United States        Office of Ground Water        EPA/816-R-99-014a
Environmental        and Drinking Water (4601)       September 1999
Protection Agency
The Class V Underground Injection
Control Study
Volume 1

Study Approach and General Findings

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                                Table of Contents

                                                                                    Page
1.      Executive Summary	1

2.      Background	12
       2.1     Class V Wells 	12
       2.2     Safe Drinking Water Act 	15
       2.3     UIC Regulations	16
       2.4     1987 Report to Congress on Class V Wells	16
       2.5     Actions Since the 1987 Report to Congress	16

3.      Study Approach	18

4.      Information Collection	19
       4.1     Literature Review	19
       4.2     State and USEPA Regional Data Collection	19
              4.2.1  Data Collection Methods	19
              4.2.2  Information Obtained	20
       4.3     Requests to the Public for Information	23
       4.4     Peer Review  	24

5.      Inventory Models	24
       5.1     Storm Water Drainage Wells  	24
       5.2     Large-Capacity Septic Systems  	25

6.      Well-Specific Summaries	25
       6.1     Agricultural Drainage Wells 	26
       6.2     Storm Water Drainage Wells  	28
       6.3     Carwash Wells	31
       6.4     Large-Capacity Septic Systems  	33
       6.5     Food Processing Wells	35
       6.6     Sewage Treatment Effluent Wells	37
       6.7     Laundromat Wells  	39
       6.8     Spent Brine Return Flow Wells	40
       6.9     Mine Backfill Wells  	41
       6.10   Aquaculture Waste Disposal Wells	43
       6.11   Solution Mining Wells	45
       6.12   In-Situ Fossil Fuel Recovery Wells	46
       6.13   Special Drainage Wells	47
       6.14   Experimental Wells	49
       6.15   Aquifer Remediation Wells	51
September 30, 1999

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                         Table of Contents (cont'd)

                                                                                Page
       6.16   Geothermal Electric Power Wells	52
       6.17   Geothermal Direct Heat Wells 	54
       6.18   Heat Pump/Air Conditioning Return Flow Wells	55
       6.19   Salt Water Intrusion Barrier Wells  	57
       6.20   Aquifer Recharge Wells and Aquifer Storage and Recovery Wells	58
       6.21   Noncontact Cooling Water Wells	59
       6.22   Subsidence Control Wells  	60
September 30, 1999

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             STUDY APPROACH AND GENERAL  FINDINGS


1.     EXECUTIVE SUMMARY

       Class V underground injection wells are typically shallow waste disposal wells or other devices
used to release fluids underground. These wells generally inject either directly into underground sources
of drinking water (USDWs) or into the shallow subsurface that overlies those resources.  Class V wells
have a variety of designs and  uses and include disposal mechanisms such as large-capacity septic
systems and storm water and  agricultural drainage systems.

       The U.S. Environmental Protection Agency (USEPA) addresses Class V injection wells
through the federal underground injection control (UIC) program under the authority of the Safe
Drinking Water Act. This program includes the basic requirement that Class V injection wells cannot
endanger USDWs and gives UIC program staff the authority to take whatever actions are needed to
ensure that underground drinking water supplies are in fact protected. Many states have  primary
responsibility for implementing the program and/or control Class V wells under their own authorities.

       This report presents the results of a study of 23 categories of Class V wells. The study was
conducted to develop background information for USEPA to use in evaluating the risk that these wells
pose to underground drinking water supplies and if additional federal regulation is warranted.
Information collected on these wells included: inventory, injectate constituents, contamination incidents,
and current state regulations.

       USEPA estimates that more than 686,000 Class V wells within these 23 different categories
currently exist in the U.S. The two largest categories by far are storm water drainage wells
(approximately 248,000) and large-capacity septic systems (approximately 353,000), which together
comprise almost 88 percent of the national total. In contrast, some categories are very  small, including
in-situ fossil fuel recovery wells, which are not presently known to exist, and spent brine return flow
wells, aquaculture waste disposal wells, geothermal direct heat wells, and
subsidence control wells, which have about 100 or less each. In general, there are significant
uncertainties associated with these data. States maintain relatively accurate numbers for mine backfill,
geothermal, aquifer recharge, aquifer storage and recovery, and aquifer remediation wells. For other
well types, however, USEPA and the states suspect that their inventories underestimate the true
numbers  of wells.

       Class V wells are located in virtually every state, especially in unsewered areas where the
population is likely to depend on ground water. This is particularly true for storm water drainage wells
and large-capacity septic systems, which likely exist in every state, as well as heat pump/air conditioning
return flow wells which exist in 46 states and aquifer remediation wells which exist in 39 states. The
following potentially exist in six or fewer states: spent brine return flow wells, aquaculture waste
disposal wells, solution mining wells, geothermal power wells, salt water intrusion barrier wells, and
subsidence control wells.  All of the others are potentially in 10 to 32 states.


September 30, 1999                                                                            1

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        Sampling data that can be used to characterize the chemical composition of the fluids released
are sparse for most well types, but the information available provides evidence that many of the wells
release fluids with one or more chemicals in concentrations above drinking water maximum contaminant
levels (MCLs) or health advisory levels (HALs).  Nitrate along with several metals and other inorganics
are particularly prevalent, with organic pollutants generally being less of a concern for most wells.
Biological contaminants (coliform bacteria and other microorganisms) are also a concern for some well
types, such as agricultural drainage wells, large-capacity septic systems, food processing wells, sewage
treatment effluent wells if treatment systems do not function properly, possibly aquaculture waste
disposal wells, and lake-level control wells (included within the storm water drainage well category).

        Class V wells are typically shallow, injecting into or above USDWs, but they may also inject
below USDWs.  Many Class V wells release fluids into USDWs.  For example,  salt water intrusion
barrier wells, aquifer recharge, and aquifer storage and recovery wells generally release fluids directly
into USDWs for the purpose of preserving drinking water supplies, and as such, are typically held to
high standards for injectate quality.  Several Class V wells inject above USDWs. Large-capacity
septic systems and other kinds of Class V wells that are designed as septic systems (including many
food processing wells and some carwash wells and aquaculture waste disposal wells) release fluids into
the shallow soil above ground water.  Class V wells may also inject below the lowermost USDW, such
as spent brine return flow wells.

        There are no or few cases of contamination linked to most of the well types  studied, although
this may be due to the fact that USEPA and state UIC programs generally have limited resources to
search for such cases. Wells with the most contamination cases are, predictably, the most prevalent
wells, including storm water wells, large-capacity septic systems, and agricultural drainage wells.  Each
of these well types, plus several others, are also vulnerable to  spills or illicit discharges. For example,
storm water wells can be located conveniently along roads and in parking lots where spills of oil,
gasoline and other contaminants can occur.

        Regulatory authority over Class V wells varies widely among states.  Regulatory schemes,
which are very state- and well-specific, include general  authority to protect USDWs using discretionary
authority; permit by rule, meaning an entire class of wells is deemed permitted as  long as they comply
with standards and requirements found in the regulations; an identical or general permit, based on state
technical regulations, is issued for each well within a given category; and authority to issue site-specific
(or individual) permits, inspect, and take enforcement action.   State UIC programs are generally
resource-constrained. This means the states are often not able to implement UIC programs as
vigorously as they would like.  The lack of resources typically manifests itself in a state program that is
more reactive than proactive.

        An overview of the Class V injection wells discussed  in this report is provided in the table
below.  These wells are described in detail in separate volumes that make up the body of this report,
except for aquifer recharge wells and aquifer storage and recovery wells, which are covered together in
Volume 21. The different well categories are extremely diverse in their purpose, their design and
operation, their number and location, the nature of the fluids they inject, their potential to  contaminate
September 30, 1999

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USDWs, and the way they are currently regulated by the states.  They include relatively simple designs
that drain storm water runoff or excess water from agricultural fields, large-capacity septic systems used
to dispose of sanitary sewage, wells used to dispose of wastewater from certain commercial and
industrial establishments, wells used to inject water for the purpose of storage or recharging an aquifer,
wells used to test new technologies, and wells used to inject fluids for the purpose of remediating a
contaminated aquifer or protecting a freshwater aquifer from the intrusion of saltwater.

       In addition to these 23 well categories, the study examined Class V motor vehicle waste
disposal wells, large-capacity cesspools, and industrial wells. On July 29, 1998, USEPA proposed
additional UIC regulations for these three well types when located in ground water- based source water
protection areas being delineated by states in accordance with the 1996 Amendments to the Safe
Drinking Water Act (63 FR 40586). To support decisions for the final rulemaking, USEPA collected
information on motor vehicle waste disposal wells, large-capacity cesspools, and industrial wells
nationwide as part of the overall Class V Study.  The information compiled from this effort was placed
in the public docket and announced in a notice of data availability (NODA) published in the Federal
Register on May 21, 1999 (64 FR 27741), and is not addressed further in this report. Just as it will
use the information presented in this report to support regulatory decisions for the 23 well categories
covered in the table below, USEPA will use the information from the NODA to support further
regulatory decisions for motor vehicle waste disposal wells, large-capacity cesspools, and industrial
wells.
September 30, 1999

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                                         Overview of Class V Wells Included in This Report

Well Type

Agricultural
Drainage Wells











Storm Water
Drainage Wells










Inventory


Documented
> 1,069












71,015












Estimated
>2,842












247,522











Number of
States
Potentially
with Wells
21












probably 50












Injectate Constituents
>MCLsorHALs

Nitrate, Boron, Sulfate,
Coliforms, Cyanazine,
Atrazine, Alachlor,
Adlicarb, Carbofuran, 1 ,2-
Dichloropropane,
Dibromochloro-propane,
Chloride, and IDS






Aluminum, Antimony,
Arsenic, Beryllium,
Cadmium, Chloride,
Chromium, Color,
Copper, Cyanide, Iron,
Lead, Manganese,
Mercury, Nickel, Nitrate,
pH, Selenium, IDS,
Turbidity, Zinc, Fecal
Coliforms, and nine
organics


Contamination Potential

Five contamination incidents
documented. Also, studies in
agricultural areas have linked
nitrate contamination in
ground water to agricultural
drainage well use. Wells may
be vulnerable to spills from
manure lagoons, direct
discharges from septic tanks,
and accidental releases of
materials used in farming
operations (e.g., motor oils,
pesticides).
Presence of these wells near
highways, parking lots, and
loading facilities increases
likelihood/vulnerability to
accidental spills and
purposeful illicit discharges.
Fifteen contamination
incidents documented.





State Regulations in States With
the Most Wells

Individual permit: ID (for wells >18 deep) and
TX

Permit by rule: OH, ID (for wells <18 feet deep)

IA: all wells that existed before 2/18/98 must
close or get a permit by 12/31/01; new wells
prohibited but may be permitted under strict
conditions (unlikely to be permitted)

Ban: MN (for "wells" that reach ground water)


Permit by rule: IL, IN, MI, OH, WI (<10 ft.
deep and constructed prior to 1994), MT, WY,
ND, SD, UT, CO, ID (< 18 ft. deep), OR, WA,
KS, TN, RI

Individual permit/registration system: AZ, CA,
HI, ID (> 1 8 ft. deep), AL, FL, TX, NH, MD,
NE,NY

Banned: NC, GA, WI (any new well since 1994
and wells >10 ft. deep since the 1930's), MN
(for "wells" that reach ground water)
September 30, 1999

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                                   Overview of Class V Wells Included in This Report (continued)

Well Type

Carwash Wells







Large-
Capacity
Septic
Systems
(LCSSs)



Food
Processing
Wells







Inventory


Documented
+ 4,651







-43,000







741










Estimated
+ 7,195







-353,000
(95%
prediction
interval of
304,000 to
403,000)


+1,468









Number of
States
Potentially
with Wells
19







50







29










Injectate Constituents
>MCLsorHALs

Antimony, Arsenic,
Beryllium, Cadmium,
Lead, Thallium,
Methylene chloride,
Tetrachloroethene,
Aluminum, Iron, and
Manganese

Aluminum, Arsenic, Fecal
Coliforms, Iron,
Manganese, Nitrate (as
N), Total Nitrogen
Species (as N),
Formaldehyde (from RV
systems), Sodium

Nitrate, Nitrite, Total
Conform, Ammonia,
Odor, Turbidity, and
Chloride







Contamination Potential

Possibility of contamination
due to self-service nature of
facilities (someone may use
degreasers or other chemicals
or change oil over drains).
Two documented
contamination incidents from
unknown causes.
Vulnerable because any
materials spilled/dumped
down drains enter the well.
Three documented
contamination incidents with
another 24 sites where
contamination may have
occurred.
High potential for contami-
nation due to little state
oversight and type/nature of
facilities. Moderate potential
for receiving spills of strong
cleaning chemicals due to
location of floor drains and
chemical storage/use
practices. One documented
contamination incident.

State Regulations in States With
the Most Wells

Permit by rule: WV

Report discharge: CA

Individual permit: AL, MS, NY, WA, MD,
NH, and ME

Ban: IA
No consistent state regulation of LCSSs. State
regulations vary from stringent siting,
construction, and operation requirements (e.g.,
MA, MN) to general construction permitting
(e.g.,NJ,IA)



Permit by rule: AL, TN, WV, and IA

Individual or general permit: AK, ME, NY, OR,
andWI

Varies by county /region: CA

Banned: OR


September 30, 1999

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                                   Overview of Class V Wells Included in This Report (continued)
Well Type
Sewage
Treatment
Effluent Wells
Laundromat
Wells
Spent Brine
Return Flow
Wells
Inventory
Documented
1,675
<700
98
Estimated
>1,739
>3,495
98
Number of
States
Potentially
with Wells
18
19
2
Injectate Constituents
>MCLsorHALs
Fecal Coliform, Nitrate,
IDS, Pesticides
IDS and pH
Barium, Boron, Chloride,
Copper, Iron, Manganese,
IDS, and pH
Contamination Potential
Potential for impacts to
ground and surface water
quality from nutrients. Low
vulnerability because most
wells appear to have
discharge limits and
monitoring requirements; any
injectate that does not meet
the permit conditions is likely
to be detected by the
monitoring program. Three
contamination incidents.
Wells may be susceptible to
uncontrolled laundering of
contaminated articles due to
unsupervised nature of coin-
op laundromats. No reported
contamination incidents.
Unlikely to receive accidental
spills or discharges. No
contamination incidents
reported.
State Regulations in States With
the Most Wells
Permit by rule: ID, TX
Aquifer Protection Program Permit: AZ
Ground Water Discharge Permit: MA, NH, and
WI (for discharge into a shallow subsurface
absorption field located in the unsaturated zone
above the water table).
Individual permit: CA, FL, HI, WV, OR, WY
Banned: WI (for direct discharge from a sewage
treatment plant into a saturated formation)
Permit by rule: IA, MS, andWV
Individual permit: AL and NY
Individual permit: AR, MI
September 30, 1999

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                                   Overview of Class V Wells Included in This Report (continued)

Well Type

Mine Backfill
Wells








Aquaculture
Waste
Disposal Wells






Solution
Mining Wells




Inventory


Documented
5,060









56








2,694






Estimated
>7,890









<106








2,694





Number of
States
Potentially
with Wells
22









6








2






Injectate Constituents
>MCLsorHALs

Antimony, Arsenic,
Barium, Beryllium,
Boron, Cadmium,
Chromium, Lead,
Mercury, Molybdenum,
Nickel, Selenium, Silver,
Thallium, Zinc,
Aluminum, Copper, Iron,
Manganese, TDS, Sulfate,
and pH
Nitrate, Turbidity, and
Chloride







Sulfate, Molybdenum,
Radium, Selenium,
Arsenic, Lead, Uranium,
TDS, Chloride,
Manganese, Aluminum,
Iron, and Zinc

Contamination Potential

Contamination potential
depends on site-specific
conditions and practices. No
contamination incidents
reported that are directly
attributable to Class V mine
backfill wells.



