SMC Martin Inc.
INVENTORY OF CLASS V
INJECTION WELLS IN THE
INDIAN LANDS OF
EPA REGION VIII
A Subsidiary of Science Management Corporation

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INVENTORY OF CLASS V
INJECTION WELLS IN THE
INDIAN LANDS OF
EPA REGION VIII
Submitted to:
U.S. Environmental Protection
Agency
Region VIII
Groundwater Protection Section
1860 Lincoln Street
Denver, CO 80295
Submitted by:
SMC Martin Inc.
900 W. Valley Forge Road
P. 0. Box 859
Valley Forge, PA 19482
Contract No. 68-01-6288
Task #24 Amendment #(b)
Ref: #8425-040-94003
March 1985

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TABLE OF CONTENTS
Page
Executive Summary	1
Introduction	2
Methodology	6
Inventory Results and Discussion	8
Potential Environmental Impact of Class V Wells
on the Indian Lands	11
Updating the Inventory	13
Summary and Conclusions	14
Appendix A Phone Contacts for Indian Lands Inventory
Appendix B Contacts for Indian Lands Inventory who
Provided the Most Useful Information
Appendix C Inventory Forms for Indian Lands Inventory

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LIST OF TABLES
Page
Table 1 Indian Reservations in Region VIII	4
LIST OF FIGURES
Figure 1 Map of Region VIII Indicating Indian
Reservations
5

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EXECUTIVE SUMMARY
Class V injection wells on Indian Lands in EPA Region VIII
were inventoried during this study effort. Surveys of the
25 separate reservations in the Region VIII states revealed only
two wells. One of the wells is for heat pump return flow and
the other for sanitary waste disposal. Telephone contact with
governmental agencies from the national level all the way to the
individual reservations provided the basis for this inventory.
Private sector contact such as well drillers, HVAC contractors
and septic system installers confirmed the information gathered
from individuals in government and tribal offices.
The limited number of Class V wells on Indian Lands is
consistent with the low populations, depressed economies, and
limited industrial development on the reservations. Because of
the low number of Class V wells, their potential for
environmental impact is limited and localized.
This inventory can most effectively be updated through
periodic contact with individuals at the reservation
governmental level. People in tribal councils and at
reservation BIA offices are the best contacts to maintain the
inventory because of their first-hand familiarity with
reservation operations.
1

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INTRODUCTION
The Underground Injection Control (UIC) program is being
developed in order to prevent or reduce deterioration of water
quality in potential or actual underground sources of drinking
water. According to UIC regulations, an injection well is a
"bored, drilled or driven shaft or a dug hole, whose depth is
greater than the largest surface dimension" used for "the
subsurface emplacement of fluids" (40 CFR 146.03).
These wells may be utilized for a variety of purposes
including heat pump return flow, aquifer recharge, hydrocarbon
and mineral production, sanitary waste disposal, and hazardous
waste disposal. Properly designed and installed injection wells
may impact ground-water resources, while injection facilities
that are improperly designed, constructed, operated and/or
abandoned may pose a'serious threat to underground drinking
water sources.
Five classes of injection wells have been defined by the UIC
program. Class V wells are those wells not included in
Classes I through IV and include wells used for heat pump return
flow, aquifer recharge, waste disposal, experimental tech-
nologies, mine backfill and in situ oil shale recovery. Though
Class V wells are reported to account for more than 61 percent
of all injection wells in the United States, there is presently
little information on the actual numbers, operation, and impact
of this well class. This lack of information has prevented the
2

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development of a regulatory system appropriate to Class V
wells. Therefore, Class V wells throughout the United States
are being inventoried.
The U.S. EPA has been mandated to administer the UIC program
on Indian Lands. SMC Martin, under U.S. EPA Contract #68-01-
6288, has compiled an inventory of Class V injection wells on
Region VIII Indian Lands. There are 25 separate, autonomous
reservations lying either completely or partly within
Region VIII. These reservations are listed in Table 1 and
mapped on Figure 1.
3

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TABLE 1
REGION VIII INDIAN LANDS
Map #
Reservation
Tribe(s)
State(s)
1
Turtle Mountain
Turtle Mtn. Chippewa

ND
2
Fort Totten
Devil's Lake Sioux

ND
3
Fort Berthold
Sioux

ND
4
Standing Rock
Standing Rock Sioux
ND
& SD
5
Sisseton
Sisseton-Wahpeton Sioux
ND
& SD
6
Cheyenne River
Cheyenne River Sioux

SD
7
Lower Brule
Lower Brule Sioux

SD
8
Crow Creek
Crow Creek Sioux

SD
9
Pine Ridge
Ogala Sioux

SD
10
Rosebud
Rosebud Sioux

SD
11
Yankton
Yankton Sioux

SD
12
Black Feet
Black Feet

MT
13
Flathead
Salish, Kootenai

MT
14
Rocky Boys
Chippewa Cree

MT
15
Ft. Belknap
Chippewa Cree, Turtle Mtn.

