-situ leaching of minerals through
injection.
Produced ground water is mixed with a leaching
agent (such as ammonium carbonate or sodium
carbonate for uranium mining) and injected into
the mineral containing formation.
The mineral-laden fluid is produced out of the
wells and the minerals are extracted out of the
fluid.
7-8
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Fluid is produced at a higher rate than it is
injected in order to maintain the driving force in
the reservoir.
SLIDE #7-25 Another type of class III well is the Frasch
Sulfur producing well.
SLIDE #7-26 The Frasch Well Operation involves injecting
superheated water (330°F) into a sulfur bearing
formation. This heats up the formation rock until
the sulfur melts (240°F). Liquid sulfur is
heavier than water so it flows down to the
production perforations. Sulfur is then air
lifted to the surface for distribution. Produced
sulfur is 99.5% pure.
SLIDE #7-27 Class IV wells are banned.
Class IV wells consist of:
Wells used by generators of hazardous or of
radioactive waste, by owners or operators of
hazardous waste management facilities, or by
owners or operators of radioactive waste
disposal sites to dispose of hazardous or
radioactive waste into a formation which,
within one quarter mile of the well, contains
an underground source of drinking water;
Wells used by generators of hazardous or of
radioactive waste, by owners or operators of
hazardous waste management facilities, or by
owners or operators of radioactive waste
disposal sites to dispose of hazardous or
radioactive waste above a formation, which
within one quarter mile of the well, contains
an underground source of drinking water; and
7-9
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Wells used by generators of hazardous waste
or owners or operators of hazardous waste
management facilities, to dispose of
hazardous wastes which cannot be classified
under Section 146.05(a)(1) or Section
146.05(d)(1) and (2), e.g., wells used to
dispose of hazardous wastes into or above a
formation which contains an aquifer which has
been exempted pursuant: to UIC Regulations
(Section 146.04).
SLIDE #7-28
Class V veils are wells that are not included in
Classes I through IV. Examples of Class V well
types include:
Drainage wells;
Geothermal wells;
Domestic wastewater disposal wells;
Mineral and fossil fuel recovery wells;
Industrial disposal wells; and
Recharge wells.
SLIDE #7-29
This slide illustrates the States which contain
Class V wells.
SLIDE #7-30
AND #7-31
These two slides illustrate how different types of
Class V wells can potentially threaten groundwater
sources.
SLIDE #7-32
THRU #7-35
Here is a list of the many types of Class V wells.
There are 32 types of Class V wells. These
include
As you can see, the Class V injection well
category is large and diverse. This is due to the
broad definition of Class V wells.
7-10
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Class V wells, will be discussed in more detail in
a later session.
As can be seen, there are many types o£ wells that
inspectors may be seeing in the field. Inspectors
need to be familiar with each type.
7-11
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UIC INSPECTIONS
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SECTION 8
UIC INSPECTIONS
This section contains material associated with UIC
inspections. Particular topics discussed include:
Inspections and the SDWA
Role of the Inspector
Inspector Responsibilities
Typical Observations to Make During Inspections
Actual Inspection Cases
8-1
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DISCUSSION UIC inspections are a vital part of maintaining
operator compliance with regulations.
As inspectors, you are asked to maintain oversight
of injection well operators and inform EPA, or
State agencies when regulations are not being
followed.
In this session, we will be discussing the role of
the inspector in the UIC program and the
importance of inspection activities.
We will also be addressing how inspections should
be conducted and the proper documentation
involved.
READ TOP OF INSPECTIONS AND THE SDWA
PAGE 2-1
Let's look at Section 2 in the UIC Inspection
Manual. You can follow along as I read the
"Overview of the SDWA and Amendments" at the top
of the page.
ROLE OF THE INSPECTOR
Inspectors play a major role in the Agency's
compliance and enforcement program. Without
inspectors, there would be no enforcement cases,
for inspectors are the ones who collect the
information upon which enforcement cases are
based.
8-2
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The inspector's work must meet the highest
standards in order to achieve ultimate success in
an enforcement action.
An inspector's failure to adequately substantiate
what he or she saw may mean that EPA cannot take-
the case to court and win a large penalty, instead
settling for a lesser action which does not send a
strong signal to the regulated community.
Inspectors are generally involved in virtually
every aspect of the compliance and enforcement
program, which includes:
Selecting specific facilities to inspect;
Determining the scope and objectives of the
inspection;
Coordinating with appropriate legal,
technical, and program staff;
Evaluating the need for a warrant and
developing the information required to
support an application if needed;
Assessing whether a violation exists and
collecting evidence;
Collecting the necessary information and
writing the report that will serve as the
basis for the Agency's decision regarding an
enforcement action;
Collecting additional evidence if needed to
support an enforcement case;
Participating in (or supporting) settlement
negotiations;
Serving as a government witness in
enforcement hearings or trials; and
8-3
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Checking to make sure that a facility has
taken the steps required by the enforcement
action to return to compliance.
SLIDE #8-1 INSPECTOR RESPONSIBILITIES
The basic responsibilities of inspectors can be
grouped into the following general categories:
Official Representative - The inspector
represents EPA and may be the only Agency
official ever seen by a plant manager. This
requires tact, a professional attitude, and
diplomacy.
Fact-finder - The inspector assesses whether
the facility is in compliance with
regulations. This requires extensive
knowledge of the regulations and skill in
obtaining information and following up leads
to identify the less obvious violations.
Enforcement Case Developer - The inspector
collects and preserves evidence of
noncompliance. Since the inspection is
usually the primary basis for the enforcement
case, good documentation is essential. The
inspector is often a key witness.
Enforcement Presence - The inspector creates
a visible presence of government interest in
the regulatory status of facilities; the
potential for being inspected creates an
incentive for compliance with regulations.
Technical Educator - The inspector serves as
a source of regulatory information and may
provide technical assistance to facility
managers by directing them to sources of
technical information.
Technical Authority - Inspectors may be
required to help the Agency interpret
regulatory requirements and technical data,
and assess the adequacy of control measures
environmental impacts.
8-4
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SLIDE #8-2
AND READ
SECTION 3:1
When preparing to conduct an inspection, the
inspector needs to consider the potential
ramifications of his or her findings during the
inspection.
Turn to Section 3 in the UIC Inspection Manual
entitled, "Techniques for Efficient Inspections."
I'll be reading from Section 3:1, "Legal
Responsibilities..."
Legal Framework for Conducting Facility Inspec-
tions:
Presentation of proper credentials
Presentation of required notices and receipts
Proper handling of necessary warrants when
facility entry is denied
Handling of confidential information
Proper handling of samples (chain of custody)
and photographs
SLIDE #8-3
This slide illustrates a Notice-of-Inspection
form.
SLIDE #8-4
Section 1445 of the SDWA is printed on the back
side of the form.
As mentioned earlier, Section 1445 of the SDWA
provides authority for inspectors to enter upon
and inspect any facility under the jurisdiction of
the UIC program.
8-5
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Inspectors should be familiar with the general
investigative techniques and procedures to ensure
accurate, concise, and legally defensible inspec-
tions.
SLIDE #8-5
This slide depicts an outline of inspector
responsibilities. The outline may be found on
page 3-3 of the Inspection Manual. Please follow
along as we read through the outline.
READ
SECTION 3:4
Pre-Inspection Preparation
The inspector should:
Establish the purpose and scope of the
inspection;
Review background information and Agency
records;
Develop a plan for the inspection;
- Refer to page 3-7, Section 3:4
Inspection Plan Development.
on
Please flip back to page 3-3 and we'll
continue our review of the outline of
the inspector's responsibilities.
Prepare documents and equipment; this
includes filling out the Notice-of-Inspection
form and making sure that gauges are in
working order; and
Review the inspection schedule, coordinating
with the lab if samples are to be collected.
8-6
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Entry
The inspector should:
Present official credentials; and
Manage denial of entry, if necessary.
Facility access and denial procedures will be
discussed in the next section.
READ Opening Conference
SECTION 3:9
The inspector should:
Discuss inspection objectives and scope; and
Establish a working relationship with facili-
ty officials.
You may want to follow along as we read
Section 3:9 on page 3-11.
Facility Inspection
The inspector should:
Review facility records;
Inspect monitoring equipment and operations;
Collect samples (if necessary); and
Document inspection activities.
Let's turn to Section 3:10 and read the first
paragraph.
SLIDE #8-6 The inspection report should be:
Accurate;
Relevant;
Comprehensive;
Coordinated;
Objective;
8-7
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Clear; and
Neat and legible.
Section 3:22 provides detailed guidelines for
writing inspection reports.
Closing Conference
The inspector should:
Collect missing or additional information;
Clarify questions with facility officials;
and
Prepare necessary receipts.
READ Turn to Section 3:11, page 3-16 and follow along
SECTION 3:11
as I read.
Follow-Dp
A follow-up letter should, be prepared to
summarize the inspection results.
All information should be submitted to the
correct personnel, keeping your record book
and copies of all data.
SLIDE #8-7 KINDS OP INSPECTIONS
There are several different kinds of inspections:
Emergency inspections
Preoperational inspections
Mechanical integrity tests
Compliance verification
Plugging and abandonment verification
Class IV closure verification
General maintenance inspections
Citizen complaint inspections
8-8
-------
Let's turn to pages 2-17 through 2-20 of your text
for a review of each type.
READ EACH Emergency, compliance, and citizen complaint
SECTION inspections are discussed on page 2-17.
Preoperational inspections are discussed on page
2-18.
Mechanical integrity test inspections are discuss-
ed on page 2-18.
Plugging and abandonment inspections are described
on page 2-19.
Closure of Class IV wells is discussed on page
2-19.
General maintenance inspection are described on
page 2-19.
TYPICAL OBSERVATIONS TO MAKE DURING INSPECTIONS
The following provides a list of items to note
during an inspection of Class I, II, or III wells:
Examine the wellhead area, noting:
- Presence of meter
Evidence of surface discharge
Evidence of recent workover
- Physical signs of injection activity
- Gauges present and pressures
Inspect the injection plant, noting:
- Evidence of surface discharge
- Capability of handling spills
Injection pump, plunger size - can
establish capability to inject
Automatic switches (murphy switches)
- Water tank capacity
8-9
-------
INVOLVE
TRAINEES
SLIDE #8-8
SLIDE #8-9
SLIDE #8-10
- Chart recorders
- Sample locations
Gauges present and pressures
ACTUAL INSPECTION CASES
These are slides of actual Class II inspections
conducted in the States of Montana and Tennessee.
This is a typical workover rig. It consists of a
truck-mounted telescoping derrick with diesel-
powered drumworks. It is capable of pulling two
joints of tubing at a time. You may see this type
of rig on location during inspections.
This is a picture of .a drilling rig. As
inspectors, you may visit a rig such as this
during the initial construction of an injection
well.
This is a picture of a high-tech enhanced recovery
injection well located in Montana. Note that the
piping is stainless steel. Pressure gauges are
located on the tubing and annulus. Shut-off
valves are located on both the tubing string and
the injection line. Note the sample tap, volume
meter (blue), and adjustable choke (gold) on the
injection line. The workover workstring is in the
8-10
-------
left foreground of the picture. The building will
be rolled back over the injection well after
testing is completed.
SLIDE #8-11 This is also an enhanced recovery injection well.
Note the double valves on the injection tubing and
a check valve (red) on the injection line to
prevent backflow. The hose running from the top
of the tubing and from the annulus is connected to
pressure sensors in the chart recorder on the
wall. The chart recorder monitors injection
pressure and annulus pressure. An electronic
meter on the injection line monitors the volume of
fluid injected.
SLIDE #8-12 This is another injection well. Note the gauge on
the injection line, the check valve (red), and the
Halliburton volume meter on the injection line
(white shape to rear of photo). There is evidence
of leakage on the injection line. Note the metal
grate over the cellar in the wellhouse. Always
check the cellar for evidence of leakage (standing
water/oil).
SLIDE #8-13 This is a picture of a well discovered by an
inspector in Tennessee. It is a possible gas
injection well. Note the lack of seal on the
casing. Anything could be dumped into the well
between the tubing and casing. Any ideas about
8-11
-------
what this, well could be? As inspectors, you may
run across abnormally constructed wells.
SLIDE: #8-14 This is a casing injection well. The injection
fluid is pumped directly into the casing without
use of tubing and packer. Note the evidence of
spills.
SLIDE #8-15 When conducting inspections, it is a good idea to
note the reading on the volume meter. This is a
volume flow meter on the injection line of an
injection well. If the well is injecting, you can
monitor the meter reading over a time interval and
calculate the injection rate. A meter reading is
also useful when taken on wells that are supposed
to be shut in. If you take a meter reading one
week, and happen to return at a later date and the
meter reading is different, the operator has been
using the well.
SLIDE #8-16 This is another example of a flow meter. In this
picture, you can also see a sample tap on the
injection line (red handle), a bull plug on top of
the well, and a gate valve on the tubing.
8-12
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SLIDE #8-17 This is a picture of a logging truck that is
rigged up on an injection well. The logging tool
is lowered by wireline into the well to log the
areas of interest. On the right side of the
workover rig is a trailer-mounted circulating pump
and 55 barrel tank.
SLIDE #8-18 This is a picture of a logging tool being prepared
to run into a well. Note that the pit located
next to the well is used for catching wellbore
fluids. Also note the wellhead on the ground
behind the well.
This slide illustrates an injection well workover.
In the foreground of the slide is a stack of
2 3/8" fiberglass tubing. The large silver piece
of equipment on the well is a hydraulic blowout
preventer. The equipment being lowered to the
ground is a stripper head. It is used so that the
tubing can be moved in and out of the well while
the well is being circulated clean.
This is a picture of a Baker AD-1 tension set
packer. Many of the injection wells you will
encounter use a packer similar to this one.
SLIDE #8-19
SLIDE #8-20
8-13
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SLIDE #8-21 This is an injection plant for a waterflood in
Montana. The pump in the foreground is a
quintuplex pump for the injection fluid. These
injection plants are normally quite noisy and
precautions should be taken to avoid hearing
damage.
SLIDE #8-22 Remember the high-tech injection well that was
previously shown. This is the injection plant
that supplies the water. This is a state-of-the-
art. injection plant. Stainless steel flow lines
are used throughout the plant to avoid any
corrosion from the brine. In the background are
two 25 horsepower booster pumps. These supply the
injection pressure. The water storage tank is
located in the background of the photo (blue tank
through archway) . Note the barrels of chemicals.
Chemicals are added to the injection fluid for
various reasons (i.e., the prevention of scale
buildup).
SLIDE #8-23 This is another example of an injection plant for
a large waterflood. Shown is a multistage
centrifugal pump powered by a 17 50 HP electric
motor. The blue panel at the back of the plant is
the computer control panel.
8-14
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SLIDE #8-24
SLIDE #8-25
SLIDE #8-2 6
8-15
This is a pump for a small injection project.
Shown is an electric motor driving a triplex pump.
The red cylinder in the foreground is a vibration
dampener. A vibration dampener is used to smooth
out the pulses of water leaving the triplex pump.
This is the more common way you will see injection
pumps in older fields. This is a triplex pump
that injects into a salt water disposal well.
This is a manifold system for injection. Each
line leads to an individual well. The injection
rate and volume are monitored at this manifold.
Note the adjustable chokes and electronic
rate/volume meters.
-------
SECTION 9
FACILITY ACCESS
This section contains material associated with facility
access. Particular topics discussed include:
Statutory Considerations
Constitutional Considerations
Case Studies
Denial of Entry
9-1
-------
The Region may wish to have members of Regional counsel
present to lead the discussion pertaining to facility access of
injection operations.
DISCUSSION
We have a memorandum prepared by Mr. Jim Ellerbe,
Office of Regional counsel in Region VIII, for use
in that Region. The memorandum has been placed in
the insert of the handout notebook. Please pull
it out at this time.
READ
SUBJECT OF
MEMORANDUM
"This memorandum is to provide you with some of
the legal considerations that EPA's inspectors
should be aware of in the field. The scope of
this memo is limited to inspection procedures in
UIC direct implementation States1, particularly
the State of Montana. As such, the goal is to
provide general legal advice that applies to the
typical inspection situation in that rural State,
and not to handle every exception and nuance that
may come up in actual inspections...."
READ SECTION With this in mind, let's read Section 3:8 on page
3:8
3-8 of the UIC Inspection Manual.
9-2
-------
discussion Upon entry to a facility, the UIC inspector must
show his/her credentials. Credentials:
May include the inspector's signature,
physical description, and photograph;
Mention proprietary issues and/or confidenti-
ality; and
Should always be carried with the inspector
when in the field to perform inspections in
the event that the owner/operator of the
facility requests them.
Inspector credentials are not typically requested
by Class II operators who are usually familiar
with UIC inspections. Operators of Class V
facilities, however, are more likely to request
credentials due to their relative unfamiliarity
with the UIC program.
The Notice-of-Inspection (NOI) form (shown
earlier) should also be carried to each UIC
inspection. The form should be completed even if
the operator is not available to sign it.
Arrangements can be made to send it to the
operator subsequent to the inspection. The back
side of the Notice-of-In'spection form contains
Section 1445 of the SDWA, which brings us back to
the memorandum prepared by Mr. Ellerbe of Region
VIII.
9-3
-------
READ FROM "The legal considerations that will be discussed
MEMORANDUM
fall into two categories: Statutory (Safe Drink-
ing Water Act Section 1445) and Constitutional
(Fourth Amendment) Considerations."
STATUTORY CONSIDERATIONS
According to Section 1445 of the SDWA, the
following conditions of entry should be followed
when possible:
Present credentials;
~ Provide Notice-of-Inspection form; and
Inspect the facility "at reasonable times"
(i.e., business hours).
Exceptions to these conditions may be made when:
The operator is not present. In such a case,
the Notice-of-Inspection form can be left at
the facility subsequent to the inspection.
EPA has reason to believe that a noncompli-
ant operation is occurring; In such cases,
EPA can use the two inspector system (i.e.
one inspector with the operator, while the
other inspector is simultaneously at the
injection facility). Circumstances may
dictate the most reasonable action to take.
CONSTITUTIONAL CONSIDERATIONS
The Fourth Amendment limits search and seizures
based on:
Expectation of privacy; and
Probable cause.
9-4
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CASE STUDIES
Marshal v. Barlow established that:
The Fourth Amendment covers commercial
premises; and that
Probable cause in the criminal law sense is
not required. An inspector can get a warrant
on the basis of a general administrative plan,
for enforcement.
Applicability to UIC inspectors:
Where the operator has taken steps to ensure
"expectation of privacy", the inspector
needs:
- Operator consent; and
- A warrant.
The inspector should always attempt to
conduct the inspection with the operator's
consent.
Air Pollution Variance Board of Colorado vs.
Western Alfalfa Corporation allowed warrantless
search on the basis of "open field" exception to
the Fourth Amendment.
Ways in which warrantless entry might be permis-
sible:
"Closely regulated business" exception based
on the rationale that by engaging in these
kinds of businesses, one gives up one's
expectation of privacy; and
"Open fields" doctrine.
9-5
-------
Applicability to UIC inspectors:
Inspections may be performed in the
operator's absence, on an unmanned, unsecured
injection facility.
If the operator does not consent to the
inspection, the inspector should leave
immediately and return with a warrant.
DENIAL OF ENTRY TO THE FACILITY
The facility owner may withdraw his consent to the
inspection at any time. The inspection is valid
to the extent to which it has progressed before
consent was withdrawn. Thus, observations by the
inspector, including samples and photographs
obtained before consent was withdrawn, would be
admissible in any subsequent enforcement action.
Denial of entry into the facility requires certain
procedural steps that should be undertaken by the
inspector to ensure that proper legal guidelines
are followed.
First, upon arrival at the facility, the inspector
should clearly identify himself as an EPA UIC
inspector and present the proper credentials and
notice of inspection to the facility owner or
agent in charge.
-------
The establishment owner may complain about
allowing an inspector to enter or otherwise
express his displeasure with EPA or the Federal
government. However, as long as he allows the
inspector to enter, the entry is voluntary and
consensual. On the other hand, if the inspector
gains entry in a coercive manner (either in a
verbal or physical sense), the entry would not be
consensual.
If entry is not granted, ask why. Tactfully probe
the reason for the denial to see if obstacles
(such as misunderstandings) can be resolved. If
resolution is beyond the authority of the
inspector, he or she may suggest that the facility
officials seek advice from their attorneys on
clarification of the scope of EPA's inspection
authority under the Safe Drinking Water Act.
If entry is still denied, the inspector should
leave the premises immediately and telephone the
designated Regional Enforcement Attorney as soon
as possible for further instructions. The
Regional Enforcement Attorney should contact the
U.S. Attorney's Office for the district in which
the establishment desired to be inspected is
located and explain to the appropriate Assistant
United States Attorney the need for a warrant to
-------
conduct the particular inspection. The Regional
Attorney should arrange for the United States
Attorney to meet with the inspector as soon as
possible. The inspector should bring a copy of
the appropriate draft warrant and affidavits.
All observations pertaining to the denial are to
be carefully noted in the field notebook. Include
facility name and exact address, name and title of
person(s) approached, authority of person(s) who
refused entry, time of denial, reason for denial,
facility appearance, any reasonable suspicions
that refusal was based on a desire to cover up
regulatory violations, etc. All such information
will be important should a warrant be sought.
In the event that a warrant becomes necessary, the
inspector should be aware of what information is
required to obtain a warrant. There are several
general rules for securing warrants. Three
documents have to be drafted:
An application for a warrant;
An accompanying affidavit; and
The warrant.
Each document should be captioned with the
District Court of jurisdiction, the title of the
action, and the title of the particular document.
9-8
-------
The application for a warrant should generally
identify the statutes and regulations under which
the Agency is seeking the warrant, and should
clearly identify the site or establishment desired
to be inspected (including, if possible, the owner
and/or operator of the sire). The application can
be a one or two page document if all of the
factual background for seeking the warrant is
stated in the affidavit, and the application so
states. The application should be signed by the
U.S. Attorney or by his Assistant U.S. Attorney.
The affidavits in support of the warrant
application are crucial documents. Each affidavit
should consist of consecutively numbered
paragraphs, which describe all of the facts that
support warrant issuance. If the warrant is
sought in the absence of probable cause, it should
recite or incorporate the neutral administrative
scheme which is the basis for inspecting the
particular establishment. Each affidavit should
be signed by someone with personal knowledge of
all the facts stated. In cases where entry has
been denied, the person would most likely be the
inspector who has denied entry. Note that an
affidavit is a sworn statement that must either be
notarized or personally sworn to before the
magistrate or judge.
9-9
-------
MY 171989
A.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
999 18th STREET - SUITE 500
DENVER, COLORADO 80202-2405
April 12, 1989
Ref: 8RC
MEMORANDUM
TO:
Laura Clemmens, Chief
UIC Program and Enforcement Section
Tom Pike, Chief
UIC Implementation Section
FROM: Jim Ellerb*^"*
Office of Regional Counsel
£2*
SUBJECT: UIC Inspections
This memorandum is to provide you with some of the legal
considerations that EPA's inspectors should be aware of in the
field. The' scope of this memo is limited to inspection
procedures in UIC direct implementation States1, particularly the
State of Montana. As such, the goal is to provide general legal
advice that applies to the typical inspection situation in that
rural State, and not to handle every exception and nuance that
may come up in actual inspections. The legal considerations that
will be discussed fall into two categories: Statutory (Safe
Drinking Water Act Section 1445) and Constitutional (Fourth
Amendment) considerations.
Section 1445 of the Safe Drinking Water Act provides as
follows:
... the Administrator, or representatives of the
Administrator duly designated by him, upon presenting
appropriate credentials and a written notice to any ...
person subject to ... an applicable- underground
injection control program ... is authorized to enter
any establishment, facility, or other property of such
... person in order to determine whether such ...
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 ....
1 Statutory considerations in delegated States vary
somewhat; see SDWA Section 1445(b)(2). Constitutional
considerations in delegated States are unaffected.
Statutory Considerations
-------
This section is interpreted to allow any inspector who is
either (1) an EPA employee, or (2) working for EPA on a
contractual basis to come onto an oil and gas lease, approach the
wellhead of an injection well, and make any observations
necessary to determine UIC compliance. This would include
looking at gauges and physically touching the wellhead apparatus
(for example, to fit the inspector's gauge onto the wellhead to
record current injection pressure) as long as the inspector's
activities; on the lease are necessary in order to determine
compliance. The inspector will not be committing a trespass
under State common law if he is on private property under the
authority of SDWA Section 1445.
Section 1445 imposes two important conditions on the
inspector's right of entry. The two conditions are that the
inspector (1) present to the operator the inspector's credentials
and (2) provide the operator written notice of the inspection.