Potential exists for operators
to dispose of liquid wastes
(e.g. waste or spent
aquaculture chemicals) via
aquaculture injection wells.
Contamination potential
depends on case-specific
factors. No contamination
incidents reported.
Not likely to receive
accidental spills or illicit
discharges. No contamination
incidents reported that are
directly attributable to Class
V wells.

State Regulations in States With
the Most Wells

Permit by rule: ID, KS, TX, IL, and NO
(sometimes general or individual permits are
required)

General permit: WY

Individual or area permit: WV, OH, IN, PA



Permit by rule: ID (for wells <18 feet deep), NY

Individual permit: HI, MD, ID (for wells  18
feet deep)

General permit: WY



Individual permit: AZ, NM





September 30, 1999

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                                   Overview of Class V Wells Included in This Report (continued)

Well Type

In-Situ Fossil
Fuel Recovery
Wells








Special
Drainage Wells






Experimental
Wells








Inventory


Documented
0










1,944







396










Estimated
0










>3,750







>396









Number of
States
Potentially
with Wells
0










15







10










Injectate Constituents
>MCLsorHALs

Ammonium nitrate










Coliform, Turbidity,
Nitrogen-total ammonia,
Arsenic, Cadmium,
Cyanide, Lead,
Molybdenum, Nickel,
Nitrate, Radium 226, Iron,
Manganese, TDS, and
Sulfate
Chloride, Sulfides,
Uranium









Contamination Potential

Most recovery operations, in
the last 20 years, seem to
have caused some ground
water contamination (number
of cases unknown). Problems
are due to recovery
operations not necessarily
injection. Injection wells,
deemed unlikely to receive
accidental spills or illicit
discharges.
Depends on the well type and
site characteristics.






Experimental tracer study
wells not likely to be
vulnerable to spills and illicit
discharges. Experimental
ATES systems inject treated
water, and are not very
vulnerable to spills or illicit
discharges. One
contamination incident
reported.

State Regulations in States With
the Most Wells

Individual permit: WY, CO










Permit by rule: ID, IN, OH

Area permit: FL (single family swimming pools
only)

Individual permit: AK, FL, OR


Permit by rule: CO, TX, ID (for wells <18 ft.
deep)

Individual permit: SC, NV, WA, and ID (for
wells >1 8 ft. deep)





September 30, 1999

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                                   Overview of Class V Wells Included in This Report (continued)
Well Type
Aquifer
Remediation
Wells
Geo thermal
Electric Power
Wells
Geo thermal
Direct Heat
Wells
Inventory
Documented
10,222
234
31
Estimated
10,756
234
48
Number of
States
Potentially
with Wells
39
4
10
Injectate Constituents
>MCLsorHALs
Sometimes inject reagents
at concentrations above
MCLs, though no data to
show levels
Aluminum, Antimony,
Arsenic, Barium, Boron,
Cadmium, Copper,
Fluoride, Lead, Mercury,
Strontium, Sulfate, Zinc,
TDS, Manganese, pH,
Iron, and Chloride
Arsenic, Boron, Sulfate,
Fluoride, Chloride, Iron,
Manganese, and TDS
Contamination Potential
Not likely to be vulnerable
because injectate quality
controlled by the conditions
of the operations being
conducted. Some concern for
unapproved or unsupervised
voluntary cleanups. One
contamination incident
reported.
Generally not vulnerable to
receiving accidental spills or
illicit discharges, in some
cases due to Best
Management Practices
(BMPs). No contamination
incidents reported.
Unlikely to receive accidental
spills or illicit discharges. No
contamination incidents
reported.
State Regulations in States With
the Most Wells
Permit by rule: TX
Individual permit: KS, OH, SC
Individual permit: CA, HI, NV, UT
Permit by rule: ID (<18 ft deep)
Individual permit: CA, NM, NV, UT, OR, ID
(> 18 ft deep)
September 30, 1999

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                                   Overview of Class V Wells Included in This Report (continued)

Well Type

Heat
Pump/Air
Condition
Return Flow
Wells








SaltWater
Intrusion
Barrier Wells

Aquifer
Recharge &
Aquifer
Storage and
Recovery
Wells
Noncontact
Cooling Water
Wells


Inventory


Documented
27,918












315



1,185





<5,775





Estimated
>32,801
(but likely
<35,000)










>609 (but
likely
<700)

>1,695
(but likely
<2,000)



>7,780




Number of
States
Potentially
with Wells
40












5



28





32





Injectate Constituents
>MCLsorHALs

Lead, Copper, Chloride,
and IDS











Typically meets MCLs



A few constituents
reported at levels above
the MCLs (typically
meets MCLs)


Injectate expected to meet
MCLs/HALs because
contains no additives/not
chemically altered


Contamination Potential

Low contamination potential
because the wells are part of
enclosed systems and are
generally maintained on
private property. Three
contamination incidents
reported.






Unlikely to receive accidental
spills or illicit discharges. No
contamination incidents
reported.
Unlikely to receive accidental
spills or illicit discharges. No
contamination incidents
reported.


Low probability of pipe leaks
that could result in accidental
releases. No contamination
incidents reported.


State Regulations in States With
the Most Wells

Permit by rule: AZ, IL, KS, MI, MN, NE, NO
(most wells), NY, OH, PA, SC, TN, TX, VA,
WV,WY

General permit: WI (for open-loop discharge to
shallow subsurface soil absorption field in the
unsaturated zone above the uppermost drinking
water aquifer)
Individual permit: DE, FL, MD (some wells),
MO, NV, NC, OR (unless individually
exempted), VT, WA
Banned: WI (for open-loop discharge directly
back into an aquifer)
Permit by rule: CA

Individual permit: FL, NY, and WA

Permit by rule: CA, CO, ID (<18 feet deep),
OK, TX

Individual permit: FL, ID (>18 feet deep), NV,
OR, SC, WA

Permit by rule: TN, WV, OH, IA, MT, CA

Individual permit: AK, WA (existing), AL, NY

Ban: WA (new)
September 30, 1999
10

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                                   Overview of Class V Wells Included in This Report (continued)
Well Type
Subsidence
Control Wells


Inventory
Documented
28


Estimated
158


Number of
States
Potentially
with Wells
5


Injectate Constituents
>MCLsorHALs
Injectate data not
available; reasonable to
assume injectate in wells
in NY, OR, and LA
exceeds MCLs for some
parameters.
Contamination Potential
Cannot be assessed due to
lack of access to details on
well design, construction, and
operation. No contamination
incidents reported.

State Regulations in States With
the Most Wells
Permit by rule: LA, OR
Individual permit: NY
Ban new wells: WI

September 30, 1999
11

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2.     BACKGROUND

       The USEPA regulates five classes of underground injection wells, called Class I through V
wells, under the authority of the Safe Drinking Water Act and through a series of UIC regulations.
While implementing this program, USEPA has studied Class V injection wells and pursued new
rulemaking activities and non-regulatory approaches to improve the management of Class V wells.

       2.1    Class V Wells

       As defined by USEPA, an injection well is any hole that is deeper than it is wide and is used to
emplace fluids underground. This includes sophisticated designs in which holes are drilled and cased
with metal or plastic pipe. However, it also includes simple designs to drain fluids to the subsurface.
For example, natural surface depressions associated with a conduit to the subsurface that have been
modified for the purpose of facilitating the drainage of fluids to the subsurface (called "improved
sinkholes") may qualify as injection wells. Likewise, both large-capacity septic systems and those at
commercial or industrial sites qualify as wells under USEPA's definitions, as do abandoned drinking
water wells that have been adapted to convey fluids  underground. Injection wells, however, do not
include surface impoundments, ditches, or trenches that are wider than they are deep.

       In order to define Class V wells, you must first define the other classes of injection wells, all of
which are regulated to protect USDWs. USDWs are aquifers or portions of aquifers that currently are,
or could in the future be, used as drinking water sources. Injection wells are classified based primarily
on the type of fluids disposed in the well, and USEPA requirements for each well class are designed to
ensure USDWs are not threatened by the well operations.  Class I wells are used to inject hazardous
and non-hazardous waste beneath the lowermost formation containing a USDW within one-quarter
mile of the well.  Class n wells are used to inject fluids associated with oil and natural gas recovery and
storage of liquid hydrocarbons. Class m wells are used in connection with the solution mining of
minerals.  Class IV wells, which are generally prohibited, are used to inject hazardous or radioactive
wastes into a formation which within one-quarter mile of a well bore contains a USDW.  Class V wells
are defined as any well not included in Classes I through IV.

       Class V injection wells are generally shallow waste  disposal wells, septic systems, storm water
and agricultural drainage systems, or other devices used to release fluids either directly into USDWs or
into the shallow subsurface that overlies USDWs.  In order to qualify as a Class V well, the fluids
released cannot be a hazardous waste as defined under the Resource Conservation and Recovery Act
(RCRA).  Frequently, Class V wells are designed  as no more than shallow holes or septic tank and
leachfield combinations intended for sanitary waste disposal. This report focuses on the following 23
categories of Class V wells:
September 30, 1999                                                                           12

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                                          Categories of Class V Wells

  1.        Agricultural Drainage Wells include all wells receiving agricultural runoff.  This includes improved sinkholes,
           abandoned drinking water wells, and underground drain tiles and cisterns receiving agricultural runoff, excess
           irrigation water, and flood water. Those drain tiles that discharge to a ditch are exempted from UIC regulation.

  2.        Storm Water Drainage Wells are shallow injection wells designed for the disposal of rain water and melted
           snow. These wells typically drain paved areas such as streets and parking lots, or roofs. Improved sinkholes and
           abandoned drinking water wells are considered storm water drainage wells when they receive storm water runoff.

  3.        Wells Used to Drain Fluids from Carwashes Where No Engine or Undercarriage Washing is Performed
           (called "carwash wells" in the remainder of this report). This includes floor drains in bays of coin-operated,
           manual carwashes where people use hand-held hoses to wash only the exterior of cars, trucks, and other vehicles.
           These kinds of carwashes are sometimes referred to as "wand washes," as opposed to  "tunnel washes" or
           "rollover washes" where automatic washing equipment is used.

  4.        Large-Capacity Septic Systems are septic tanks and fluid distribution systems, such as leachfields or wells,
           used to dispose of sanitary waste only (not industrial waste, motor vehicle waste fluids, or other kinds of
           commercial waste that does not qualify as "sanitary waste"). These kinds of systems  are typically used by
           multiple dwellings, business establishments, or communities for the disposal of sanitary waste. Individual or
           single family septic systems and non-residential systems having the capacity to serve fewer than 20 persons a
           day are not included.

  5.        Food Processing Wells are any type of system that accepts food processing wastewater and releases it into or
           above USDWs.  This includes  systems used to dispose of wastewaters generated from  the preparing, packaging,
           or processing of food products (e.g., slaughterhouses, seafood or poultry processing facilities, etc.), not septic
           systems used solely for the disposal of sanitary waste.

  6.        Sewage Treatment Effluent  Wells are used to inject treated effluent from publicly owned treatment works or
           treated effluent from privately  owned treatment facilities receiving solely sanitary waste. A well that receives
           effluent from a privately owned treatment facility that receives industrial waste (as opposed to solely sanitary
           waste) qualifies  as an industrial well, not a sewage treatment effluent well. Also, a well that  injects municipal
           waste beneath the lowermost USDW in an area qualifies as a Class I well rather than a Class  V well.

  7.        Wells Used to Inject Fluids from Laundromats Where No Onsite Dry Cleaning is Performed or Where
           No Organic Solvents are Used for Laundering (called  "laundromat wells" in the remainder of this
           report). This includes drains that lead to drywells (open holes) or septic systems at coin-operated laundromats
           that do not have onsite dry cleaning services.

  8.        Spent Brine Return  Flow Wells are used to dispose of brines from which minerals, halogens, and other
           compounds have been extracted. These wells are commonly associated with manufacturing facilities that produce
           specialty chemicals such as boron, bromine, magnesia, or their derivatives.

  9.        Mine Backfill Wells are used to place slurries of sand, gravel, cement, mill tailings or refuse, fly ash, or other
           solids into underground mines.  These wells can serve a variety of purposes, including  subsidence prevention,
           filling dangerous mine openings, disposing of wastes from mine operations, and fire control.

  10.       Aquaculture Waste Disposal Wells dispose of water used for the cultivation of marine and freshwater animals
           and plants under controlled conditions.

  11.       Solution Mining Wells are used to extract desired minerals from mines that have already been conventionally
           mined. Leaching solutions (called "lixiviants") are injected through solution mining wells into an underground ore
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                                   Categories of Class V Wells (continued)

  12.       In-Situ Fossil Fuel Recovery Wells are used for recovery of lignite, coal, tar sands, and oil shale. The wells
           inject water, air, oxygen, solvents, combustibles, or explosives into underground or oil shale beds to liberate fossil
           fuels. Underground coal gasification and in-situ oil shale retorting are two processes that use in-situ fossil fuel
           recovery wells.

  13.       Special Drainage Wells include a variety of wells such as potable water tank overflow, construction
           dewatering, swimming pool drainage, and mine dewatering wells.  These wells receive fluids that cannot be
           classified as agricultural, storm water, or industrial drainage.

  14.       Experimental Wells are used to test new technologies. Wells are not classified as experimental if the technology
           can be considered under an established well subclass.  For example, a well used  for bioremediation should be
           classified as an aquifer remediation well.

  15.       Aquifer Remediation Wells are used to clean up, treat, or prevent contamination of ground water. Treated
           ground water (from pump and treat systems), bioremediation agents, or other contaminant recovery enhancement
           materials may be injected into the subsurface via these wells. These wells may be associated with RCRA or
           Superfund cleanup projects.

  16.       Geothermal Electric Power Wells dispose of spent (meaning cooled) geothermal fluids following the extraction
           of heat for the production of electric power.

  17.       Geothermal Direct Heat Wells dispose of spent (cooled) geothermal fluids following the extraction of heat used
           directly, without conversion to electric power, to heat homes or provide heat to commercial or industrial
           activities.

