SMC Martin Inc.
EVALUATION OF THE INVENTORY
OF CLASS V INJECTION WELLS
IN THE STATE OF WYOMING
A Subsidiary of Science Management Corporation

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EVALUATION OF THE INVENTORY
OF CLASS V INJECTION WELLS
IN THE STATE OF WYOMING
Prepared for:
Angus Campbell, Project Officer
U.S. EPA Region VIII
Ground-Water Protection Section
1860 Lincoln Street
Denver, CO 80295
Prepared by:
SMC MARTIN INC.
900 W. Valley Forge Road
P. 0. Box 859
Valley Forge, PA 19482
March 1985
EPA Contract #68-01-6288
Task #24 Amendment #(b)
Ref: 8425-040-94001
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TABLE OF CONTENTS
Page
Executive Summary	1
Introduction	3
Methodology	5
Analysis of Inventory	7
Potential Environmental Impacts of Class V
Wells in Wyoming	16
Conclusions and Recommendations for Updating	22
Appendix A Explanation for the Inclusion of Septic Systems
in the Wyoming Inventory

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LIST OF TABLES
Page
Table 1 Wyoming Inventory	8
Table 2 Evaluation of Wyoming Inventory	9
Table 3 EPA and Wyoming Class V Well Descriptions	11

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EXECUTIVE SUMMARY
An inventory of Class V injection wells in Wyoming was
reviewed and evaluated by SMC Martin as part of U.S. -EPA
Contract #68-01-6288. The inventory was compiled under a
contract between the Wyoming Department of Environmental Quality
(DEQ) and Professional Solutions, Inc., of Cheyenne, Wyoming.
The methodology utilized in compiling the inventory is well
conceived and comprehensive. This inventory has been tailored
to the needs of the DEQ, however, and does not represent a
complete inventory as defined by EPA. Recommendations are made
in this report for the completion and maintenance of the
inventory.
Approximately 700 injection wells are listed in the
inventory, including at least 445 septic systems with drain
fields. These septic systems are not defined by the EPA as
injection wells (40 CFR 146.03). In addition, although
SMC Martin has confirmed their existence in Wyoming, no aquifer
recharge wells or in situ hydrocarbon (e.g., shale oil) extrac-
tion related wells are listed in the inventory. These depar-
tures from EPA's inventory requirements were apparently built
into the inventory the by Wyoming DEQ. The DEQ believes that
its files on injection wells used for aquifer recharge and oil
shale extraction are complete and accurate, and that its files
on sanitary waste disposal contain data gaps The DEQ directed
the inventory contractors to concentrate on septic systems at
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the expense of other areas such as oil shale and aquifer
recharge wells. With this in mind, it appears that integration
of DEQ's existing files with the Professional Solutions'
inventory should result in a largely complete and accurate
account of Wyoming injection wells.
Several additional problems were noted with regard to
existing inventory information. There are 131 unverified wells
listed in appendices to the inventory report. The type, status,
and number of these wells should be confirmed and they should be
added to the inventory where appropriate. In addition, a number
of duplicate entries, multi-well projects showing incorrect
numbers of wells, and wells whose status, as reported in that
inventory, has changed were noted. It is felt that rigorous
application of previously-employed inventory methodology to the
unverified wells, coupled with integration of the DEQ files,
should allow Wyoming's inventory to be completed to the
satisfaction of both the EPA and the DEQ. Once complete, the
inventory can be regularly updated if the state enacts permit
requirements for Class V wells which are currently out of its
jurisdiction. The state Class V permit file can then be
monitored periodically.
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INTRODUCTION
The Underground Injection Control (UIC) program was
developed in order to prevent or reduce deterioration of quality
in potential or current underground sources of drinking water
(USDWs). According to UIC regulations, an injection well is
"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, mineral
resource production, hydrocarbon storage, and waste disposal.
Properly designed and applied injection wells may impact
ground-water resources. Injection facilities that are
improperly designed, constructed, operated, and/or abandoned can
pose a serious threat to underground drinking water sources.
Five classes of injection wells have been defined in the UIC
program. Class V wells include those used for heat pump return"
flow, aquifer recharge, non-hazardous waste disposal, experi-
mental technologies, 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 wells in this class. This lack of information has
prevented the development of a regulatory system appropriate to
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Class V wells. Therefore, Class V well inventories have been
commissioned by the EPA.