These procedures should be followed, if possible, as a matter of
routine just as the inspection begins; if the operator is
present, there should be no problem with them. The problem
arises, however, when the operator is not present at the time of
inspection. In such a case, there is nobody to present the
credentials and give the written notice to. This should not stop
the inspector from making the inspection, however; it is enough
to notify the operator after the inspection has taken place,
either by (1 ) leaving a notice of inspection at the wellhead, or
(2) mailing the notice to the operator. Another procedure that
is acceptable is to have one EPA employee present the written,
notice at the operator's office at the same time another EPA
employees is inspecting the well^. it should be emphasized that
the credentials and notice procedures should not be interpreted
to preclude surprise inspections or to require the operator's
presence on site during the inspection.
A third condition on the inspector's right of entry is that
the inspection take place "at reasonable times." Ordinarily this
means normal business hours (e.g. Monday through Friday between
8:00 a.m. and 5:00 p.m.), but there is an important exception
when EPA has reason to believe that non-compliant operation is
occurring during other than normal business hours. In law, as
elsewhere, what is "reasonable" depends on the circumstances.
2 For further guidance on the written notice condition, the
reader is referred to an August 24, 1987 EPA Memorandum from
Michael B. Cook to James S. Kutzman entitled "UIC Inspection
Notice Requirements."
2
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Constitutional Considerations
The Fourth Amendment to the Constitution reads as- follows:
The right of the people to be secure in their
persons, houses, papers, and effects, against
unreasonable searches and seizures, shall not be
violated, and no Warrants shall issue, but upon
probable cause, supported by Oath or affirmation, and
particularly describing the place to be searched, and
the persons or things to be seized.
The Fourth Amendment is a limit on the search and seizure
(arrest) powers of the Government, the purpose of which is to
prevent the Government from harassing or intimidating citizens by
conducting intrusive searches (or arrests) without good reason.
Most Fourth Amendment law has developed in the criminal law
context, but the Fourth Amendment affects agencies with civil
regulatory programs as well. In general (there are-exceptions),
the Fourth Amendment prevents the Government from' searching areas
in which a person has an "expectation of privacy" without a
search warrant. To obtain a search warrant, the Government must
present to a court some kind of factual basis that would lead one
to suspect that a crime, has been committed ("probable cause").
The search warrant then allows the Government to conduct a search
at a particular time and place.
With respect to Government agencies enforcing civil
regulatory programs, such as the UIC program, the leading case is
Marshall v. Barlow's3. This case involved an OSHA inspector who
attempted to enter the nonpublic area of Barlow's commercial
premises (an electrical and plumbing business) without a search
warrant. For his authority to inspect, the OSHA inspector was
relying on Section 8 of the Occupational Safety and Health Act,
which allows OSHA inspectors to inspect any facility covered by
the Act, and does not mention the need for a search warrant.
(The language of OSHA Section 8 is very similar to that of
Section 1445 of the Safe Drinking Water Act.) When the case got
to the U.S. Supreme Court, the Court held that (1) the Fourth
Amendment covers commercial premises as well as private
residences, (2) OSHA Section 8 does not allow warrantless
inspections; rather, the Fourth Amendment imposes an independent
requirement for a warrant regardless of OSHA's statutory
authority to conduct inspections, and (3) to obtain a warrant,
"probable cause" in the criminal law sense is not required. It
will be enough for the Government to show that "... a specific
business has been chosen for an OSHA search on the basis of a
3 For further guidance on the effect of the Barlow1s
decision, see OECM Guidance #GM-5, "Conduct of Inspections After
the Barlow's Decision," April 11, 1979.
3
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general administrative plan for the enforcement of the Act
derived from neutral sources." In other words, the Government
can get a warrant in this context merely by showing that it is
someone's turn to be inspected in a plan that treats everybody in
the regulated community equally.
How does Marshall v. Barlow's apply to the UIC inspector?
First, if the inspector needs to enter an operator's business
offices or other area where the operator has taken steps to
ensure an "expectation of privacy" (for example, a manned and
fenced injection facility), the inspector will need to have
either (1) the operator's consent, or (2) a warrant. SDWA
Section 1445 is not enough, by itself, to get the inspector past
an operator who does not consent to entry4. Second, if the
inspector is acting under a neutral inspection plan, the
procedure- for obtaining a warrant should be straightforward. The
major inconvenience is that, in most cases, the inspector should
attempt to make the inspection with the operator's consent before
going to court for a warrant and returning to the inspection site
with the warrant in hand5.
With respect to UIC inspections in the State of Montana, the
inspector is more likely to encounter an unguarded and unmanned
injection facility miles from the nearest town than he is to
encounter a guarded facility. Typically there is no fence or any
other obstacle to complete access to the facility. Absent the
operator's consent, does the- inspector need a warrant to come
onto the lease and inspect? Although there is no caselaw
interpreting the Fourth Amendment in the context of searches of
rural injection wells, there are persuasive reasons to believe
that a warrant is not required in this instance.
4 SDWA 1445(c) provides for a civil penalty of up to
$25,000 for failure to allow EPA representatives to conduct
inspections authorized by SDWA 1445(b). Established case law
holds that persons who have exercised their Fourth Amendment
rights by refusing to consent to warrantless inspections may not
be prosecuted under this kind of provision. In fact, if an
inspector obtains consent to inspect by threatening prosecution,
there is a serious risk that a court might later find that
consent was coerced, the search was unconstitutional, and
evidence gained thereby is inadmissible.
5 in Montana, making two trips to the site with a stop in
federal court can obviously be a significant burden. Under
certain circumstances, the Government can obtain an "ex parte"
warrant before the first attempt to inspect, but the Government
must be prepared to show the court why a simple request for the
operator's consent is likely to be unproductive.
4
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The key to whether a warrant is required or not is the
degree to which the operator has a legitimate "expectation of
privacy" in the injection operations/facilities that the
inspector wishes to search. As courts use the term, "expectation
of privacy" is not something a person either has or he doesn't
have; courts recognize the expectation of privacy in varying
degrees, and afford persons with a diminished expectation of
privacy a diminished degree of protection under the Fourth
Amendment.
With respect to public areas and unsecured private property,
warrantless searches are permissible under the "open fields"
doctrine because here the courts recognize only a diminished
expectation of privacy or no such expectation at all. So, for
example, in the case of Air Pollution Variance Board of Colorado
v. Western Alfalfa Corporation, a State inspector entered the
outdoor premises of the company to make a visual opacity test of
plumes of smoke emitted from chimneys. He was on the company's
property but not in an area from which the public was excluded,
and he vas observing plumes of smoke, which anyone near the plant,
could see. The court allowed the warrantless search in this
instance because the search was within the "open fields"
exception to the warrant requirement of the- Fourth Amendment.
The "open fields" doctrine is one way in which a warrantless
search of an injection well might be permissible. Another
justification for a warrantless search of an injection well might
be the "closely regulated business" exception to the Fourth
Amendment's warrant requirement. The United States Supreme Court
is allowing more and more warrantless searches on the commercial
premises of closely regulated businesses (for example, the liquor
industry, firearm dealers, stone quarry mining, automobile
salvage yards, etc.) on the rationale that by choosing to engage-
in these businesses and accept a federal license the businessman
gives up some of his expectation of privacy. This has never been
used in the context of oil and gas regulation or environmental
regulation, but the Supreme Court.has shown a tendency to find
one exception after another to the Fourth Amendment's protections
in the last few years.
The bottom line for UIC inspectors is that if an injection
facility is unmanned and unsecured, the inspector can go onto the
lease without a search warrant. If the operator's employee is
there telling the inspector that he doesn't consent to the
inspection, the inspector should leave immediately and return
with a warrant. The same principle applies to unmanned secure
facilities with fences and locks; it's preferable to get a
warrant than to jump fences, break locks, etc.
5
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SECTION 10
FIELD SAFETY
This section contains material associated with general field
safety. Particular topics discussed include:
Personal Protective Equipment
other General considerations for Personal Safety
Drilling and Workover Safety
Safety During Routine Inspections
Safety During Mechanical Integrity Testing
Sampling
Initial Hazard Assessment
Levels of Personal Protection
Decontamination
10-1
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DISCUSSION Much of the material presented on inspector field
safety may be found in Section 5 of the UIC
Inspection Manual.
First of all, we can reduce the potential for
accidents through education. The 40-hour
Occupational Health and Safety course is
a comprehensive safety training program.
How many have taken that training course? NOTE:
Get a show of hands.
Those that have taken the OSHA course know that it
covers items such as the handling of hazardous
wastes, air monitoring and instrumentation,
personal protective equipment, principles of
decontamination and safety, and site planning
and organization.
This discussion will deal in part with some of the
subjects covered in that course, which may be
useful to UIC inspectors.
A couple basic points need to be made:
The dangers encountered by UIC inspectors are
few.
Increased awareness is achieved through
experience.
Good safety habits can be developed to reduce
on-site risks.
10-2
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PERSONAL PROTECTIVE EQUIPMENT
The use of personal protective equipment is often
a choice.
Hard hats and steel toed boots are a requirement
for Class II inspections. Boots should be worn:
during any inspection. The national standards for
each are quoted in the UIC Inspection Manual.
It is easy to disregard these requirements and not
wear them unless specifically required by
operator. Safety begins with the development of
good habits.
READ Let's read part of Section 5:1 of the UIC
Inspection Manual. We'll start at the top of page
5-2 and read the section, entitled "General
Protective Equipment."
REFER CLASS Eye protection is not typically required during
TO PAGE 5-3
inspections of Class II or Class V facilities.
Brines encountered at production facilities are
not apt to cause vision damage except in unlikely
situations.
Most Class I operators require eye protection and
a hard hat upon entering the facility.
10-3
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It may be desirable to utilize eye protection
while conducting certain Class V activities, most
specifically during sampling efforts.
Host Class V inspection situations require very
little personal protective equipment.
Class V sampling situations, on the other hand,
may require the most personal protection of all
inspection situations.
Hazard assessment may necessitate the need for all
of the previously mentioned equipment in addition
to:
Gloves;
Chemical resistant suit; and
Breathing apparatus.
READ Let's read Section 5:3 of the UIC Inspection
SECTION
5:3 Manual. This section may be found on pages 5-4
and 5-5.
OTHER GENERAL CONSIDERATIONS FOR PERSONAL SAFETY
The UIC inspector will encounter different types
of hazards depending on the type of inspection
being conducted.
10-4
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SLIDE #10-1 We will look at the hazards involved with the
following inspection activities and provide safety
tips for each:
- Drilling and workover operations;
Routine inspections;
Mechanical integrity testing; and
Sampling.
We will be reviewing Section 5:6 of the UIC
Inspection Manual, starting on page 5-6.
DRILLING AND WORKOVER SAFETY
The inspector's greatest potential for exposure to
accidents is during workover operations. Equipment
is generally under pressure and heavy tools are
used during workover operations. Safety is often
sacrificed for the sake of speed.
SLIDE #10-2 The following rules should be applied when
involved with workover operations:
Always park outside guidewires.
Always wear steel toed shoes/boots and hard
hat.
Evaluate dangers upon arrival. Identify the
specific operation and potential hazards.
Know what's occurring overhead. It is very
important to be aware of what is happening
overhead. Activity overhead may be the most
life threatening of all situations.
Being attentive at the site is a necessity.
Be aware of what others are doing around you.
Do not smoke.
10-5
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SLIDE #10-3 Occasionally, inspectors are asked to witness well
AMD #10-4
construction during drilling operations. Follow
the sane rules as previously mentioned when ap-
proaching the drilling operation:
Know the hazards;
Wear hard hat and boots; and
Do not smoke.
Now, let's look at Section 5:7 on page 5-7
SAFETY DURING ROUTINE INSPECTIONS
The following considerations apply to safety
during routine inspections.
Be careful about entering enclosed facilities.
Accumulation of H2S, if present in high, concentra-
tions, can be lethal. Most facilities are well
marked by warning signs. The ventilation of the
facility is also an important factor to consider
upon entry.
SLIDE #10-5 Casing heads with bull plugs in each port should
not be tampered with. This constitutes an auto-
matic inspection alert and should be considered a
failure. Any tampering under these circumstances
should not be suggested or condoned by the inspec-
tors present.
10-6
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When performing inspections, "shabby" equipment is
often encountered. Gauges and valves may have
weakened threads resulting from corrosion.
Tampering without absolute isolation is not
advised. Faulty valves may not isolate the gauge
for safe removal. Treat every valve encountered
as if it does not properly contain pressure. A
threaded fitting which requires a lot of force to
turn may be a tale-tell sign that it is under
pressure. Once the connection has been broken,
wiggle the fitting in an attempt to bleed pressure
off of it.
Exercise caution in opening and closing valves.
It is not a good idea to open or close a valve
suddenly. Pressure surges could induce failure in
old equipment. Inspection reports require the
inspector to record tubing/casing annulus
pressure. This is often accomplished by opening
the casing valve to verify that no pressure
exists.
Difficulty in opening a valve may indicate the
existence of substantial pressure.
Breaking connections which are difficult to break
can result in injury if carelessly handled.
Always position a wrench in a position to push
down instead of pulling up with the back.
10-7
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SAFETY DURING MECHANICAL INTEGRITY TESTING
Safety during pressure tests can be accomplished
by following a few basic rules:
Think before you act.
If there is any uncertainty, communicate with
co-workers.
Make an attempt to be aware of the position
and action of co-workers.
People do boneheaded things. The most competent
of individuals can make mistakes.
SLIDE #10-6 Chicsem lines are often used on trucks to
pressurize.
Never strike any portion of a line that is under
pressure. If a leak is detected during a test,
bleed pressure back to zero and make the
adjustments; then repressurize, following the same
procedure for leaking fittings.
One needs to acguire a respect for pressure. A
couple of hundred pounds of pressure can be lethal
in the wrong circumstance.
As the story goes, an inspector pulled up to an
injection well to perform a routine inspection.
Arriving with the pumper, he pulled to the side of
the well and began organizing his paperwork. In
the mean time, the pumper had begun to remove the
10-8
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bull plug from a wellhead with plugs on both ports
of the wellhead. One turn with a 24" pipe wrench
sent the plug like a projectile around 80 yards
into the field. The 24" wrench landed about 10
yards away.
This illustrates a few of the points which we are
attempting to make, particularly to be aware of
the actions of others and to respect pressure.
The story also illustrates the importance of safe
practices with regard to vehicle location. Each
location has anchors at four points around the
wellhead. Prudent inspectors will practice
parking outside of these anchors. Some degree of
thought, in any case, should be given to the
vehicle location.
SAMPLING (FROM RCRA MANUAL)
Hazardous waste sampling is not a common practice
for UIC inspectors; however, exposure to
potentially harmful constituents can occur during
sampling or inspections of Class I and Class V
facilities.
The purpose of the following information is to
provide some insight into the manner by which
harmful substances may enter the human body.
10-9
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SLIDE #10-7 The four basic routes of entry include:
Inhalation;
Skin absorption;
Ingestion; and
Eye contact.
Inhalation - breathing a gas, vapor, mist or dust.
This route of entry is the most common accidental
form of exposure and is most likely to cause
systematic illness. The inhalation hazards depend
on a number of factors, such as:
Chance that the chemical will leak into the
air;
The concentration present;
The volatility at ambient;
Length of exposure; and
Physical properties such as particle size of
the mist, fumes, or dust.
The body may be affected in two distinct ways:
Effects on the lining of the air passages;
and
Absorption from lungs into the blood stream.
The following precautions can be taken. First,
the Self-Contained Breathing Apparatus (SCBA) or
appropriate respirator should be used. Respirator
selection should be based on assessment of the
hazard. Secondly, avoid prolonged time periods in
poorly ventilated areas.
10 - 10
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Skin absorption - Skin exposure can result in skin
irritation. Certain chemicals have the capacity
to penetrate unbroken skin, and enter the blood
stream.
Although no clothing is absolutely impermeable to
chemical penetration, certain clothing types
provide adequate protection and should be selected
based on the assessment of the particular
situation.
The following precautions should be taken when
inspecting sites which may contain materials
which are hazardous by skin contact:
Assure that all skin areas which may be
contacted are protected during site work.
When taking samples, wipe all the residue off
of containers after filling with sample.
After completing the inspection, use proper
procedures for removing contaminated clothing
while still on site.
Gloves, rags, and other disposable items
should be bagged for proper disposal.
Ingestion - Toxic amounts of hazardous waste may
be carried to the mouth by hand when drinking,
eating, or smoking. These activities must never
occur during or immediately following inspections
until decontamination procedures have been
completed. Decontamination procedures will be
discussed later in this section.
10 - 11
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Eye contact - The eyes can be harmed by chemicals
in solid, liquid, or vapor form.
The following precautions should be taken to avoid
eye injury:
- Wear safety glasses or face shield.
Avoid rubbing eyes during inspection or
sampling activities.
Do not wear contact lenses in areas where
hazardous materials may be encountered.
INITIAL HAZARD ASSESSMENT
In order to determine whether to enter a
potentially hazardous field site and to determine
the appropriate level of protection, the nature
and extent of the hazard must be assessed. A
site-specific health and safety plan should be
developed based on the assessment. In developing
the health and safety plan, the following steps
must be taken:
Review all evidence of potential
contaminants. A check list of potential
contaminants may be found on page 15 of
"Standard Operating Procedures for Injectate
and Sediment Sampling at Class V facilities."
This document is located in the Class V
Addendum. Material Safety Data Sheets (MSDS)
and other information collected during in-
depth facility inspections can be used to
identify potential contaminants on the list.
Review all available toxicological informa-
tion regarding types of hazardous materials
handled.
10 - 12
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Choose protective clothing according to the
types and levels of waste material handled at
the facility, potential for exposure to
substances in air, splashes of liquids, and
other direct contact.
LEVELS OF PERSONAL PROTECTION
SLIDE #10-8 Level A is the highest level of skin and respira-
tory protection. Level A protection is character-
ized by:
Supplied air respirator;
Totally encapsulated suit;
Gloves; and
Boots and boot covers.
SLIDE #10-9 Level B provides only the highest respiratory
protection level. This level can be used when
exposure to unprotected areas of skin is
unlikely. Level B protection is characterized by:
Supplied air respirator; and
Chemical resistant clothing, such as
- Splash suit;
- Gloves (inner and outer);
- Boot;
- Boot covers; and
- Hard hat.
If conditions require Levels A or B, delegate
entry to the facility to a trained emergency
response team.
10 - 13
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The level of respiratory protection can be
selected as a function of the percentage of
oxygen (19.5%) present in the working atmosphere,
threshold limit values (TLV), levels, immediately
dangerous to life or health (IDLH), and
Permissible Exposure Levels.
SLIDE #10-10 Level C can be used when respiratory protection
can be afforded by air purifying respirators and
exposure to unprotected areas of the skin is
unlikely. Level C protection is characterized by:
Air purifying respirator; and
Chemical resistant clothing, such as
- Splash suit;
- Gloves (inner and outer);
Boots;
- Boot covers; and
Hard hat.
SLIDE #10-11 Level D can be used when no respiratory protection
is necessary and there is little or no possibility
of contact with the contaminants. Level D
protection is characterized by:
Splash suit;
Gloves;
Boots;
Safety glasses; and
Hard hat.
10 - 14
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DECONTAMINATION
Decontamination is defined as the process of
removing or neutralizing contaminants that have
accumulated on personnel and/or equipment.
To ensure personal safety, the inspector should
verify that a decontamination plan has been
developed and set up before any activities are
performed, regardless of the simplicity of the
site.
SLIDE #10-12 The decontamination plan should:
Determine the location of decontamination
stations;
Determine the decontamination equipment need-
ed;
Determine appropriate decontamination methods;
and
Establish methods of disposing of equipment
and clothing, if necessary.
Many factors affect the selection of a
decontamination method. From a health and safety
standpoint, two key questions must be addressed:
Is the decontamination method effective for
the specific substances present?
Does the method itself pose any health and
safety hazards?
10 - 15
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Decontamination methods may:
Be incompatible with the hazardous substances
being removed;
Be incompatible with the clothing or equip-
ment being decontaminated; and
Pose a direct health hazard.
The chemical and physical compatibility of the
decontamination solutions or other decontamination
materials must be determined before they are used.
Any method that permeates, degrades, damages or
otherwise impairs the safe functioning of the
Personal Protective Equipment (PPE) is
incompatible and should not be used.
An effective decontamination method is desirable
not only for the sake of safety, but serves as a
method of quality control for the samples taken.
Quality control measures and decontamination
methods will be covered in the sampling
presentation which will be given later in the
course.
10 - 16
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IMECH. INTEGRITY TESTING
-------
8ECTI0N 11
MECHANICAL INTEGRITY TESTING
This section contains material associated with mechanical
integrity testing. Particular topics discussed include:
Well Construction Types
Newly Constructed Wells
Mechanical Integrity Test Methods
11-1
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DISCUSSION Mechanical integrity testing can be a simple
process if the inspector is aware of all potential
problems that can appear during a test. Before an
inspector travels to conduct an MIT, they must
first prepare for the test.
The inspector will need to be aware of how the
well is constructed. The well construction can
often dictate the type of testing procedure that
is going to be used on the well. Each EPA Region
determines the type of MIT which is acceptable for
a particular well construction type.
Once the well construction is known and the type
of test method is determined, the inspector should
prepare himself/herself for any problems that can
occur while the test is being conducted.
WELL CONSTRUCTION TYPES
To get started, we will be discussing some of the
types of well constructions you may see while in
the field and how each well type is tested for
mechanical integrity. We will then discuss each
test method in more detail.
An injection well should be constructed in a
manner that ensures that USDWs are protected.
11-2
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8LIDE #11-1
Let's first discuss an ideal well construction.
The first step involves boring the surface hole to
emplace the surface casing. The surface hole is
normally drilled through the lowermost USDW and
into a shale, or clay confining zone.
SLIDE #11-2
Surface casing is then run into the well and
should be cemented to the surface.
SLIDE #11-3
After letting the cement cure, drilling is
initiated again to drill to the target depth. In
this example, drilling was stopped at the top of
the injection zone.
SLIDE #11-4
After reaching the target depth, casing is run
into the well and should then be cemented to
surface.
SLIDE #11-5
SLIDE #11-6
In this example, the well was drilled through the
injection zone and underreamed to enlarge the hole
size. This could be done for 2 reasons:
To enlarge the surface area of the hole to
minimize problems with the clogging forma-
tion; or
To emplace a gravel pack.
In this well, a gravel pack and screen assembly
were installed.
SLIDE #11-7
Tubing and packer can then be run in the hole for
injection purposes.
11-3
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This slide illustrates a conventionally completed
well which contains casing, tubing, and packer.
As you know, not all wells are completed this way
or contain this much cement.
Many injection wells in this country are completed
in unconventional manners. These unconventional
completion types include:
Packerless;
Slimhole;
Tubingless;
- Sometimes called "casing injectors"
Dual; and
Annular disposal.
SLIDE #11-10 A packerless completion contains an injection
tubing string in a long string of casing, but does
not contain an injection packer. Packerless
completions are, sometimes implemented for Class I
hazardous disposal wells due to the extremely high
cost associated with the special packers and/or
seal bore assemblies required for these systems.
Injection wells with packerless completions often
require standard annular pressure tests to
initially demonstrate mechanical integrity.
Routine monitoring is subsequently required to
ensure that mechanical integrity is maintained.
SLIDE #11-8
SLIDE #11-9
11-4
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The Ada pressure test, a variation of the standard
pressure test, is also used to demonstrate
mechanical integrity on packerless wells. The
radioactive tracer survey may also be used for
mechanical integrity demonstration.
SLIDE #11-11 Slimhole completions are commonly referred to as
those completions which contain only a small
tubular string which is cemented to the surface.
Wells constructed in this manner generally pose a
more serious threat than conventional completions
due to the fact that the only tubular string in
the well acts as the injection conduit. The
tubing and the primary cement are the only
barriers acting to prevent fluid movement into
USDWs. The internal mechanical integrity of a
slimhole completion can be tested through the use
of a retrievable bridge plug. The bridge plug is
run into the well and set above the injection
perforations. Once set, the bridge plug isolates
the tubing string so that it can be pressurized
and tested. Upon completion of the pressure test,
the bridge plug is retrieved from the well.
Radioactive tracer surveys (RTS) are accepted in
many States to demonstrate internal mechanical
integrity in slimhole completions. The test is
11-5
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considered successful if results show that all
injection fluid is exiting the well through the
injection perforations.
The Water-in-Annulus test is approved for use as a
MI test in certain areas of EPA Regions II and
III.
SLIDE #1112 Tubingless completions do not contain an inner
tubing string for injection; they inject directly
through casing set to or through the injection
zone. Tubingless completions may or may not
contain surface casing; therefore, the number of
USDW protective barriers can very. Injection
wells of this construction type can be tested
similarly to slimhole completions. A retrievable
bridge plug can be run on wireline and set above
the perforations. The bridge plug can then be
removed after testing. Another method commonly
used to test the integrity of tubingless
completions entails the temporary use of a work
string and packer. The work string and packer are
run into the well, the packer is set, and the
standard annular pressure test is performed.