  18.       Heat Pump/Air Condition Return Flow Wells reinject ground water that has been passed through a heat
           exchanger in order to heat or cool buildings. A heat pump takes thermal energy from the ground water and
           transfers it to the space being heated. When cooling is required, the heat pump removes heat from a building and
           transfers it to the ground water.

  19.       Salt Water Intrusion Barrier Wells are  used to  inject fluids to prevent the intrusion of salt water into an
           aquifer. These wells may have secondary purposes, such as to recharge an aquifer with fresh water to be used
           later.

  20.       Aquifer Recharge Wells are used to inject fluids to recharge an aquifer.  These wells may have secondary
           purposes, such as salt water intrusion prevention, subsidence control, or aquifer storage and recovery.

  21.       Aquifer Storage and Recovery Wells are used to inject water for later recovery and use. These wells may have
           secondary purposes, such as aquifer recharge.

  22.       Noncontact Cooling Water Wells. Noncontact cooling water is water used in a cooling system designed to
           maintain constant separation of the water with process chemicals. Wells that inject contact cooling water or
           noncontact cooling water that contains additives (e.g., corrosion inhibitors, biocides) or is contaminated compared
           to the original source water are considered  industrial wells.

  23.       Subsidence Control Wells inject fluids to control land sinking, or  subsidence, caused by ground water
           withdrawal and other activities (but not oil and gas production).
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       USEPA estimates that more than 686,000 Class V wells within the above categories currently
exist in the United States.  These wells are located in virtually every state, especially in unsewered areas
where the population is likely to depend on ground water.

       In addition to these 23 well categories, there are three other types of Class V wells:

      Motor vehicle waste disposal wells that receive or have received fluids from vehicular repair
       or maintenance activities, such as an auto body repair shop, automotive repair shop, new and
       used car dealership, specialty repair shop, or any facility that does any vehicular repair work.

      Cesspools used to dispose of untreated sanitary waste, including multiple dwelling, community
       or regional cesspools, or other devices that have an open bottom and sometimes perforated
       sides. The UIC requirements do not apply to single family residential cesspools nor to non-
       residential cesspools that receive solely sanitary waste and have the capacity to serve fewer
       than 20 persons a day.

      Industrial wells used to inject non-hazardous industrial or commercial fluids other than those
       described for the other types of Class V wells listed above.

       USEPA also addressed these three well types in this study.  The results for these wells have
already been published and placed in the public docket, as announced in a May 21, 1999 NODA (64
FR 27741).  Therefore, rather than repeating the information compiled on motor vehicle waste disposal
wells, large-capacity cesspools, and industrial wells, this report focuses only on the study methods and
results for the other 23 well categories listed above.

       2.2    Safe Drinking Water Act

       The  Safe Drinking Water Act (SDWA or the Act) is designed to protect the quality of drinking
water in the United States. Part C of the Act specifically mandates the regulation of underground
injection of fluids through wells.

       Section 1421 of the Act requires USEPA to propose and promulgate regulations specifying
minimum requirements for state programs to prevent underground injection that endangers drinking
water sources.  USEPA promulgated administrative and permitting regulations, now in 40  CFR Part
144 and 146, on May  19, 1980 (45 FR 33290), and technical requirements in 40 CFR Part 146 on
June 24, 1980 (45 FR  42472). These regulations have since been amended on several occasions.

       Section 1422 of the Act provides that states may apply to USEPA for primary responsibility to
administer the UIC program (those states receiving such authority are referred to  as "Primacy States").
Where states do not seek this responsibility or fail to demonstrate that they meet USEPA's minimum
requirements, USEPA is required to prescribe, by regulation, a UIC program for such states.  These
direct implementation  (DI) programs were established in two phases, on May 11, 1984 (49 FR 20138)
and November 15, 1984 (49 FR 45308).


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       2.3    UIC Regulations

       Under the USEPA UIC Program, Class V wells are currently authorized by rule, meaning they
do not have to obtain an individual permit unless required to do so. Under 40 CFR 144.12(a), owners
or operators of all injection wells are prohibited from engaging in any injection activity that allows the
movement of fluids containing any contaminant into USDWs, if the presence of that contaminant may
cause a violation of any primary drinking water regulation or may otherwise adversely affect human
health. Sections 144.12(c) and (d) specify actions to be taken by the UIC Program Director if a well is
not in compliance with section 144.12(a).

       Owners or operators of Class V wells are also required to submit basic inventory information
under 40 CFR 144.26. In addition, Class V wells are subject to the general program requirements of
section 144.25, under which the UIC Program Director may require a permit, if necessary, to protect
USDWs. Moreover, under section 144.27, USEPA may require owners or operators of any Class V
well, in USEPA-administered programs, to submit additional information deemed necessary to protect
USDWs. Owners or operators who fail to submit the information required under sections 144.26 and
144.27 are prohibited from using their wells.

       2.4    1987 Report to Congress on Class V Wells

       In accordance with the 1986 Amendments to the SDWA, USEPA  summarized information on
Class V wells in a Report to Congress entitled Class VInjection Wells   Current Inventory; Effects
on Ground Water; and Technical Recommendations,  September 1987 (USEPA Document Number
570/9-87-006). That report presents a national overview of Class V injection practices  and state
recommendations for Class V design, construction, installation, and siting requirements.  These state
recommendations, however,  did not give USEPA a clear mandate on what, if any, additional measures
were needed to control Class V wells on the national level. For any given type of well, the
recommendations varied broadly and were rarely made by more than two  or three states. For
example, the recommendations for large-capacity septic systems ranged from further studies (three
states) to statewide ground water monitoring (one state).

       2.5    Actions Since the 1987 Report to Congress

       On December 30, 1993, the Sierra Club filed a complaint against USEPA in the United States
District Court for the District of Columbia alleging that USEPA failed to comply with section 1421 of
the  SDWA regarding publication of proposed and final regulations for Class V injection wells. The
complaint alleged that USEPA's current regulations regarding Class V wells do not meet the SDWA's
statutory requirements to "prevent underground injection which endangers drinking water sources."

       On August 31, 1994, USEPA entered into a consent decree with the Sierra Club requiring that
by no later than August 15, 1995, the USEPA Administrator sign a notice to be published in the
Federal Register proposing  regulatory action that fully discharges the Administrator's rulemaking
obligation under section 1421 of the SDWA with respect to Class V injection wells. The consent


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decree further required that a final rule on Class V wells be signed by November 15, 1996.
Accordingly, on August 15, 1995, the Administrator signed a notice of proposed rulemaking intended
to fulfill this obligation  (60 FR 44652, August 28, 1995). In this notice, USEPA proposed not to adopt
additional federal regulations for any types of Class V injection well. Instead, the Agency proposed to
address the risks posed by certain wells using existing authorities and a Class V management strategy
designed to (1) speed up the closure of potentially endangering wells; and (2) promote the use of best
management practices to ensure that other Class V wells of concern do not endanger USDWs.

       USEPA received many comments that supported the Agency's proposal to not impose more
regulations for Class V wells.  However, USEPA also received a number of comments that raised
concerns about the proposal. In particular, several commenters questioned whether a UIC program
without additional requirements for relatively high-risk well types, including Class V motor vehicle waste
disposal wells, industrial waste disposal wells, and large-capacity cesspools, could prevent
endangerment to drinking water sources as required by the SDWA. The Sierra Club Legal Defense
Fund alleged that the proposal failed to carry out statutory requirements.

       Based on these and other comments, USEPA decided to reconsider the 1995 proposed
approach. Because this reconsideration would extend the time necessary to complete the rulemaking
for Class V wells, USEPA and the Sierra Club Legal Defense Fund entered into a modified consent
decree on January 28, 1997 that extended the dates for rulemaking that had been in the 1994  decree.
The modified decree requires three actions.

      First, by no later than July 17, 1998, the USEPA Administrator was required to sign a notice to
       be published in the Federal Register proposing regulatory action that fully discharges the
       Administrator's rulemaking obligation under section 1421 of the SDWA with respect to those
       types of Class V injection wells presently determined to be high risk and for which additional
       information is not needed. According to the consent decree, as modified, the Administrator
       must sign a final rulemaking for such high-risk Class V wells by no later than October 29, 1999.

      Second, by no later than September 30, 1999, USEPA must complete a study of all Class  V
       wells not included in the rulemaking on high-risk Class V injection wells. Based on this study,
       USEPA may find that some of these other types of Class V wells also pose a high risk.

      Third, by no later than April 30, 2001, the USEPA Administrator must sign a notice to be
       published in the Federal Register proposing to discharge the Administrator's rulemaking
       obligations under section 1421 of the SDWA with respect to all Class V injection wells not
       included in the first rulemaking for Class V injection wells. The Administrator must sign a final
       rulemaking for these remaining Class V wells by no later than May 31, 2002.

       On July 29, 1998  (63 FR 40586), in response to the first action required under the modified
consent decree, USEPA proposed revisions to the Class V UIC regulations that would add new
requirements for the following three types of wells that, based on information available at the time, were
believed to pose a high  risk to USDWs: motor vehicle waste disposal wells, large-capacity cesspools,


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and industrial wells when located in ground water-based source water protection areas. In response to
the second action required under the modified consent decree, USEPA conducted this study of the
remaining 23 well categories defined above to determine whether they warrant additional UIC
regulation. At the same time, the Agency collected information on motor vehicle waste disposal wells,
large-capacity cesspools, and industrial wells to support rulemaking decisions for those wells.  In
accordance with the third action required under the modified consent decree, USEPA will use the
information presented in this report for the 23 well categories, combined with the study results
published previously for the three well types targeted in the July 29, 1998 proposal, to make regulatory
decisions for all those well categories not addressed in the initial rulemaking on high-risk wells.

3.    STUDY APPROACH

       USEPA initiated the Class V study by convening a workgroup of USEPA and state UIC
representatives to help design the research effort.  Workgroup members met during the spring and
summer of 1997 to develop a method for collecting information. Based on these meetings, USEPA
concluded that state programs have information useful to the study, but that additional information
should be collected from other sources as well. USEPA also recognized that very little inventory
information (i.e., data on the numbers of existing Class V wells in different locations) was available from
the states for some types of wells.

       As a result of this initial scoping, the final  Class V study design had two components: (1) an
information collection effort for the 23 Class V well categories; and  (2) inventory models to estimate the
number of storm water drainage wells and large-capacity septic systems, two types of wells that were
believed to be quite prevalent but for which adequate inventory information was particularly lacking.
These two components  are described below in Sections  4 and 5, respectively. The workgroup
continued to meet throughout both of these efforts to provide feedback as the study progressed.

       The information developed from this research has been compiled into a 23-volume final report
that consists of:

      Volume 1 (this volume), which provides general  information on the study approach and results;

      Volumes 2-23, which provide a well-specific information summary for each of the 23
       categories of wells that were studied (Volume 21 covers both aquifer recharge wells and
       aquifer storage and recovery wells); and

      Five appendices, as follows:

             Appendix A provides the Class V Study Information Collection Request.
             Appendix B presents the questionnaires that were used in general information collection
              effort.
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             Appendix C outlines the methods and information used to select census tracts to visit
              for the purpose of developing the inventory models, presents the results from those
              census tract visits, and summarizes the inventory model development and results.
             Appendix D presents the drinking water standards and other criteria used in the well-
              specific summaries to compare to data on the quality of fluids released by the 23 well
              types; and
             Appendix E presents information on the ground water persistence and mobility of
              various chemicals possibly released by Class V wells.

4.     INFORMATION  COLLECTION

       The information collection consisted of four activities:  a literature review, state and USEPA
Regional data collection, requests to the public for data, and peer review.  Each of these efforts is
described in turn below.

       4.1    Literature Review

       USEPA started the search by locating available references from the Ground Water Protection
Council's (GWPC's) Injection Well Bibliography. To supplement this bibliography, USEPA used a list
of key words to search the Boston Library Consortium, individual libraries, ten scientific databases, the
World Wide Web, the Library of Congress, and libraries linked to the Library of Congress. USEPA
also sought available information through targeted phone calls to trade associations, research institutes,
universities, and other sources.

       4.2    State and USEPA Regional Data Collection

       4.2.1   Data Collection Methods

       USEPA prepared an Information Collection Request (ICR) that outlined the methodology,
identified the information to be collected, and calculated the burden associated with responding to a
Class V survey. OMB approved the ICR (OMB # 240-0194) on July 31, 1998.

       The first step in the collection process was to ask USEPA Regional representatives to identify
the best UIC contact for each state in the Region. The scope of this search included all 50 states, the
District of Columbia, Guam, the Commonwealth of Puerto Rico, the Northern Mariana Islands, the
Virgin Islands, American Samoa, and the Trust Territory of the Pacific Islands.  It also included Indian
lands in USEPA Regions 5, 8, 9, and 10.

       Next, USEPA  called each contact person to explain the study, obtain some preliminary
information about the data the contact had available, and describe an information request letter that the
contact would soon receive.  This letter requested information on the types of wells in each state and
appropriate contacts for those wells.
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       USEPA then sent well-specific questionnaires to the contacts identified in responses to this
letter. USEPA distributed nearly 700 questionnaires to USEPA Regional, state,  and local respondents.
Because some states were unable to complete the questionnaires due to resource constraints and other
states (particularly DI states) had very limited information to share, USEPA supplemented the
information from the questionnaires through follow-up telephone interviews and on-site file searches in
ten primacy states (Massachusetts, Maryland, West Virginia, Florida, Illinois, Minnesota, Kansas,
Wyoming, Oregon, and Washington); two DI states (California and Colorado); and two Regional
Offices with DI states (Region 3: Pennsylvania, Virginia, and the District of Columbia; and Region 8:
Colorado). In some cases, USEPA also completed summaries using information from other sources
such as state Internet Web sites or studies and reports.

       4.2.2   Information Obtained

       USEPA received information on all but a few UIC programs. American  Samoa was the only
program to report that no Class V wells exist. Altogether, USEPA received and completed by
telephone approximately 475 questionnaires, conducted scores of telephone conversations, and
received a large volume of written and e-mail correspondence.

       While USEPA collected a significant amount of information, the study also discovered where
states are lacking data. The following sections summarize the information collected and limitations of
that information in four categories: inventory data, injectate quality data, contamination incidents, and
regulatory authority and implementation.

       Inventory Data

       Two generalizations can be made about the inventory information that was obtained:

      States generally maintain accurate inventories for mining, geothermal,  aquifer recharge, aquifer
       storage and recovery, and aquifer remediation wells.  Because these wells often require state
       approval before construction, states believe that they have kept accurate  records of these wells.

      For other well types, states and USEPA Regions suspect that their inventories underestimate
       the true number of wells.  For example,  inventories of agricultural drainage wells may be
       inaccurate because of limited public records of these wells and the inability of public officials to
       locate these wells on rural private property without the coordination of the landowner.  The
       survey responses indicate that agricultural drainage and storm water drainage wells are often
       constructed and used by individuals who may not be aware of Class V regulations and, thus,
       have never been reported.  Furthermore, local agencies often have jurisdiction over these well
       types, so they may not be accounted for in a state's inventory.
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       In addition, there are significant uncertainties associated with the inventory data:

      In some cases, different sources provided different numbers, both for documented and
       estimated number of wells.  In particular, documented numbers of wells reported in survey
       responses sometimes differed from the numbers reported in computer database printouts
       provided by the same state staff.  These differences occasionally could not be reconciled.