Under the auspices of the UIC program, an inventory of
Class V injection wells was developed by Wyoming, which has
assumed primacy over its UIC program. On September 26, 1983,
the State of Wyoming's Department of Environmental Quality
(DEQ), Water Quality Division (WQD) contracted Professional
Solutions, Inc., of Cheyenne, Wyoming, to perform the required
Class V inventory. The completion date for the inventory is
listed as July 1, 1984.
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METHODOLOGY
The methodology which Professional Solutions, Inc., used to
conduct the Wyoming inventory was stated as follows:
"The inventory of Class V wells in Wyoming
was initiated by interviewing State and Federal
government agencies and reviewing available
records. Representatives from each government
agency were asked to review the list of Class V
injection well categories and provide any
information they could regarding the presence of
these well types in Wyoming. Local government
offices were then contacted regarding the presence
of Class V injection wells within their
jurisdiction.
For each well category, potential owners of
injection wells were identified, as well as
businesses likely to install or service such
wells. These persons and/or businesses were then
contacted for information.
When potential well owners or information
sources could not be reached, an extensive
telephone and letter follow-up system was
employed. Due to the number and diversity of
information sources used throughout the inventory,
meticulous recordkeeping was essential. Records
of persons contacted, information provided, and
persons yet to be contacted were kept on
computerized text editor files. These records
were frequently updated throughout the course of
the inventory." (Professional Solutions, Inc.,
1984) .
This methodology is similar to that developed by SMC Martin for
inventories of Class V injection wells in other states.
SMC Martin has reviewed and evaluated the Wyoming inventory
as part of EPA Contract #68-01-6288. In accordance with the
work plan for this task, a representative sample of well owners,
operators, and other information sources was contacted in order
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to verify the accuracy of the inventory data. The owners and/or
operators of 24 of 32 facilities with 215 of 254 inventoried
non-septic system wells were contacted. The Wyoming DEQ,
Highway Department, Geological Survey, and County Health
Services were among governmental agencies contacted. Private
sector contacts included well drillers and a variety of
businesses and individuals listed as well owners. By direction
of Region VIII of the EPA, none of the septic system entries
were checked by SMC Martin since they are not classified by the
EPA as injection wells and because this data was collected from
state and local government sources which are considered to be
reliable. Professional Solutions contacted owners of septic
systems in the course of their inventory study to verify the
data.
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ANALYSIS OF INVENTORY
A total of 699 Class V wells at 366 facilities were
inventoried in the Wyoming study. An additional 131 -entries
were listed in that study as possible, but unverified, wells or
well sites. Table 1 summarizes the Wyoming study findings.
Telephone contacts made during this evaluation/assessment
process provided revisions and updates of existing inventory
information. This information is summarized in Table 2.
SMC Martin's analysis and comments regarding the inventory
effort and its findings are presented in the following pages by
topic.
DEQ Vs. EPA Class V Well Definitions
A comparison of EPA versus Wyoming descriptions of Class V
wells are presented in Table 3. EPA's Class V well
descriptions, as they apply to required inventory activities,
are given in 40 CFR 146.05. In the contract between Wyoming DEQ
and Professional Solutions, Inc., Item 4 does not follow the EPA
definition as it appears in Table 3. It seems likely that the
latter part of Item 5 was transposed to become part of Item 4.
This error was traced back as far as the Request for Proposal,
issued August 10, 1983 by the Wyoming Department of
Administration and Fiscal Control, Purchasing and Property
Control Division. This wording should be modified to prevent
the possible incorrect classification of injection wells in the
State of Wyoming.
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TABLE 1
CLASS V INJECTION WELL INVENTORY FOR WYOMING,
PROFESSIONAL SOLUTIONS, INC.
Number of	Number of
Well Type Description	Facilities	Wells
Heat pump (air conditioner)
return flow	5	7
Backfill	5	75
Cesspools	3	3
Drainage	3	6
Dry Wells	4	33
Experimental Technology	10	116*
Septic Systems	334	445*
Solution Mining of
Conventional Mines	2	14
Total of Verified Systems	366	699
Total of Unverified Systems	131	131
* Some sites have an unknown number of wells present.