The radioactive tracer survey can also be used
to demonstrate MI.
11-6
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The Water-in-Annulus Test is approved for use in
specific cases in areas of EPA Regions II and III.
SLIDE #11-13 A dual completion is a single well that produces
and/or injects from/into two separate formations
at the same time. Each zone is segregated by
running either: (1) two tubing strings with
packers inside the single string of production
casing; or (2) one tubing string with a packer run
through one zone while the other is produced or
injected through the annulus. Wells which dispose
of fluids below the production interval are
generally tested for mechanical integrity by
resetting the packer above the production zone
perforations and performing the standard annular
pressure test.
A dual completion test is approved by EPA for use
on dual completion wells in the States of Montana,
Wyoming, Kansas, Nebraska, Michigan, and the Osage
Mineral Reserve.
The Ada pressure test and RTS are also used on
dual completion wells.
SLIDE #11-14 Annular disposal wells are those wells which
AND #11-15
inject fluids through any annulus of an injection
or production well. Many of these wells inject
between the surface casing and the long string
casing.
11-7
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Because the annulus is perforated, it is not
possible to use the standard annular pressure test
on these wells.
The State of Ohio has developed two procedures for
testing annular disposal wells. Both methods are
based on the Ada pressure test principle of
monitoring fluid levels in the annulus.
NEWLY CONSTRUCTED WELLS
In some cases, inspectors will be asked to verify
the construction of new injection wells. This
includes being on site while wells are being cased
and cemented; therefore, inspectors should be
familiar with the cementing practices involved.
READ In Section 4:17 of the UIC Inspection Manual (page
CHECKLIST
4-18) there is a section on witnessing a primary
cementing job. Section 4:18 includes a checklist
that can be used to verify the cementing job.
SLIDE #11-16 Mechanical Integrity Testing
Mechanical Integrity Testing is covered in
Section 4:23, which begins on page 4-23 of the
Inspection Manual. Follow along as I read the
first paragraph.
11-8
-------
READ FIRST
PARAGRAPH
SLIDE: #11-17 MIT requirements must meet 2 criteria:
There must be no significant leaks in the-
casing, tubing, or packer (internal MI); and
There must be no significant fluid movement
into a USDW through vertical channels adja-
cent to the well bore (external MI).
READ
SECTION 4:45
Please follow along as I read Section 4:25 on
"Internal Mechanical Integrity."
SLIDE #11-18
There are several things that need to be
considered when deciding which mechanical
integrity test to use on a given well. They are:
Type of Completion;
Depth of Well;
Injection Interval;
Inside Diameter of Casing and Tubing;
Pipe Wall Thickness; and
Type of Packer.
SLIDE #11-19
INTERNAL MECHANICAL INTEGRITY TEST METHODS
There are several tests available for use, in
demonstrating internal MI. These tests include:
Standard Annular Pressure Test;
Water-in-Annulus Test;
Annular Pressure Monitoring;
Injection Rate vs. Injection Pressure
Monitoring ?
Dual Completion Test;
11-9
-------
Ada Pressure Test; and
Radioactive Tracer Survey.
We'll now talk about each test method separately.
Standard Annular Pressure Test
The standard annular pressure test is the. most
widely used method to determine internal
mechanical integrity.
The test requirements vary for each EPA Region and
Primacy State. In Regions 4 and 5, the test
usually requires that a pressure of 300 psi be
held for 30 minutes, with 3% change in pressure
allowed.
When conducting the test, it is important to make
sure that there is at least a 100 psi differential
between the injection tubing pressure and the
annulus pressure. This is needed to ensure that
the test pressure is greater than the formation
pressure at all depths.
SLIDE #11-20 On page 4-27 of the Inspection Manual, there is an
AMD #11-21
equation which can be used to make sure that the
test pressure is greater than the hydrostatic head
in the tubing at all depths.
After you determine the pressure required for the
test, you need to consider the type of packer in
the well.
11 - 10
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Next, you need to make sure the annulus is full of
fluid. The operator needs to be informed to fill
the annulus a day or two ahead to ensure that all
the air that got trapped in the fluid has worked
its way out. In addition, the fluid will expand
as it is heated by the formation.
After you have filled the annulus, you can then
pressure it up.
In. the field, pressurizing the annulus can be
achieved through different methods. The use of a
pump truck or hot oiler is common. When this
equipment is used, the water used to fill the
backside (annulus) is fresh water, and it is
pumped through a hose connected to the water tank
on the truck. Some trucks are equipped with
continuous pressure reading charts, which can then
become a permanent record of the test. The
advantages of using this equipment are that: (1)
the fluid used for the test is non-contaminating;
and (2) if a strip chart recording of the pressure
is taken, it supports and validates non-witnessed
tests. The disadvantages of using a pump truck
are that: (1) it is expensive to rent the
equipment; and (2) weather conditions prohibit
moving the equipment onto a location more often
than other pressuring methods. An average truck
11 - 11
-------
will rent for around $75/hour, with, an 8-hour
minimum charge. The size and weight of the
equipment make it difficult to move on muddy
roads, through snow drifts, across flooded areas,
etc.
Another common method of pressurizing the backside
is achieved through use of the injection line
connected to the tubing. A jumper hose is run
from the injection line to the annulus, and the
valves are shut-off when the test pressure is
reached. The advantages of pressuring with a
jumper hose are that: (l) it requires only an
inexpensive hose and valves; and (2) the pumper
can hook up unassisted, which reduces labor costs
to the operator. The possible disadvantages are
that: (1) on wells injecting at low pressure, the
injection line may not provide sufficient testing
pressure; and (2) the fluid used for the test is
the injection fluid.
Weather delays are infrequent when pressurizing
with a jumper hose. Inspectors have tested wells
after wading through hip-deep mud and water, after
climbing up steep hills which are inaccessible to
equipment, and after riding on three-wheeled all-
terrain vehicles to get to locations where the
roads have long since been overgrown.
11 - 12
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A third method used for pressuring up the backside
is through the use of a hand pump. When using the
hand pump, the casing is usually filled from the
injection line first. The hand pump is connected
with a hose to a 5-gallon bucket on one end and
the casing valve on the other end. The pump is
used to apply pressure to the casing, and then the
valve is shut-in for the test. A hand pump is
often used on wells in which the injection
pressure is too low to achieve testing pressure.
This pressurization method may also be used on
wells where there is concern regarding the use of
injection fluids for the test (e.g., an external
fluid source is used).
Look for signs of surface leakage at the wellhead.
If there is air in the top of the wellhead, it
might leak. The leak may stop when the fluid
reaches it.
After pressuring up, allow the well to settle for
about 5 minutes. This allows the pressure exerted
by the fluid to stabilize. Record the time and
pressure at the start of the test. If a well is
going to fail the standard annular pressure test,
it will generally fail during the first 5 minutes
of the test.
11 - 13
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SLIDE #11-22 These two slides illustrate the types of forms the
AND #11-23
Regions use to record test data.
An example test procedure would include recording
the pressure about every 5 minutes during the
beginning of the test, then about every 10 minutes
thereafter. After 30 minutes, a final pressure
reading should be taken. If the well did not lose
or gain 3% of the initial test pressure, it
passed.
Many times the well will be on the borderline of
pass/fail. This requires the inspector to make a
judgment call. For instance, if there is a small
leak in the casing head (around the tubing), many
times the inspector can give the benefit of the
doubt and pass the well.
After the test, have the operator bleed the
pressurized fluid from the well and into a bucket.
Depending on the depth of the packer, the fluid
return for a 3,000 ft well should be 2 or 3
gallons. This helps determine approximately how
deep the packer is set.
Tests can be run either while the well is
injecting or shut-in you just need to be sure
that there is a pressure differential between the
annulus and the tubing.
11 - 14
-------
This series of slides demonstrates the steps
involved in conducting a standard annular pressure
test.
SLIDE #11-24 When the inspector arrives at the well site, he or
she needs to fill out the Notice-of-Inspection
form.
SLIDE #11-25 After you have filled out the Notice-of-Inspection
form, have the operator read the form, both front
and back, and sign the form, acknowledging that
he/she knew you were on site conducting the MIT.
SLIDE #11-2 6 After you have completed that paperwork, have the
operator hook the pump truck up to the annulus.
It is a good idea to have the hammer union nearest
the well tightened with a pipe wrench. Then you
can disconnect the pipe after pressurizing the
well without hurting your gauge.
SLIDE #11-27 Have the pump truck operator fill the annulus with
water slowly until it runs out the other side of
the wellhead. Then attach your gauge. This allows
for little air to be trapped in the wellhead.
11 - 15
-------
SLIDE #11-28 This slide illustrates the packing around the
tubing being tightened. Many times when you first
pressurize the well, it will leak around the
tubing. This will often seal the leak. Make sure
your gauge is not on the well when it is being
hammered tight.
SLIDE #11-29 After getting everything tight, install your gauge
on the wellhead. Then pressurize the annulus.
SLIDE #11-30
The pressure test usually lasts 3 0 minutes. Try
to take readings every 10 minutes. In this
picture, you can see how well someone planned
where to drill. The large rock to the right of
the well was only part of a much larger buried
rock.
SLIDE #11-31
SLIDE #11-32
After the test, bleed the fluid back into a 5-
gallon bucket. This will help you determine the
approximate depth of the packer. Be careful to
avoid splashing water on yourself.
This shows the amount of fluid returned from this
well. 5 1/2" casing, 2 7/8" tubing, approximately
2500' deep will give you 2 1/2 to 3 gallons of
fluid return.
SLIDE #11-33
After the test, fill in the rest of the MIT form,
have the operator sign it, and give the operator
his copy of the form.
11 - 16
-------
Water-in-Annulus Test
Another type of internal mechanical integrity test
is the Water-in-Annulus test, discussed on page 4-
49 o£ the Inspection Manual.
The Water-in-Annulus test is being conducted with
approval (final approval granted 6/12/89) from EPA
Headquarters for use in the Bradford area
encompassing portions of New York and
Pennsylvania. The procedure was originally
conceived of and designed to accommodate the well
constructions in the Appalachians which precluded
the use of long string casing. After a study of
the geological formations exposed in the uncased
portion of the hole (Dewan, 1979), the test was
conditionally approved to be run as follows:
1. Shut-in the well and bleed off the tubing
pressure.
2. Fill the annulus to the surface with water.
3. Wait 1 hour.
4. Measure the drop in the fluid level.
5. Resume injection into the well and allow
pressure stabilization (usually a few
minutes).
6. Re-fill the annulus to the surface with
water, as necessary.
7. Wait 1 hour.
8. Measure the drop in the fluid level.
11 - 17
-------
A well is considered to have demonstrated
mechanical integrity if the fluid level falls no
more than 10 feet during the test, and if the rate
of falling is the same during both portions of the
test. If a well does not pass, it is classified
as an inconclusive test, unless the water level
rises during the injection portions of the test
(obvious tubing and/or packer leak).
When conducting the WIA test, you need to
make sure that the annulus is filled with
water. If the conductor pipe annulus is
filled, there is no way to detect a leak.
Make sure that pressure is bled off for the
first part of the test.
Annular Pressure Monitoring
Another type of internal mechanical integrity test
used by operators is annular pressure monitoring
(APM) . APM can be considered a continuous
pressure test of the casing/tubing annulus in
wells using a pressurized annulus. Not all wells
using APM have a pressurized annulus. The
practice involves the continuous monitoring of the
pressure within the closed tubing/casing annulus
of an injection well in an attempt to continuously
confirm the well's internal mechanical integrity.
Class I hazardous waste injection wells are
required to continuously monitor annular pressure.
Such monitoring requires very sophisticated
11 - 18
-------
(usually computer controlled) indicators, records,
control valves, and alarms.
Annular pressure monitoring, when utilized on
Class II injection wells, is not as sophisticated
at it is when utilized on Class I wells. For
Class II wells, the annular pressure is rarely
monitored continuously with chart recorders;
rather, manual readings of the annular pressure
are taken daily, weekly, or monthly. Requirements
for Class I wells mandate that a positive pressure
differential exist between the annular fluid and
injection fluid over the entire length of the
tubing. However, annular pressure requirements
for Class II wells vary among States. Some States
require significant pressure while others have no
pressure requirements at all (allow an annular
pressure of zero).
When inspecting wells in a field that use
annular pressure monitoring, the annulus
pressure needs to be recorded for each well
visited.
The inspector should look for evidence of
surface flow.
Most operators in Michigan and Indiana which
use APM do not maintain a pressurized
annulus.
11 - 19
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Injection Pressure vs. Injection Rate Monitoring
Another type of monitoring allowed for mechanical
integrity testing is Injection Pressure vs.
Injection Rate (IPIR) Monitoring.
This monitoring method consists of an evaluation
of monitoring records showing the absence of
significant changes in the relationship between
injection pressure and injection flow rate for the
following types of Class II enhanced recovery
wells:
Existing wells completed without a packer
provided that a pressure test has been
performed; and
Existing wells constructed without long
string casing, but with surface casing which
terminates at the base of the fresh water.
Injection pressure/injection rate monitoring is
based on the fact that, while injecting, the ratio
of injection pressure to injection rate remains
somewhat constant over short periods of time
(months). Any significant variations in either
rate or pressure can be interpreted as abnormal,
and may indicate a potential failure in mechanical
integrity.
11 - 20
-------
The reliability of injection pressure/injection
rate monitoring, like the annular pressure
monitoring method, depends upon the normal
injection pressure fluctuations of the well. if
significant fluctuations are common, mechanical
integrity failures may not be detected.
When inspecting wells that use IPIR, it is
critical to obtain pressure and rate readings
over a period of time.
Most wells using IPIR monitoring are required
to have chart recorders installed on each
well. Inspectors should check these chart
recorders to look for any discrepancies.
SLIDE #11-34 Dual Completion Test
This test is also called the liquid level
monitoring test. The wells are completed with two
strings of tubing, with a packer run on the long
string to isolate the well bore. In these wells,
injection occurs through the long string of
tubing, while oil is produced through the short
string.
The proposed MIT consists of monitoring the fluid
level open to the production interval to ensure
that the level is always below the base of USDWs.
Fluid levels would be taken of the producing
interval both during operating and static
conditions. Fluid levels would then be measured
on a regular basis to ensure that the fluid level
showed no significant variances. Should a leak
11 - 21
-------
occur in the injection tubing, it would be
identified immediately through the corresponding
rise in the producing fluid level. The major
safeguard to this method, though, is that if a
tubing leak were to occur in the injection string,
then the oil production would "water out"
immediately. The operator would notice the drop
in oil production and the corresponding rise in
water production within 24 hours. During this 24-
hour period, the fluid level in the producing
interval probably would not approach the base of
the USDWs, since the pump would be drawing down
the head to some extent.
When inspecting these wells, inspectors
should contact the operator in the field and
have him accompany the inspector to shoot
fluid levels on the wells.
The inspector should also look at the
production records of wells using this
method. This can identify problem wells.
Pressure tests are required on these wells at
each workover.
11 - 22
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Ada Pressure Test
The Ada pressure test, or nitrogen test, was
developed to provide a means of determining
mechanical integrity in wells with open
perforations above the packer. Well constructions
which might use this testing method include:
Dual completion wells without a packer above
the top perforations; and
Wells with a cemented annulus.
READ
SLIDE #11-35 Ada Pressure Test Requirements
SLIDE #11-35 Ada Pressure Test Procedures
SLIDE #11-36 Ada Pressure Test Results
Radioactive Tracer Survey
The radioactive tracer survey gained final
approval for use in mechanical integrity testing
on September 18, 1987.
It is approved for use in determining leaks in
tubing and packer, and is approved to determine
lack of fluid movement through vertical channels
adjacent to the wellbore above the injection zone.
Radioactive tracer surveys will be discussed in
the cased hole logging section which will be
presented later.
11 - 23
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As you can see, there are many things to consider
when conducting mechanical integrity tests.
The construction of the well needs to be checked.
The well construction dictates the type of test
being administered.
Once an inspector knows the type of well
construction and the test method to use, he/she
can gather the information necessary to prepare
for the test. It is to the inspector's advantage
to prepare for the test and consider any potential
problems that could arise during the testing
procedure.
SLIDE #11-38 EXTERNAL MECHANICAL INTEGRITY TEST METHODS
Once you have determined the internal mechanical
integrity of the casing, tubing, and packer, the
external MI must also be determined. The methods
available to demonstrate external MI are:
Cement records;
Noise log;
Temperature log;
Radioactive Tracer Survey (conditional); and
Oxygen Activation Log (interim approval).
As field inspectors, you will be called upon to
witness logging operations performed on injection
wells. Well logging will be discussed in a
subsequent section.
11 - 24
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CASED HOLE LOGGING
-------
SECTION 12
CASED HOLE LOGGING
Presentation of this section will be made through individual
discussion of each slide contained within the section. The
slides represent a general outline of the subject matter.
Discussion should be promoted to encompass any points not covered
on the slides.
This section includes discussion of the following subjects:
Wireline Logging of Injection Wells
Well Logging Methods and Their Uses
The tests previously discussed satisfy the requirements of
Part I of the definition of mechanical integrity (i.e., no leaks
in the tubing, casing or packer).
Determination of Part II of MI is achieved through the use
of wireline logs.
12-1
-------
SLIDE #12-1 WIRELINE LOGGING OF INJECTION WELLS
SLIDE #12-2 Injection Well Logging Necessary To:
Determine lithology (open hole logs)
Define effective injection interval
Demonstrate mechanical integrity (MI)
Internal (casing, tubing, packer leaks)
- External (flow behind casing)
Most logging witnessed by inspectors
conducted for mechanical integrity
testing
SLIDE #12-3 Primary Components of a Logging System (Guyod and
Shane, 1969):
Downhole sensor (tool)
Wireline cable
Powered winch
Calibrated sheave
- Line measurement
- Weight indicator
Prime power unit
Surface control and recording systems
SLIDE #12-4 Mechanical Surface Equipment Required for Logging:
Wireline truck
Bottom sheave
Top sheave
Mast
Lubricator (for pressure control)
12-2
-------
SLIDE #12-5
Basic Inspector Responsibilities When Witnessing
Logging Operation:
Be familiar with procedure and well before
arriving on location
Ensure that procedure is followed to the
extent possible
- Defer all but the most elementary interpret-
ation until back in the office
Obtain expert opinion when necessary
SLIDE #12-6
SLIDE #12-7
WELL LOGGING METHODS AMD THEIR USES
MIT Logging Can Determine:
Presence or absence of casing leaks
Quality of cement bonding
Channeling of fluids behind casing
Rate and direction of fluid flow
Casing condition
Tubing integrity
SLIDE #12-8
SLIDE #12-9
Temperature Surveys
Temperature Survey Purpose:
Locate cement tops after primary cementing
Fluid migration determination
- Casing shoe behind pipe
- Tubing, casing, packer leaks
Flow (volumetric) profiling (rare)
Identification of intervals producing gas
(expanding gas = cooling)
12-3
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SLIDE #12-10 Temperature Survey Operation Principle:
Downhole temperature governed by geothermal
gradient
Injection of fluid with large temperature
difference
Zones (or leaks) that take injected fluids
will return to natural temperature at a
slower rate
8LIDE #12-11
Temperature Survey Procedure:
Let well stand idle at least 24 hours
Run base log to determine geothermal gradient
Ensure injection fluid temperature is signif-
icantly different than bottom-hole tempera-
ture
Start injection, and log hole while injecting
(optional)
Shut in after predetermined volume is
injected
Log hole at 0, 1, 2, and 4 hours after shut
in
SLIDE #12-12 Radioactive Tracer Surveys (RTS)
SLIDE #12-13
Radioactive Tracer Survey Purpose:
Flow (volumetric) profiling
Fluid migration determination
- Casing shoe behind pipe
- Casing, tubing, packer leaks
12-4
-------
SLIDE #12-14 RTS Principle Of Operation:
Use radioactive iodine (1/2 life = 8 days)
Eject tracer at surface or downhole
Follow tracer as it travels downhole
Use gamma ray tool as detector
Migration of tracer into other than injection
zone is detected through tubing and/or casing
SLIDE #12-15 Factors Affecting Gamma-Ray Measurement:
Radioactive (hot) formations
Injection rate
Ejector/detector configuration
Pipe scale
SLIDE #12-16 RTS Equipment:
Radioactive material ejector (surface or down-
hole)
2 or more gamma ray detectors
Configuration of ejector/detectors varies
depending on objective
Tool diameter as small as 1 1/2 inches
Recommend with spinner tool
SLIDE #12-17 RTS Procedure:
Load tracer at surface
Run in tubing or casing
Run base log while injecting
Eject tracer at or near surface
Follow tracer to injection zone checking for
tubing or casing leaks
12-5
-------
Log vicinity of casing shoe and/or packer for
potential migration
Check flow profile with spinner
Run with casing collar locator
SLIDE #12-18 Oxygen Activation Log (OA Log)
SLIDE #12-19 Oxygen Activation Log Purpose:
To determine the presence of fluid flow
behind casing
Measures:
- Flow Direction
- Linear Flow Velocity
- Volumetric Flow Rate
- Radial distance of flow from tool
OA Log Principle of Operation:
Similar to RTS
Tracer is created within the flowing water
behind the casing
- Water behind pipe bombarded with
energetic neutrons
- Radioactive nitrogen isotope (1/2 life =
7 seconds) formed when neutrons react
with oxygen in water
Emitted gamma-rays detected by two detectors
at different distances
SLIDE #12-20
SLIDE #12-21
OA Log Limitations:
Depth of investigation (about 12 inches)
Fluid composition - must contain oxygen
Fluid velocity
12-6
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SLIDE #12-22
OA Log Equipment:
Neutron source
Neutron shield
2 gamma ray detectors above source to detect
upward migration
Tool size = 1 3/4-3 5/8 inches x 34-26 feet
Computer analysis at surface
SLIDE #12-23
OA Log Procedure:
Run log during normal injection
Calibrate OA instrument in test barrel at
surface
Run base gamma-ray log
Log at 10 foot stations (5 minutes at each)
starting below perforations (no flow
condition)
- Three 5 minute readings at each station
Repeat 10 feet up hole
SLIDE #12-24 Noise Logs
SLIDE #12-2 5 Noise Log Purpose:
To "hear" fluid flow occurring inside or out-
side the well tubulars
Behind casing channels
- Tubing and/or casing leaks
12-7
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SLIDE #12-26
Noise Log Principle of Operation:
Fluid turbulence (flow) causes noise
Different kinds of flow create different
frequencies of noise
Noise is measured at different frequency cuts
- <200 Hz
- <600 Hz
- <1000 Hz
<2000 Hz
Type of flow discerned by its typical
frequency
SLIDE #12-27 Noise Log Equipment:
Transducer that converts sound to electrical
signal
Depends on metal to metal contact (no cen-
tralizers)
Frequency separating network
Typical size = 1 3/4 inches x 3 1/2 feet
SLIDE #12-28
Factors Affecting Noise Log:
Well construction material
Surface noise (noise log not reliable at
<1000 feet)
Fluid in casing (liquid vs. gas)
Tool contact with casing
12-8
-------
SLIDE #12-29
Noise Log Procedure:
Pull tubing if necessary
Run base log while well is shut in (readings
at 20-50 foot intervals for 1-2 minutes at
each)
Start injection to initiate flow if necessary
Run noise log (readings at same points as
base logs)
Ensure tool stops moving at each station
Readings at 10 foot intervals within zones of
interest
SLIDE #12-30 Cement Bond Logs (CBL)
SLIDE #12-31
Cement Bond Log Purpose To Infer:
Quality of cement bond to casing
Quality of cement bond to formation
Presence of channel in primary cement
Top of cement
SLIDE #12-32
CBL Limitations:
Cannot find leaks
Cannot determine fluid movement
Sensitive to microannulus
Many parameters affect reading and interpret-
ation (fast formations, etc.)