MT
16
Fort Peck
Assiniboine, Sioux

MT
17
Crow
Crow

MT
18
Northern Cheyenne
Northern Cheyenne

MT
19
Wind River
Northern Arapaho, Shoshone

WY
20
Skull Valley
Ute

UT
21
Uintah and Ouray
Ute

UT
22
Navajo
Navajo Nation
UT
(AZ,NM)
23
Goshute
Goshute
UT
(NV)
24
Ute Mountain
Ute Mtn. Ute
UT
& CO
25
Southern Ute
Southern Ute

CO
Map numbers correspond to Figure 1.
4

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Ul

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METHODOLOGY
To implement this inventory, telephone contacts were made
with governmental agencies from the national level down to
individual reservation offices. Private sector contacts
included well drillers, septic system installers, and HVAC
contractors. Phone contacts for this inventory are compiled in
Appendix A. This general methodology has been successfully
applied in EPA Region VIII states to complete and verify
existing inventories. However, the governmental structure of
the Indian Lands, being quite different from that for the
Region's states, necessitated a very different "slate" of
governmental contacts to solicit the required information.
Indian Lands are divided into reservations which lie both
within and across state borders. The reservations are
autonomous regions whose governing bodies (Tribal and
Reservation Councils) are directly responsible to the Federal
government. The Federal organizations which deal with the
reservations include the Bureau of Indian Affairs (BIA), Bureau
of Land Management (BUI), and Environmental Protection Agency
(EPA). The regional and local offices of these organizations
may have direct input into issues concerning resources on the
individual reservations. Of the Federal organizations
contacted, BIA "agencies" (local reservation offices) were by
far the most valuable sources of information for this
inventory.
6

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Tribal governmental groups on the reservations have
influence over many aspects of environmental legislation that
might involve Class V injection wells. Tribal Departments of
Water Resources, Public Health, Realty, and Environmental
Quality are among the organizations that may have knowledge of,
and control over, Class V wells. Contacts with individuals in
tribal offices provided a significant amount of valuable
information for this inventory.
Individuals in reservation BIA and tribal offices provided
the names of people and agencies at higher governmental levels
who might have information about injection wells. People in
reservation offices have the most intimate knowledge of
reservation facilities and operations that could involve
injection wells. Therefore, they were the best contacts for
this inventory. Appendix B lists the contacts who were most
knowledgeable about Class V injection wells.
The governmental structure of the Indian Lands generally
involves only Federal and reservation (tribal) agencies.
However, on some reservations, state and/or county agencies such
as highway departments and irrigation districts also have some
influence over and/or knowledge about Class V injection wells.
Because state agencies may have some jurisdiction over Class V
injection wells on Indian Lands, all potentially relevant
offices in Region VIII states were contacted (Appendix A). Very
little specific information was gathered from state agency
contacts.
7

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INVENTORY RESULTS AND DISCUSSION
Two Class V injection wells were identified on Region VIII
Indian Lands. The inventory forms for these wells are presented
in Appendix B. One of the wells is for heat pump return flow
and the other for septic system effluent disposal. The scarcity
of Class V wells is attributed to the limited population and
generally depressed economic conditions on the Indian Lands in
Region VIII. Other factors which restrict the utilization of
Class V wells include limited industrial development other than
mineral exploration and production (Class II and Class III
wells), and the use of surface waters rather than ground water
for irrigation in some Indian Lands.
In total, the Indian Lands in the Region VIII states of
Colorado, Montana, South Dakota, North Dakota, Utah, and Wyoming
comprise an area of about 47,000 square miles. The total
population of all 25 Indian Lands is estimated by the BIA to be
108,311 (January, 1985 number) for an approximate population
density of about 2.3 people/square mile. This is in contrast to
Wyoming's 4.4 people/square mile, the lowest population density
of the Region VIII states. Indian towns within reservations are
quite small, ranging in size from about 3,000 (Sisseton, SD) to
less than 300 (Box Elder, MT). These towns often serve as
tribal headquarters and are served, with one exception, by
sewage systems utilizing waste treatment systems with leach
8