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TABLE 2
ac = active ab =
EVALUATION OF CLASS V INJECTION WELL INVENTORY FOR WYOMING
abandoned *facilities with unknown number of wells are inventoried
Well Description
Heat Pump
Return Flow
FaciIi ties/welIs
Inventoried by
Professional
Solutions
5/7
Facilities/wells
from Inventory
Contacted by
SMC Martin
4/6 ac
FaciIi ties/welIs
as Revised by
SMC Martin
5/6 ac
Comments
C-V Ranch has 2, not 3, return
flow wells. The third well is
for extraction.
Backfi11
5/75
5/75 ac
5/75 ab
No changes. A new project
with about 57 wells is
planned (Appendix A).
Cesspool
Drainage Well
3/3
3/6
2/2 ac
3/6 ac
3/3 ac
2/5 ac
No change.
Wycon Chemicals has 2, not
one, wells but both are
classed by the DEQ as Class I.
Dry Wei I
4/33
4/33 ac
3/23 ac	Roger Hessler has one 5-well
5 ab	project, now abandoned; not
2 active 5-we11 facilities.
Experimental
Technology
10*/116*
3/77
14/129	Sequoyah Fuels (Kerr McGee) has two
projects with 21 total wells, not one
10 well project. Cleveland Cliffs
has 44, not 41, welIs.
Septic System
Solution Mining
of Conventional
Mi nes
334*/445*
2/14
0/0
2/14
0/0
2/7
None contacted.
Sequoyah Fuels (Kerr McGee)
has 2 projects, but with 7,
not 14, wells.

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TABLE 2
(Continued)
EVALUATION OF CLASS V INJECTION WELL INVENTORY FOR WYOMING
ac = active ab = abandoned *facilities with unknown number of wells are inventoried
Well Description
Aquifer Recharge
FaciIities/welIs
Inventoried by
Professional
Solut i ons
0/0
FaciIi ti es/welIs
from Inventory
Contacted by
SMC Martin
0/0
Facilities/wells
as Revised by
SMC Martin
2/3+
Comments
Teton Village Sewage has 3 wells
Caspar Reclamation project could
not be confirmed.
ID Situ Hydrocarbon
(e.g., shale oiI)
Recovery
0/0
0/0
estimated 1/	Preliminary contacts only, no
unknown	substantive information was
received at the time of this
report writing.

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TABLE 3
EPA AND WYOMING CLASS V WELL DESCRIPTIONS:
DRAINAGE WELLS AND DRY WELLS
EPA Description
(40 CFR 146.05 amended
February 3, 1982)
Wyoming Description
DEQ Contract for Services
for Class V Well Inventory
. Drainage wells used to
drain surface fluid,
primarily storm runoff
into a subsurface
formation.
4. Drainage wells used
for the injection of
wastes into a
subsurface formation.
5. Dry wells used for the
injection of wastes into a
subsurface formation.
5. Dry wells used for the
injection of wastes into
a subsurface formation.
Note the difference between EPA and Wyoming Type 4.
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Septic Systems
Note that of the 699 verified wells, about 445 are listed as
septic system injection wells. Nearly all of these 'wells' are
a.
leach field septic systems, which are wider than they are deep,
thus they do not qualify as underground injection wells
according to EPA's definition. This conclusion was confirmed by
SMC Martin via contacts with some listed owners/operators and
government officials. A separate category of Class V wells (dry
wells) was used in the inventory to account for septic systems
with well injection. Contact with Mr. Jake Strohman and
Mr. Dick Lennox of the Wyoming DEQ indicated that the septic
systems were inventoried at the state's request. Appendix A
documents the DEQ's desire to include all large septic systems
in the inventory.
Unverified Wells
There are 131 unverified wells listed in appendices to the
inventory report but not included in the 699 inventoried wells.
The number, type, and status of these wells must be established
in order to complete the inventory. The potential margin of
error for the inventory implicit in this number of unverified
wells (Table 1) is too great to allow them all to remain as
unknowns. Many of the listings for unverified wells suggest
that only a limited amount of effort was expended in trying to
obtain information (e.g., only a single telephone call). It is,
therefore, suggested that the number of unverified wells could
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be reduced by following more rigorously the methodology utilized
for the inventory.