Logging tools are not standardized
12-9
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CBL Principle of Operation:
Pulsed sound energy (sonic)
Travels thru casing, cement, and formations
at different velocities
Sound energy from transmitter
Received by receiver after traveling thru
casing, cement, formation
Diagram showing Tool and Principles of Operation
(CBL/VDL)
Factors Affecting Signal Amplitude (Georhart,
1982):
Magnitude of original sound pulse
Internal diameter of casing
Type of fluid in well
Thickness of casing wall
Amount of cement bonded to casing
Compressive strength of cement
Fast formations
SLIDE #12-36 CBL Equipment:
Sonic transmitter
1 or 2 receivers
Transmitter - receiver spacing = 3-7 feet
Longer spacing for VDL
Tool size = 1 1/8-3 5/8 inches x 10-22 feet
Signals received at regular intervals called
a gate
Gate can be fixed or floating depending on
interpretation needs
SLIDE #12-33
SLIDE #12-34
SLIDE #12-35
12 - 10
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SLIDE #1237
SLIDE #12-38
CBL/VDL Procedure:
Remove tubing
Ensure tool is centralized
Log at different pressures to find microannu-
lus
~ Log only in liquid-filled casing
Run with casing locator and gamma ray
This slide illustrates a:
Receiver signal
Transit time measurement
Typical cement bond log
SLIDE #12-39 Variable Density Log (VDL)
SLIDE #12-40 Cement Evaluation Tool (CET)
SLIDE #12-41
Cement Evaluation Tool Purpose:
Same as CBL/VDL, only more advanced principle
Investigate cement radially
Measure casing diameter, casing roundness,
and tool eccentering
SLIDE #12-42 CET Principle of Operation:
Ultra sonic energy makes casing resonate
Rate of dampening is measured
9 transducers allow radial investigation
SLIDE #12-43 Diagram showing Principle of Operation
12 - 11
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SLIDE #12-44
SLIDE #12-45
Factors Affecting Measurement:
Type of fluid in well
Thickness of casing wall
Amount of cement bonded to casing
Compressive strength, of cement
CET Equipment:
8 transducers in helical pattern
1 transducer measures fluid sound velocity
Tool size = 3 3/8-4 inches
SLIDE #12-46 Diagram of Tool
SLIDE #12-47 CET Procedure:
Remove tubing
Ensure tool is centralized
Log only in liquid-filled casing
Run with casing collar locator and gamma ray
SLIDE #12-48 CET Advantages:
Radial cement evaluation
Cement channel identification
Immune to microannulus
Not affected by fast formations
SLIDE #12-49 Comparison of CBL/VDL and CET Log Presentations
12 - 12
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SLIDE #12-45 General Logging Procedures:
Know planned procedure and well construction/
history prior to arrival on location
Pre-logging meeting
In. the truck
- Weight indicator
- Casing collar locator
- Depth indicator
- Logging speeds
Ask questions!
12 - 13
-------
PLUGGING AND ABANDON.
-------
SECTION 13
PLUGGING AND ABANDONMENT
Presentation of this section will be made through individual
discussion of each slide contained within the section. It should
be noted that this presentation is a synopsis of the section
presented in the handout notebook. This section has been based
on the content of the Technical Assistance Document entitled,
"Cementing for the Plugging and Abandonment of Injection Wells."
The instructor may find that a review of the cementing
guidance would be beneficial prior to presenting the section.
Call the attendees' attention to page 4-57 and Section 4:34
"Plugging and Abandonment" of the handout notebook. NOTE:
Additional information in Appendix D, G, and H.
This section includes discussion of the following subjects:
Basic Considerations
Plugging Materials
Cement Plug Placement
Plugging Job Execution
13-1
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Plugging and Abandonment
Plugging and Abandonment For Environmental
Concerns:
Prohibit movement into or between USDWs
Unplugged or improperly plugged wellbore is-
potential migration conduit
Documented cases of USDW contamination via
abandoned wells
Successful abandonment = one or more cement
plugs through selected intervals
Operational concerns, also
BASIC CONSIDERATIONS FOR PLUGGING JOB DESIGN:
Geology
Mechanical condition of well
Equipment availability and expense
Define Geology:
USDWs
Potential producing zones
Lost circulation zones
Ascertain mechanical condition of well:
Casing integrity
Cement integrity
Junk in hole
Stuck tubing
Collapsed casing
Remedial action necessary?
13-2
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SLIDE #13-6 Equipment Availability and Expense:
Workover rig
Access to location
Fishing tools
Cutting and milling tools
Service companies
Wellbore fluids
All part of plan
SLIDE #13-7 Halliburton (or similar) Book provides:
Tubular specifications
Hole and tubular capacity
Annular volumes
Cement slurry volumes
Cement setting properties
Invaluable in plugging and abandonment
SLIDE #13-8 PLUGGING MATERIALS:
Wellbore fluid system
Cement slurry
Mechanical plugs
SLIDE #13-9 Wellbore fluid system:
Clean hole
Static well condition
Uniform throughout well bore
Necessary environmental for successful cement
plug setting and placement
Stabilizing material between plugs
13-3
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SLIDE #13-10 Wellbore Fluid System Properties:
Sufficient weight
Ability to remain in place over long period
of time
Chemical and physical stability for unlimited
period of time
Recommended fluid would contain:
Water
- Clay
- Gel
Lost circulation material
SLIDE #13-11 Cement Slurry:
Compressive strength
Density
Setting time
Additives
Recommended properties:
- Sealing to prevent fluid movement
- Good bonding characteristics
- Durability
- Long life
SLIDE #13-12 Cement Mixing Procedures:
Proper mixing important
- Proper proportions
- Predictable properties
Mixing water from purest avai-lable source
(potable water recommendedclear water
suitable)
13-4
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Pretest slurry
Mixing Methods:
- Jet
- Recirculating
- Batch
- Bulk
SLIDE #13-13 CEMENT PLUG PLACEMENT
SLIDE #13-14
Plug Placement Methods:
Balance method
Cement retainer method
Two-plug method
Dump bailer method
SLIDE #13-15
Placing Multiple Plugs:
Most jobs require multiple plugs
Each plug should set before next plug is
placed (8-24 hours)
Should tag to verify
Recirculate plugging fluid (well back to
static conditions)
Repeat procedure
SLIDE #13-16
Tools and Materials to Assist in Plug Placement:
Scratchers
Centralizers
Chemical washes
Spacers to prevent contamination
13-5
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8LIDE #13-17
PLUGGING JOB EXECUTION
SLIDE #13-18 Major Plugging Activities:
Well preparation:
- Inspection of well conditions
- Removal of tubulars and equipment
- Remedial operations (fishing, milling^
cementing, etc.)
- Establishment of static equilibrium
Well plugging:
- Placing mechanical plugs
- Placing cement plugs
- Testing of cement plugs
SLIDE #13-19 Inspection of Well Conditions:
Well records/files
Size, grade, depths of tubulars
Primary cementing program
Condition of cement and tubulars
Perforations/open hole
Downhole equipment
Formation pressure
SLIDE #13-20 Removal of Well Equipment:
Requires workover rig
First step
Tubing almost always removed
Some packers not retrievable
13-6
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Cutting uncemented casing:
- Jet
- Chemical
- Mechanical
- Explosive
Pulling casing
Fishing
SLIDE #13-21 Remedial Operations:
Well cleanout
Casing repair
Plug-back operations
SLIDE #13-22 Establishment of Static Well Conditions:
Very important
Prevents cement contamination
Proper weight (well control)
Circulate at least one wellbore volume
SLIDE #13-23 Plug Types and Location:
Mechanical plugs:
- Just above injection zone
- Above unretreivable equipment
Bridge plugs
- Sand or cement on top
Cement plugs:
- Above lowermost production or injection
zone
- Through each fresh water strata
13-7
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- Across casing stubs
At the surface
SLIDE #13-24
Diagram of Well Plugging
Casing
- Well with Insufficient
SLIDE #13-25
Diagram of Well Plugging
with Removable Packer
- Cased and Cemented Well
SLIDE #13-26 Diagram of Well Plugging - Partially Cased,
Partially Cemented with Non-removable Packer
SLIDE #13-27
Placement and Setting of Cement Plugs:
Reguires careful planning
Contamination should be avoided
Most effective if:
Static eguilibrium established
Spacer fluid utilized
Surfaces of casing and borehole clean
before placement
Allow adequate time to set
SLIDE #13-28
Testing Cement Plugs:
No simple method
Wait on cement (WOC) 8-24 hours
Tagging
Testing recommended for:
Plugs critical to pressure control or
USDW protection
Questionable plugs
13-8
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SLIDE #13-29 Sample Procedure and Calculations:
See page 5-18 of "Cementing for the Plugging
and Abandonment of Injection Wells"
SLIDE #13-30 Guidelines to Ensure Cement Plug Quality (Smith,
1987) :
Circulate hole sufficiently
Ensure well in static equilibrium
Place plugs across competent formations for
maximum bonding
Precede cement with flush or spacer
Use low water ratio cement (API Class A, C,
G, or H)
Minimize contamination
Carefully calculate cement, water, and dis-
placement volumes
Place plug with care (move pipe slowly)
13-9
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CLASS V INSPECTIONS
-------
SECTION 14
INSPECTIONS OF CLASS V INJECTION WELLS
This section contains material associated with Class V
inspections. Particular topics discussed include:
Types of Inspections
Preparing for Class V Inspections
Conducting Class V Inspections
Activities Subsequent to Inspections
Class V Well Types/Inspection Tips
14-1
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DISCUSSION The Class V injection well grouping is large and
diverse. This is due to the broad definition of
Class V wells. If a well does not fit one of the
first four classes of injection wells and meets
the definition of an injection well, it is
considered a Class V well.
Class V injection wells can be divided into two
general types of wells based on construction.
"Low-tech" wells:
Have simple casing designs and wellhead
equipment; and
Inject into shallow formations by gravity
flow or low volume pumps.
In contrast, "high-tech" wells typically:
Have multiple casing strings;
Have sophisticated wellhead equipment to
control and measure pressure and volume of
injected fluid; and
Inject high volumes into deep formations.
Generally, ^Class V injection is into or above
USDWs. Certain special Class V facilities are
known to inject fluids below USDWs. Potential for
contamination to USDWs varies and is dependent
upon where injection occurs relative to USDWs,
well construction, design and operation, injectate
quality, and injection volumes.
14 - 2
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SLIDE #14-1 This is a theoretical view of various sources of
contamination and transport of contamination in
the subsurface.
SLIDE #14-2 This is a diagram showing the relationship between
an injection well and an abandoned well which, does
not flow to the surface.
SLIDE #14-3 This is a diagram showing the relationship between
an injection well and a flowing abandoned well.
According to inventory figures reported in the
1987 Report to Congress, there are approximately
170,000 Class V injection wells in the United
States, its territories, and possessions.
It must be emphasized that the reported inventory
figures are considered to be very conservative.
The inventory collection is an on-going process,
and figures are subject to change frequently and
dramatically.
SLIDE #14-4 This shows the total number of Class V wells by
State (as reported in the Report to Congress,
1987). Note that States reporting the greatest
number of wells generally are those States with
the most active inventory programs.
14-3
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SLIDE #14-5 This shows the total number of Class V wells by
Region (as reported in the Report to Congress,
1987). Note that Regions reporting the greatest
number of wells generally are those Regions, with:
the most active inventory programs.
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; and
Assessment-level.
The primary types of inspections conducted at
Class V facilities have historically included:
Reconnaissance-level inspections (basic
information gathering);
Verification-level (verify information given
in State or local permit applications);
Assessment-level (gather information
necessary to assess groundwater contamination
potential); and
Enforcement-level (gather information
necessary to prove Class IV hazardous waste
injection or Class V endangerment).
14-4
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Reconnaissance-Level Inspections
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."
Verification-Level Inspections
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 application
information prior to inspecting the facility. The
main intent of this type of inspection would then
be to verify the previously submitted information
and look for compliance with permit
specifications.
Assessment and Enforcement-Level Inspections
Both assessment and enforcement-level inspections
involve the collection, verification, or
generation of extensive information about the
Class V facilities being inspected. Assessment-
14-5
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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 when a well may present
endangerment to USDW (although hazardous waste is
not injected). Injectate sampling and analyses
may be necessary to determine the impact of such
injection practices on groundwater quality. Site
investigations at this level, and especially those
which include sampling, must be well prepared and
coordinated in advance. Sample and safety plans
must be prepared, and legal counsel may need to be
consulted.
PREPARING FOR CLASS V INSPECTIONS
The inspector should perform numerous activities
prior to conducting Class V inspections:
The inspector should review all 32 Class V
injection well types. Wells are classified
according to the injectate.
The inspector should review example facility
files to become familiar with the various
types of businesses/industries and Class V
disposal well systems. It is important to
note the types and extent of information
collected during actual inspections. The
inspector will be expected to write an
inspection summary report similar to those
included in the files.
14-6
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The inspector should review the "Guide for
Conducting Inspections of Class V Wells."
The inspector will be expected to cover all
points included in the list. This document
may be found in the pocket of the Class V
Addendum.
Prior to each facility inspection, an
inspection file should be prepared. The file
should include:
- Notice-of-Inspection form;
- Blank Inspection Summary Report form;
and
- Any other information pertinent to the
inspection (such as telephone corre-
spondence records, etc.).
The inspector should purchase necessary maps
and film.
CONDUCTING INSPECTIONS
The following lists several tips to assist the
inspector in conducting an efficient, thorough
inspection:
Immediately upon entry to a site, the
inspector should provide the facility
representative with a brief explanation of
the UIC program and the Class V program. The
inspector should inform the representative
that he/she is interested in Class V wells
which may be located on site (including waste
disposal systems, storm water drainage wells,
etc.). The inspector's EPA credentials
should be presented and the Notice-of-
Inspection form should be signed by the
facility representative.
Each point identified in the document, "Guide
for Conducting Inspections of Class V Wells"
should be answered or addressed at every
facility and recorded in the field notebook.
The inspector should request any necessary
documentation (i.e., Material Safety Data
Sheets, plumbing blueprints, etc.). The
"Guidelines and Procedures for Field Book
Use" should be reviewed by the inspector.
14-7
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Both documents are included in the pocket of
the Class V Addendum. Please pull them out
so we can'review them.
A site map should be obtained or sketched
indicating the location of all Class V
systems, fluid discharge points, plumbing,
etc. Hazardous waste storage areas, waste
oil tanks, and any other possible sources of
contamination should also be plotted on the
site map. The site map may be sketched in
the field book for convenience. The most
accurate site map will be based upon visual
observation by the inspector.
After obtaining as much verbal information as
possible, the inspector should ask the
facility representative to direct him/her to
the Class V systems and entry points to these
systems. The inspector should make note of
all drains to the system, potential
contaminants, and access points (for
sampling). The inspector also should note
where hazardous chemicals are stored in order
to be certain that no Class V wells are
susceptible to drainage and/or spills from
chemical storage areas. This information
should be sketched on the site map.
The inspector should photograph all Class V
wells, systems, and/or access points, or note
why photos were not taken. A description of
each photo should be recorded in the field
notebook with the film roll number and frame
number denoted.
Upon completion of the inspection, note any
requested information to be provided by mail
(e.g. MSDS, site blueprints) on the
Notice-of-Inspection form. Detach the pink
copy and leave it with the facility
representat ive.
Any time an inspector is unable to conduct an
inspection when scheduled (if inspections
have been scheduled), the facility must be
called as soon as possible for rescheduling,
or to confirm that the inspection has been
cancelled.
14-8
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ACTIVITIES SUBSEQUENT TO INSPECTIONS
The following activities should be performed
subsequent to inspections:
The inspector should complete the Inspection
Summary Report form immediately following
each inspection. All Inspection Summary
Report forms should be filled out in ink,
neatly printed or typed.
Field notes should be reviewed for clarity
and completeness. For each facility, the
inspector should note the number and types of
Class V wells in the field notebook.
All film should be developed, and photos
should be labeled, documented, and inserted
into appropriate plastic photo holders.
An inspection summary report (1 to 3 pages)
should be written and typed for each facility
inspected. Each report summarizes all
activities conducted during the inspection;
describes the site history, Class V systems
identified, and waste disposal practices;
describes hydrogeology (as completely as
possible using information provided); and
makes recommendations regarding follow-up
investigations.
The inspector should review each file to
ensure that the following documents are
included:
- Copy of field notes;
- completed Inspection Summary Report
form;
- Labeled photos;
- Signed Notice-of-Inspection form (2
copies);
- Typed summary report; and
- Any maps, MSDS, manifests, etc. collect-
ed during the inspection.
14-9
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CLASS V WELL TYPES/INSPECTION TIPS
Agricultural Drainage Wells (5F1)
SLIDE #14-6 Agricultural drainage wells receive irrigation
tailwaters, other field drainage, and animal yard,
feedlot, or dairy runoff. Most of these wells are
used by farmers to provide adequate drainage of
surface runoff and subsurface flow so the crop
root zone can be well aerated, allowing optimum
crop growth.
SLIDE #14-7 This slide illustrates the number of agricultural
drainage wells by State (as reported in the 1987
Report to Congress).
SLIDE #14-8 This slide presents a schematic of an agricultural
drainage well. Note that this well is injecting
direct flow from the surface and flow from the
subsurface through a perforated collection drain
pipe. The injection zone is fractured limestone
with solution channels.
Well Construction, Operation, and Siting
- Shallow well completions dominate.
Wells may be designed to receive surface
and/or subsurface drainage.
Large capacity wells drain 80 to 640
acres while small capacity wells drain
less than 80 acres. Casing diameters
range from 3 to 8 inches for small
capacity wells to 9 to 24 inches for
large capacity wells.
14 - 10
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- Large capacity wells generally have
screened or inverted inlets, settling
ponds, and surface seals. Small
capacity wells may not have these
features.
- Agricultural drainage wells inject into
or above USDWs.
- Systems are susceptible to corrosion,
incrustation, and plugging.
- These wells are usually sited in areas
with low soil permeabilities, shallow
water tables, and insufficient natural
surface drainage.
Injected Fluids
- Fluid constituents vary depending upon
differing farm practices and soil types.
- Potential agricultural contaminants
include nutrients, pesticides, organics,
salts, metals, and pathogens.
SLIDE #14-9 This slide illustrates an agricultural drainage
well showing three sources of flow:
Direct flow from the surface;
Flow from the surface with minimal infiltra-
tion prior to injection; and
Subsurface flow.
SLIDE #14-10 This is a diagram of a subsurface flow collection
system. This system consists of perforated
collection pipes which flow to the agricultural
drainage well. The drainage well is located
centrally.
14 - 11
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SLIDE #14-11
This illustrates the surface expression of an
agricultural drainage well. Note that a portion
of the screen over the injection well inlet is
missing. The purpose of this screen is to prevent
debris, which may cause clogging, from entering
the well.
SLIDE #14-12
This is an agricultural drainage well located in a
sump with a concrete cover. Flow from the
subsurface is diverted to this well through a
perforated-pipe collection system (as previously
illustrated).
SLIDE #14-13
This slide illustrates the surface expression of
an agricultural drainage well. This well is sited
at a low point to allow direct injection of sur-
face flow.
Well-Type Specific Questions/Inspection 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.)?
14 - 12
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- Are septic systems or cesspools used?
If yes, continue to ask 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/opera-
tors may not consider them "real wells".
- These wells are also known as dry wells,
pits, sumps, drains, and other local
"pet" names.
- Construction and operation details along
with other specific information may not
be readily available.
Storm Water Drainage Wells (5D2)
Storm water drainage wells receive storm water
runoff from paved areas, including parking lots,
streets, residential subdivisions, building roofs,
highways, etc.
SLIDE #14-14 This slide illustrates the number of storm water
drainage wells by State (as reported in the Report
to Congress, 1987).
Well Construction, Operation, and Siting
- Wells are usually simply constructed and
are relatively shallow.
Most wells have large diameter settling
basins or other "treatment" devices
above or attached to the well bore or
casing. Casing may or may not be used;
sometimes the well bore is filled with
rocks or other filter material.
14 - 13
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- Wells are sited in topographically low
spots in areas that do not drain well or
within facility or property boundaries
if ordinances require retention of storm
water on site.
- Wells often inject above USDWs and less,
frequently into USDWs.
Injected Fluids
- Fluid may contain herbicides, pesti-
cides, fertilizers, deicing salts,
asphaltic sediments, gasoline, grease
and oil, tar and residues from roofs and
paving, rubber particulates, liquid
wastes and industrial solvents, heavy
metals, and coliform bacteria.
SLIDE #14-15 This slide illustrates some typical storm water
drainage well designs. The next four slides show
the detail for each example.
SLIDE #14-16 Construction features of a typical storm water
drainage well.
SLIDE #14-17 Construction features of a typical storm water
drainage well.
slide #14-18 Construction features of a typical storm water
drainage well.
SLIDE #14-19 Construction features of a typical storm water
drainage well.
SLIDE #14-20 This slide illustrates pre-cast perforated
concrete dry well "rings." Perforations allow
seepage of storm water to the subsurface.
14 - 14
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SLIDE #14-21 This shows a storm water drainage well accepting
flow from a nearby catch basin, which is plumbed
to the well through the subsurface.
SLIDE #14-22 This is a storm water drainage well which has been
utilized by the public for garbage disposal.
SLIDE #14-23 This is a large-diameter storm water drainage well
sited within a municipal storm water retention
basin. Surface runoff from city streets is
diverted to this basin for injection.
SLIDE #14-24 This is a storm water drainage well located near a
municipal water supply well. A well house is
shown in the background of this photograph.
Construction features of both wells would be of
interest in this situation in order to establish
the vertical separation distance between the
injection well and the production zone of the
water supply well. Depth of the annular seal in
the supply well would be of interest, since
injected fluid from the storm water drainage well
may flow horizontally to an open annulus in the
water supply well, allowing possible contamination
of the water supply.
14 - 15
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SLIDE #14-25 This illustrates a storm water drainage well
maintenance crew utilizing a vacuum truck to clean
a drainage well in a residential area. This must
be done when the wells become clogged with silt,
which leads to poor infiltration and flooding
problems.
Well-Type Specific Questions/Inspection Tips
- Are storm water drainage wells utilized?
- 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, measure well
depth (or depth to backfill).
- Is the measured depth eguivalent to the
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?
Peculiarities/Potential Problems
- Finding an inspection contact may1 be
difficult. Getting information from the
inspection contact may also be diffi-
cult.
14 - 16
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Shallow wells like these may not. be
considered "real wells" 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.
Access to the well may require special
grate or lid removal tools; these can
usually be obtained from the city main-
tenance division.
Industrial Drainage Wells (504)
Industrial drainage wells include wells located in
industrial areas which primarily receive storm
water runoff but are susceptible to spills, leaks,
or other chemical discharges.
SLIDE #14-2 6 This illustrates the number of industrial drainage
wells by State (as reported in the Report to
Congress, 1987).
Well Construction, Operation, and Siting
Similar to storm water drainage well
construction
14 - 17
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Injected Fluids
- Constituents found in 5D4 wells are
similar to those which may be found in
5D2 wells.
- Heavy metals such as lead, iron, and
manganese, and organic compounds may be-
found in industrial drainage wells..
SLIDE #14-27 This is a picture of an industrial drainage well
located at a service station.
SLIDE #14-28 This is an industrial drainage well located near a
chemical storage area.
SLIDE #14-29 This is an industrial drainage well located in a
loading dock adjacent to a storage tank.
SLIDE #14-30 This industrial drainage well is located adjacent
to barrels of fuel, oil, and waste chemicals.
Well-Type Specific Questions/Inspection Tips
Same as for 5D2 wells
Peculiarities/Potential Problems
Same as for 5D2 wells
14 - 18
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Improved SinXhole3 (5D3)
Improved sinkholes receive storm water runoff from
developments located in karst topographic areas.
These "wells" may also receive other fluids such
as sewage and industrial wastes, in which case,
these wells should be reclassified to the appro-
priate well type (such as 5W9 raw sewage waste
disposal wells).
SLIDE #14-31 This slide illustrates the number of improved
sinkholes by State (as reported in the Report to
Congress, 1987).
Well Construction, Operating, and Siting
- Sinkholes can be improved in a number of
ways, such as placing a pipe or casing
down into the sinkhole throat or paving
a cement pad to improve drainage or
injection.
- Many sinkholes have a grate or screen at
the opening to prevent rapid clogging
and must be routinely maintained to
prevent total clogging.
Concentrated usage of some sinkholes has
caused flooding or rapid caving in other
sinkholes which are connected by large
fracture solution networks to the
improved sinkholes.
- Improved sinkholes inject directly into
or above USDWs.
Injected Fluids
- Improved sinkholes may receive runoff
from paved areas containing lead and
petroleum products from automobiles,
pesticides from horticulture and lawn
care, nitrates from fertilizers, fecal
material from wild and domestic animals,
and normal fallout from air pollutants.
14 - 19
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- These wells may also receive other
fluids such* as sewage or industrial
wastes, in which case, these wells
should be reclassified.
- Carbonate aquifers, in which sinkholes
occur, provide little, if any,
filtration or other means of attenuating
contaminants.
SLIDE #14-32 This slide illustrates a sinkhole development near
improved sinkholes.
Well-Type Specific Questions/Inspection 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?
Peculiarities/Potential Problems
- The Agency has not defined precisely
what constitutes an improved sinkhole.
The inspector should be aware of this,
but should still maintain keen observa-
tion for intentional discharge of fluids
into sinkholes. Hopefully, this gray
area will be better defined as more
site-specific data is gathered and
reported.
14 - 20
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The owner or operator may not consider
the improved'sinJchole to be a well and,
thus, without direct questioning, may not
provide useful information.
Special Drainage Wells (5630)
Special drainage wells are used for disposing of
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; lake level control drainage wells;
and municipal and construction dewatering drainage
wells.