      Estimated numbers were often provided as a range, or as "more than"  or "less than" the
       documented number.

      In some state databases, different subclasses of wells could not be distinguished.  For example,
       most states do not distinguish between carwash wells, laundromat wells, food processing wells,
       or non-contact cooling water wells, grouping them instead into a general industrial well
       category. Also, some states do not distinguish between aquifer storage and recovery wells and
       aquifer recharge wells in their current inventories.

      State classification of some well types differs from the classification used in this study. This was
       commonly the case for experimental wells. It is also possible that some states reported Class
       IV aquifer remediation wells as Class V aquifer remediation wells (see Section 6.15 below for
       the distinction between these wells).

      Although a number of studies that discuss the likely existence of agricultural drainage wells in
       various areas were found, USEPA was unable to get much documentation of the number or
       location of this type  of well.  State and local officials often either did not know of the existence
       of agricultural drainage wells or simply reported that there were none because they were
       banned or being phased out in the state.

      Most states use different criteria than in the federal UIC regulations for distinguishing between
       small and large-capacity septic systems (most states use a flow threshold rather than USEPA's
       20 persons-a-day definition).

       Injectate Quality Data

       The  injectate quality data obtained during the study vary widely. They range from a one-time
sample at one well to multiple samples at multiple wells in multiple states.  The data include results from
routine and special  monitoring, studies, permit applications, journal articles, and reports.

       There is little injectate data available for well types perceived to pose low risks to USDWs,
such as heat  pump/air conditioning return flow wells.  State injectate sampling data for agricultural and
storm water  drainage wells were also difficult to find since many  of these wells are located on private
property. However, many studies on these well types have been conducted and USEPA more often
found injectate data in the literature.
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       Contamination Incidents

       Contamination incidents are often handled by an office other than the UIC program office, such
as separate state enforcement and compliance offices.  The study was less successful in tapping these
other offices for information. As a  separate issue, states were often reluctant to disclose contamination
incidents, especially when enforcement action was pending.  Furthermore, very little documentation is
available that directly links contamination problems to Class V wells, although wells are often suspected
of contributing to contamination.

       Regulatory Authority and Implementation

       Regulatory authority over Class V wells varies widely among states. Four typical regulatory
schemes are as follows:

      General authority to protect USDWs.  The State UIC Program Director has discretionary
       authority to take actions necessary to protect USDWs.

      Permit by rule. An entire class of wells is deemed permitted as long as they comply with
       standards and requirements  found in the regulations.

      General permit.  An identical permit, based on state technical regulations, is issued for each
       well in a specified class of wells.

      Authority to issue site-specific (or individual) permits, inspect, and take enforcement
       action. This authority may be linked to technical standards in the regulations and/or may give
       the State UIC Program Director discretion to include standards necessary to protect USDWs.

       Where states have technical standards, they may contain requirements for siting or setbacks,
construction, mechanical integrity testing, injection pressure or flow, injectate quality, monitoring, best
management practices, reporting, financial responsibility, and closure and post-closure care.

       State UIC programs are generally resource-constrained. This means the states are often not
able to implement UIC programs as vigorously as they would like. This lack of resources typically
manifests itself in a state program that is more  reactive than proactive.  For example:

      States do not make wide use of discretionary authority, except when problems are evident;

      Sampling and inspections are often problem- or complaint-driven with few states conducting
       routine inspections;  and

      States are often unable to confirm that abandoned wells are properly plugged so that
       contaminants cannot enter them.
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       4.3    Requests to the Public for Information

       USEPA sought information from the public for the Class V study. One avenue for obtaining
information was the National Drinking Water Advisory Council (NDWAC). The Class V study was an
agenda topic during a NDWAC workgroup meeting held on January 7-8, 1999 in Denver, Colorado
(see 63 FR 66168, December 1, 1998).  Issues relevant to the study also were discussed in another
NDWAC workgroup meeting on March 25-26, 1999 in Washington, DC.  In both of these meetings,
members of the public were allowed to make statements.  To obtain additional information on issues
raised during these NDWAC discussions, USEPA accompanied state UIC program staff on site visits
of facilities with Class V wells in New Hampshire and Maine.

       USEPA also requested information through three notices in the Federal Register:

       64 FR 1008, January 7,  1999, Call for Peer Reviewers and Data on Aquaculture Injection
       Wells, Mining Wells, Sewage Treatment Effluent Wells, and Other Class V Injection Wells
       Including Certain Industrial Wells; and

       64 FR 1008, January 7,  1999, Call for Data on Class V Wells Including Agriculture and Storm
       Water Drainage Wells, Large-Capacity  Septic Systems, and Geothermal Wells.

       64 FR 1007, January 7,  1999, Call for Peer Reviewers and Data on Aquifer Storage and
       Recovery Wells, Aquifer Recharge Wells, Saline Intrusion Barrier Wells, Subsidence Control
       Wells, and Aquifer Remediation Injection Wells.

       USEPA staff made presentations about the status of the study at semiannual meetings of the
GWPC, including a March 1998 meeting in Annapolis, MD, a September 1998 meeting in
Sacramento, CA, a March 1999 meeting in Washington, DC, and a September 1999 meeting in
Newport, Rhode Island. During each of these presentations, the meeting participants were requested
to provide  available information and to identify additional information sources.

       USEPA also maintained an Internet Web site for the Class V study  (http://www.epa.gov/
OGWDW/uic/cl5study.html). The Web site included definitions of the well types, successive drafts of
well-specific information summaries, and other information about the study.  It also included a form that
anyone could  submit on-line to provide information about Class V wells.  The Web site, which was
frequently  visited, was advertised in the Federal Register notices listed above, at the GWPC meetings,
and in other forums.

       Finally, the July 28, 1998 proposed rule on Class V motor vehicle waste disposal wells,
industrial wells, and large-capacity septic systems introduced the study and gave the pubic an
opportunity to comment on the need to regulate those and all other kinds of Class V wells. Indeed,
several comments were submitted providing information useful to the Class V study, including additional
information on Class V food processing waste disposal wells and other types of Class V wells in
Tennessee. USEPA followed up on these comments by conducting, along with state UIC Program


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staff, site visits to a number of food processing facilities in Tennessee that own or operate Class V
wells.

       4.4    Peer Review

       USEPA coordinated peer reviews of draft information summaries for each of the 23 types of
wells studied in order to ensure technical accuracy and completeness of the documents.  These reviews
ranged from a formal peer review process in which recognized technical experts for selected well types
were sought, to an informal process in which drafts of the well-specific information summaries were
distributed to teams of state, USEPA Regional, and USEPA Headquarters reviewers.

       During these processes, reviewers were supplied with the draft information summary and a
charge that asked general and specific questions to help guide the review.  Some of the reviews
included a conference call as an opportunity for the reviewers to discuss and share thoughts on the
document. USEPA incorporated the comments received into the information summaries. Upon
completion of the review process, USEPA also developed a table explaining how USEPA used the
comments.

5.     INVENTORY MODELS

       Although the general information collection effort did include storm water drainage wells and
large-capacity septic systems, the participants in the Class V study workgroup meetings told USEPA
that very little inventory data on these wells were available from the states. In general, states believe
that their inventories of these well types are inaccurate and would not provide a realistic national
estimate.  As a result, USEPA determined that it would be necessary to construct statistical inventory
models to provide national estimates of the numbers of storm water drainage wells and large-capacity
septic systems.

       The inventory models predict the number of storm water drainage wells and large-capacity
septic systems nationally based on geologic, demographic, and other characteristics. There is little
theory  - and virtually no empirical research - regarding the factors affecting the number and location
of these wells.  Therefore, USEPA selected and visited a sample of 99 census tracts across the nation
to collect information on the numbers of wells and a variety of factors that might influence the wells'
prevalence. USEPA then analyzed the data collected from these visits to develop mathematical models
that can be used to estimate the numbers of storm water drainage wells and large-capacity septic
systems in other locations based on certain characteristics known to exist in those areas. Appendix C
describes the development and results of the inventory models in more detail.

       5.1    Storm Water Drainage Wells

       Storm water drainage wells were located in 22 of 99 census tracts surveyed.  Such wells were
primarily found along streets, but were also common in parking lots and residential areas. A few storm
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water drainage wells were also found in other areas, such as along bike paths or in recreational vehicle
parks.

       The estimate of the number of storm water drainage wells in the nation is the combination two
estimates: a model estimate for wells in non-urbanized areas, and state estimates of the number of wells
in urbanized areas. This approach is necessary because of the sampling strategy. Urbanized areas
were excluded from the sample based on the assumption that very few storm water drainage wells
would be found in urbanized areas. While a few cities make extensive use of these wells, USEPA
could not adequately represent all urbanized areas in the sample to account for these wells because of
the relatively small size of the sample.  Therefore, USEPA relied on state and other estimates gathered
as part of the general data collection effort to account for the wells in urbanized areas, and used the
sample to build a model of the number of wells in non-urbanized areas.

       The estimate for the total number of storm water drainage wells in the country is approximately
125,500. This represents the sum of the number of documented and estimated wells in urbanized areas
(35,000 and 26,500, respectively) and the model's estimate for non-urbanized areas (64,000).

       5.2    Large-Capacity Septic Systems

       Large-capacity septic systems were found in sewered and unsewered areas and were used in a
wide variety of circumstances. They were found in 88 out of 99 of the census tracts visited. The
largest percentage of systems were located at churches, but many were also found in commercial areas,
restaurants, campgrounds, public buildings, motels, residential areas, industrial areas, schools,
recreational areas, and a few in other areas  such as farms and ranger stations.

       The model assumes that the number of large-capacity septic systems in a census tract is a linear
function of the number of households on septic systems in the tract, the tract's housing density, and the
percentage  of soil in the tract that is poorly drained. Using an equation with these variables, the model
predicts approximately 353,400 large-capacity septic systems nationwide. The 95 percent prediction
interval is 304,100 to 402,600.

6.     WELL-SPECIFIC SUMMARIES

       This section presents information summaries for each of the 23 categories of Class V wells
addressed in this report.  Volumes 2 through 23 of this report provide more detail on each of these well
categories in the same  order in which they appear below (with Volume 21 covering both aquifer
recharge and aquifer storage and recovery wells). Although each summary below is tailored to the
particular issues relevant to the different wells, they all address the following basic topics in the following
sequence: (1) well purpose and fluids released; (2) the extent to which the fluids released exceed
drinking water standards at the point of injection; (3) generalizations about the characteristics of the
underground zone receiving fluids from the wells; (4) contamination incidents or studies, if any; (5)
vulnerability of the wells to spills or illicit discharges; (6) prevalence of the wells; and (7) existing state
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and federal controls. If any other factors are key in summarizing information on a given well type, they
are woven into appropriate places within this general outline.

       6.1    Agricultural Drainage Wells

       Agricultural drainage wells (ADWs) are used in many places throughout the country to drain
excess surface and subsurface water from agricultural fields, including irrigation tailwaters and natural
drainage resulting from precipitation, snowmelt, floodwaters, etc. ADWs may also receive animal yard
runoff, feedlot runoff, dairy runoff, or runoff from any other agricultural operation.  In some cases, these
fluids are released into ADWs in order to recharge aquifers that are used as sources of irrigation water.

       The water that drains into ADWs may contain high levels of naturally occurring minerals or may
be contaminated with fertilizers, pesticides, or bacteria and other microorganisms.  Available sampling
data show that the primary constituent in ADW injectate that is likely to exceed health-based standards
is nitrate. The data also indicate that boron, sulfate, coliforms,  and certain pesticides (cyanazine,
atrazine, alachlor, aldicarb, carbofuran, 1,2-dichloropropane, and dibromochloropropane) in
agricultural drainage have exceeded primary, or health-based, MCLs or HALs. Total dissolved solids
(TDS) and chloride in some ADWs also have been measured above secondary MCLs, which are
designed to protect against adverse aesthetic effects such as objectionable taste and odor.

       Concerns about high concentrations of contaminants entering ADWs are compounded by the
recognition that suitable subsurface geologic formations for ADWs often include areas with shallow,
fractured bedrock formations, or limestone bedrock, particularly where affected by karst development
that provides solution channels and sinkholes that allow rapid transmission of water. As discussed in
Volume 3, some ADWs are in fact nothing more than improved sinkholes in areas with karst.  Such
hydrogeologic settings usually allow contaminants to migrate readily without significant attenuation.

       A number of studies and incidents have shown that ADWs have in fact contributed to or caused
ground water contamination.  In particular, ten studies reviewed for this report document nitrate
contamination of ground water in agricultural areas.  Six of these studies clearly link the nitrate
contamination to ADW use. For example, one study in north central Iowa between 1981 and 1983
found that areas with the highest density of ADWs also had the highest average concentrations of nitrate
in ground water samples (37 percent of the farm wells sampled in an area with a relatively large number
of ADWs had nitrate concentrations above the MCL). Four other studies, however, do not clearly
distinguish nitrate contamination from ADWs versus more general sources of nonpoint source pollution
associated with agriculture. In addition to these nitrate studies, there are two known contamination
incidents in Iowa (in 1977 and 1997) involving direct discharges from septic tanks to ADWs.  In one of
these incidents, the ADW was also contaminated by runoff from the field application of hog manure.
Other contamination incidents include ground water and drinking water contamination linked to 15
drainage wells in Minidoka County, Idaho in 1979, and a community supply well in Dane, Wisconsin
being contaminated around 1988 by atrazine that likely drained into an improperly abandoned water
well that had been illegally modified to receive surface runoff from an agricultural area.
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       A further concern associated with ADWs is the potential for some wells to be vulnerable to
spills or illicit discharges. The close proximity of ADWs to large earthen lagoons for storing manure at
large-scale confined animal feeding operations is a particular issue that has been recognized for some
wells in Iowa; the growth of such operations nationwide may also make it an issue in other locations.
The two cases cited above involving septic tank discharges to ADWs in Iowa may also illustrate a
practice that is not uncommon in other states. Following one of those incidents, it was estimated that as
many as 30 percent of the rural septic tanks in one Iowa township may be directly connected to
ADWs. Separately, some ADWs may occasionally receive accidental releases of materials during
farming operations, such as spills of motor oils used in equipment or bulk releases of pesticides during
storage or handling. Moreover, if not carefully managed, the land application of manure in areas
drained by ADWs can cause contamination, as illustrated by one of the incidents reported in Iowa.