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fields or lagoons for effluent disposal. The town of
Sisseton, SD uses seepage pits to dispose of its sewage.
Outside of the towns, single dwellings or small groups of
houses provide residence for the Native American inhabitants.
None of those dwellings was reported to use injection for
sanitary waste disposal. The abundant open space available to
reservation dwellers encourages the use of ditches, fields, and
other means of spreading sanitary waste rather than injecting it
via a well.
Surface discharge of sanitary and other wastes through
lagoons, ponds, ditches, etc., is the most common means of
disposal on the Indian Lands. Though this is not injection
per se according to the EPA, these wastes may directly
infiltrate into shallow aquifers and impact drinking water in a
manner little different from well injection. An example of such
a situation is the uranium mine tailings and processing waste
pile at the abandoned Susquehanna Western Uranium Processing
Plant on the Wind River Reservation.
Class V injection wells used for cooling water return flow
are not found in the Indian Lands because of the absence of
industrial operations that might utilize them. Heat pump return
flow wells are absent, with one exception, because heat pumps of
any kind, much less the more expensive ground-water systems with
both supply and recharge wells, are relatively high-cost items,
9

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out of place on the economically depressed and sparsely
populated reservations.
Other types of Class V injection wells were also found to be
unsuited to the Indian Lands for physical and/or economic
reasons. Conversations with people familiar with operations and
conditions on the reservations made it clear that very few
Class V wells would be found there.
10

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POTENTIAL ENVIRONMENTAL IMPACT OF CLASS V WELLS
ON THE INDIAN LANDS
Heat pump return flow wells have a variety of potential
environmental impacts. Among them are: change of temperature
in the receiving aquifer; mixing of waters from different
aquifers; and introduction of contaminants into the receiving
aquifer. Ground-water heat pumps inject water which is warmer
or colder than the receiving aquifer. This temperature change
could change chemical reaction rates, effect ground-water biota,
and alter mineral stabilities in the receiving aquifer.
If ground water extracted for heat pump use is returned to a
different aquifer, then disruption of the receiving aquifer's
geochemistry could take place. A lowering of the receiving
aquifer's ground-water quality could occur if its ground-water
quality is higher than that of the source aquifer.
Contaminants such as air, bacteria, pipe scale, or Freon
might be introduced by injection of heat pump return flow.
These substances have the potential to impact the receiving
aquifer by altering redox conditions, changing volatile
concentrations, plugging pore space, and introducing
contamination.
Although there is a long list of potential environmental
impacts, a properly constructed and maintained heat pump system
is likely to have only a minor and localized environmental
impact. No adverse effects have been reported from the single
heat pump return flow well on the Indian Lands.
11

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Wells for the injection of septic system effluent have a
number of significant potential environmental impacts. Primary
among these is the introduction of bacterial and viral
contamination into ground water. Other household wastes
disposed of in the septic system may also enter ground water.
Septic tanks are designed for primary and limited secondary
treatment of sewage. Effluent leaving a septic tank will enter
the ground water and degrade water quality, particularly if the
septic system does not use a leach field. The problem of
contamination of ground water from sanitary waste injection
wells is most acute if extraction wells for drinking water are
nearby. No problems have been reported related to the single
inventoried septic system injection well on Indian Lands, but
site specific investigation would be needed to determine the
specific environmental impact of this well.
12

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UPDATING THE INVENTORY
This inventory can best be updated if individuals in local
agencies who are familiar with the operations of individual
reservations are periodically contacted to determine if any
activity involving Class V injection wells has recently taken
place on the reservation. Local BIA officials and/or tribal
council members should be contacted. A knowledgeable person on
each reservation could be empowered by the EPA to monitor
Class V (and perhaps all) injection wells on that reservation.
Periodic reporting by these people to EPA would ensure that the
inventory remains current.
13

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SUMMARY AND CONCLUSIONS
This inventory presents an accurate picture of Class V
injection wells on Region VIII Indian Lands. No major projects
(e.g., irrigation, oil shale recovery) which might use injection
wells were found, and none are believed to exist. Individual
well types including mine backfill, solution mining of
conventional mines, experimental technology, aquifer recharge,
and cooling water return flow wells were not found on the Indian
Lands and most probably do not exist there. One each of heat
pump return flow wells and septic system discharge wells were
identified and inventoried. Largely because of economic
constraints, no other heat pump wells are likely to be present
on the Indian Lands. It is possible that some small septic
system injection wells and drainage wells installed by
individual property owners may have been inadvertently missed by
this inventory. Comprehensive lists of injection wells on
Indian Lands do not exist because it was necessary to depend
almost solely on contact with knowledgeable individuals for well
information. Therefore, it is possible that a "missed
connection" may have resulted in a non-inventoried injection
well. SMC Martin does feel that this small inventory is due to
the almost total lack of injection wells on the Indian Lands and
the extremely limited environmental impact of the wells that do
exist.
14