Well Construction, Operation, and Siting
- Most wells are shallow, injecting into
or above shallow USDWs.
- Construction varies with purpose and
siting. Casing and screens are often
used.
Injected Fluids
- Constituents in injected fluids are
highly^ variable depending on the system
design.
For landslide control wells, ground
water is usually the fluid drained. For
swimming pool wells, the fluids may
contain lithium hypochlorite, calcium
hypochlorite, sodium bicarbonate,
chlorine, bromine, iodine, cyanuric
acid, aluminum sulfate, algaecides,
fungicides, and muriatic acid.
14 - 21
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SLIDE #14-33 This is a one example of special drainage wells.
These landslide control drainage wells are
utilized to lower the water table in order to
prevent a landslide on the highway.
SLIDE #1434 This is another example of special drainage wells.
This is a typical swimming pool drainage well in
Dade County, Florida.
Well-Type Specific Questions/Inspection Tips
- Specific questions are difficult to list
due- to the variable nature of this well
type.
- During inspections, the inspector must
initially determine the use of wells,
type and volume of injected fluids, and
construction details of wells to
correctly subcategorize the 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. The inspector
should use common sense and intuition.
Use and location of these wells will not
generally be obvious or often talked
about.
- Swimming pool owners may not know
whether their pool drains to the sewer
system or a well.
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Geothermal Reinjaction Wells
Electric Power Reinjection Wells (5A5)
Electric power reinjection wells reinject spent
geothermal fluids which were used to generate
electric power.
Well Construction, Operation, and Siting
- Wells typically have surface and conduc-
tor casing strings cemented in place.
- Injection zones are usually deep and are
geothermal reservoirs or margins of such
reservoirs.
- Wellhead equipment is sophisticated.
Designs are location and project
specific. Production wells may be
converted to injection wells; construc-
tion is similar.
- Wells are maintained regularly. 5A5
wells are monitored constantly or
regularly by operators.
- Wells inject below or into USDWs. Many
geothermal reservoirs are USDWs, but may
naturally exceed some Drinking Water
Regulation standards.
Injected Fluids
- At vapor dominated resources, fluids may
contain heavy metals (arsenic, boron
selenium), sulfates, and dissolved
solids.
- At hot water dominated resources, fluids
may contain heavy metals (arsenic,
boron, selenium), chlorides, dissolved
solids, and have an acidic pH.
SLIDE #14-35 This slide illustrates construction features of a
geothermal injection well associated with
electrical power generation.
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SLIDE #14-36 This is a wellhead of a geothermal reinjection
well associated with electrical power generation.
Well-Type Specific Questions/Inspection 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?
Peculiarities/Potential Problems
- Many operators (and State regulatory
agencies holding records) will claim
confidentiality of information, espe-
cially 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.
Direct Heat Reinjection Wells (5A6)
Direct heat reinjection wells reinject geothermal
fluids used to provide heat for large buildings or
developments; they can be deep or shallow wells.
Well Construction, Operation, and Siting
- Same as 5A5 wells
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Injected Fluids
- Same as 5A5 wells; and
- Fluids may contain arsenic, boron,
fluoride, dissolved solids, sulfates,
and chloride.
SLIDE #14-37 This is a wellhead for a typical geothermal
reinjection well associated with domestic direct
space heating operations.
SLIDE #14-38 This slide shows the construction features for a
typical domestic direct space heating reinjection
well.
Well-Type Specific Questions/Inspection Tips
- Does the direct heat system use downhole
or surface heat exchangers?
Is the geothermal fluid piped to a
central facility or to many buildings/
facilities?
Is information available on analyses of
geothermal fluids, etc?
Peculiarities/Potential Problems
- Some direct heat facilities are consid-
ered by the State to be utilities.
- Regulation of these wells varies from
State to State and may be dependent on
volumes of heat-spent fluid injected.
- Where these wells are actively regulated
(e.g., permitted), a large information
database should exist.
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Heat Pump/Air conditioning Return Flow Wells (5A7)
Heat pump/air conditioning return flow wells
reinject ground water used to heat or cool a
building in a heat pump or air conditioning
system.
Well Construction, Operation, and Siting
- These wells are generally shallow and
are completed in the same aquifer as the
production well. Average depth is 200
feet and ranges from 19 to 930 feet
according to inventory data.
- Construction varies across the nation.
Casing and cement are often used for
surface seals, and sometimes injection
tubing is used to prevent aerating
injected fluids.
Injected Fluids
- Fluids are primarily thermally altered
ground water with additives designed to
inhibit scaling, corrosion, and
incrustation (used when ground water is
high in metals and salts, or has a high
of low pH) .
SLIDE #14-39 This shows the construction features for a typical
shallow heat pump/air conditioning return flow
well.
SLIDE #14-40 This slide illustrates the construction features
for a typical shallow heat pump/air conditioning
return flow well.
Well-Type Specific Questions/Inspection Tips
- Does the ground-water pump utilize an
open-loop system or a closed-loop
system? [Note that some heat pump
systems are installed with subsurface
14 - 26
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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.
Aquaculture Return Flow or Discharge Wells (5A8)
Aquaculture return flow or disposal wells reinject
ground water or geothernal fluids used to support
aquaculture. Non-geothermal fluids are also
included in this category (e.g., marine aquariums
in Hawaii use relatively cool ocean water which is
injected into wells for disposal).
Well Construction, Operation, and Siting
- Most wells are shallow and are of
relatively simple design with only
surface casing in place. Cement may or
may not be used.
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- Wells must be maintained regularly to
prevent total clogging.
- Lightweight steel or PVC casing is often
used and a perforated casing or liner
may be used opposite the injection zone..
- Most wells inject into or beyond USDWs
along the coast in Hawaii.
Injected Fluids
- Aquaculture wastewater in Hawaii is
composed of salt or brackish water with
added nutrients, bacteriological growth,
perished animals, and animal detritus.
- Effluent may contain nitrates, nitrites,
ammonia, high BOD, and orthophosphate.
SLIDE #14-41 This slide illustrates the construction features
for a typical aquacultural return flow well.
SLIDE #14-42 This is a aquacultural operation in Hawaii.
Well-Type Specific Questions/Inspections 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).
14 - 28
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- 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
Raw Sewage Waste Disposal Wells (5W9) and
Cesspools (5W10)
Raw sewage waste disposal wells receive raw sewage
wastes from pumping trucks or other vehicles which
collect such wastes from single or multiple
sources. Abandoned mines, lava tubes, and/or
cavern systems which receive raw sewage, raw
sewage wastes, or sludges are included.
Cesspools include multiple-family dwelling,
community, or regional cesspools, or other devices
that receive wastes and which have an open bottom
and sometimes have perforated sides. To be
regulated under the Class V program, USEPA has
specified that cesspools must serve more than 20
persons per day if receiving solely sanitary
wastes.
SLIDE #14-43 This shows the number of untreated sewage waste
disposal wells by State (as reported in the Report
to Congress, 1987).
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slide #14-44 This shows the number of cesspools by State (as
reported in the Report to congress, 1987).
Well Construction, Operation, and Siting
- For 5W9 wells, construction may simply
include access to a lava tube, cavern,
abandoned mine, etc. Wells may be
covered by a manhole cover.
- For 5W10 wells, precast concrete rings
or cesspool blocks are often used.
Wells are typically very shallow. Wells
may require periodic maintenance.
- These wells inject above or directly
into USDWs.
Injected Fluids
- Raw sewage wastes are generally poor
quality and include high fixed
volatiles, BOD, COD, TOC, nitrogen
(organic and ammonia), chloride,
alkalinity, and oil and grease.
- Pathogens are a major health concern in
raw sewage wastes.
SLIDE #14-45 This slide presents a sectional view of a
cesspool.
Well Types Specific Questions/Inspection Tips
- See Septic Systems
Peculiarities/Potential Problems
- See Septic Systems
Septic Systems (5W11, 5W31, 5W32)
Septic systems - undifferentiated disposal methods
(5W11) inject the waste or effluent from a
multiple-family dwelling, business establishment,
community, or regional establishment septic tank
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via an undetermined disposal method. To be
regulated under the Class V program, these wells
must serve more than 20 person per day if they
receive solely sanitary wastes.
Septic systems - well disposal method (5W31)
inject the waste or effluent from a multiple-
family dwelling, business establishment,
community, or regional establishment septic tank
through a well. Examples of wells include actual
wells, seepage pits, cavitettes, etc. To be
regulated under the Class V program, these wells
must serve more than 20 persons per day if they
receive solely sanitary wastes.
Septic systems - drainfield disposal method (5W32)
inject the waste or effluent from a multiple-
family dwelling, business establishment,
community, or regional establishment septic tank
into a drainfield. Examples of drainfields
include drain or tile lines and trenches. To be
regulated under the Class V program, these wells
must serve more than 20 persons per day if they
receive solely sanitary wastes.
SLIDE #14-46 This slide illustrates the number of undifferenti-
ated septic systems (5W11) by State (as reported
in the Report to Congress, 1987).
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SLIDE #14-47 This slide shows the number of septic systems with
wells (5W31) by State (as reported in the Report
to Congress, 1987).
SLIDE #1448 This illustrates the number of septic systems with
drainfields (5W32) by State (as reported in the
Report to Congress, 1987).
Well Construction, Operation, and Siting
- Septic tanks consist of a baffled tank
specially designed for primary treatment
of sewage wastewater.
- Septic tanks may discharge to a variety
of subsurface disposal devices such as
simple dry or drainage wells, cesspools,
or seepage pits.
- These types of wells are often crude,
not having casing or surface seals.
- Septic tanks may also discharge to tile
or leach lines, commonly referred to as
drainfields, or to trenches.
- These wells inject above or directly
into USDWs.
- Periodic maintenance is required for
properly designed systems. Improperly
designed systems often fail and
discharge wastes to the surface.
Injected Fluids
- Fluids vary with the type of system
used.
Typical septic tank effluent contains
99.9 percent water (by weight) and .03
percent suspended solids (including
nitrates, chlorides, sulfates, sodium,
calcium, and fecal coliform and other
pathogens).
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slide #14-49 This is a cross-sectional view of a conventional
septic tank.
SLIDE #14-50 This is a cross-sectional view of a seepage pit
associated with a septic tank (5W31).
SLIDE1 #14-51 This is a cross-sectional view of a drainfield
associated with a septic tank (5W32).
SLIDE #14-52 Drainfields may be constructed in absorption
mounds when natural conditions do not allow for
adequate drainage or treatment.
Well-Type Specific Questions/Inspection Tips
- How are sewage wastes disposed? [If a
septic system is used, ascertain what
kind 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 pumped 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,
floor 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."
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- 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.
Sewage Treatment Plant Effluent Disposal
Wells (5W12)
Domestic wastewater (sewage) treatment plant
effluent disposal wells dispose of treated sewage
or domestic effluent from various types of plants,
ranging from small package plants to large
municipal sewage treatment plants. Treatment is
usually of secondary quality and sometimes is
capable of producing highly treated tertiary
effluent.
SLIDE #14-53 This slide illustrates the number of domestic
wastewater treatment plant effluent disposal wells
by State (as reported in the Report to Congress,
1987).
Well Construction, Operation, and Siting
- These wells are specially designed and
sited to meet the hydrogeologic and
operational considerations.
14 - 34
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- Most wells have multiple casings
cemented in place.
- Injection fluids or ground water are
often monitored.
- Most wells inject directly into USDWs
although some inject above them.
Injected Fluids
- The injected fluids, after secondary or
tertiary treatment, are believed to be
generally compatible with receiving
formation waters; however, the fluids
may contain high nitrates and pathogenic
contaminants if improperly treated.
slide #14-54 This is a construction diagram of a wastewater
treatment plant disposal well and associated
monitoring well.
SLIDE #14-55 This is a diagram of a wastewater, treatment, and
disposal facility in Teton County, Wyoming.
SLIDE #14-56 This is a wastewater treatment plant in Hawaii.
SLIDE #14-57 This injection well accepts effluent from a
wastewater treatment plant in Hawaii.
Well-Type Specific Questions/Inspection 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?
14 - 35
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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 descriptions
should be noted.
Mineral and Fossil Fuel Recovery Related Wells
Mining, Sand/ or Other Backfill 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 including radioactive mining
wastes. Also included are special wells used to
control mine fires and acid mine drainage wells.
Well Construction, Operation, and Siting
Backfill wells are usually simply
constructed.
- Conductor casing may or may not be used;
cement is sometimes used to seat the
casing firmly in the well bore.
14 - 36
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- Sometimes abandoned mine shafts are used
as injection wells. By definition,
backfill wells are sited in mined-out
areas. Wells may be used for only a few
days at some sites if the void space is
entirely filled. Other wells may be
used for several months.
- These wells often inject into or above
USDWs, though at some sites, injection
may be below or beyond USDWs.
Injected Fluids
- Fluids are injected as either hydraulic
or pneumatic slurries.
- The solid portion of the slurries may be
sand, gravel, cement, mill tailings or
refuse, or fly ash.
- Slurry waters may be acid mine water or
ore extraction process wastewater.
SLIDE #14-58 This illustrates the construction features of
typical mine backfill well.
SLIDE #14-59 This presents scenarios for potential groundwater
contamination resulting from mine backfill
injection wells.
Well-Type Specific Questions/Inspection Tips
- What is the composition of materials
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 raining
project permit? . [Obtain permit
application data, or note type of
information and where it is available
for review.]
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Peculiarities/Potential Problems
- Some backfill wells have a very short
lifetime (2 to 3 days).
- Backfill wells can be used for
subsidence control, mining waste
disposal, acid mine drainage, and mine
fire control.
Solution Mining Wells (5X14)
Solution mining wells are used for in-situ
solution mining in conventional mines, such as
stopes leaching (these wells are non-Class III
wells).
Well Construction, Operation, and Siting
- Plastic piping is used for casing in
most cases, although light-weight steel
casing is sometimes used.
Diameters range from 2 to 8 inches and
injection well depths range from about
200 feet to more than 1,000 feet,
depending on the depth of the ore body.
- The annular space is generally cemented
from depth to surface.
- Injection is by gravity flow.
Siting is project specific, but is
primarily situated to enhance mineral
recovery.
Injection is usually in areas where USDW
occurrence is rare or USDWs are of poor
quality.
Injected Fluids
- Injected fluids are typically weak acid
solutions (sulfuric and hydrochloric),
ammonium carbonate, sodium carbonate/
bicarbonate, or ferric cyanide.
14 - 38
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SLIDE #14-60 This illustrates the construction features of a
proposed large-diameter, high-volume solution
mining injection well. Note annular cement to
total depth of the borehole.
SLIDE #14-61 This is a block diagram of solution-mining
operations illustrating application and collection
of leaching fluid.
SLIDE #14-62 This is a conventionally-mined area in Arizona,
now being solution mined for copper.
Well-Type Specific Questions/Inspection Tips
- What minerals are being produced and
what is the 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 aguifers in the mining
vicinity, and is there a groundwater
monitoring network? If so, are analyses
available?
Peculiarities/Potential Problems
- Solution mining operations may use both
Class III and V injection wells. Class
V wells are those used in previously
mined areas (by conventional methods) or
pilot-scale experimental projects.
- Solution mining operations typically use
many hundreds of injection wells. Often,
these operations will recover over 100%
of fluids injected, which indicates the
mine is acting as a groundwater sump.
14 - 39
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- Operators 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.
In-Situ Fossil Fuel Recovery Wells (5X15)
In-situ fossil fuel recovery wells are used for
in-situ recovery of coal, lignite, oil shale, or
tar sands.
Well Construction, Operation, and Siting
In-situ fossil fuel recovery related
wells are specially designed to
withstand high variations in temperature
and pressure.
In addition to high temperatures and
possible melting, the well materials
(casing, cement, wellhead and surface
valves) are subjected to sulfidation and
oxidation from combustion, thermal
expansion and contraction forces, and
cement shrinking and parting due to
overburden drying or volatilization.
Subsidence is also likely.
- Carbon or high strength stainless steel
is used for casing.
Injection may be above, into, or below
USDWs.
Injected Fluids
- For underground coal gasification, air,
oxygen, steam, water, or igniting agents
such as ammonium nitrate fuel oil may be
injected.
For in-situ oil shale retorts, injected
fluids include air, oxygen, steam,
water, sand, explosives, or igniting
agents (generally propane).
14 - 40
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- The purpose in both cases is to initiate
and maintain combustion.
- Combustion products include polynuclear
aromatics, cyanides, nitrites, and
phenols.
SLIDE #14-63 This is a cross sectional view of an in-situ coal
gasification process utilizing an injection well
(right) and a production well (left).
Well-Type Specific Questions/Inspection 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 ground-
water 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 types 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.
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spent Brine Return Flow wells (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.
Well Construction, Operation, and Siting
- These wells are constructed and operated
like Class II salt water disposal wells.
- Siting is dependent upon location of the
halogen deposit.
- Injection is below USDWs and is
typically greater than 5,000 feet below
land surface.
- Mechanical integrity tests used for
Class II wells would be appropriate for
spent brine return flow wells.
Injected Fluid
Injected fluids are limited to brines
from which halogens or their salts have
been extracted.
- There is a potential for illicit
addition of other undefined constituents
into the waste stream.
SLIDE #14-64 This slide illustrates the construction features
of a spent brine return flow well.
Well-Type Specific Questions/Inspection 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.]
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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, tubing, and other construction
features are susceptible to corrosion
from the brines disposed.
Oil Field Production Waste Disposal Wells
Air Scrubber (5X17) and Water softener (5X18)
waste Disposal Wells
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 well.
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
14 - 43
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used directly for enhanced recovery and not just
disposal, it is a Class II well. All air
scrubber waste disposal wells and water softener
regeneration brine disposal wells inventoried to
date are Class II wells.
Well Construction, Operation, and Siting
- All wells in California are located
within or adjacent to currently active
oil fields.
Some wells were drilled solely for
injection purposes, but must have been
converted from poor or marginal
production wells to injectors. As such,
construction designs are consistent with
standard oil production or Class II
injection well design.
- Injection is almost always into an oil
producing zone although some facilities
inject into non-oil bearing USDWs.
Injected Fluids
For air scrubber wastes, injected fluids
may have high TDS, nitrates, sulfates,
and chlorides. These scrubber wastes
are commingled with excess produced
water and water softener regeneration
brine wastes.
For water softener wastes, injected
fluids may have high TDS, calcium, and
chlorides, and often have high nitrates.
These wastes may be commingled with
excess produced water.
SLIDE #14-65 This slide shows the construction features of an
air scrubber waste disposal well.
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SLIDE #14-66 This slide depicts the construction features for a
water softener regeneration brine disposal well.
Well-Type Specific Questions/Inspection Tips
- 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?
- Similarly, for regeneration brine
disposal wells, what are the approximate
relative percentages of regeneration
brine and produced water?
- Is cogeneration a part of the overall
operation? If so, what processes are
involved? (This is important primarily
for inventory purposes.)
- Is the system fired 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 often 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
- Waste streams will be commingled either
at the wellhead 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
14 - 45
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wellhead. This may involve the use of
high pressure wellhead 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.
Industrial, Commercial, and Utility Disposal Wells
Cooling Water Return Flow Wells (5A19)
Cooling water return flow wells are used to inject
water which was used in a cooling process,
including open-loop, closed-loop, and contact
systems. These wells are classified separately
from heat pump or air conditioning return flow
systems.
Well Construction, Operation, and Siting
- Well construction varies greatly through-
out the nation.
- Most wells are relatively shallow, often
less than 600 feet deep.
- Wells may be cased to depth, cased at
the surface, or open hole for the entire
depth.
- Wells are often completed in the source
aquifer, and injection is usually into
or above USDWs.
- Cooling water systems are often closed,
meaning the ground water used in cooling
does not become exposed to the air at
any point between withdrawal and
reinjection.
14 - 46
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Open systems expose ground water to the
air at some point before injection.
- Contact systems run ground water used
for cooling directly over the product to
cool it.
Injected Fluids
- Injectate quality is dependent upon the
type of system, type of additives, and
temperature of water.
- Open pipe and contact systems may expose
ground water to accidental introduction
of surface contaminants or unauthorized
disposal of wastes.
SLIDE #14-67 This illustrates the proper concentration of
annular space in the cooling water return flow
well. Note that the well construction allows
injection into the deeper aquifer (often utilized
for water production) while preventing migration
of water from the shallow contaminated aquifer.
Well-Type Specific Questions/Inspection Tips
- What products are manufactured at this
facility?
What processes are employed to make the
products?
- What wastes are generated from each
process? How are wastes disposed?
- 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?
14 - 47
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- Are any chemical additives used?
- Is there a scale problem and, if so, how
is it removed? [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/ contingency plan?.
Peculiarities/Potential Problems
- Wastes other than spent cooling water
may be injected along with cooling
water.
- If 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.
Industrial Process Water and Waste Disposal
Wells (5W20)
Industrial process water and waste disposal wells
are used to dispose of a wide variety of wastes
and wastewaters from industrial, commercial, or
utility processes. Industries include refineries,
chemical plants, smelters, pharmaceutical plants,
laundromats and dry cleaners, tanneries, laborato-
ries, electric power generation plants, car
washes, and electroplating industries.
14 - 48
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SLIDE #14-68 This slide illustrates the number of industrial
process waste disposal wells by State (as reported
in the Report to Congress, 1987).
Well Construction, Operation, and Siting
- Well construction varies greatly,
ranging from simple dry wells with no
casing and rock filled well bores to
sophisticated relatively deep wells with
multiple strings of casing cemented in
place.
- Wells are usually sited on facility
property and injection is into or above
USDWs.
- Some periodic maintenance is required
for most wells.
- Some industrial wells have operators
which control injection operations.
Injected Fluids
- Potentially, any waste fluid produced by
various industries, utilities, and
commercial ventures can be injected by
Class V industrial disposal wells.
Fluids may have high total dissolved
solids, alkalinity, chloride, phosphate,
sulfate, and may include spent solvents
or other organic compounds.
SLIDE #14-69 This is a homemade treatment system (solids
removal) discharging to a floor drain. This floor
drain discharges to a 300 by 600-foot drainfield.
SLIDE #14-70 This is a floor drain located in a paint mixing
area. This floor drain discharges to a 3 00 by 600
foot drainfield.
14 - 49
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SLIDE #14-71 This industrial waste disposal well accepts
several sources of effluent from discharge piping.
Well-Type Specific Questions/Inspection 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? How are these wastes disposed?
- 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
disposal system (e.g. lab chemicals,
etc.)?
- Are any wastes discharged into, or could
any waste potentially enter, 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?
14 - 50
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- 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
disposal wells.
- Many industries mix their waste streams.
- Many industries use dual purpose wells
(e.g., sewage waste disposal 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.
Motor vehicle Service Station waste Disposal
Wells (5X28)
Motor vehicle service station waste disposal wells
receive wastes from repair bay drains and floor
drains at gasoline stations, garages, automobile
dealers, motorpool divisions, car washes, etc.
SLIDE #14-72 This shows the number of motor vehicle waste
disposal wells by State (as reported in the Report
to Congress, 1987).
Well Construction, Operation, and Siting
Wells are usually constructed very
simply and may be similar to cesspools
or dry/drainage wells.
14 - 51
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- Wells are usually very shallow and
injection is above or into USDWs.
- Specific construction features will vary
from site to site.
- Some pretreatment may be provided by
oil-water separators, catch basins, or
grease traps if installed and maintained
properly.
- Wells are sited on facility property.
Injected Fluids
Injected fluids can contain waste oil,
antifreeze, floor washings (including
detergents, organic and inorganic
sediment), and other petroleum products.
Waste oils may contain heavy metals such
as lead, chromium, and cadmium.
SLIDE #14-73 This is a catch basin detail for a facility in New
York. This catch basin discharges to a dry well.
Note that the inlet drain pipe for this particular
catch basin is designed in a manner which does not
allow separation of the floating phase. As a
result, oil is discharged to the injection well.
(Many catch basins have an inverted pipe which
penetrates the oil layer, allowing injection of
the aqueous phase below.)
SLIDE #14-74 This slide illustrates the detail of a disposal
well at a service station in New York. Note the
inlet drain pipe from the catch basin (illustrated
in the previous slide).
14 " 52
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SLIDE #14-75 This is a photograph of a motor vehicle waste
disposal well at a service station. Mote the
floating, oily scum within the well.
Well-Type Specific Questions/Inspection 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? If so, obtain the
plans.
Does the facility have a car wash? If
so, how is the car wash effluent
disposed 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
provide some answers which were not
easily answered before.
14 ~ 53
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- 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.
- Some wastes injected by such facilities
may be Class IV hazardous wastes. All
sampling and analysis must be carefully
undertaken, especially if enforcement
actions are anticipated.
Recharge Wells
Aquifer 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.
SLIDE #14-76 This slide depicts the number of aquifer recharge
wells by State (as reported in the Report to
Congress, 1987).