       According to the state and USEPA Regional survey conducted for this study, there are at least
1,069 documented ADWs and more than 2,842 ADWs estimated to exist in the U.S.  Although
believed to exist in at least 21 states, more than 95 percent of the documented wells are in just five
states: Idaho (303), Iowa (290), Ohio (>200), Texas (135), and Minnesota (92).  In truth, there may
be thousands more ADWs than these results suggest, recognizing the significant uncertainties in the
current inventory. For example, it is likely that more ADWs exist than have been counted because (1)
there is often a lack of public records on such wells, (2) public officials are unable to document the
locations of ADWs in remote areas on private land without the  cooperation of the landowner,  (3)  some
ADWs are hard to find or not even known to exist because they consist of tile drainage lines and
cisterns entirely below ground, and (4) ADWs have been grouped with storm water drainage wells in
some state inventories.  Looking forward, the number of ADWs should decrease as the risk to USDWs
becomes known and ADWs that cause or threaten contamination are discovered and closed.
However, the known number of ADWs may actually increase as the existing wells are actively looked
for and discovered.

       States with the majority of known ADWs are developing and implementing regulatory
programs to address these wells.  Specifically:

      In Idaho, wells >18 feet deep are individually permitted, while shallower wells are permitted by
       rule.

      All ADW owners in Iowa are required to have applied for a permit by July 1, 1999. The only
       exception to this is ADW owners who can  demonstrate that their ADW will be closed prior to
       December 31, 2001. New wells  in Iowa are generally prohibited, although they may be
       permitted under very strict conditions (these conditions are so stringent that new ADWs in
       Iowa  are unlikely to receive a permit).

      The regulations in Ohio authorize ADWs by rule as long as inventory information is submitted.
       All existing ADWs in the state are considered out of compliance (not rule authorized) because
       their owners or operators did not  submit required inventory information by the applicable
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       deadline. Any new ADWs would be examined individually by the state and subjected to
       conditions believed necessary to protect USDWs.

      All of the known ADWs in Texas received individual authorizations for construction of the
       wells. Owners or operators of any new wells would have to submit basic information to the
       state, which would either disapprove the well or authorize it subject to conditions deemed
       necessary to protect USDWs.

      Minnesota rules, which became effective on July 15, 1974, prohibit injection or disposal of any
       materials into a well.  State staff, however, acknowledge that some ADWs continue to exist and
       require them to close when they are found.  The prohibition relates to wells that reach ground
       water.  Horizontal drain tiles are not included in the definition of a "well" in Minnesota.

       The regulatory picture in other states with few or no ADWs in the current inventory is varied.
In particular, Georgia, North Carolina, and North Dakota have banned new ADWs and require
existing ADWs to close when they are found.  Oregon, Washington, and Wisconsin also have a ban,
but recognize that some ADWs continue to exist. Most other states authorize ADWs by rule,
consistent with the existing federal UIC requirements.

       These regulatory programs in the states are supplemented somewhat by non-regulatory
programs and guidance at the federal level.  Namely, under the authority of the Clean Water Act, the
U.S. Department of Agriculture and USEPA released a  draft Unified National Strategy for Animal
Feeding Operations on September 11, 1998. Once finalized, the goal of this strategy will be for
owners and operators of animal feeding operations to take actions to minimize surface and ground
water pollution from confinement facilities and land application of manure. In addition, under the
Coastal Zone Act Reauthorization Amendments, 29 coastal states are required to develop and
implement Coastal Nonpoint Pollution Control Programs addressing nonpoint pollution from agriculture
and other sources. Although these programs are aimed primarily toward surface water protection, they
also will benefit ground water by emphasizing contaminant source reduction and conservation measures
such as nutrient, integrated pest, and irrigation management.  To support the development and
implementation of these programs, USEPA issued Guidance Specifying Management Measures for
Sources of Nonpoint Pollution in Coastal Waters. Much of this  guidance is relevant to Class V
ADWs because it presents techniques for minimizing seepage to ground water.

       6.2    Storm Water Drainage Wells

       Storm water drainage wells are used extensively throughout the country to remove storm water
or urban runoff (e.g., precipitation and snowmelt) from impervious surfaces such as roadways, roofs,
and paved surfaces to prevent flooding, infiltration into basements, etc.  The primary types of storm
water drainage wells are bored wells, dug wells, and improved sinkholes.  In addition, "lake level
control wells" are used to  drain lakes to prevent overflow following heavy precipitation. Subsurface
disposal of storm water is prevalent in places where there is not enough space for, or site characteristics
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do not allow, retention basins; where there is not a suitable surface water to receive the runoff; or
where near-surface geologic conditions provide an attractive drainage zone.

       The runoff that enters storm water drainage wells may be contaminated with sediments,
nutrients, metals, salts, fertilizers, pesticides, and/or microorganisms.  Storm water sampling data
indicate that concentrations of antimony, arsenic, beryllium, cadmium, chromium, cyanide, lead,
mercury, nickel, nitrate, selenium, and certain organics (e.g., benzene, benzo(a)pyrene, bis(2-
ethylhexyl) phthalate, chlordane, dichloromethane, pentachlorophenol, tetrachloroethylene, and
trichloroethylene) in storm water runoff have exceeded primary MCLs. Available sampling data show
that concentrations of aluminum, chloride, copper, iron, manganese, TDS, zinc, and methyl tert-butyl
ether have exceeded secondary MCLs or HALs.  Water quality data from Florida indicate that lake
level control well injectate has exceeded primary MCLs or HALs for turbidity, arsenic,
pentachlorophenol, and fecal coliforms, as well as secondary MCLs for iron, manganese,  pH, and
color. Some of these same studies, however, report that no adverse  effects on ground water were
detected. In addition, some industry representatives assert that the quality of storm water  drainage
should be better today than reported in some of these studies,  which predate the use of best
management practices (BMPs) required under the National Pollutant Discharge Elimination System
(NPDES) program.

       In general, the point of injection for most storm water drainage wells is into sandy, porous soils,
a permeable coarse-grained unit, karst, or a fractured unit because these types of formations can
readily accept large volumes of fluids. Such hydrogeologic characteristics usually allow contaminants to
migrate readily into ground water without significant attenuation.

       Contamination related to storm water drainage wells has been reported to various degrees in
Ohio, Kansas, Wisconsin, California,  Washington, Arizona, Oklahoma, Tennessee, New  York,
Indiana, Florida, Kentucky, and Maryland.  Several studies, however, do not clearly distinguish
contamination from storm water drainage wells versus more general, nonpoint source pollution.  The
following three examples demonstrate cases in which storm water drainage wells have contributed to or
caused ground water contamination.

      In 1989, a commercial petroleum facility in Fairborn, Ohio accidentally released 21,000 gallons
       of fuel oil that overflowed a diked area and entered two storm water drainage wells.

      In 1980, organic solvent contamination was discovered in drinking water supply wells for
       Lakewood, Washington  following the disposal of organic waste solvents and sludge in leach
       pits and storm water drainage wells at McChord Air Force Base.

      In 1998, the Oak Grove, Kentucky water plant (a ground water system) was shut down due to
       a sharp increase in raw turbidity following a severe storm event.

       Lake level control wells have  been associated with two documented contamination incidents.
The first occurred in 1993 when private drinking water wells in Lake Orienta, Altamonte Springs,


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Florida, were contaminated. In 1998, private wells in Lake Johio, Orange County, Florida, were
contaminated by fluids released into lake level control wells.

       As illustrated by some of these incidents, storm water drainage wells are generally vulnerable to
spills or illicit discharges of hazardous substances, as they are often located in close proximity to
roadways, parking lots, and commercial/industrial loading facilities where such substances are handled
and potentially released. The use of a number of BMPs can reduce the likelihood of contamination,
including siting, design, and operation BMPs as well as education and outreach to prevent misuse, and
finally, proper closure and abandonment (see Volume 3 for a detailed discussion on these BMPs and
their effectiveness). However, the frequency and pattern of BMP use varies across the country.  For
example, public commenters on the July 28, 1998 proposed revisions to the Class V UIC regulations
cited cases in which citizens have been observed draining used motor oil into storm water drainage
wells, where no measures are in place to prohibit illicit discharges. Some lakes that are drained by lake
level control wells are also vulnerable to spills or illicit discharges.

       Based on the state and USEPA Regional  survey conducted for this study, there are
approximately 71,015 documented storm water drainage wells and approximately 247,522 storm
water drainage wells estimated to exist in the U.S. About 81 percent of the documented wells are in
seven western states: Arizona (14,857), California (3,743), Washington (22,688), Oregon (4,148),
Idaho (5,359), Montana (4,000), and Utah (2,890).  Five other states contain approximately 15
percent of the total wells: Ohio (3,036), Florida (2,153), Mchigan (1,301), Maryland (1,678), and
Hawaii (2,622).  There is considerable uncertainty regarding the exact number of storm water drainage
wells for several reasons. There are approximately 200-250 lake level control wells in Florida.

       In general, the installation of new storm water drainage wells is expected to increase
nationwide. Many states are allowing the installation of new wells, and with the increased regulation of
surface discharge under the NPDES, there may be increased use of underground injection to dispose of
storm water runoff.

       Some states with the majority of storm water drainage wells have developed and are
implementing regulatory programs to address these wells. Examples include the following:

      In Idaho, wells  18 feet deep are authorized by rule, while deeper wells are individually
       permitted.

      In Arizona, California, Hawaii, Florida, and Maryland, storm water drainage wells are
       individually permitted.

Other states with large numbers of storm water drainage wells, however, are essentially implementing
only the minimum federal UIC requirements. In particular, Washington, Oregon, Montana, Utah, Ohio,
and Mchigan authorize storm water drainage wells by rule.
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       The regulatory structure in other states with fewer or no storm water drainage wells in the
current inventory is also mixed. For example, Indiana, Illinois, Wyoming, North Dakota, South
Dakota, Colorado, Kansas, Tennessee, and Rhode Island also authorize storm water drainage wells by
rule. Alabama, Texas, New Hampshire, and Nebraska have a permit and registration system for storm
water drainage wells.  Georgia and North Carolina ban new and existing wells. In Wisconsin, storm
water drainage wells deeper than 10 feet have been prohibited since the 1930's.  Shallow storm water
drainage wells (less than 10 feet deep) in Wisconsin were authorized by rule until 1994; since 1994,
construction of any storm water drainage well has been prohibited. Storm water drainage wells that
meet the definition of a "well" in Minnesota are prohibited. This prohibition only applies to wells that
reach ground water and not to french drains, gravel pockets, or drainfields, which normally would not
meet the definition of a well in Minnesota.

       These regulatory programs in the states are augmented to a degree by programs and guidance
at the federal level. The Sole Source Aquifer Program has been used by some regions as a way to limit
or prevent the use of storm water drainage wells by reviewing federal financially assisted construction
projects in sole source aquifer areas.  The Federal Highway Administration's (FHWA's) highway
runoff water quality standards indirectly reference storm water. Although these are non-enforceable
recommendations only, FHWA has issued guidance that discusses BMPs,  such as wet and dry
detention basins, infiltration trenches and basins, and dry wells, for controlling storm water runoff and
infiltration into ground water.  The Coastal Zone Management Act and Coastal Nonpoint Pollution
Control Program also indirectly reference storm water in nonpoint pollution regulations; however, storm
water discharges controlled under the NPDES program are exempt from the coastal nonpoint pollution
control program.

       6.3     Carwash Wells

       Wells used to dispose of washwater that was used to wash only the exterior of vehicles
(sometimes called "wand washes") are the only carwash wells within the scope of this volume.1 These
are typically located  at coin-operated, manual carwashes where people use hand-held hoses to wash
vehicles. Even though the term "carwash"  is used, the category includes wells that receive used
washwater at facilities designed for washing all kinds of vehicles, including cars, vans, trucks, buses,
boats on trailers, etc.

       The cleaning solutions used at these carwashes generally consist of soap solutions, rinsewater,
and wax, and are not expected to contain significant amounts of degreasing agents or solvents such as
methylene chloride or trichloroethylene (because these wells, as defined, are not supposed to be
receiving engine or undercarriage washwater, which is more likely to contain such substances). As a
result, the spent washwater disposed in a carwash well (as defined in this report) primarily contains
       'Class V wells used to inject fluids from carwashes where engine or undercarriage washing is
performed were classified as industrial wells and wells that receive both carwash wastewater and waste
fluids from vehicle maintenance activities were classified as motor vehicle waste disposal wells in the July
29, 1998 proposed revisions to the USEPA Class V UIC regulations.

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detergents, road salts, sediments, and incidental contaminants that may be washed from a vehicle's
exterior, comparable to typical storm water runoff.  Although there are no data on the issue, there is
also concern that de-icing agents may be rinsed from cars and enter ground water. The data available
on the quality of fluids entering carwash wells indicate that the concentrations of antimony, arsenic,
beryllium, cadmium, lead, and thallium in the injectate typically exceed primary drinking water MCLs
and HALs. Some samples show that ethylene glycol, methylene chloride, naphthalene, and
tetrachloroethene also have exceeded primary MCLs or HALs, indicating that degreasers may in fact
be working their way into the washwater at some facilities. The concentrations of pH, aluminum, iron,
and manganese in the injectate have exceed secondary MCLs.

       Two possible contamination incidents involving carwash wells were reported in Hawaii in the
early  1990s. The nature and extent of contamination are unknown, but both wells were closed.

       Although there are only these two reported contamination incidents associated with carwash
wells, there is concern over the potential for such wells to be vulnerable to spills or illicit discharges.
Because the facilities are usually unsupervised (meaning an attendant is not onsite), individuals may in
fact wash their engines or undercarriages using degreasers, wash the exterior of their vehicles with
chemicals other than common soap solutions, or may pour used oil, antifreeze, or other hazardous
materials down these drains. No actual contamination incidents associated with this kind of illicit
discharge, however, were discovered during the course of this study. Industry representatives also
assert that illegal dumping of unauthorized materials into drains at self-service carwashes is less of a
problem now than in the past, due to increased environmental awareness and the  greater availability of
hazardous material collection centers.

       The inventory results for these wells are very uncertain because most responses to the state and
USEPA Regional survey conducted for this study did not distinguish carwash wells from other kinds of
commercial or industrial wells.  These survey results  suggest that there are up to 4,651 documented
carwash wells and approximately 7,195 estimated carwash wells in the U.S. Although the wells are
documented in 14 states, 99% of the documented wells and 98% of the estimated wells are located in
nine states: Alabama, Mississippi, New York, Washington, Maryland, Iowa, West Virginia, California,
and Maine. Many states estimate that more than the documented number of wells exist, although these
estimates are typically based only on best professional judgment and the true number of wells is
unknown. As sewer system hookups become increasingly available to carwash owners, it is expected
that the number of Class V carwash wells will decrease.  Many states close carwash wells when they
find them.

       Although West Virginia permits carwash wells by rule (in accordance with the existing federal
UIC program), other states with the majority of carwash wells are developing and implementing more
extensive regulatory programs to address these wells. Specifically:

      Alabama, Mississippi, New York, Washington (when the well meets BMP requirements),
       Maryland, and New Hampshire issue individual permits.
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      Iowa bans carwash wells.

      California requires reporting of discharges from carwash wells.