Eight suspected well owners are listed who would not provide
information that could verify their wells. Most of the
pertinent information for their evaluation can be derived from
state or local permits. These wells should be added to the
inventory, if they are in fact Class V wells.
Aquifer Recharge Wells
Aquifer recharge wells were found to be missing from the
existing state inventory. Contacts with state officials
identified two aquifer recharge projects: Teton Village Sewage
System and the Casper Reclamation Project. Only the former
project was confirmed and a total of three wells were identified
at Teton Village. The Casper Reclamation Project could not be
verified because the information from the contractor was not
received in time for this report.
In Situ Extraction Wells
The Wyoming inventory included no wells used for in situ
recovery of lignite, coal, tar sands, and oil shale. However,
it is stated in the inventory report that "Several such
operations have been conducted in the state; however, they
involved only the injection of air and/or steam and small
amounts of tracer." If this is the case, then these are in fact
injection wells which should be inventoried.
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It is recognized that both aquifer recharge and in situ
wells were omitted from the inventory at Wyoming DEQ's direction
to permit the inventory authors to concentrate on septic systems
in their work. Contact with the DEQ indicated that these
omissions were expected and acceptable since the state files in
these, and other, areas are complete and accurate. Therefore,
the omissions from the inventory of aquifer recharge and in situ
wells is only a shortcoming with regard to fulfillment of EPA
inventory requirements. Augmentation of existing inventory
findings with state files on these specific types of injection
wells should remedy this situation.
Backfill Project Wells
Mr. George Barnes (Land Quality Division, DEQ) indicated
that another backfill project, in addition to those inventoried,
using injection for subsidence control is scheduled to begin in
the summer of 1985. A total of approximately 57 injection bore-
holes are prepared for this project: 17 for fly ash injection
and about 4 0 for portland cement group injection. This project
should be monitored so that its injection wells can be
inventoried.
Minor Updates/Corrections
In addition to the problem area of uninventoried wells, both
unverified and omitted, a few relatively minor mistakes were
found in specific inventory entries during SMC Martin's
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verification effort. A heat pump installation at the C-V Ranch,
for instance, was listed in the inventory as having three
injection wells for return flow. Contact with the owner
revealed that one of the three wells was for extraction
purposes. In another case, one individual (Roger Hessler) was
listed as the owner of two sites with five active wells each.
The owner indicated that only one site with five wells, now shut
down, existed. Apparently, two sites were listed because the
operation had both state and county permits and each permit was
thought to represent a different site. A number of well status
changes were also noted, reflecting changes that have occurred
in the months since the Wyoming inventory was completed
(Table 2).
In addition, one injection well, the Wycon Chemical Company
well, was incorrectly classified as a drainage well. This well
is classified by the state as a Class I injection well because
of its deep injection of industrial waste. A second Class I
well, similar to the inventoried well, has recently been put
into operation at Wycon.
Based on the sample of well owners contacted, SMC Martin
estimates that about 10 percent of the entries in the inventory
contain minor errors. This estimate does not take into account
the non-inventoried wells. It should be noted that verification
of inventory entries was greatly facilitated by the listing of
reliable contact names and telephone numbers for each well in
the inventory.
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POTENTIAL ENVIRONMENTAL IMPACTS OF CLASS V
INJECTION WELLS IN WYOMING
Class V injection wells in Wyoming have varied potential
environmental impacts that relate primarily to the functions of
the wells. For discussion of environmental impact potential,
wells will be grouped as follows: 1) heat pump return flow
wells; 2) backfill wells; 3) cesspools and dry wells; and
4) wells used for solution mining.
Heat Pump Return Flow Wells
No adverse environmental impacts have been reported for any
heat pump return wells in Wyoming. Wells of this type do have
the potential for a variety of adverse environmental impacts,
which, based on past research (SMC Martin, 1983), are generally
limited and localized. Injection of heat pump effluent can
change ground-water temperatures. If the heat pump was being
used for heating, as opposed to air conditioning, the effluent
or discharge fluid would have a lower temperature than the
initial ground-water temperature. Change in temperature could
affect the aquifer by changing chemical reaction rates, altering
the stability of mineral phases and influencing ground-water
biota. These temperature changes and impacts, however, are
generally limited to the vicinity of the well bore.