Well Construction, Operation, and Siting
- Many recharge wells are specially de-
signed and sited to accomplish recharge
objectives and are under control of an
operator.
- Wells may have one or more casing
strings cemented in place and some wells
may use injection tubing.
- Wells inject directly into USDWs in most
cases, but some facilities may inject
above aquifers.
14 - 54
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Some wells may serve a dual or secondary
purpose such as sewage effluent
disposal, water production, or drainage
of surface water or ground water.
Injected Fluids
- Injected fluids are dependent on the
water source.
- Water quality changes which can take
place in injected fluids or in the
mixing zone between injected and aquifer
fluids include adsorption, ion exchange,
precipitation and dissolution, chemical
oxidation, biological nitrification,
aerobic or anaerobic degradation,
mechanical dispersion, and filtration.
SLIDE #14-77 This shows the construction features of an aquifer
recharge well in California.
Saline Water Intrusion Barrier Wells (5B22)
Saline water intrusion barrier wells are used to
inject water into fresh water aquifers to prevent
intrusion of salt water into the fresh water
aquifers.
Well Construction, Operation, and Siting
Most wells are sophisticated and have
multiple casing strings cemented in
place.
- Wells are usually sited in lines paral-
lel to coast lines to form a hydraulic
barrier against salt water intrusion.
- Wells inject directly into USDWs under
control of an operator.
Injected Fluids
- A large variety of fluids are used in
salt water barrier projects, much like
aquifer recharge wells. Fluids are
site-specific.
14 - 55
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SLIDE #14-78 This illustrates construction features of saline
water intrusion barrier wells. These wells are
operated in California. Note that the well on the
right is constructed to allow injection into the
upper and lower aquifer.
SLIDE #14-79 This is a saline water intrusion barrier operation
utilizing injection wells to form a fresh-water
ridge acting as a sea-water barrier.
Subsidence Control Wells (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.
Well Construction, Operating, and Siting
- Well construction is similar to aquifer
recharge and subsidence control wells.
- Wells are sited to stop or improve
subsidence due to overdraft of ground
water on a site-specific basis.
Injected Fluids
- A variety of injected fluids may be used
and are site specific. See the section
on aquifer recharge wells since
potential fluids are similar.
14 - 56
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SLIDE #14-80 This is an injection well utilized for subsidence
control in the Wilmington Oil Field, Long Beach,
California. This slide is for illustration of
subsidence control utilizing injection wells - the
injection well shown is injecting into an oil
bearing zone, and therefore is not considered a
Class V injection well. This is a Class II
injection well which serves to prevent subsidence
and enhance oil recovery.
SLIDE #14-81 These are injection wells utilized to prevent
subsidence in a previously-mined area. This slide
is for illustration of subsidence control
utilizing injection wells - the injection wells
shown are classified as Class V mine backfill
wells (type 5X13).
SLIDE #14-82 These are areas of land subsidence resulting from
ground-water withdrawal.
Well-Type Specific Questions/Inspection 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.
14 - 57
-------
- Is there a groundwater monitoring and/or
injectate monitoring system on site? If
so, would a review of the periodic/
continuous analyses be possible?
- 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
USDWs.
- Some of these projects may be operated
irresponsibly with regard to injectate
water quality.
Miscellaneous Wells
Radioactive Waste Disposal Wells (5N24)
Radioactive waste disposal wells include all non-
Class IV radioactive waste disposal wells. Class
IV wells inject radioactive wastes into or above
USDWs and Class V wells inject radioactive wastes
below all USDWs.
SLIDE #14-83 This slide illustrates the number of radioactive
wastes disposal wells by State (as reported in the
Report to Congress, 1987). Note that any well
utilized by a generator of radioactive waste to
inject radioactive waste into or above USDWs is
defined as a Class IV well in 40 CFR.
14 - 58
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Well Construction, Operation, and Siting
- No details are available on the con-
struction of these wells.
- Wells are generally sited on federal
property such as DOE, NRC, DOD
facilities and arsenals.
- Inventory data are notably lacking for
these wells.
Injected Fluids
A variety of radioactive materials may
be injected including Beryllium 7,
Tritium, Strontium 90, Cesium 137,
Potassium 40, Cobalt 60, beta particles,
Plutonium, Americium, Uranium, and
radionuclides.
SLIDE #14-84 This is a radioactive waste disposal well in the
western United States.
Well-Type Specific Questions/Inspection Tips
- What specifically is injected and what
is the fluid quality and quantity?
- Please delineate all aquifers (USDWs)
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 USEPAs 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.
14 - 59
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Experimental Technology Wells (5X25)
Experimental technology wells include wells used
in experimental or unproven technologies such as
pilot-scale in-situ solution mining wells,
secondary water production, tracer studies,
thermal storage, and a number of projects already
named as utilizing Class V wells (such as oil
shale retorting, aquifer remediation, and
underground coal gasification).
Well Construction, Operation, and Siting
- Well construction, operation, and siting
vary greatly from site to site.
- Wells may inject into, above, or below
USDWs.
Injected Fluids
- Due to the diversity of experimental
technology wells, a wide variety of
fluids may be injected including:
highly acidic or basic lixiviants for
solution mining; domestic wastewater
effluent containing high total suspended
solids, fecal coliform, ammonia, BOD,
pH; and air for secondary recovery of
water from unsaturated zones.
SLIDE #14-85 This slide depicts some examples of projects
utilizing injection wells associated with
experimental technology.
Well-Type Specific Questions/Inspection Tips
- Please explain the project and the
specific usage of injection wells.
- What type and quality of fluids are
injected?
14 - 60
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- Does the facility have a groundwater or
injectate quality monitoring system on
site?
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.
Aquifer Remediation Related Wells (5X26)
Aquifer remediation related wells include wells
used to prevent, control, or remediate aquifer
pollution, including but not limited to Superfund
sites. These wells also include wells used for
the disposal of treated ground water. Some wells
serve secondary purposes such as aquifer recharge.
SLIDE #14-86 This slide illus
remediation wells
Report to Congress
trates the number of aquifer
by State (as reported in the
, 1987).
14 - 61
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Well Construction, Operation, and Siting
- Well construction, operation, and siting
are site-specific and vary widely.
- Many wells have one or more casing
strings cemented in place.
- Wells are specially designed to aid in
aquifer remediation and may be an active
or passive component of the remediation
project.
- Siting is also site-specific.
- Most wells are under control of a
designated operator and may be regulated
by a federal, State, or local agency.
- Most wells inject into or above USDWs.
Injected Fluids
- Injected fluids are dependent upon the
hydrogeologic regimen, parameters of the
contamination plume, and design of the
remediation program.
For aquifer remediation projects at
refineries, typical injectate constitu-
ents may include oil and grease,
phenols, toluene, benzene, lead, and
iron.
SLIDE #14-87 This shows construction features of a product
recovery well used to recover free-floating
product during aquifer remediation. The lower
production string produces water and causes a cone
of depression, while the upper production string
produces free floating product which flows down
the depression cone to the well.
14 - 62
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SLIDE #1488 This is an aquifer remediation injection well
utilized to return coproduced water to the aquifer
from which it was produced.
SLIDE #14-89 This is a schematic of flow lines illustrating
hydraulic containment of a contamination plume
utilizing production wells and injection wells.
SLIDE #14-90 This is a well screen with centralizers ready for
installation. This screen may be utilized in
production or injection wells.
Well-Type Specific Questions/Inspection Tips
- What contaminants are being recovered by
the remediation system?
- Please detail the remediation system
specifics.
Are any treatments used before the
recovered ground water 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.]
14 - 63
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Peculiarities/Potential Problems
- Each system is site-specific. Inspec-
tion 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 during site
investigations.
- Depending on the site and the stage of
remediation in place, it may not be
practical or necessary to treat
recovered ground water before injection.
This is true for facilities where
hydrocarbon contamination is being
remediated; at such sites, the "free
hydrocarbon" (source) is first removed
before further groundwater treatment can
effectively be conducted.
Abandoned Drinking Water Wells Used for Waste
Disposal (5X19)
Abandoned drinking water wells used for waste
disposal include any abandoned drinking water
wells used or converted for waste disposal.
Well Construction, Operation, and Siting
Many States have improperly abandoned
drinking water wells and some of these
wells may have been converted or may be
used for waste disposal.
- Well construction is usually identical
to or deteriorated from standard
drinking water well construction.
Injection is directly into USDWs.
- Land owners may maintain or "operate"
such wells.
14 - 64
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Injected Fluids
- Abandoned drinking water wells used for
waste disposal could potentially receive
any kind of fluid, particularly brackish
water, dangerous chemicals, pesticides,
and sewage.
SLIDE #14-91 This abandoned water well is used for sewage waste
disposal. This well should be reclassified as a
septic system sewage waste disposal well (5W31)
since the waste disposed is known to be sewage
waste from a septic tank.
Well-Types Specific Questions/Inspection 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 been
affected? [Inspect all wells, including
the abandoned water wells, on or near
site.]
Peculiarities/Potential Problems
- Finding out about such wells is
difficult.
- Many 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.
14 - 65
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Other Wells (5X27)
Other wells include 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.
14 - 66
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UNDERGROUND INJECTION CONTROL PROGRAM
GUIDE FOR CONDUCTING INSPECTIONS
OF CLASS V WELLS
General Information
Facility Name, Address, and Phone Number
Facility Contact(s) and Title(s)
Parent Company/Corporate HQ, Address, and Phone Number
Inspection Date and Time
Weather Conditions
Names and Affiliations of Inspectors
Additional Participants or Observers
Nature of Business/Site History
What products or services are offered at the facility?
How long has the current business, been operating at the
facility? When, was the facility constructed?
What kinds of business have been active at the- site and for
how long?
Have there been any additions to the facility since its
initial construction? If so, when and which ones? How many
buildings exist at the facility?
How many persons are currently employed at the facility?
Is the facility hooked to the city sewer system or is it on
septic?
Class V Injection Well Information
Ask for plumbing plans and a site map illustrating all
buildings. With the assistance of the facility contact,
construct a flow diagram of processes, waste generation, and
disposal showing any floor drains, restrooms, sinks, pits,
storm/parking lot drains, ponds, creeks, surface discharge
points, septic tanks, drainfields, dry wells, chemical
storage areas, etc. Verify the accuracy of this information
during the site tour. Concentrate on plumbing associated
with Class V systems.
The facility contact states that floor drains discharge to a
self-contained tank, ask for as-built diagrams. If these
are not available, ask what the volume of the tank is, and
how often it is pumped. Ask for a hauling invoice from the
-------
last hauling date. (If information provided does not add up,
chances are that the "self-contained tank" is not self
contained; therefore, it is a Class V injection well.)
What processes or operations are performed at the facility?
Observe and note these operations during the site tour.
What liquids are used in each process/operation and how are
generated wastes disposed?
Verify numbers and types of Class V injection wells. Where
are the wells located and what fluids are discharged to the
wells?
Obtain the current status of the well(s) and years of
operation.
Obtain well construction data such as depth, diameter,
casing type, etc. If such data are not available, please
note..
Are ther injection wells, regulated by a State or local
program? Does the- facility have any operational permits?
If so, obtain copies of permits and information regarding
permit requirements.
Describe the- source of injectate for each Class V well.
Include ALL points of entry to the system (e.g., process
wastes through floor drains, sink drains, etc.).
Describe any pre-treatment processes which may occur prior
to injection (e.g., oil-water separation, neutralization).
Describe possible contaminants by observing the constituents
of fluids which are stored near disposal points or which
enter floor drains, etc.
How much fluid is injected into each well? How often is
fluid injected?
When touring the facility, visually examine floor drains,
Class V wells, etc. Take photos of liquid discharge points
and Class V well sampling points, recording film roll number
and frame number. Visual observations to note would include
dimensions of well, susceptibility to chemical spills,
security, general appearance of well, color and consistency
of fluids in well, etc. Are the Class V wells accessible at
the surface? Describe any obstacles that may exist at
sampling points (e.g., heavy vegetation at septic tank
access port).
How often are septic systems/holding tanks cleaned? Have
any operational problems occurred?
JL.
-------
Other Information
What chemicals are stored on site? This would include any
process chemicals such as paints, solvents, oils, etc.
Where are the chemicals stored and in what quantities are
they used? Obtain Material Safety Data Sheets (MSDS) for
any chemicals contained in waste streams discharged to Class
V disposal systems.
Are waste oils generated at the facility? If so, how are
they disposed of? Obtain an invoice' demonstrating that the
facility has waste oils hauled.
What hazardous wastes are generated at the facility? What,
process generates the wastes? Where and how are they
stored? How often are wastes hauled? Obtain or observe
hazardous waste manifests from the facility contact. Note
the waste generator ID number and EPA waste stream numbers.
If the facility utilizes solvents, paints, or other
hazardous, chemicals but: claims that no hazardous wastes are
generated, question the facility contact in regard to
disposal methods of waste products.
Are there any underground storage tanks (USTs) on site? If
so, where- are they located? Note tank sizes: and contents.
When were the USTs last pressure- tested?
Does, the facility discharge wastes- to surface waters? If
so, does the facility operate under an NPDES permit for
surface discharge to creeks, or tributaries?
How does the facility receive its water supply? If there
are supply wells on site, locate them on the site map. Does
the facility use the water for drinking purposes? If not,
why not? Obtain any water analyses available. Obtain water
supply well construction and depth information. Obtain
depth to water (static water level) information.
Are there any monitoring wells on site? If so, where are
they located, why were they installed, and how are they
constructed?
-------
Checklist for Documents to Request from Facility Contact
Map of Facility/Plumbing Plans
Flow Diagram of Processes, Waste Generation, and Disposal
Pertinent Material Safety Data Sheets
Invoice Demonstrating Waste Oil Hauling/Reclaiming
Manifests Demonstrating Hazardous Waste Disposal
As-built Diagrams of Injection Wells
Reports on Well Performance or Maintenance
Records of Injectate Composition and Volume
Drillers' Logs or Wireline- Logs (if applicable)
Water Supply Well Location and Construction Data
Water Quality Analyses
Reports- on Site Hydrogeology, Other Regulatory Agency
Investigations
Monitoring Well Location and Construction Data
4
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GUIDELINES FOR PROPER MAINTENANCE OF A FIELD NOTEBOOK
The field notebook normally serves as a place to record data
for later use in the office. It may, however, be used in
litigation, or as evidence in court. As such, it represents
an. official document which should provide an objective
record of both the normal and the abnormal. Accordingly,
personnel are asked to. adhere to the following guidelines
regarding field notes.
Notebooks must be bound and contain water resistant pages.
All entries should be clearly legible and in ink. The
notebook should contain the employee's name and company
identification. Each page should be numbered, front and
back, with no skips. In the event, a page is left blank,
draw a. single diagonal line across the page, write "Blank
Page," and initial the entry. Deletions should be lined out
with a single line and initialed..
Entries for field days, should include the time you left home-
or office, destination, mode of transport, time of arrival
at. the' destination, weather conditions, and activities
planned.. The names of all personnel with whom you have
contact should- be noted. These might include client,
representatives, subcontractors, observers, regulators,
guests and. visitors.
The end of any given field day should also be noted. If for
some reason a log book is discontinued, the notation, "Log
Closed" with date and name should be written on the last
page. If the book is full, note "continued in book
Profanity, jokes, or reference to anyone's character should
specifically not be recorded. Remember that the field book
is a serious document and that lawsuits have been won and
lost based on the information contained in a field notebook.
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CLASS V SAMPLING
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SECTION 15
SAMPLING OF CLASS V INJECTION WELLS
This section contains material associated with. Class V
sampling operations. Particular topics discussed include:
Lab Selection
Sampling Point Selection
Sampling Equipment
Sampling Containers
Sampling Methods and Procedures
Quality Assurance/Quality Control
Sample Collection
Types of Samples and Analyses
Sample Documentation and Shipment
Field Modifications
Health and Safety SOP
Typical Sampling Event
15-1
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DISCUSSION This section provides a summary of Class V
sampling activities. Let's turn to the Sampling
Section in the Class V Addendum.
We will review together "Standard Operating
Procedures for Injectate and Sediment Sampling at
Class V Facilities" and "Standard Operating
Procedures Concerning Health and Safety During
Sampling at Class V Facilities."
The Standard Operating Procedures (SOPs) were
developed in response to EPA. guidance for develop-
ment of SOPs for any routine activities carried
out under EPA direction. The SOPs are continually
updated as additional experience is gained.
We'll begin by reviewing the Standard Operating
Procedures for Sampling.
LAB SELECTION
Several factors must be considered when selecting
a laboratory for analyzing samples.
As pointed out on page 3 of the Sampling SOP, a
laboratory operating under the EPA Contract Lab
Program (CLP) should be used whenever possible.
CLP labs are familiar with EPA protocol.
The contract Lab Program is the only
national certification-type program.
15-2
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Efforts should be made to locate a laboratory
which is in close proximately to sampled sites in
order that samples may be hand-delivered.
A State-certified lab may be used if approved by
the EPA Region. States can supply a list of labs
along with the types of analyses they are
certified to run. This is generally determined by
standard samples which are sent by the State for
analyses (i.e.Oklahoma Water Resources Board,
Mew York Department of Environmental Protection).
The lab chosen must retain all equipment,
maintenance and calibration records, sample
information and results, plus all lab data for the
required time frame designated by EPA.
The selected lab must also be able to run analyses
by requested methods and meet internal quality
assurance/quality control (QA/QC) requirements
(i.e., split samples, standards).
SAMPLING POINT SELECTION
The goal of sampling investigations is to
characterize the injectate at the point of
injection (we want to know what contaminants are
entering the subsurface). Therefore, the sampling
point selected should be as near to the injection
point as possible.
15-3
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It is preferable to sample after all pretreatment;
however, this is not always possible. Always
sample as far downstream from the source as
possible. For instance, in the case of discharge
to a seepage pit or well, the most desirable
sampling point is the actual well containing fluid
which has passed through all pretreatment systems
and is destined for injection.
SAMPLING EQUIPMENT
Sampling equipment includes the following items:
SLIDE #15-1 Modified Pond Sampler
- The pond sampler consists of an
adjustable telescoping aluminum pole
(swimming pool skimmer pole) with an
adjustable stainless steel C-clamp. A.
stainless steel beaker can be attached
(the beaker size can vary; typically
1000 ml.)
- The pond sampler is used when access to
the sampling point is easy (i.e. bay
sumps, catch basins).
SLIDE #15-2 Bailer
- We carry both stainless steel and teflon
bailers. Dimensions are about 2" in
diameter (1 7/8") by 3' in length.
- Bailers are generally used to sample
small-diameter wells, septic tank clean-
outs, and catch basins where the fluid
depth is greater than the length of the
pond sampler.
In these cases, a rope is attached and
the bailer is lowered into the well or
basin, etc.
15-4
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SLIDE #15-3 Nalgene Beaker
- A nalgene beaker is used for liquid
sample transfer, mixing, and splitting.
Oil-Water Interface Probe
- An oil-water interface probe is used to
determine the exact: depth to fluid or
depth of any floating phase, and can be
used to measure total depth.
- How it works: Distinct tones designate
oil and water; the line is marked off in
5 foot intervals; a tape measure is used
to measure exact footage between the top
of the floating phase and the water.
SAMPLE CONTAINERS
Sample containers must be compatible with the
conditions expected during the sampling event.
Typical containers are illustrated on pages 8 and
9 of the sampling SOP.
Fluid Containers
Samples for volatile organics analysis
(VOA) are taken in two-40 ml. glass
vials with teflon septa.
- Each metals sample, including total,
dissolved, EP toxicity, or TCLP is taken
in one-1 L. plastic bottle (a
preservative is included for total and
dissolved metals analyses).
- The ignitability sample is taken in one-
1 L. amber glass bottle.
Sediment Containers
- The EP toxicity metals sample is taken
in one-500 ml. glass jar.
- Volatile organic analysis (VOA) samples
are taken in two-250 ml. wide-mouth jars
with teflon lids.
15-5
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All sample containers and preservatives
generally are suppled by the lab.
BASIC SAMPLING METHODS AND PROCEDURES
The following procedures are recommended for
sampling:
Preliminary Activities
- A site-specific sampling plan should be
completed for each site prior to
sampling. The plan should be attached
to page 41 of the SOP. We will go over
filling one out a little later in the
presentation.
- All sample data sheets, tags, labels,
and custody seals should be completed
prior to conducting sampling (saves time
in the field).
- All notes should be recorded in a bound
field notebook.
Site Entry
- The samplers should show credentials and
provide a Notice-of-Sample-Collection
form. A copy of the form is found on
page 12 of the Health and Safety SOP.
- The Notice-of-Sample-Collection form was
developed to inform the operator that
samples will be collected, and to get
(in writing) his/her denial of the need
for a split sample. The operator's
signature on the form also verifies that
a disposal bucket containing possible
hazardous waste was left with the
operator.
Site Reconnaissance
- Basically, a guick reinspection of the
site should be performed, verifying
sampling points and site conditions, and
confirming decisions made with regard to
which samples are to be obtained and
which sampling equipment is to be used.
Note any modifications made to the site-
specific sampling plan.
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Operations Set-Up
- The sampling van should be parked in a
location convenient to all sampling
points so that it will not have to be
moved during sampling operations.
- The decontamination station should be
set up.
- As required by the Health and Safety
SOP, work space air monitoring should be
performed prior to sampling.
SLIDE #15-4 Equipment Decontamination
- All necessary sampling equipment should
be decontaminated prior to and following
each sampling event (i.e., if 2 points
are- sampled at the same site, 3
decontaminations are necessary).
- Decontamination involves the following
steps:
1. Disassemble all equipment.
2. Wash with tap water and non-phos-
phate detergent (alconox).
3. Rinse with tap water.
4. Squirt rinse with acetone or
isopropyl alcohol (if sampled waste
was oily).
5. Rinse with deionized water.
6. Squirt rinse with certified, metals
free/organic free water (supplied
by the lab).
15-7
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QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
Quality assurance (QA) is the process of assuring
that data obtained are technically sound and
properly documented. Quality control (QC)
procedures are employed to measure the degree to
which guality assurance objectives are met. The
following are common QA/QC measures:
Equipment Blanks
Equipment blanks are taken immediately
after the initial decontamination for
all fluid analyses to be conducted.
- Use metals free/organic free rinse water
to fill sample containers.
Label as other samples are labeled in
order that lab personnel will be unaware
that the sample is a blank.
Equipment blanks are required for 10% of
sampled sites; however, we generally
take blanks more often to provide solid
enforcement-quality data.
Trip Blanks
- These blanks are lab prepared. one
should accompany each transport cooler
full of samples.
Replicate Samples
- Replicates are generally collected for
10% of total sampled sites (1 of 10).
- Replicates need to be true splits of
sample (VOAs); must be filled from the
same bailer-full or poured from the same
beaker dipped. Metals and EP toxicity
(metals) are composited, mixed, and
poured up.
- Label replicates as separate samples (so
that the lab won't know that it's a
replicate).
15-8
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Background or Transfer Blanks
- A background blank is taken if samplers
suspect that the atmosphere may contain
volatiles.
- A transfer blank is taken at the
Region's request; when equipment blanks
are taken, the blank is poured directly
from the mineral free, organic free
water container.
SAMPLE COLLECTION
First, the oil-water interface probe is used to
determine the presence and extent of any free-
floating phase, depth to water (fluid), and total
depth of the sampled system. The probe is useful
for the following reasons:
If sampling a well, you get an idea of the
quantity of free product typically present.
Use of the probe can help determine if
separate phase samples are obtainable. Some
Regions request separate phase samples if
there is greater than 2" of floating product
and you are sampling from a shallow sump.
The floating phase is collected first by use
of a beaker which must be dipped carefully.
The floating phase is skimmed and is then
transferred to containers. The fluid beneath
the floating phase is then sampled by
directly filling containers. To date, this
procedure has never been performed.
The interface probe can help determine the
depth to sediment (if obtainable). Sediments
are collected with the pond sampler.
15-9
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After taking measurements with the oil-water
interface probe, samples are collected. Liquid
samples are collected first and sediment samples
are collected second. As described earlier, a
bailer and/or pond sampler are used to collect
samples. If possible, each should be lowered
approximately 2 feet below the fluid surface.
TYPES OF SAMPLES AND ANALYSES
Liquid Samples
Liquid . samples are always collected before
sediment samples. Liquid samples are taken for
the following types of analyses:
Volatile Organics Analysis (VOA)
This is the first sample collected in order
to limit disturbance and prevent the loss of
volatiles in the liquid to be sampled. The
sample is carefully poured to form a meniscus
at the lip of the vial, and is capped so that
no head space or air bubbles are present.
This is easier said than done; oily or soapy
samples make it much harder to eliminate head
space. From field experience, prechilled VOA
vials assist in controlling head space.
15 - 10
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The analytical method requested is EPA Method
624 or Method 8240, as described in SW 846.
These methods detect extractable volatile
organic compounds by purge and trap GC/MS
Analysis.