      Maine issues discharge licenses for new wells and permits for existing wells.

       6.4    Large-Capacity Septic Systems

       Large-capacity septic systems (LCSSs) are an on-site method for partially treating and
disposing of sanitary wastewater. Only those septic systems having the capacity to serve 20 or more
persons-per-day are included within the scope of the UIC regulations.

       LCSSs do not utilize a single design but instead are designed for each site according to the
appropriate state and/or local regulations.  Many conventional LCSSs consist of a gravity fed,
underground septic tank or tanks, an effluent distribution system, and a soil absorption system. LCSSs
may also include grease traps, several small septic tanks, a septic tank draining into a well, connections
to one large soil absorption system, or a set of multiple absorption systems that can be used on a
rotating basis.

       LCSSs are used by a wide variety of establishments, including residential (multi-unit housing)
and non-residential (commercial, institutional, and recreational) facilities. The characteristics of the
sanitary wastewater from these establishments vary in terms of biological loadings and flow  (e.g., daily,
seasonal). Generally, the injectate from LCSSs is characterized by high biological oxygen demand and
chemical oxygen demand,  nitrate, trace metals and other inorganics, limited trace organics, and
biological pathogens.

       Even with a fully functioning system, data indicate LCSS effluent may contain arsenic, fecal
coliform, nitrate (as N), total nitrogen species (as N), and formaldehyde (in septic systems serving
recreational vehicles) at concentrations above primary MCLs or HALs.  The concentrations of
aluminum, iron, manganese, and sodium may exceed secondary MCLs.

       The effect of these constituents on USDWs depends in part on the characteristics of the
injection zone. It is difficult to generalize about the injection zone for LCSSs because these  systems
have been constructed nationwide.  Typically, LCSSs are located  in well-drained soils; however,
LCSSs have been located in areas with karst or fractured bedrock.  The injectate from LCSSs
receives partial treatment within the system (i.e., settling and biodegradation in the  septic tank).
However, attenuation occurs as the septic tank effluent travels through the soil media below  the fluid
distribution system, which is most commonly a leachfield. Dissolved organic matter, pathogens, and
some inorganic constituents can be attenuated in unsaturated soils  below the soil absorption system.

       The likelihood of ground water contamination resulting from LCSSs may be minimized by
following BMPs relating to siting, design, construction and installation, and operation and maintenance.
Careful siting and design of the LCSS are important because understanding site limitations can prevent


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future system failure.  The construction and installation of the septic system is best left to professionals,
so that the underlying soils are not damaged through compaction and systems are not constructed
during periods of high moisture, both of which are likely to contribute to early system failure. Further, it
is recommended that LCSSs be properly operated and maintained by conducting inspections and
performing maintenance as appropriate, "resting" the soil absorption field, pumping the septic tank to
remove solids as necessary, and limiting system loading (e.g., water conservation, reducing chemical
use or addition).  Owners or operators  of LCSSs who follow such BMPs are likely to maximize the life
of their system and lower the likelihood that their system would contaminate a USDW.

       Nevertheless, contamination incidents caused  by LCSSs have occurred.  For example, in
Racine, MO during 1992, two drinking water wells at a nearby church and school were contaminated
by sewage, causing 28 cases of Hepatitis A. In Coconino County, AZ  during 1989, failure of the
leaching field (due to excessive flow) at a resort area resulted in approximately 900 cases of
gastroenteritis. In Richmond Heights,  FL during 1974, a drinking water well was contaminated by
sewage from a nursery school, and resulted in approximately 1,200 cases of gastrointestinal distress. In
addition, 24 other instances have been identified where LCSS failure and ground water contamination
may have resulted. While there are surely other examples of LCSS failure across the U.S. beyond
these known incidents, the prevalence of contamination cases appears low relative to the prevalence of
these systems.

       LCSSs are vulnerable to spills because any materials spilled or dumped down sinks, toilets,  or
floor drains connected to the sanitary waste system can enter the septic tank. Examples of the materials
that may enter LCSSs include household cleaning products and wastes (e.g., cleaning solvents and
spent solutions) that were either intentionally or accidentally spilled as well as chemicals dumped illicitly
(e.g., waste oil).  Once in the LCSS, these materials are not necessarily treated by the system and may
be released to ground waters that may serve as USDWs.  USDWs may also be vulnerable due to the
large numbers of LCSSs operating nationwide.  While the incremental effect associated with spills at
each LCSS may be small, aggregating each of these spills may provide evidence of a broader
contamination problem for USDWs.

       According to anecdotal evidence, the LCSS is believed to be a frequently used onsite
wastewater disposal option.  Yet, until this study constructed the inventory model to estimate total
numbers of LCSSs nationwide, no quantitative information on system prevalence was available. As
discussed in Section 5.2, the inventory model estimated 353,400 LCSS in the nation; with a 95 percent
prediction interval, the range is 304,100 to 402,600. In comparison, the survey responses documented
about 43,000 systems and estimated approximately 132,000 systems.

       In the future, the total number of systems is expected to increase as the population increases.
USEPA found that construction and use of LCSSs will continue in areas where geological conditions
are favorable and sewerage is not readily available or economically feasible.  In addition, these systems
will continue to be constructed because using LCSSs is an accepted and economically attractive
practice.  While some states are now encouraging owners of large systems to connect to municipal
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sewers (when such connections become available), there do not seem to be any states planning to ban
LCSSs entirely.

       USEPA also found that there are no consistent state definitions or regulations of LCSSs. While
the 20 persons-per-day criterion is used to define systems subject to federal UIC regulation, states
generally characterize large systems using flow definitions that range from 2,000 to 20,000 gallons per
day (gpd). Regulation of LCSSs is also highly variable across states.  Some states have stringent
requirements for large systems. For example, Massachusetts and Minnesota both use 10,000 gpd as
the cutoff for large systems and have strict requirements for siting, construction, and operation.  Other
states only require general construction permitting. For example, New Jersey and Iowa both use a
2,000 gpd threshold for large systems but only require that such systems meet specific construction
standards. In addition, LCSSs may be  regulated by local regulations that focus on enforcing state
and/or county building and health ordinances.

       6.5     Food Processing Wells

       Food processing wells are essentially commercial septic systems used to dispose of food
preparation-related wastewater and equipment or facility wash down water. This group of wells also
includes food processing wastewater drywells, which allow wastewater to enter the soil untreated.
Both kinds of systems usually inject process wastewater that may contain high levels of organic
substances (e.g., food waste), cleaning  compound residues, and various inert substances.  These wells
are typically found at small facilities that usually have less than ten full time employees and are located in
unsewered, rural areas.

       Food processing wells are similar to domestic septic systems, but instead of receiving toilet and
shower water, they receive larger quantities of equipment washdown and process wastewater. The
wastewater entering the soil via these wells can contain high biochemical oxygen demand (BOD) levels
due to the organic fluids (e.g., blood from animal slaughtering facilities)  and some food residues (e.g.,
shellfish meat from shellfish processing facilities) entering the wastewater stream. In addition, the
injectate may contain high levels of nitrate, nitrite, total coliform, ammonia, turbidity and chlorides. No
injectate sampling has been performed, so it is difficult to ascertain what constituents typically exceed
MCLs or HALs. However, based on observations during site visits and assumptions described in
studies of similar wastewater treatment systems, it appears likely that the concentrations of nitrate,
nitrite, total coliform, and ammonia may exceed primary MCLs or HALs.  It is also possible that due to
the high organic content of the injectate, the secondary MCLs for turbidity and chloride may be
exceeded.

       Food processing wells typically inject above USDWs and into a variety of different geological
formations, terrains, and soils. However, one recently closed food processing well at a fruit processing
facility in Hawaii was injecting directly into a USDW.  As with  sanitary  septic systems, for food
processing wells to work properly it is necessary that the injection zone consist of moderately
permeable soils. Site visits in Tennessee revealed that some food processing facilities inject
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slaughterhouse wastewater, via septic systems, into fractured geologic units and karst terrains that
apparently had very little top soil.

       Only one USDW contamination incident has been identified that is clearly linked to a food
processing well.  In Maine, in 1998, a lobster processing/holding facility discharged large volumes of
seawater into its combined food processing well and sanitary septic system.  As a result, the chloride
concentration in a nearby private drinking water well exceeded the secondary MCL.

       Food processing wells may be vulnerable to receiving spills that occur at the facility. Some
food processing facilities use strong cleaning compounds to clean or disinfect equipment and, based on
observations from site visits, some facilities may not always be storing these chemicals in storage areas
away from floor drains that are connected to food processing wells. Therefore, spills may result in the
release of cleaning/disinfecting chemicals into the injection zone.

       According to the state and USEPA Regional survey conducted for this study, there are at least
741 documented food processing wells and more than 1,468 estimated to exist in the U.S. Of the 741
documented wells 43% are found in Maine and New York and 52% are found Alabama and West
Virginia. The remaining few are found in Alaska, Wisconsin, Hawaii and a few other states.  Tennessee
also has a significant number of food processing wells but the inventory has not been finalized. These
well totals are considered very uncertain because they are often based on professional judgment only
and because many  states do not distinguish between food processing wells and other kinds of
commercial/industrial wells in many state inventories. Overall, it seems that the number of active food
processing wells throughout the country is decreasing because many UIC program staff are actively
encouraging individuals not to install injection wells for this purpose and because the areas served by
sewers are expanding. Additionally, there are some states that are closing all food processing wells as
they are found.

       States such as Maine, Alabama and New York, which have significant numbers of food
processing wells, require individual permits or waste discharge licenses prior to construction and
operation. However, in Maine if the food processing well meets local plumbing codes,  no discharge
license is required.  West Virginia and Tennessee, on the other hand, authorize these wells by rule but
may require more extensive permitting or closure efforts if it appears that operations may result in
USDW endangerment. All food processing wells in Wisconsin are permitted individually through the
Wisconsin Pollutant Discharge Elimination System (WPDES).  Oregon covers these wells under a state
general permit. Hawaii, with only a few wells, prohibits injection into a USDW unless an individual site-
specific permit is issued. Depending on the type of food being processed, food processing facilities
must comply with food handling and preparation regulations put forth by counties and states, as well as
requirements from  the federal government under the Federal Meat Inspection Act, the Federal Poultry
Inspection Act, or the Federal Drug and Cosmetic Act.
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       6.6     Sewage Treatment Effluent Wells

       Class V sewage treatment effluent wells are used in many places throughout the country for the
shallow disposal of treated sanitary waste from publicly owned treatment works or treated effluent from
a privately owned treatment facility that receives only sanitary waste. For the purpose of this study,
injection wells that are used to dispose of industrial waste (not sanitary waste) from industrial
wastewater treatment facilities (not publicly owned treatment works) are not sewage treatment effluent
wells, but rather are industrial wells.  In addition to being used for the purpose of wastewater disposal,
sewage treatment effluent wells are commonly used where injection will aid in aquifer recharge or
subsidence control, or to prevent salt water intrusion.

       The effluent that is injected into sewage treatment effluent wells is generally subjected to
secondary or tertiary treatment in a municipal wastewater treatment plant or a privately owned
wastewater treatment plant.  However, one facility identified in the study discharges effluent that is
subject to only primary treatment to subsurface disposal units.  Secondary treated effluent may contain
fecal coliform and nitrates at concentrations above primary MCLs, and either secondary or tertiary
treated effluent also may exceed secondary MCLs for chloride, sulfates, or TDS.  Available injectate
quality data for sewage treatment effluent wells indicate that injectate samples have exceeded MCLs for
fecal coliform, nitrates, TDS, and pesticides at at least one facility; however, many of these reported
exceedances are represented by only one or two injectate samples, and data are not available to
indicate whether these exceedances are one-time events or routine occurrences.  Also, available
information indicates that at least one facility is permitted to discharge injectate that exceeds the
secondary MCL for chloride.

       Approximately 42 percent of the documented sewage treatment effluent wells are located in
Florida, and approximately 700 of these wells (35 percent of the total documented inventory) are
located in the Florida Keys and inject into shallow (<50 feet) aquifers that are of extremely poor quality
and that are not likely to be used as  sources of drinking water. Approximately 26 percent of the total
documented well inventory are located in California.  Other sewage treatment wells in Florida, Arizona,
and other states, are used to inject treated wastewater effluent for aquifer recharge, and may be
injecting into  aquifers of drinking water quality.  Nearly 19 percent of the documented wells are located
in Hawaii.  Hawaii UIC regulations do not allow operation of sewage treatment effluent wells within one
quarter mile of a drinking water source, and it is anticipated that many of these wells inject into aquifers
that are not of drinking water quality.   No data were provided by survey respondents concerning the
characteristics of injection zones for other states where sewage treatment effluent wells are currently
operated.

       Several studies and incidents have shown that sewage treatment effluent wells may have
contributed to or caused ground water or surface water contamination. One study showed nitrate
contamination of onsite ground water at a sewage treatment effluent site in New Hampshire where both
primary treated effluent and septage were released into a leach field. Two sewage treatment effluent
wells on the Island of Maui, Hawaii  were thought to be causing surface water contamination through
migration of nitrates in the injectate to surface water bodies.  One of these wells has been shut down


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and the other is the subject of an ongoing enforcement action by USEPA.  The U.S. Geological Survey
is conducting a long-term study of the operation of sewage treatment effluent wells in the Florida Keys
to assess whether migration of nitrates from injectate is contributing to surface water contamination.

       Sewage treatment effluent wells are not vulnerable to spills or illicit discharges.  The injectate is
treated wastewater, and the wastewater treatment plants that generate the injectate are generally
subject to effluent quality standards and monitoring, reporting, and record keeping requirements.
Incidents where injectate failed to meet injectate quality standards would generally be detected, and
corrective action would be taken by the wastewater treatment plant operator. Moreover, sewage
treatment effluent injectate is piped to the well from the wastewater treatment plant, so contamination in
route is unlikely, and the types and quantities of hazardous materials that would be present at a
wastewater treatment plants is limited.  Spills of hazardous materials (e.g., chlorine) into the wastewater
treatment plant system are unlikely and would also generally be detected by the wastewater treatment
plant effluent monitoring system.

       According to the state and USEPA regional survey  conducted for this study, there are 1,675
documented sewage treatment wells, and more than 1,739 wells are estimated to exist in the U.S.
More than 95 percent of the documented wells are located in five states: Arizona (79); California
(205); Florida (830); Hawaii (378); and Massachusetts (105). New York did not report any
documented sewage treatment effluent wells in the state, but reported that there may be less than 50
undocumented wells.