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APPENDIX A
PHONE CONTACTS FOR INDIAN LANDS INVENTORY

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APPENDIX A
Contacts for Indian Lands Inventory
Federal Level
Department of the Interior
Bureau of Indian Affairs (BIA)
Indian Health Services
U.S.G.S.
Bureau of Land Management (BLM)
Department of Agriculture
Soil Conservation Service
Regional Level
Department of the Interior
BIA Area Offices
Aberdeen
Albuquerque
Billings
Navajo
Phoenix
BLM Offices
Cheyenne
Lander Resource Area
Durango
State Level
For each state in Region VIII (ND, SD, MT, WY, CO, UT), the
following agencies or their equivalent were contacted:
Department of Health
Waste Management Division
Department of Natural Resources
Water Resources Division
Land Resources Division
Geological Survey
Department of Environmental Quality
Water Quality Division
Land Quality Division
Highway Department
Engineers Office
A—1

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Reservation Level
For each of the 25 separate reservations in Region VIII
(listed in Table 1), the following offices or their
equivalents (if present) were contacted:
BIA Agencies
Public Health
Natural Resources
Tribal Council
Realty
Environmental Quality
Water Resources
Housing Authority
A-2

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APPENDIX B
CONTACTS FOR INDIAN LANDS INVENTORY WHO PROVIDED
THE MOST USEFUL INFORMATION

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APPENDIX B
Contacts for Indian Lands Inventory who
Provided the Most Useful Information
Wind River Reservation
Ed Baruth, Wyoming DEQ Lander office
Lander, WY (307) 332-3144
Gary Collins, Wind River Reservation Joint Tribal Council
Ft. Washakie, WY (307) 255-8210
Charles Dillahanty, BIA Agency, Lease Compliance Office
Ft. Washakie, WY (307) 255-8306
Bruce Maytebbe, BIA Agency, Realty Office
Ft. Washakie, WY (307) 255-8243
Ute Mountain and Southern Ute Reservations
A1 Henning, BIA Agency, Indian Health Services
Towaoc, CO, Public Health Services (303) 565-4441
Ignacio, CO, Public Health Services (303) 563-4581
Byron Red Southern Ute Nation, Water Resources Council
Ignacio, CO, (303) 563-4525
Lynda Taylor, BIA Agency Office
Towaoc, CO, (303) 565-8471
Uintah and Ouray Reservation
Skull Valley Reservation
Uintah and Ouray Tribal Energy and Minerals Dept.
Fort Duchesne, UT (801) 722-5141, Ext. 255
Navajo Reservation
Steve Hallesey, BIA Agency Office
Public Health Service
Window Rock, AZ (602) 871-5151, Ext. 5320
Carol Larery, Navajo Tribe, Water Development Division
Window Rock, AZ (602) 871-4941
Arlene Luther, Navajo Tribe, Environmental Protection Adm.
Window Rock, AZ (602) 871-4941
Turtle Mountain Reservation
Allen Shinwalt, Tribal Public Health Dept.
Belcourt, ND (701) 477-6111
Fort Totten Reservation
Mike Doctor, Tribal Public Health Dept.
Fort Totten, ND (701) 766-4291
Fort Berthold Reservation
Tribal Natural Resources Council
New Town, ND (701) 627-3628
B-l

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Sisseton Reservation
Vine Marks, Sisseton Housing Authority
Sisseton, SD (605) 698-7606
Standing Rock Reservation
Craig Larson, BIA Indian Health Services
(605) 845-7245
Cheyenne River Reservation
John Lind, Tribal Health Department
Eagle Butte, SD (605) 964-6111
Lower Brule Reservation
Dave Moser, Tribal Public Health Department
Lower Brule, SD (605) 224-1644
Pine Ridge Reservation
Wayne Iteska, Ogala Sioux Nat'l. Resources Council
Pine Ridge, SD (605) 867-5821
Yankton Reservation
Delton Woodford, BIA Indian Health Services
Aberdeen, SD (605) 225-0250, Ext. 461
Rosebud Reservation
Terry Hoskins, BIA Indian Health Services
Aberdeen, SD (605) 225-0250, Ext. 451
Blackfoot Reservation
Charles Farmer, Tribal Planning Office
Browning, MT (406) 338-7406
Rocky Boys Reservation
Don Bradford, Tribal Public Health Department
Box Elder, MT (406) 395-4490
Fort Belknap Reservation
Bill Stiffarm, Tribal Water Department
Harlem, MT (406) 353-2205, Ext. 340
Fort Peck Reservation
Jerry Lee, Tribal Environmental Health Department
Poplar, MT (406) 768-5301, Ext. 407
Northern Cheyenne Reservation
Richard Rubudahl, Northern Cheyenne Utilities
Lame Deer, MT (406) 477-6205
Crow Reservation
Ronnie Stewart, Crow Public Health Department
Crow Agency, MT (406) 638-2626
B-2

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APPENDIX C
INVENTORY FORMS FOR INDIAN LANDS INVENTORY

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