The VOA is performed because it can detect:
- Hazardous wastes, such as solvents
denoted under RCRA, 40 CFR, Part 261.31.
If present, the well would be classified
as a Class IV well, which is banned.
Exceedance of EPA Drinking Water Maximum
Contaminant Levels (MCLs) or Health
Advisories (HA). Such exceedances may
constitute potential endangerment.
The maximum holding time before running a VOA
on the sample is:
- 7 days for unacidified; and
14 days for acidified (HCl).
Semi-Volatile Organics Analysis
This type of analysis is rarely performed;
however, it may be appropriate if the waste
stream is suspect for semi-volatile organics.
Metals Analyses
A determination must be made in regard to the
type of metals analysis to run (i.e., total,
dissolved, or EP toxicity). This determina-
tion should be made by the EPA Region.
Unless otherwise specified, each of the
metals analyses are run for arsenic (As),
15 - 11
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barium (Ba), cadmium (Cd), chromium (Cr), lead
(Pb), mercury (Hg), selenium (Se), and silver
(Ag).
Total Metals Analysis
- An unfiltered fluid sample is taken and
transferred to a 1 L. plastic bottle
containing HN03 in a sufficient volume
to acidify the sample to a pH of less
than 2.0. This should be checked by the
samplers with litmus paper and addition-
al HNO3 should be added, if necessary.
- The lab digests the sample with heat and
HNO^ to free all chemically bound met-
als. Each metal is then run by the
approved EPA method AA or cold vapor
(Refer to page 26 of the SOP, Table 4).
- The problem in using this type of metals
analysis is that the analysis also
determines the metal content of particu-
late suspended materials. Once inject-
ed, the suspended materials do not
actually travel with the liquid
(suspended material settles or is
filtered by the injection zone).
- The Maximum holding time before running
the analysis is 39 days for Hg, and 6
months for the other metals.
Dissolved Metals Analysis
- The fluid is filtered in the field
through a 0.45 micron membrane filter
and is acidified to a pH of 2.0 or less
(AA) .
- The lab uses the same method as with
total metals samples, except that diges-
tion is only required if a precipitate
forms.
- When filtering in the field, oily sam-
ples may present serious filtration
problems, and often require multiple
filter membranes.
15 - 12
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The maximum holding time for the analy-
sis is 39 days for Hg, and 6 months for
all other metals.
Toxicity Analysis
Due to the problems associated with the
total and dissolved metals analyses,
only the EP toxicity analysis for metals
is typically run, unless the presence of
pesticides and herbicides is suspected
(see page 28 of the SOP, Table 5.
The fluid sample taken is not filtered
or acidified prior to being submitted to
the lab.
The lab separates the solids from the
liquid ASAP and determines whether there
are greater than 0.5% solids present
(see schematic on page 29 of the SOP).
To date, there has always been less than
0.5% solids; therefore, the liquid is
treated as the extract and the metals
are run either by AA or cold vapor
methods (Hg), as mentioned before.
The EP toxicity analysis is performed
because:
o It can detect EP toxicity metals in
a liquid. A liquid can be defined
as an EPA hazardous waste by char-
acteristics of EPA toxicity (see
page 28 of the SOP, Table 5). If
present at certain levels, the well
may be a Class IV well, which is
banned.
o A large amount of time is saved in
the field (no field filtering).
o Metals concentrations below toxic
levels can still be used to
indicate endangerment based on EPA
Drinking Water Maximum Contaminant
Levels and Health Advisories. .
15 - 13
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o A fluid is considered hazardous due
to toxicity if these EP Tox metals
levels are exceeded:
As
5.0
mg/L
Ba
100.0
mg/L
Cd
1.0
mg/L
Cr
5.0
mg/L
Pb
5.0
mg/L
Hg
0.2
mg/L
Se
I/O
mg/L
Ag
5.0
mg/L
- If there are greater than 0.5% solids in
the sample, the metals concentration
extracted from the solids portion is
combined with that of the fluid.
- Most Regions have decided that the
analysis used for EP toxicity-metals is
the most economically feasible.
- A possibility exists that the Toxicity
Characteristic Leaching Procedure Test
(TCLP) 40 CFR, Part 268 App. 1, could
replace both the VOA and EP toxicity
analysis when fully approved, since it
is designed to determine the mobility of
both inorganic and organic contaminates
present in liquids and multiphase waste.
- The analtyical method requested is EPA
Method 1310 (from SW 846).
- The holding time for the extract is 6
months.
Ignitability Analysis
If a fluid is ignitable, it is characteristi-
cally hazardous, as defined in 40 CFR, Part
261.21.
15 - 14
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The analytical method used is Method 1010
from SW 846 (Pensky Martin Closed Cup
Method); a flash point of less than 60°C
(140°F) is considered ignitable.
The holding time for the sample is 14 days.
pH, Temperature, and Conductivity Analysis
(see page 32 of the SOP)
This is a field test; the sample is obtained
with a temperature compensated pH/conductivi-
ty meter; pH values are recorded in the
appropriate place in the site-specific plan.
The pH probe is calibrated at every site (a 2
point calibration is performed bracketing
the expected pH - typically a pH of 7.0 and
10.0 buffer solution is used for repair bays,
where pH is expected to be slightly caustic;
and a pH of 4.0 and 7.0 is used for
industries such as electroplaters).
The pH sample is split into 3 beakers and the
pH is determined on each. Each pH value must
be within 0.1 of the others.
If the pH is less than or equal to 2.0, or
greater than 12.5, the waste is defined as a
characteristically hazardous corrosive waste,
as defined in 4 0 CFR, Part 261.22.
15 - 15
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Other fluid analyses which have been
requested by some EPA Regions include
reactivity, BOD, COD, total phenol, and
ethylene glycol analyses.
sediment Samples
Sediment samples are always collected after all
liquids samples are obtained. As mentioned earli-
er, sediment samples are collected with a pond
sampler. Analyses performed on sediments include:
VOA
Method 8240 is used; sample preparation is
the only difference.
EP Toxicity - Metals only
The analysis determines which metals are
mobile and will leach out of the sludge under
a pH condition of 5.
Sediment samples can help determine if a sludge is
characteristically hazardous.
SAMPLE DOCUMENTATION AND SHIPMENT
The following steps should be taken to ensure
proper documentation- and shipment of samples:
Affix the container labels, which are
generally supplied by the lab. Each lab
supplies slightly different labels, but
labels should always include the sample
number, analysis requested, date and time of
collection, collection point, and names of
samplers; all should be recorded in
indelible ink.
15 - 16
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Sample tags made of tyvek should be filled
out with indelible ink and placed in each
baggie with the sample bottles. These are
used in case the bottle label smears due to
leakage.
Parafilm lids if samples are to be shipped.
Place each sample container in a baggie with,
a tyvek tag; remove air, seal, and place the
custody seal around the baggie.
Chill samples.
Hand deliver or pack for shipment to the lab.
The Department of Transportation (DOT)
requires high concentrations to be packed in
tin containers such as paint cans (this is
rarely required).
Typically, pack the chilled samples in a
cooler lined with a plastic bag. Fill the
bag with vermiculite, tape the bag shut, put
ice on top, and seal the cooler with strap-
ping tape and a custody seal. It is helpful
to complete labels, tags, and custody seals
before going into the field; then fill in the
blanks as required.
A sample data sheet will be filled out for
each sample collected and kept as part of the
permanent record along with the site-specific
sampling plan. The sheet helps to identify
the sample, matrix, and analysis (see page
38 of the SOP).
A chain-of-custody form will accompany the
samples from the field to the laboratory (see
page 39 of the SOP).
All decontamination fluids, excess fluids and
sludges from samples, along with rags, paper
towels, coveralls (Tyvek), and gloves which
have contacted the fluid or sediment, will be
disposed of in a 5-gallon bucket and left on
site as discussed in the Notice-of-Sample
Collection form.
15 - 17
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FIELD MODIFICATIONS
Any deviation from the SOP or modifications made
to the site-specific sampling plan must be
completely documented in the plan.
We will now review Standard Operating Procedures
concerning Health and Safety.
HEALTH AND SAFETY SOP
Field inspectors/samplers must complete a 40-hour
approved health and safety training course for
hazardous waste site workers and have 3 days field
experience under a trained and experienced
supervisor.
In addition, an 8-hour annual refresher course is
required.
Prior Preparation
A health and safety site plan should be
completed from inspector notes and other
resources.
On-site Procedures
Site reconnaissance must be conducted to
verify points noted during the inspection and
to make sure the health and safety site plan
addresses them.
15 - 18
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Operations Set-Up
A first aid station is typically set up on
the front dash board and front passenger seat
of the sampling van. The station includes:
- First aid kit;
- Eye wash;
- Respirators;
- Potable water;
- Fire extinguisher; and
- Site health and safety plan (with map to
hospital and MSDS for chemicals).
Air Monitoring
Air monitoring is generally required when
sampling pure product from drums, or when
sampling in an enclosed area (i.e. service
bay) . In an open air environment (outside),
there may be no need to monitor the air. Do
not stick you head into the well.
Air monitoring equipment includes:
- Instruments used to measure organic
vapors. These include the HNU meter,
organic vapor analyzer (OVA), and
organic vapor monitor (OVM).
- Combustible Gas Indicator (CGI) measur-
ing 02 and H2S levels.
Background readings should be taken near the
sampling van (not running), work space, sump,
and/or well bore.
Readings should be recorded in the field
book, as those on page 5.
Weather conditions affect the HNU; therefore,
it is important to record the relative amount
of moisture and the temperature.
Upgrading to Level C respiratory protection
from Level D is indicated when a 10 ppm
increase over background is observed with the
HNU.
15 - 19
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If Level B is required, do not sample. This
would occur when:
- 02 reading < 19.5%;
- Detection of H2S occurs at any level;
- Any enclosed space,which is not used on
a daily basis, must be entered.
Sampling is not to be conducted when:
- The Lower Explosive Limit (LEL) exceeds
20% or greater than a readout of 20 on
the digital Combustible Gas Indicator
(CGI).
All air monitoring is covered in-depth during
the 40-hour health and safety course.
Participants get the opportunity to use the
instruments and learn about protective
equipment.
All sampling is typically conducted in Level
D equipment, with double-glove (inner
surgical and outer neoprene/ plastic)
protection for hands (Level C); hands are
routinely immersed and should be protected.
Outer gloves should be decontaminated prior
to and following sampling operations.
Personal protective equipment and the routes
of exposure were covered previously in the
training course.
15 - 20
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Health and Safety Plan
A site Health and Safety Plan must also be
completed for each facility to be sampled (see in
Class V addendum). The plan is basically a fill-
in-the-blank form.
The most important items include:
Emergency phone numbers;
A map depicting the route to the hospital;
MSDS; and
Unusual physical features such as power lines
or automobile traffic.
A safety review meeting must be conducted at each
site prior to sampling. The meeting should be
held on-site with sampling and all regulatory
personnel present. Each attendee must sign the
last page of the health and safety plan indicating
that he/she was present at the safety meeting.
TYPICAL SAMPLING EVENT
We will now run through a typical sampling event
together. We will begin by reviewing the
inspection notes. Then we will complete a site-
specific sampling plan (see the Class V addendum).
You have reviewed all the day's inspections; one
site ranked extremely high; however, you did not
personally conduct the inspection.
15 - 21
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A septic tank accepts effluent from both a
drainage sump in a repair bay and a floor drain in
a paint booth at a small garage and auto body-
shop. The septic tank has an access port to both
chambers.
From the septic tank, the waste discharges to a
drainfield with a monitoring tube. Fluid is
present in the monitoring tube.
The septic tank chamber cover is approximately 2
feet in diameter, and fluid depth within the tank
is approximately 4 feet from the surface. The
diameter of the monitoring tube is approximately 4
inches, and depth to fluid is approximately 8
feet.
The sump in the repair bay appeared to be very
oily during the inspection. The service bay sump
measures 3 feet by 2 feet; Fluid depth in the
sump measures 6 inches.
A paint booth measures 10 feet by 12 feet and
exhibits a very shallow slope to floor drain.
Waste oil and solvents are hauled for recycling;
no Material Safety Data Sheets (MSDS) are
available.
Please turn to the blank sampling plan found in
the Class V Addendum.
15 - 22
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First of all , the cover page of the sampling plan
should be completed.
Page 3 of the sampling plan depicts various
sampling points which may be encountered. For
this example, the dimensions of the monitoring
tube should be documented. This is the primary
sampling point.
The secondary sampling point is the septic tank.
Its dimensions should be noted on page 3, also.
A third sampling point will probably not be
necessary as back-up, but you may want to take
sediments from the sump in the repair bay; if so,
fill out the appropriate section on page 3.
Page 6 contains the Potential Contaminant
Checklist. Let's run through the checklist
quickly.
On page 7, we find a schematic of samples to be
collected and analyses requested.
For liquids, we would normally collect samples for
VOA, ignitability, and EP toxicity-metals. For
sediments, we would normally run EP toxicity-
metals.
Page 9 includes an equipment checklist. This
should be checked before going to the field.
15 - 23
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Page 10 contains a checklist for sample
containers.
Page 11 contains sample data sheets. one should
complete a form for each sample taken. Fill out
labels, tags, and custody seals as completely as
possible.
The basic steps involved during the sampling trip
are listed below:
Arrive at the site.
The samplers should show credentials and fill
out the Notice-of-Sample Collection form.
The facility operator should sign the form.
Site reconnaissance should be conducted. In
our example, you would see the sump, paint
booth, and septic tank.
The safety meeting should be conducted; no
new hazards are identified.
The oil-water interface probe should be
decontaminated before other equipment. The
depth of fluid in the monitoring tube should
be checked; only 2 inches, an insufficient
volume to obtain a sample; so a secondary
sample point will be chosen.
Changes should be noted under field
modifications, which should be page 11 of the
site-specific plan.
Collect the samples (no problems).
Clean up the decontamination station. All
fluids and materials which contacted the
fluid should be placed in the disposal
bucket. This includes the plastic sheeting
placed beneath the decontamination wash tubs.
Label the disposal bucket as mentioned
earlier.
15 - 24
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Leave the bucket and a copy of the Notice-of-
Sample Collection form with the facility
operator.
Leave the site.
15 - 25
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HYPOTHETICAL SITUATIONS'
-------
SECTION 16
HYPOTHETICAL INSPECTION SITUATIONS
CLASS II WELLS
This section, contains eleven cases with hypothetical
situations which might arise while conducting inspections of
Class II wells. Each case provides a background description, as
well as questions and answers for class participants.
16-1
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CASE #11-1
You arrive at the well to perform an inspection. The: completion
is conventional. The injection is intermittent and the pump is
on the down cycle. How should you proceed with the inspection?
Check the tubing pressure.
If positive, check the annular pressure.
If both the annular and tubing pressures are zero:
- Wait for the pump to kick on. Then check both pres-
sures again.
If operator is present, have him initiate injection.
you turn the pump on without the operator?
No. Either:
Come another day or time; or
- Contact the operator.
Why conduct an inspection?
Field Presence
Monitoring Equipment
Well Status
Photo Documentation
Should
16-2
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CASE #11-2
You arrive at the location to run the standard annular pressure
test. Tubing pressure is 800 psi, and the annulus pressure is
zero. At what pressure is the test to be conducted?
The test should be conducted at the pressure required by
the EPA Region or State that you are working in. This
test pressure is usually 300 psi for 30 minutes.
Is it necessary to run the MIT at a higher pressure than tubing
pressure?
No. If tubing pressure is high (such as 800 to 1000
psi), running the MIT at a pressure above tubing pressure
will possibly cause casing damage. In old wells, the
casing may have deteriorated to a point that it may not
hold if subjected to a large amount of pressure. Testing
a well at a high pressure may cause more problems than
the results will justify.
If tubing pressure is substantially higher than annular pressure,
doesn't annular pressure verify lack of tubing and packer leak?
Yes. If the tubing pressure is at 500 psi and annular
pressure is zero, you can assume that there is not a leak
in the tubing and packer.
When testing wells with tubing pressure, the main thing
to remember is that you need to have a differential of at
least 100 psi at the packer between the annulus pressure
and the tubing pressure. The specific gravity of the
injectate and the annular fluid also need to be
considered.
16-3
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CASE #11-3
You have contacted an operator about performing an inspection.
He indicates that the pumper is difficult to contact and has no
problem with you performing an inspection in his absence. Upon
arriving at the well site, you visually observe the annulus
pressure to read 1,000 psi and there is no gauge on the tubing.
How should you proceed with the inspection? Should the gauge be
removed to verify the annulus pressure?
Ascertain the tubing pressure if possible.
Do not attempt to remove the annulus pressure gauge.
Return to the injection plant.
Check the injection plant for indicators of tubing
pressure.
- Is the pump running?
- Check chart recorders.
Sample tap at the pump (access tubing pressure at
the pump).
- Take pressure reading off of gauges (if present).
- Note pressures, date, and time.
- Call to notify the operator of findings.
A phone call to the operator indicates that the operator is aware
of the problem with the well. What should you do?
Indicate that the well needs to be brought back into
compliance.
Suggest that the operator cease operation until such work
has been completed.
- Unless you work directly for the EPA or State
Agency, inspectors cannot tell an operator to shut
the well in. Inspectors can only suggest that the
operator shut the well in until he works the well
over.
Indicate that an MIT will need to be run subsequent to a
workover, before reinitiating injection.
16-4
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CASE #114
The EPA Regional office received a letter indicating that the
operator's lease was protected by Smith, and Wesson. At a later
date, having been informed of the> requirement to perform an MIT,
the operator contacts the inspector to set up the test. As an
inspector, how do you handle this situation?
Contact the regional supervisor.
The supervisor may advise legal counsel of the situation.
Legal counsel may suggest that if the inspector felt
threatened, that the services of a federal marshal would
be warranted.
A State conservation officer or equivalent may accompany
the inspector. The inspector should keep a low protect-
ive profile.
16-5
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CASE #11-6
In. route to your favorite trout stream, you notice that the
retention pit located near the tank battery of production
facilities is receiving a good 2*' stream of produced water front
the water tank. The pit is full and the levee has been broken,
allowing water to flow out. The tank battery is located 1/4 mile
from the creek. Tracing the stream of discharge proves that
water empties into the creek. What do you do?
Note the date, time, and occurrence.
Recognize the incident as a potential surface discharge
violation.
Notify appropriate NPDES or equivalent State program
representative of your findings.
Call the operator to collect information regarding the
situation.
16-7
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CASE #11-7
A. well is constructed with 5 1/2" surface casing, and 2 3/8"
tubing set, cemented, and perforated into the injection interval.
Injection occurs down the tubing in this well. Other wells in
the field are conventionally completed and are being tested by
arching from the injection line to pressurize the annulus.
Pressure does not exist at the injection line because of leaks up
the line. The well has been idle for an undisclosed period of
time. The operator contends that the well requires 2,200 psi to
initiate any fluid movement (the reason for cessation of
injection activities). Tubing pressure reads 1,000 psi and
remains so the following day. The operator contends that the
fact that it takes 2,200 psi to initiate flow indicates that the
perforations are impervious and act as a bottom hole plug.
Discuss.
This well could be tested by:
- Bleeding the tubing pressure back to zero if
possible; see if the tubing repressurizes overnight.
If not, run a pressure test.
- If so, set a retreiveable bridge to isolate the
tubing from the injection zone. Run a pressure test.
- Run a radioactive tracer survey to demonstrate
internal mechanical integrity.
16-8
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CASE #11-8
You arrive at the location to perform a routine inspection and
find this scenario. Water around the wellhead bubbles slightly,
but steadily. Subsequent inspections reveal a similar situation
at 3 to 4 more wells in the area. What do you do?
Question the pumper about the existence of the fluid
migration.
Take photographs of the wells for documentation.
The pumper claims to have never noticed the occurrence,
completion of inspections is followed by discussion with the
field foreman, whom confirms prior knowledge of the situation.
He also volunteers to pump the cellar to identify the source of
the problem.
Contact the Regional supervisor.
Have the operator talk with the Regional office before
conducting any work.
Further contact with operator representatives indicates that the
situation was first noticed in a plugged well. The well was re-
entered and steps were taken to eliminate the fluid migration.
The source was identified as hydrocarbon from an underlying gas
storage zone. Is this situation enforceable under the UIC
program?
No. See 40 CFR, Part 144.6 (b)(3); must be liquid under
standard conditions to be UIC enforceable.
The gas is apparently moving behind the surface casing, to the
surface. Do these wells have mechanical integrity?
Yes, if they passed the internal MIT. External MI is
questionable, but if well passed other external MIT test
then well has mechanical integrity.
What do you offer as a solution to this situation?
Have the operator contact the gas storage company. Help
them work out a method to fix the problem.
16-9
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CASE #119
You are asked to run MXTs with a nev operator of a recently
purchased lease. After performing several tests on wells
throughout the field, you arrive at a well which has bull plugs
located on both sides of the wellhead. The tubing pressure is-
determined to be approximately 1,900 psi. All the wells in the
field are conventional completions; that is, a standard annulus
pressure test needs to be performed. Discuss.
Attempting to remove either bull plug could be extremely
dangerous in this situation. If there is a tubing or
packer leak in this well, then there is 1,900 psi on the
annulus. One turn of either bull plug with a pipe
wrench could result in failure of the threads. The
result would be a projectile with the velocity to do
serious damage to health or property. Do not attempt to
remove the bull plug.
Do not allow the operator to attempt to remove the bull
plug in your presence without your resistance. If the
operator insists on removing the bull plugs, do not stand
in the pathway of the bull plugs should they be shot
away from the wellhead.
Record the well as a failure until the operator proves
otherwise.
16 - 10
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CASE #11-10
You are conducting a routine inspection of a salt water disposal
well. Tubing pressure is found to be 1,500 psi. Annulus
pressure is 250 psi during inspection. The operator returns with
you to the veil to bleed off pressure. Discussion indicates that
pressure usually runs around 100 to 150 psi. What could explain
this- situation?
Consider the construction characteristics of the well.
Consider expansion and contraction characteristics due
to temperature as a possibility.
Open hole zones may be contributing pressure.
The inspector should check permit conditions. Some
permits are written with annulus pressure limits.
16 " 11
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CASE #11-11
The operator has been notified of the need to perform an
inspection. However, the operator was not present at the time of
the inspection. Upon entering- the injection plant, there is
noticeable evidence that discharge has been occurring at the
pump. Erosion has created a trench which cuts underneath the
shed. Exiting the injection plant, to view the fate of the
apparent discharge, reveals: the existence of a small pit dug by
the operator to contain the discharge. The injection isv
intermittent and the pump is not operating at the time of the
inspection. Is this a violation? On what basis?
The inspector should:
- Document the date and time. Take photographs.
- Contact the operator to confirm findings and gather
further information regarding the situation.
- Contact the appropriate State agency to confirm
permit approval or existence.
16 - 12
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HYPOTHETICAL SITUATIONS
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SECTION 17
HYPOTHETICAL INSPECTION SITUATIONS
CLASS V INJECTION WELLS
This section contains six cases with hypothetical situations
which might arise while conducting inspections of Class V
injection wells. Each case provides a background description, as
well as questions and answers for class participants.
17-1
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CASE #V-1
Your contact on an assignment is the service manager of a
corporate-owned gasoline service station. He gives to you the
Material Safety Data Sheets for the stored fuels at the site, as
provided by the corporate office. The contact claims to know
nothing of the construction of the disposal system at the
location. There is a floor drain located in the service bay
area, what should the inspector do?
Observe waste handling and disposal practices.
Observe the floor drain to check for fluid contents, note
the general nature of the contents, and photograph the
drain (if potentially harmful fluids are observed).
Determine if there is a municipal sewer system.
If so, ask to see a record of the city billing.
Determine the owner of the building.
Attempt to contact the owner.
Ascertain the construction of disposal systems from the
owner (request blue prints).
Categorize the Class V well appropriately (i.e., 5W11,
5X28).
17-2
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CASE #V2
The operator of a commercial dishwasher distributor provides
details of three septic systems located on site. One receives
solely sanitary wastes. The second system receives sanitary
wastes, but also accepts fluids from the sink in the shop area.
The third receives wash water from cleaning returnable containers
used in their blending operation. What is the classification of
each, well?
Determine the construction of Septic System 1.
- Classify as either a 5W11, 5W31, or 5W32 system.
Determine the potential contaminants from the sink
(System 2).
- System 2 may be classified as a 5W20.
System 3 is a 5W20.
17-3
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CASE #V3
While interviewing the operator of a service station, you are
informed that floor drains feed to a line which discharges to a
dry creek bed. What would be your course of action?
Ask for blue prints (seldom have) .
Ascertain the discharge point (i.e., the creek bed). If
found:
- Photograph.
- Indicate on facility map.
- Possibly run water into a floor drain to verify
information provided by the operator.
- Include an NPDES referral, if permit is not produced.