       Considering that sewage treatment effluent wells are associated with either publicly or privately
owned wastewater treatment plants that are generally required to have operating permits, the inventory
of sewage treatment effluent wells is considered to be relatively accurate compared with other injection
well categories for which wells do not always receive permits. Nevertheless, there may be a somewhat
larger or smaller number of sewage treatment effluent wells than these results suggest. For example,
New Hampshire did not report any sewage treatment effluent wells in the state in its survey response;
however, two facilities that inject treated effluent into subsurface  disposal units, classified as injection
wells for the purpose of this report, were identified through field visits. Conversely, Maine initially
identified 168 sewage treatment effluent wells in its survey response; however, further investigation
revealed that these facilities are discharging untreated wastewater effluent to subsurface disposal units
that are classified as large-capacity septic systems and not as sewage treatment effluent wells.  Although
no state UIC programs other than Maine and New Hampshire are known to have miscategorized
sewage treatment effluent wells, if other states have done so, the  reported inventory may either
overestimate or underestimate the true number of sewage treatment effluent wells in the U.S.

       States with the majority of sewage treatment effluent wells have developed and implemented a
variety of programs to address these wells.  Specifically:

      In Florida, sewage treatment effluent wells are required to have individual permits and meet
       MCLs.
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      In Hawaii, regulations have established ground water protection zones where the construction
       of sewage treatment effluent wells is prohibited.  Wells outside of these zones are required to
       obtain individual permits.

      Arizona requires sewage treatment effluent wells to obtain ground water protection permits, and
       requires the well operators to demonstrate that MCLs will not be exceeded at the facility
       property boundary. Arizona also has published BMPs for the operation of wastewater
       treatment plants (and their associated sewage treatment effluent wells).

      California requires sewage treatment effluent wells to obtain individual permits.

      Massachusetts requires sewage treatment effluent wells to obtain ground water discharge
       permits.

       The regulatory picture in other states with few sewage treatment effluent wells in the current
inventory is also mixed. States either permit sewage treatment effluent wells by rule (e.g., Texas,
Idaho), require them to obtain ground water protection permits (e.g., New Hampshire), or require them
to obtain individual permits (e.g., West Virginia). Some states (e.g., New Hampshire) establish ground
water compliance zones (generally at the site boundary) while others (e.g., Idaho) require injectate to
meet MCLs at the point of injection. In Wisconsin, the operator of a facility that discharges sewage
treatment effluent into a subsurface soil absorption system that is constructed in the unsaturated zone
above the water table is required to obtain a WPDES permit. Direct discharges into a saturated
formation is prohibited in Wisconsin.

       These regulatory programs in the states are supplemented by regulatory standards and
guidelines that apply to the operation of municipal wastewater treatment plants under the authority of
the Clean Water Act and associated  state regulations. BMPs for wastewater treatment plants have
also been established by USEPA under the Clean Water Act. These BMPs are equally appropriate for
treatment plants that discharge to surface water and those that discharge (inject) into ground water.

       6.7     Laundromat Wells

       Wells used to inject fluids from laundromats where no onsite dry cleaning  is performed or
where no organic solvents  are used for laundering are classified as "laundromat wells" for the purpose
of this study.  These wells are located throughout the U.S. and can be found at coin-operated
laundromats.

       The characteristics of the fluids drained into these wells are similar to those of grey water from
household washing machines. The limited data that are available from coin-operated washers indicate
that none of the primary drinking water MCLs or HALs are  exceeded by laundromat washwater.
However, the injectate  has exceeded the secondary MCLs for pH and TDS.
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       It is not a typical practice to locate laundromat wells in injection zones with specific geologic
characteristics (laundromat wells do not tend to be located in areas with karst, fractured bedrock, or
any other particular kind of subsurface feature).

       Although there are no reported contamination incidents associated with laundromat wells, some
wells may to be vulnerable to spills or illicit discharges.  For instance, the unsupervised nature of coin-
operated laundromats may make Class V wells at those facilities susceptible to contamination due to
laundering of contaminated articles. For instance, an individual may wash highly contaminated articles,
such as solvent-soaked or oily rags, that may result in increased contaminant concentrations in the wash
water.  As another example, it is reasonable to expect that any sinks or floor drains at the facility, which
also may receive minor spills, would be hooked into the same plumbing system that collects and
transfers wash water to the injection well.  No actual  contamination incidents associated with these
kinds of discharges, however, were discovered during the course of this study.

       The inventory results for laundromat wells are very uncertain because most responses to the
state and USEPA Regional survey conducted for this study did not distinguish laundromat wells from
other kinds of commercial or industrial wells.  These results suggest that there are less than 700
documented laundromat wells in the U.S.  The wells are documented in 12 states, with Alabama, West
Virginia, New York, Mississippi, and Iowa providing the highest estimates (Collectively, these five
states account for more than 90 percent of the estimated national inventory). Although many states
estimate numbers of wells much higher than the numbers documented,  most are unsure of the exact
number of wells.

       States with the majority  of documented or estimated laundromat wells are implementing various
kinds of regulatory programs to  address these wells.  Alabama and New York issue individual permits.
Individual permits are also sometimes required in West Virginia. However, in Iowa, Mississippi, and
West Virginia, the wells are permitted by rule; that is, as long as owners and operators meet certain
requirements, they are allowed to operate a laundromat well.

       6.8     Spent Brine Return Flow Wells

       Naturally occurring surface and underground brines are used as the source for commercial
production of a variety of mineral commodities, including common salt, calcium chloride, sodium sulfate,
and/or magnesium, iodide, or bromide compounds.  When underground brines serve as the raw
material for production of mineral commodities, the brine is extracted from the subsurface through
production wells, the target compounds or elements are extracted, and the resulting "spent brine" is
normally2 returned to  the subsurface through spent brine return flow (injection) wells.

       The chemical characteristics of the injected spent brine are determined primarily by the
characteristics of the brine that is withdrawn for processing and the nature of the extraction and
       2 At least one facility disposes of spent brines from extraction of minerals from brine withdrawn
from underground sources by surface discharge (to a playa lake bed) instead of by injection.

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production processes used.  As a result, spent brine characteristics can vary substantially from facility to
facility, although in some cases the brine characteristics are similar when several facilities withdraw brine
from a common formation, as is the case in Arkansas. In Arkansas, available data indicate that
concentrations of barium and boron in spent brine routinely exceed primary MCLs or HALs. Data
available for Michigan facilities indicate that chloride, copper, iron, manganese, TDS, and pH levels
frequently exceed secondary MCLs. Data are not available to determine whether concentrations of
some other constituents, including some heavy metals, are present at concentrations above health-based
levels.

       Spent brine return flow wells inject spent brine into the same formation from which it was
withdrawn, which in all current cases is below the lowermost USDW. (In fact, most spent brine return
flow wells were initially drilled as production wells and subsequently converted to injection wells.) The
chemical composition of the spent brine is generally similar to that of the produced brine except that the
concentration of target elements (e.g., magnesium) has been reduced and the concentration of other
elements (e.g., calcium) may have been increased through substitution.  Thus, the MCL exceedances
observed for the spent brine are also typical for the produced brine and the receiving formation.

       No incidents of USDW contamination by spent brine return flow wells were identified during
preparation of this report. In addition, spent brine return flow wells are not likely to receive accidental
spills or illicit discharges. Corrosion of some well materials by the brine is a common problem,
however.  Therefore, injection is through corrosion-resistant tubing and well integrity is monitored on an
ongoing basis.

       According to the state and USEPA Regional survey conducted for this study, there are 98
documented spent brine return flow wells that are regulated as Class V injection wells in Arkansas (74)
and Michigan (24).  Several other states, including New York, Tennessee, California, and Oklahoma,
indicate that spent brine wells exist, but they are regulated as Class n or m wells.

       The specific features of well construction and operation may vary somewhat with the location
and timing of construction of the well, but in general, all the wells are built according to regulatory or
permit requirements that have many features in common with Class I and Class n injection wells.
Arkansas has placed jurisdiction over spent brine return flow wells in its Oil  and Gas Commission,
which applies Class n UIC permitting requirements as well as a special set of construction and
operating standards.  For wells in Michigan, individual UIC permits are issued by USEPA Region 5.

       6.9     Mine Backfill  Wells

       Mine backfill wells are used in many mining regions throughout the country to inject a mixture of
water and sand, mill tailings, or other materials (e.g., coal combustion ash, coal cleaning wastes, acid
mine drainage treatment sludge,  flue gas desulfurization sludge) into mined out portions of underground
mines. On occasion, injection (in low porosity grout form) also occurs into the rubble disposal areas at
surface mining sites.  Mine shafts and pipelines in an underground mine, as well as more "conventional"
drilled wells, used to place slurries and solids in underground mines are considered mine backfill wells.


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Such wells may be used to provide subsidence control (the most common purpose), enhanced
ventilation control, fire control, reduced surface disposal of mine waste, enhanced recovery of minerals,
mitigation of acid mine drainage, and improved safety.

       The physical characteristics and chemical composition of the materials that are injected into
backfill wells vary widely depending on the source of the backfill material, the method of injection, and
any additives (e.g., cement) that may be included. Data from leaching tests (e.g., USEPA Method
1311--TCLP) of backfill materials indicate that concentrations of antimony, arsenic, barium, beryllium,
boron, cadmium, chromium, lead, mercury, molybdenum, nickel, selenium, thallium, sulfate, and zinc
frequently exceed primary MCLs or HALs. Concentrations of aluminum, copper, iron, manganese,
TDS, sulfate, and pH frequently exceed secondary MCLs.

       At sites where water is present in the injection zone (the previously mined ore body), the mine
water may already exceed MCLs or HALs prior to injection either as a result of mining activity or
natural conditions. At such sites, one objective of injection often is to improve the already poor quality
of the mine water by reducing the availability of oxygen in the mine workings and/or neutralizing acid
mine drainage.  In other areas, water from coal beds may be used to supply domestic wells.

       No incidents of contamination of a USDW have been identified that are directly attributable to
injection into mine backfill wells. Although ground water contamination is not uncommon at mining
sites, it is generally difficult to identify the specific causes. The chance that backfill injection will
contribute to ground water contamination is highly dependent on site conditions, including mine
mineralogy, site hydrogeology, backfill characteristics, and injection practices. Some studies of the
effects of backfill injection on mine water quality show that concentrations of some cations and anions
can increase in mine water following injection, whereas concentrations of trace metals generally are
relatively unaffected or decline over time.  Other studies (at other sites) show an increase in selected
metal concentrations.

       The vulnerability of mine backfill wells to receiving spills or illicit discharges also depends on
site-specific conditions and practices. For example, if coal ash is hauled to a mine site, slurried with
water, and then injected, the likelihood of contamination of the injected material resulting from a spill  or
illicit discharge is relatively low. On the other hand, if mill tailings are collected in a tailings pond along
with site runoff and other facility wastes prior to injection, then the likelihood of contamination of the
backfill material by spills would be higher.

       According to the state and USEPA Regional survey conducted for this study, there are
approximately 5,000 documented mine backfill wells and more than 7,800 wells estimated to exist in
the United States. A total of 17 states report having mine backfill wells.  More than 90 percent of the
documented wells reported are in four states: West Virginia (401), Ohio (3,570), North Dakota (200),
and Idaho (575).  In truth, there may be more due to the broad scope of this well type and the fact that
some state inventories may count these wells as subsidence control wells while others did not. Also,
the number of active wells at any given time varies widely due to their generally short life span, most
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often a few days or less.  The number of mine backfill wells has the potential to grow in the future due
to the growing movement to decrease surface disposal and control ground subsidence.

       State regulations pertaining to mine backfill wells vary significantly in their scope and stringency.
Some states impose few specific restrictions while others require permitting, or impose requirements by
contract rather than regulation. Some of these approaches include permit by rule (e.g., Idaho, Kansas,
Texas, Illinois, North Dakota), general or area permits (e.g., Wyoming), and individual permits (e.g.,
Ohio, West Virginia, Indiana, Pennsylvania). In addition, federal requirements for planning and
approval of mining activities include mine backfill activities.  These requirements apply in states that
have not obtained primacy under the Surface Mining Control and Reclamation Act and to activities on
federal and Native American tribal lands.

       6.10   Aquaculture Waste Disposal Wells

       Methods employed for the controlled cultivation of aquatic organisms can vary substantially.
Some aquaculture facilities use pens suspended in open water bodies, while others use systems that
circulate water through tanks. Many aquaculture operations accumulate wastewater and sludge that
requires removal.  At dozens of such facilities in Hawaii and in several other states, this effluent is
disposed via underground injection.

       Injected aquaculture effluent includes fecal and other excretory wastes  and uneaten aquaculture
food. The primary chemical and physical constituents of these wastewaters are therefore nitrogen- and
phosphorus-based nutrients and suspended and dissolved solids. The effluent may also contain bacteria
pathogenic to humans and chemicals, pesticides, and/or aquaculture additives.  However, the incidence
and concentrations of human pathogenic bacteria, chemicals, pesticides, and additives in injectate is
unknown. Information on aquaculture wastewater quality industry-wide is very limited, and wastewater
properties are believed to vary greatly among different aquaculture operations.  Available analytical
data for aquaculture injectate and aquaculture effluent suggest that the concentrations of most
parameters are generally below applicable standards. Contaminants that may exceed the  standards
under some circumstances include turbidity and possibly nitrite and nitrate.  The secondary MCL for
chloride is also exceeded in the wastewater from some seawater-based operations, but as long as these
wastes are injected to saline aquifers, they pose no threat to USDWs.

       The injection zone for aquaculture wastewater is characterized by relatively high porosity, as
aquaculture wastewaters typically have significant suspended solids content. Seawater-based
aquaculture operations in Hawaii inject wastewater into brackish or saline aquifers that flow seaward.
Little information is available regarding other aquifers receiving aquaculture injectate.

       No contamination incidents related to aquaculture wastewater disposal have been reported.
Information about the threat of contamination posed  by these wells is also inconclusive.  For example,
in Idaho,  an aquaculture well is known to inject wastewater directly into an aquifer, but the quality of
the aquifer, its status as a USDW, and the resulting impacts, are unknown.  The subsurface disposal
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system (i.e., a leaching field) known to be in use by an aquaculture operation in Maryland is situated
above a Type 1 (high quality) aquifer, but no impacts have been observed.

       Aquaculture wells generally are not vulnerable to spills or illicit discharges. Most are located
within private facilities and are not accessible to the public for unsupervised waste disposal. However,
the potential exists for operators to dispose of harmful liquid wastes (e.g., waste aquaculture chemicals,
or spent tank water with higher concentrations of chemicals used for temporary treatment of cultivated
organisms) via aquaculture injection wells. No such cases have been reported.

       According to the state and USEPA Regional survey conducted for this study, a total of 56
documented Class V aquaculture waste disposal wells exist in the U.S. The great majority occur in
Hawaii (51 wells, or  93 percent).  The remaining documented wells are in Wyoming (2 wells), Idaho (1
well), New York (1 well), and Maryland (1 well).  In addition to these documented wells, as many as
50 additional wells are estimated to exist in California.  Thus, the true number of aquaculture waste
disposal wells in the U.S. is likely to approach 100. Given that the value of U.S. aquaculture
production has grown by 5 to 10 percent per year over the past decade,  and that the aquaculture
industry remains the fastest growing segment of U.S.  agriculture, there is some possibility that the
number of Class V aquaculture waste disposal wells will increase.