If the source and disposal aquifers in a ground-water heat
pump system are different, mixing of waters from different
aquifers could have adverse results. Changes in ground-water
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quality in the receiving aquifer is the most serious potential
impact of mixing.
Injected heat pump effluent may also have the effect of
plugging pore spaces in the receiving aquifer. The introduction
of solids and/or air can cause plugging as can the action of
bacteria carried by the effluent. Plugging of aquifers would be
a serious problem since paths for ground-water flow would be
thereby restricted and hydrologic parameters (e.g., trans-
missivity) of the aquifer affected. Here again, however,
potential would generally be limited to the vicinity of the
wellbore. If the heat pump system construction is faulty or
fails during use, contaminants such as Freon could be introduced
to the ground-water system.
Although a variety of potential environmental impacts of
heat pump systems using injection wells have been identified,
all are generally minor and limited in areal extent within the
aquifer. This has been found to be true even where there is a
high concentration of systems, such as in the Tidewater,
Virginia area (SMC Martin, 1983). The small total number of
heat pump return flow wells in Wyoming (only five were
identified) further reduces the potential environmental impact
of this group of wells.
Backfill Wells
The inventory identified 75 backfill wells in Wyoming,
concentrated in the city of Rock Springs. These now-abandoned
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sites were used for injection of backfill to stop surface
subsidence into mined-out, underground coal workings beneath the
city. Cased holes drilled into mine voids were used for the
injection of material: 22 of the wells introduced a dry sand
slurry; 45 wells injected fly ash in an air slurry. The
potential environmental impact of the backfill wells at Rock
Springs and backfill wells in general is significant and, for
the most part, beneficial. First and foremost, the reduction of
surface subsidence into mine voids is an important and positive
impact, particularly in a developed area such as Rock Springs.
The injection of fly ash, the residue from coal-burning
operations, is in itself beneficial, since it is essentially a
waste product that would alternatively require some other means
of disposal. Fly ash is alkaline in chemistry, generally with a
pH greater than 8.5. Ground water which moves through the fly
ash backfill in the mine workings will become alkaline, perhaps
neutralizing any acid that may be leaching from pyritic coal
wastes or roof rock materials remaining in the mine voids. One
unlikely adverse feature is that the fly ash backfill has the
potential to introduce very fine-grained solids into the ground
water resulting in possible plugging of aquifers. Sand used for
backfill is generally not perceived as having any significant
impacts on the environment. Further site specific evaluations
are required to assess the environmental impacts of backfill
injection at any given site.
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Cesspools/Dry Wells
In Wyoming, the three cesspools are garage floor drains
while the 28 dry wells are used for sanitary wastewater
disposal. The major potential impact of this group of wells is
the introduction of bacterial and viral contaminants into ground
water. Other household wastes which have been introduced
through the system may also enter the ground water. Effluent
from sanitary waste disposal systems can infiltrate into
aquifers, carrying with it pathogens and other substances that
have escaped the treatment processes in the septic tank.
Effluent from septic tanks which drain into cesspools/dry
wells does not undergo treatment and filtering in a leach
field. For this reason, cesspools/dry wells have a greater
potential environmental impact than leach fields. However, the
potential statewide impact of these wells in Wyoming is limited
by their low total number. Outside of a single 20-hole facility
used for seasonal disposal of gray water from RVs, there are
only 11 cesspools/dry wells in Wyoming. Further study is needed
to evaluate the environmental impact of these specific
facilities.
The 440+ septic systems, which do not use injection wells,
were included in the inventory by DEQ to permit evaluation of
potential environmental impacts. Those systems which may
significantly impact ground-water resources will be classified
as Class V injection wells.
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Solution Mining Wells
All of the wells in this group, including experimental
technology wells used for this purpose, inject fluids designed
to mobilize mineral resources so that they can be pumped to the
surface. The potential environmental impact of these wells is
significant; but projects utilizing them are carefully screened
initially and monitored during operation to prevent serious
environmental problems.