If the discharge to the creek bed cannot be found:
- Determine if the facility is on sewer.
- Request additional information to be mailed.
Classify as a possible 5X28 (the facility discharges
to the subsurface if it is not sewered, and if it
is not discharging to the surface).
17-4
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CASE #V-4
A single restroom and shop sink exist in the maintenance shop at
this municipal golf course (SLIDE #17-1). The restroom and sink
are located adjacent to and in the same building as the mower and
chemical storage area (SLIDE #17-2). While the sink was heavily
stained, no odor of paint or other chemicals could be detected.
What information is necessary to classify the system?
How many people does the system have the capacity to
serve?
Try to ascertain what goes down the sink.
Get construction blueprints from the facility operator?
if not available, ascertain as best as possible from
employees.
What chemicals are stored on site? Are MSDS available?
Are there any floor drains present in the chemical
storage area?
Of greater concern at this facility was a steam cleaning pad used
to clean the golf course eguipment. Such equipment includes
mowers, pickup trucks, and fertilizer sprayers. The pad drains
to a sump immediately below the wash area (SLIDE #17-3). What
information is necessary to classify this system?
Investigate the fate of the wash water.
Request blueprints.
Ascertain the constituents in the wash water.
During the inspection, a pesticide sprayer was being washed down
and the inspectors noted the surface discharge (SLIDE #17-4).
What does this indicate?
The wash pad is not associated with a Class V well.
Washing this equipment and discharging to the surface may
constitute an NPDES violation. An NPDES referral should
be completed and included with the inspection report.
17-5
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The important points to make in regard to this case are as
follows:
Many facilities operate disposal systems which do not
have construction blue prints. Interrogation of
employees is sometimes successful in ascertaining these
details. In this case, the location and well type were
identified by a long-term employee at the facility. The
well in question was determined to be a 5W10 (cesspool)
serving 20 persons daily and receiving solely sanitary
wastes. Details regarding the sink which discharges to
this system are not clear. These uncertainties are duly
noted in the inspection report.
Once again, determining the fate of the effluent from
the sump is critical. Construction plans were evidently
not furnished by the operator and the surface discharge
may have gone undetected under other circumstances.
The discharges observed at the site, due to the nature
of the facility and amount of equipment, is substantial.
The presence of fertilizers and pesticides, as well as
greases and oil, is evident in the wash water being
discharged. The decision to include an NPDES referral
with the UIC inspection report was appropriate in this
case.
17-6
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CASE #V-5
An inspection was completed at a large manufacturing complex
which produces semiconductors and associated components. The
first building on site was constructed in 1957 and expansion has
been ongoing since that time.
The area surrounding the facility in east Phoenix was proposed as
an addition to the National Priority List of superfund sites in
late 1984. Inclusion on this list would make the site eligible
to receive Federal superfund monies for activities such as
investigation and cleanup. The operator has assumed
responsibility for evaluating the extent of this groundwater
contamination problem and for implementing appropriate remedial
measures. These activities are being conducted under the
auspices of a state and Federal task force as outlined in the
project's Remedial Investigation/Feasibility Study work plan.
The work plan was approved by EPA in October of 1984.
In January of 1983, the facility confirmed a trichloroethane leak
in a virgin materials storage tank. Subsequent investigations
revealed extensive soil and groundwater contamination, associated
primarily with the company's past disposal practices.
Trichloroethene (TCE) and trichloroethane (TCA) have been found
under the facility at levels of 1,400,000 ppb (parts per billion)
and 750,000 ppb, respectively. Several other organic chemicals
and heavy metals have also been detected in lesser amounts. Off-
site groundwater monitoring has indicated that contamination has
traveled about one mile west of the plant boundary. Several
irrigation and unused domestic wells in the area have been tested
and found to contain organic pollutants, especially TCE. The
closest public drinking water well, however, is located more than
six miles from the plant. Ten storm-water drainage wells are
present at this site.
To date, the facility has drilled 33 groundwater monitoring
wells, including 23 multi-point wells, with this knowledge, how
should we proceed with the investigation?
Determine if contamination was the result of injection
practices. If so:
Determine the fate of the injection wells (plugged?).
Who conducted and supervised the plugging event (if
wells are plugged)?
17-7
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What should be considered to classify the 10 injection wells?
Are they susceptible to spills or receiving fluids other
than storm water?
Do the wells receive discharge from elsewhere? The
inspector must remove the grate or well cover to make
this determination~
Hake a physical evaluation of the liquid present at the
time. Note: Evidence is an indication of what is happen-
ing at that moment. Classify each well as a 5D2 if it
accepts solely storm water. Classify as a 5D4 if the
system is susceptible to accepting other fluids (chemi-
cals) . Classify as a 5W20 if industrial process wastes
are routinely discharged.
Also located on the facility were a number of wells used to
dispose of condensate generated by air conditioners on the
facility. How should the wells be classified?
Classify as 5G30.
17-8
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CASE #V6
The following case introduces a situation in which a violation
under another regulatory program could be helpful in identifying
a DIC violation. The facility in question manufactures ejection
seats and associated survival equipment for military aircraft.
This equipment includes small rocket motors and solid rocket
fuel. They began leasing this property from the State in 1972.
The whole operation has been at this 160-acre site since 1978.
There are 29 buildings and approximately 190 employees. Over 200
different materials are used in various manufacturing processes.
A list of these was supplied to the inspectors.
There are six septic systems which serve restrooms in various
buildings. There are two other subsurface disposal systems on
the facility property. One septic system with a dry well
receives wash water from an X-ray developing machine used for
quality control. This system was operating from 1978 to 1983/ at
which time the waste stream diverted to a dry creek bed on site.
From 1983 to 19 8 6/ the film developer wash was discharged
continuously to the creek bed. The facility was cited for an
NPDES violation regarding this discharge so they have reverted to
the septic system. Analyses of the film wash water indicate that
it exceeds National Primary Drinking Water Regulations standards
for silver, cadmium, and chromium. The total dissolved solids
level of the wash solution is very high. The system currently
discharges 3 gpm for an average of 2 to 3 hours per day.
The NPDES violation resulted in identification of the
disposal practice in this case. The field inspectors in
this instance sought and were supplied with analyses of
the film wash water. The analyses showed some
constituents to be in excess of the National Primary
Drinking Water Standards. The system in question
receives 360 to 540 gallons of effluent per day.
The inspection report included the following recommenda-
tion: "It is recommended that a sample of the film
developer wash water be collected and analyzed to verify
its composition. Because an on-site water well supplied
drinking water to employees, EPA may wish to require
monitoring of the developer wash discharge and/or water
supply well under a Class V permit."
Although not confirmed, the basis of the NPDES violation
was most probably due to the silver content in the waste
stream. The constituents of the discharge have not
changed unless the process which produces them has been
altered. Sampling of the waste stream could prove it to
be characteristically hazardous by EP Toxicity. If the
sampling effort supports this suspicion, the inspection
effort may identify the existence of a dry well disposing
of hazardous waste into USDWs. This defines a Class IV
injection well, which is declared illegal and banned
under RCRA and UIC regulation.
17-9
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FIELD WORK REQUIREMENTS
-------
SECTION 18
FIELD WORK REQUIREMENT SUGGESTIONS
USEPA training course field requirements for program-
specific training have not been established by EPA Order 3500.1.
The UIC inspector training course should contain a measure
of field involvement by the participating persons. Previous
training courses presented by the L.O.E. contractor have included
8 hours of field work (including drive time).
Some field activities should be planned based on the needs
of the Region(s) involved. The degree of knowledge within a
given group can be widely varied, and suitable field training for
all may be unattainable. This fact may alienate some members of
the group if the field activities do not stir their interest.
The field work for previous courses has been kept elemental to
address the needs of new inspectors. Each member regardless of
background, shall benefit in some regard from the work. This
section summarizes past activities planned by EEI to fulfill the
field requirements for the USEPA inspector training course.
18-1
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CLARKSVILLE, INDIANA
The group was led on a tour of the Dupont Louisville Plant.
The facility has two permitted Class I hazardous waste injection
wells. The facility tour was conducted in a manner similar to
that practiced during an actual inspection.
The group first sat down with Dupont personnel to discuss
background, nature of the facility processes, and waste
generation. This was followed by the facility tour to view the
well site and monitoring system. The-tour was completed with a
closing session to address any unanswered questions.
The afternoon field session was completed by visiting the
lease of an independent oil and gas operator. The small lease
was comprised of two producing wells and one Class II injection
well. The session was initiated by an introduction by the
operator at the injection plant. The group was then led to the
well site to view the wellhead configuration and equipment.
SAN FRANCISCO, CALIFORNIA
The group was transported to Modesto, California to witness
a number of municipal wells located throughout the city. The
class was able to view stormwater drainage (5D4) wells in both a
parking lot and loading dock.
Modesto contains a drainage basin designed to handle large
volumes of storm water. Drainage wells are intermittently
located along the length of the basin. The class was able to
take a close look at several of these wells.
18-2
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In addition to the Modesto visit, the class was given a
field demonstration of sampling equipment. A crate of equipment
was utilized to familiarize the group with material necessary to
collect acceptable samples from Class V wells. A mock sampling
station was set up, and each piece of equipment was identified
with its specific function.
DALLAS/ TEXAS
The group was transported to Sadler, Texas near Lake Texoma
to tour the Big Mineral Production Unit. The production fore-
man for the field led the class on a guided tour of the entire
unit. Beginning at the injection plant, the class watched the
start-up of injection wells which had gone down due to an
overnight power failure. The class was shown pumping units,
source wells, injection wells, dual completion separation
equipment, tanks, and the elaborate computer-controlled radio
system of transmission at Big Mineral. Four injection zones and
five production groups make Big Mineral a complex waterflooding
operation, necessitating an equally complex monitoring system.
Facility tours, although valuable from an exposure
standpoint, fall short of providing hands-on experience of
inspection work. There are a myriad of field training activities
which could be developed to enhance the knowledge of new
inspectors. It must be understood that most inspection-related
activities will require the cooperation and assistance of an
operator to conduct such activities. The Region participating in
the training course may choose the field training activities it
18-3
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considers most beneficial. Here are some suggestions for hands
on field activities, which could be arranged by the Regions:
Conduct a mechanical integrity test.
Witness a cased hole logging operation, such as:
- Radioactive tracer survey;
- Temperature log;
- Noise log; or
- Oxygen Activation log.
Witness remedial work, such as:
- Squeeze cementing; or
- Compliance remediation
Witness a plugging operation, which would involve:
- Determining cement tops;
- Pulling casing, tubing, and packer; and
- Calculating and pumping cement.
Conduct inspections (small teams).
Perform sampling.
Witness well construction activities.
Review injection well permits.
18-4
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CERTIFICATION TEST
-------
UIC INSPECTOR CERTIFICATION TEST
REGULATORY STRUCTURE
1) The National Pollutant Discharge Elimination Systems was
established by which environmental act?
a) Safe Drinking Water Act
b) Clean Water Act
c) Resource Conservation and Recovery Act
d) Toxic Substance Control Act
e) Solid Waste Disposal Act
2) Point source discharges to waters of the U.S. are
authorized by the:
a) Safe Drinking Water Act
b) National Pollutant Discharge Elimination Systems
c) Resource Conservation and Recovery Act
d) Toxic Substance Control Act
e) Solid Waste Disposal Act
3) Spill Prevention Control Countermeasure regulations were
established by which of the following?
a) Resource Conservation and Recovery Act
b) Safe Drinking Water Act
c) Clean Water Act
d) Toxic Substance Control Act
e) 40 CFR
4) Which program was established to protect USDWs from
endangerment by subsurface emplacements of fluids?
a) Underground Injection Control
b) National Pollutant Discharge Elimination System
c) Superfund
d) Wellhead Protection Program
5) The Underground Injection Control program was established
under which of the following?
a) Resource Conservation and Recovery Act
b) Clean Water Act
c) Safe Drinking Water Act
1
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6)
Management of hazardous waste falls under Subtitle C of
the:
a) Safe Drinking Water Act
b) Federal Water Pollution Control Act
c) Resource Conservation and Recovery Act
d) Comprehensive Environmental Response, Compensation and
Liability Act
7) Listed hazardous wastes are contained in:
a) Resource Conservation and Recovery Act
b) Solid Waste Disposal Act
c) Federal Water Pollution Control Act
d) Comprehensive Environmental Response Compensation and
Liability Act
e) 40 CFR
8) Which act mandated a study to be performed to determine the
effects of drilling fluids, produced water and other wastes
associated with production of crude oil and natural gas?
a) Federal Water Pollution Control Act
b) Safe Drinking Water Act
c) Resource Conservation and Recovery Act
d) Clean Water Act
9) List the four criteria by which a waste can be considered
characteristically hazardous as defined by RCRA.
1.
2.
3.
4.
10) Oil Pollution Prevention Regulations are established in:
a) Federal Water Pollution Control Act
b) Resource Conservation and Recovery Act
c) 40 CFR
d) Safe Drinking Water Act
e) Solid Waste Disposal Act
2
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11) The National Priorities List refers to which of the
following?
a) 40 CFR
b) Resource Conservation and Recovery Act
c) Safe Drinking Water Act
d) Comprehensive Environmental Response Compensation and
Liability Act
12) Name three of seven containment systems acceptable to
prevent discharged oil from reaching navigable waters.
1.
2.
3.
13) 40 CFR Part establishes criteria and standards for
underground injection wells.
a) 144
b) 145
c) 146
d) None of the above
14) The Land Disposal Restrictions Program regulates liquid
hazardous wastes or free liquids associated with treatment
of hazardous wastes.
a) True b) False
15) Transporters of listed hazardous wastes may store the wastes
for up to...
a) 5 days
b) 10 days
c) 15 days
d) 30 days
16) Dilution of wastes is allowed as a method of treatment in
the Land Disposal Restriction regulations.
a) True b) False
17) Name three areas that are prohibited for use as disposal
sites by the Land Disposal Restrictions Program.
1.
2.
3.
3
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UIC STRUCTURE
1) UIC Regulations are found in 40 CFR Part(s)...
a) 144
b) 146
C) 144, 145, 146
d) 144 through 148
e) None of the above
2) States which have primary enforcement responsibility for the
UIC program are called states.
3) States which have Federally administered UIC programs are
called states.
4) Match each well to its class of well type.
1.
Class
I
A.
Oil and gas enhanced recovery
injection well
2.
Class
II
B.
All other well types
3.
Class
III
C.
Hazardous waste injection well
4.
Class
IV
D.
Mineral extraction well
5.
Class
V
E.
Radioactive waste injection well
injecting above the USDW
5) Which of these is not a well according to the EPA
definition?
a) 24-inch casing driven 10 feet deep
b) A pit with surface dimensions 4' by 4' by 61 deep
c) A hole that is 4 feet deep and 6 feet in diameter
d) A drilled hole 12 feet deep and 6 inches in diameter
6) A well completed with casing, tubing, and packer is an
example of a completion.
7) Name three types of unconventional completions.
1.
2.
3.
4
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8) Which of these is not a Class III well type?
a) Frasch sulfur mining well
b) Enhanced recovery well
c) In-situ leaching well
d) Solution mining well
5
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V WELLS
How many subclasses of Class V wells have been identified to
date?
a) 16 b) 24 C) 32 d) 48
Which of the following represents a high-tech Class V well?
a) Improved sinkhole (5D3)
b) Cesspool (5W10)
c) Automobile service station disposal well (5X28)
d) Radioactive waste disposal wells (5N24)
e) None of the above
A 4' by 4' by 31 deep rock-filled pit located at an
industrial facility and accepting only storm-water runoff is
classified as a:
a) Storm-Water Drainage Well (5D2)
b) Industrial Drainage Well (5D4)
c) Special Drainage Well (5G30)
d) None of the above
drainage well located in a parking lot of an industrial
icility, designed to accept stormwater, appears to be
:cepting spills (stains on asphalt) from a chemical storage
ea located up-gradient. The well should be classified as
Storm-Water Drainage Well (5D2)
Industrial Drainage Well (5D4)
Industrial Process Water and Waste Disposal Well (5W20)
Special Drainage Well (5G30)
None of the above
'i of the following items should be noted at each
ction site?
~"he facility is connected to sanitary and/or storm
ewer
\e injectate is treated prior to injection
e construction date of the well
i and b
of the above
-------
10) Which scenario would most likely pose the greatest
environmental threat?
a) Service bay waste, treatment prior to injection,
nearest water supply well <1 mile, low permeability
injection zone, 100' vertical distance between
injection zone and currently used USDW
b) Electroplating waste, treatment prior to injection, 1/2
mile to water supply well, moderate permeability, 25*
vertical distance between injection zone and USDW
c) Silkscreening shop waste, no treatment, 3/4 mile to
water supply well, high permeability (karst), 75*
vertical distance between injection zone and USDW.
11) During a site inspection, the facility operator informs you
that all waste fluids generated are discharged to the city
sewer, except for storm water which is handled by drainage
wells. Therefore, you
a) only inspect the drainage wells and ignore a sump in
the service bay and a floor drain in the painting
booth.
b) inspect all drainage wells, sump, and floor drain.
c) verify that the facility is hooked into the city sewer
system.
d) a and c
e) b and c
12) What two well types appear to pose the greatest threat to
USDWs?
a) Industrial Drainage Wells (5D4) and Industrial Process
Water and Waste Disposal Wells (5W20)
b) Industrial Drainage Wells (5D4) and Automobile Service
Station Disposal Wells (5X28)
c) Industrial Process Water and Waste Disposal Wells
(5W20) and Automobile Service Station Disposal Wells
(5X28)
d) Industrial Process Water and Waste Disposal Wells
(5W20) and Untreated Sewage Waste Disposal Wells (5W9)
8
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SAMPLING
1) When sampling a Class V system, the preferred sampling point
is:
a) as near to the potential contaminants as possible
(drainage sump)
b) at an intermediate stage between the point of
origination and injection (septic tank)
c) as near to the injection point as possible (monitoring
tube)
d) none of the above
2) To avoid sample contamination due to equipment materials,
fluid sampling equipment should be constructed out of these
materials:
a) Teflon f) a, c, and d
b) PVC g) All are preferred materials
c) Glass
d) Stainless steel
3) Fluid samples collected for a Volatile Organics Analysis
should be transferred to the following container type:
a) 2-40 ml. glass vials
b) 1-80 ml. glass vial
c) 2-500 ml. glass bottles
d). 1-1 liter glass bottle
4) All sampling equipment should be decontaminated...
a) before each sampling event.
b) after each sampling event.
c) prior to each day's sampling.
d) following each day's sampling.
e) a and b
9
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5) Equipment blanks are:
a) supplied by the lab to assure no cross contamination in
transport.
b) supplied by the lab to assure contamination is not
present in their lab equipment.
c) prepared in the .field to assure proper sampling
techniques.
d) prepared in the field to assure proper equipment
decontamination.
6) A fluid is considered RCRA hazardous based on pH if the pH
is. ..
a) <_ 1
b) <2
c) <3
d) <4
or > 11.5
or > 12.5
or > 13 . 5
or > 10
7) All waste fluids generated during the sampling process...
a) can be dumped back into the disposal well.
b) must be containered and put in the trash.
c) must be containered and stored on-site until analysis
is complete for further determination of proper
handling.
d) must be containered and always treated as hazardous
waste.
8) Site health and safety plans should contain the following
information:
a) Material Safety Data Sheets
b) Route map to nearest hospital emergency room
c) Police and fire department phone numbers
d) a and b
e) All of the above
10
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FIELD SAFETY
1) Name the four basic routes of entry to the human body
relative to exposure of harmful substances:
1.
2.
3.
4.
2) Which level of protection provides maximum protection from
potentially hazardous contaminants?
a) 1
b) 4
c) A
d) D
3) Which route of entry is the most common accidental form of
exposure and most likely cause of systemic illness?
4) Which four body parts should be afforded protective
equipment to prevent injury during regular inspection
activities?
1.
2.
3.
4.
11
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MECHANICAL INTEGRITY TESTING
1) Wells completed with a small tubular string cemented to
surface are completions.
a)
packerless
b)
slimhole
c)
tubingless
d)
dual
e)
annular disposal
2) Wells which injected between the surface casing and long
string casing are completions.
a)
packerless
b)
slimhole
c)
tubingless
d)
dual
e)
annular disposal
3) When witnessing the cementing of a well, it is important to
record all volumes of cement pumped, pressures exerted, and
sizes of casings.
a) True b) False
4) Name three types of internal mechanical integrity tests:
1.
2.
3.
5) When conducting the standard annular pressure test, the
pressure in the tubing has no bearing on the test pressure
used for the test.
a) True b) False
6) Which of the following is a viable method of pressuring up
the annulus for the standard annular pressure test?
a) Pump truck
b) Hand pump
c) Nitrogen bottle
d) Injection line pressure
e) All of the above
12
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7) It is good operating practice for the inspector to witness
and record the amount of fluid returned from a pressure
test.
a) True b) False
8) Which of the following is allowed by regulations to
demonstrate external mechanical integrity?
a) Casing bond log
b) Noise log
c) Cement evaluation log
d) Temperature log
e) b and d
13
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UIC INSPECTIONS
1) Which section of the Safe Drinking Water Act provides
authority for inspectors to enter upon and inspect any
facility subject to the UIC program?
a) 1422
b) 1425
C) 1445
d) 1545
2) When conducting an on-site field inspection it is important
to. . .
a) present proper credentials to the operator before
conducting the inspection.
b) gain entry unnoticed and identify yourself only when
noticed by the operator.
c) identify yourself to the operator before conducting the
inspection.
d) a and c
e) All of the above
3) A notice of inspection form needs to be completed for every
inspection.
a) True b) False
4) Operators must always be notified when an inspection is
going to take place at their facility.
a) True b) False
5) Which of the following is not information that should be
recorded at a Class II well inspection?
a) Injection pressure
b) Evidence of surface discharge
c) Evidence of recent workover
d) Annulus pressure
e) Color of the wellhead sign
6) Inspection reports should be completed....
a) within 24 hours
b) within a week
c) by the end of the month
d) All of the above
e) None of the above
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7) Name three types of well inspections.
1.
2.
3.
8) Name three situations in which warrantless facility access
is legally justified.
1.
2.
3.
9) When gaining entry into a facility, it is acceptable for the
inspector to allow the operator to make a copy of the
inspector's credentials.
a) True b) False
10) Specific information regarding the planned activities during
the inspection should be written on the notice-of-inspection
form prior to presentation to the operator.
a) True b) False
11) Inspection notes should be written in a:
a) spiral notebook
b) any pad of paper
c) bound notebook
d) bound notebook with numbered pages
12) Corrections to field notebooks should be handled by:
a) tearing out page and throwing away
b) correcting by copying on a separate sheet and
discarding initial notes
c) marking out and putting initials near correction
d) erasing mistake and making correction
13) Interviewing employees at a facility that you are inspecting
is a waste of time since they will not give you any good
information due to their company loyalty.
a) True b) False
15
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During a sampling inspection, when the owner/operator of the
facility requests split samples, you should:
a) give the operator samples in the containers which he
provides you with
b) give the operator samples in spare containers brought
along for the inspection
c) refuse the operator samples
d) None of the above
16
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PLUGGING AND ABANDONMENT
1) Produced water is suitable for mixing cement,
a) True b) False
2) When setting multiple plugs, each plug should be allowed to
set for how long before the hole is recirculated and another
plug sets?
a) 2 hours
b) 4 hours
c) 8-24 hours
d) Until the test cement at the surface hardens
e) None of the above
3) Removal of equipment (tubing, packer, etc.) in the well is.
the first operational step in plugging and abandoning the
well.
a) True b) False
4) List 3 activities or considerations that can ensure cement
plug quality:
1.
2.
3.
17
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WELL LOGGING
1) Because planned procedures are always altered at the well
site, it does no good to be familiar with the well or
procedure before you arrive on location.
a) True b) False
2) How long should a well be shut in before running a base
temperature log?
a)
0 hours
b)
at
least
3 hours
c)
at
least
8 hours
d)
at
least
12 hours
e)
at
least
24 hours
3) The cement bond log depends on sonic energy traveling-
through the casing- fluid, casing, cement, and formations and'
returning to the sensor to give an indication of cement bond
to the casing and formation.
a) True b) False
4) Cut off frequencies for the noise log output are (in. Hz):
a) 10; 100? 1000? 10,000
b) 1? 5; 10? 20
C) 200? 600? 1000? 2000
d) 100? 500? 1000? 2000
5) The primary advantage of the Cement Evaluation Tool over the
Cement Bond Log is that:
a) it investigates radially
b) it is a newer generation tool
c) it is less expensive
d) it is standardized
18
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SECTION 19
INSPECTOR CERTIFICATION TEST
The UIC inspector certification test is to be administered
to the class participants at the conclusion of the training
course. Arrangements for grading the test- may be made with the
designated Work Assignment Manager at USEPA Headquarters.
19-1
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