Of the (at least) 136 solution mining wells in Wyoming
(Table 2), nearly all are or were utilized for uranium
extraction. In this process, an alkaline liquid (e.g., sodium
bicarbonate solution) with an added oxidizing agent
(e.g, hydrogen peroxide) is injected into uranium-bearing
formations. Uranium is oxidized to the +6 valence state by the
oxident and is taken into solution by the alkaline liquid. The
"pregnant" solution is then pumped out through extraction
wells.
The contamination of ground water by any of the chemical
species in the solution is the primary potential environmental
impact. This impact potential is reduced greatly by carefully
maintaining equivalent fluid injection and fluid extraction
volumes. This balance prevents waste of fluid and helps
maintain the cost effectiveness of solution mining projects. In
addition, numerous monitoring wells positioned around the
solution mining projects identify any ground-water contamination
before it migrates past the project area. Finally, all of the
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experimental projects have ended, or will end, with a restora-
tion phase during which cleanup of the mined region takes
place. At least 129 wells are part of experimental projects;
the other seven wells are used for solution mining of a
conventional mine. Overall, although the environmental impact
of this group of wells could be significant, it is limited in
Wyoming by the economic and regulatory constraints imposed on
solution mining. Further site specific study would be needed to
evaluate the actual environmental impacts of these projects.
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CONCLUSIONS AND UPDATING SUGGESTIONS
Of the 254 Class V wells at 32 facilities inventoried by
Professional Solutions, Inc. (excluding the septic system drain
fields), SMC Martin has confirmed 215 wells at 24 facilities.
Two tasks are required before the inventory can be considered
complete: 1) the injection wells in the files of the Wyoming
DEQ must be integrated into the inventory; and 2) the
131 unverified wells need to be substantiated and added to the
inventory, where appropriate. This can be done by following
more persistently the methodology developed by the contractor
who produced the inventory.
Once the inventory is complete and correct, there should
also be a means to regularly update it. The Wyoming DEQ is
planning to permit all Class V wells at the state level. The
inventory can then be updated by periodic reference to the
relevant state permit files.
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APPENDIX A
EXPLANATION FOR THE INCLUSION OF SEPTIC SYSTEMS
IN THE WYOMING INVENTORY

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°F WY0MING
ED HERSCHLER
GOVERf.'OP
allmenl of SnvitonmenlaI Qua Illy
tyia/el Quality Q)ivibion
HERSCHLER BUILDING
David Weiss
SMC Martin Corporation
9000 West Valley Forge Road
Valley Forge, PA 19482
Dear Mr. Weiss:
CHEYENNE. WYOMING 82002
February 19, 1985
TELEPHONE 307 777 7781
In response to your question concerning why the class V well inventory conducted
for the State of Wyoming contained so many septic systems, I offer the following:
1.
2.
From Water Quality Rules and Regulations Chapter IX, a well is defined: "'Well'
means an opening, excavation, shaft, or hole in the ground allowing or used for
a subsurface discharge or for the purpose of extracting a fluid, mineral, prod-
uct or pollutant from the subsurface or for monitoring".
From the State Engineers Regulations and Instructions Part III, a well is
defined as: "Well means any artificial opening or excavation in the ground, how-
ever constructed, by which groundwater is sought or from which it flows under
natural pressure or is artificially withdrawn. An excavation for the purpose of
artificial recharge to the groundwater body, or for the disposal of industrial
or municipal wastes, is also considered a well."
Based on the fact that the majority of Wyoming communities are established in
close proximity to waterways which have associated shallow groundwater regimes that
can be significantly affected by faulty septic systems; the decision was made to
include in the class V well inventory all septic systems of a residential or
non-residential nature that either received wastes other than sanitary waste or had a
capacity greater than 2000 gallons per day; i.e., 20 persons x 100 gallons per person
per day.
Therefore, in light of the way wells are defined by Wyoming and the usefulness
of the information towards administering the state's groundwater protection program
ample justification to have septic systems included in the inventory existed.
Should you have any further questions on this matter, please feel free to con-
tact the undersigned at (307) 777-7781.
Sincerely,
RJL/pj b
cc: Jake Strohman, WQD
A. J. Mancini, WQD
Richard J. L^fTnojc
Engineering EValvlator

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