       Programs to manage Class V aquaculture waste disposal wells vary between the states with
such wells:

      In Hawaii, aquaculture injection wells are authorized by individual permit. Class V wells are
       grouped for purposes of permitting into six subclasses.  Aquaculture wells may fall into two of
       the subclasses, depending on the character of the injectate and the water in the receiving
       formation.

      In Wyoming, aquaculture wells are covered under a general permit. The permit specifies
       certain construction and operating requirements (e.g., pretreatment of wastewater).

      In Idaho, wells greater than 18 feet deep are individually permitted, while shallower wells are
       authorized by rule.

      In New York, the Class V UIC program is directly implemented by USEPA Region 2.
       Beyond the federal UIC requirements, state regulations require permits for all point-source
       discharges into ground water.

      In Maryland, individual permits are required for any discharge of pollutants to ground water, for
       any industrial discharge of wastewater to a well or septic system, for any septic system with
       5,000 gpd or greater capacity, or for any well that injects fluid directly into a USDW.
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      In California, regional authorities issue permits for all Class V wells but the stringency of these
       authorities varies across the state.  Aquaculture facilities thought to operate injection wells may
       not be required to obtain permits for these wells.

       6.11    Solution Mining Wells

       Solution mining wells are used to inject a fluid (lixiviant) into underground mines to dissolve
mineral values from the ore.  The resulting "pregnant" solution is then brought to the surface, through
separate wells, for subsequent recovery of the dissolved mineral being produced. Solution mining wells
that are currently regulated under the federal definition of Class V injection wells are used in the
recovery of copper, uranium, and potentially other minerals, from mines that have already been
conventionally mined, through the injection of solutions of sodium bicarbonate or sulfuric acid in ground
water or recirculated mine water. When solution mining techniques are used to extract minerals from
ore bodies that have not been conventionally  mined, the injection wells are classified as Class HI
injection wells under USEPA regulations.

       The characteristics of the injected solution are highly dependent on those of the ore body being
mined because a variety of metals present in the ore body are incorporated into the solution as it goes
through repeated cycles of injection, extraction, and reinjection. Data on the composition of solution
mining fluids indicate that the concentrations of sulfate, molybdenum, radium, selenium, arsenic, lead,
and uranium exceed primary drinking water MCLs or HALs. Concentrations of TDS, chloride,
manganese, aluminum, iron, sulfate, and zinc have been measured above the secondary MCLs. Site-
specific factors determine which constituents exceed one or more of the standards.

       In many cases, the hydrogeology of the injection zone, or mined ore body, has already been
altered by ground water pumping as well as previous mining.  In uranium mining, for example, the
formation is a water-bearing sandstone.  As part of solution mining operations, ground water flow is
normally modified to create a drawdown, or zone of depression, so that the injected lixiviant is retained
in the leaching zone for subsequent recovery.

       No ground water contamination incidents have been identified that are directly attributable to
Class V solution mining injection wells.  However, the fluids injected into these wells inherently contain
a variety of metals at concentrations above MCLs or HALs, and contamination resulting from a
combination of mining-related activities has been reported at several sites. Elevated concentrations of
metals have been observed in ground water in the vicinity of solution mining operations, but complex
hydrogeology and other mining and mining-related activities make it difficult to attribute the cause to a
specific activity, such as solution mining injection wells. At sites where solution mining injection wells
are used, the likelihood that ground water contamination will result is dependent primarily on overall
mining operations rather than the specific construction and operational practices of the injection wells.
Specifically, the chance of migration of the solubilized metals from the injection zone depends on the
effectiveness  of measures like ground water pumping and monitoring that are used to ensure that the
leaching solution is contained within the in situ leaching zone.
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       No information was collected that indicates these wells are vulnerable to receive spills or illicit
discharges.

       The state and USEPA Regional survey results indicate that there are 2,694 documented
solution mining wells in the U.S. (no more were estimated, indicating that there is substantial confidence
in this documented number).  Eight of these wells are associated with a uranium mine in New Mexico;
the remaining wells occur at two copper mines in Arizona.  Wells at one solution mining operation in
Potash, Utah that meet the federal Class V definition are not included in this report because they are
regulated by the state as Class m wells. Another solution mining well in Colorado that was initially
permitted as an experimental Class V well is considered a Class HI well. The prevalence of Class V
solution mining wells in the future depends on a wide range of factors such as commodity prices and the
development of lower cost mining and beneficiation processes.

       Both Arizona and New Mexico control solution mining through the use of individual permits,
although in Arizona, where the UIC program is implemented by USEPA Region 9, the state uses an
Aquifer Protection Permit rather than a UIC permit. Both states have operating and monitoring
requirements. Arizona also places requirements on construction and maintenance practices, and
financial assurance must be demonstrated.

       6.12   In-Situ Fossil Fuel Recovery Wells

       In-situ fossil fuel recovery wells are used to facilitate in-situ conversion of a hydrocarbon
resource into a gaseous  or liquid form that can be extracted through production wells.  Specifically, in-
situ fossil fuel recovery wells are used to initiate and then to maintain and control combustion through
injection of air, oxygen, steam, carbon dioxide, or ignition agents.  There are three types of processes
that may use in-situ fossil fuel recovery wells: in-situ combustion of tar sand deposits, underground coal
gasification (UCG), and in-situ oil  shale retorting.  In-situ combustion of tar sand deposits has not been
employed in the U.S.

       Most of the injected materials are gases (e.g., air, oxygen) that are not likely to show
exceedances of MCLs or HALs. When ignition agents such as ammonium nitrate are injected,
exceedances of MCLs or HALs would be expected, but has not been documented.

       In-situ fossil fuel recovery wells inject into a hydrocarbon-containing unit, which is often a
steeply inclined coal seam or oil shale deposit that is not practical to mine with conventional methods.
Although injected gases generally do not introduce contaminants into the subsurface, injection may alter
the characteristics of a USDW, if the gases are allowed to contact a USDW, by changing the USDW's
temperature or increasing the level of gas saturation.

       Contamination of ground water resulting from in-situ fossil fuel recovery operations is well
documented, to the extent that most, if not all, in-situ fossil fuel recovery operations initiated in the last
20 years appear to have caused some ground water contamination.  The ground water is not
contaminated with the injected materials, however.  Rather, it is contaminated with combustion


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byproducts, such as benzene. At some sites, water containing benzene and other combustion
byproducts, such as phenols, has migrated via fractures or other means from the reaction zone into
nearby ground water.

       The in-situ fossil fuel operations conducted in the U.S. have all operated on a trial, rather than
full-scale basis. The scale of the reaction zone in these cases led to lower temperatures than would be
expected in full-scale operation. At these lower temperatures, pyrolysis can dominate the process,
resulting in greater generation of products of incomplete combustion than would be expected in a full-
scale operation.  In addition, full-scale operation would create a larger combustion cavity, resulting in a
stronger and more extensive ground water depression zone. Such a depression zone would be
expected to cause ground water to flow to, rather than  away from, the combustion zone, thus reducing
the migration of contaminants outside the combustion zone.

       The observed contamination problems are associated with in-situ fossil fuel recovery
operations, rather than rare spills or accidents. Overall, in-situ fossil fuel recovery wells are not likely to
receive spills or illicit discharges.

       According to the state and USEPA Regional survey conducted for this study, there are neither
documented nor estimated active in-situ fossil fuel recovery wells in the U.S.  The Agency is not aware
of plans to construct any new wells.

       State UIC regulations in Wyoming and state mining regulations in both Wyoming and Colorado
establish permitting  and operating requirements for in-situ fossil fuel recovery wells. In both states,
mining plans are required that must address siting, construction, operation, monitoring, and closure of
production and injection wells. Colorado's mining regulations do not include specific requirements for
mechanical integrity testing, plugging and abandonment, or financial assurance. Requirements in
Wyoming are both extensive and more specific.

       6.13   Special Drainage Wells

       Special drainage wells are used throughout the country to inject drainage fluids from sources
other than direct precipitation. This is  a "catch-all" category, including all drainage wells that are not
agricultural, industrial, or storm water drainage wells. The specific types of wells that fit into this
category are:

      Pump control valve discharge  and potable water tank overflow discharge wells;

      Landslide control wells;

      Swimming pool drainage wells; and

      Dewatering wells.
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       Pump control valve discharges and potable water tank overflows may be drained to the
subsurface on occasion, usually when an emergency overflow or bypass procedure takes place.
Landslide control wells are used to dewater the subsurface in landslide-prone areas. Removing ground
water from sediments decreases the weight of the sediments and increases the resistance to shearing in
the area.  Swimming pool drainage wells are used to drain swimming pool water to the subsurface for
seasonal maintenance or special repairs.  Dewatering wells  are used at construction sites to lower the
water table and keep foundation excavation pits dry.  Dewatering wells may also be used at mining
sites, where they are known as "connector wells," to drain water from an upper aquifer into a lower
one to facilitate mining activities.

       In addition to these four types of wells, USEPA Region 5 reports the existence of steam trap
wells, which inject steam condensate collected from a system of pipelines at one industrial facility in
East Chicago, Indiana.  Although classified as special drainage wells for the purpose of this study, these
steam trap wells are not considered in detail because they only exist at one facility and no specific
information about them is available.

       Injectate characteristics vary among the types of special drainage wells.  The injectate from
pump control valve discharge and potable water tank overflows is expected to meet all drinking water
standards due to the potable nature of the water.  The quality of injectate in landslide control wells
depends on the quality of the ground water that is being drained to a deeper level in the subsurface.
The limited amount of available data indicates that swimming pool drainage well injectate contains
coliforms. In addition, the recommended chemical composition of swimming pool water includes TDS
levels above the secondary MCL for drinking water.  Data show that dewatering well injectate typically
contains the following constituents above primary MCLs or HALs: turbidity, nitrogen-total ammonia,
arsenic, cadmium, cyanide, lead, molybdenum, nickel, nitrate, and radium 226. Additionally, the
following constituents in dewatering well injectate are typically detected  above secondary MCLs: iron,
manganese, TDS, and sulfate.  Measured pH levels are also below the lower end of the secondary
MCL range.

       Because special drainage wells do not tend to be located in areas with specific geologic
characteristics (they are typically located wherever the need for a certain type  of drainage exists),
generalizations about the injection zone characteristics are very limited. In Florida, where swimming
pool drainage wells  and mine dewatering wells are prevalent, the injection zone is typically karst.
Swimming pool water is often injected into aquifers from which the pool water was initially withdrawn,
and the injected water quality is usually not significantly degraded from that in the receiving aquifer. In
some  cases, swimming pool drainage wells inject into saline aquifers. Landslide control wells and
dewatering wells inject into deeper aquifers that can accept large volumes of fluid from upper aquifers.

       No contamination incidents have been reported for  pump control valve discharge and potable
water tank overflow discharge wells, landslide control wells, or swimming pool drainage wells. A 1984
study  expressed concern over water quality received by the Floridan aquifer when dewatering wells
were operated at several phosphate mining sites. However, no contamination  incidents caused by the
use of dewatering wells have been reported.


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       In general, special drainage wells are not highly vulnerable to spills or illicit discharges. The
extent of any potential contamination caused by dewatering or landslide control wells is highly
dependent upon the characteristics of the construction or mining site or potential landslide location that
is being dewatered. Pump control valves and potable water tanks and swimming pools are not
especially vulnerable to spills or illicit discharges.

       According to the state and USEPA Regional survey conducted for this study, there are
approximately 1,944 documented special drainage wells and more than 3,750 special drainage wells
estimated to exist in the U.S.  The wells are documented in 13 states, although 97 percent are located
in Florida (782) and Indiana (1,102). The trends in constructing and operating special drainage wells
indicate that these numbers are likely to decrease in the future. An alternative type of landslide control
well may replace the type that injects water deeper into the subsurface. This alternative moves water to
the ground surface or to surface water bodies.  Swimming pool drainage wells, which are mainly
located in Florida, are associated with older pools and are generally no longer constructed. Many of
the mine dewatering wells associated with phosphate mining in Florida have been closed.

       Special drainage wells are rule authorized in Idaho, Indiana, and Ohio. However, the other
states with the majority of special drainage wells are implementing more specific regulatory programs to
address these wells. Specifically, individual permits are issued in Alaska, Florida, and Oregon, and
general permits for single family swimming pools are issued in Florida.  A de facto ban on connector
wells exists in Florida because old wells are terminated and plugged as they are discovered, and new
connector wells are not permitted.

       6.14   Experimental Wells

       Experimental technology injection wells have been reported in seven states and are used to test
new or unproven technologies. Experimental "tracer study" wells, which inject chemicals to evaluate
hydrogeological parameters, comprise the vast majority of wells classified as experimental wells for the
purpose of this study.  Experimental technologies also have been recently applied in Class V wells
associated with Aquifer Thermal Energy Storage (ATES) systems, which store thermal energy by
injecting heated and/or cooled water into an aquifer. The existence of experimental wells varies widely
from state to state because, in some instances, different definitions of "experimental well" are used by
different states. The definitions used by the states may not necessarily correspond to the USEPA
definition included in the Class V Study questionnaire.

       Experimental Tracer Study Wells

       Many different types of substances are injected into experimental tracer study wells.  Examples
of these substances include organic dyes, inert gases, short half-life radionuclides, rare earth metals,  and
inorganic or organic compounds. Only one experimental well was reported for which injectate did not
meet the primary MCLs, secondary MCLs, and HALs, this being a tracer study well at a site in
Naturita, Colorado. The injectate for this tracer well exceeded MCLs for sulfates and chloride, and
contained arsenic and molybdenum at levels greater than HALs.


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       The injection zone characteristics for experimental technology injection wells vary widely
depending upon the purpose of the well. Wells used for tracer studies may inject into contaminated
aquifers, sometimes including aquifers that serve as drinking water supplies.

       No contamination incidents were reported for experimental tracer study wells.  In addition,
these wells are not vulnerable to spills or illicit discharges because injectate quality is controlled by the
conditions of the experiment being conducted. Tracer study wells generally release tracers in small
quantities.

       According to the state and USEPA Regional survey conducted for this study, six states have a
total of 396 documented experimental tracer study wells: South Carolina, Colorado, Nevada, Idaho,
Texas, and Washington. More than 97 percent of the documented tracer study wells exist in South
Carolina (207 wells or 52%) and Nevada (179 wells or 45%, although some of these wells are
reportedly now plugged and abandoned).  Most of the tracer study wells in South Carolina and
Nevada are being operated at U.S. Department of Energy facilities.  The States of Massachusetts,
Florida, and Mississippi indicated that they may have experimental wells, but that they could not
provide an estimate of how many wells actually exist.  The Texas and Washington UIC programs
identified five and two experimental wells operating in their states,  respectively, but did not provide any
information concerning the types of wells (they may in fact be something other than tracer study wells).
The Illinois UIC  program reported two experimental wells that are most likely no longer operating.
Survey responses from the other states indicated that they had no experimental wells as defined in the
survey questionnaire.

       The experimental technology wells in South Carolina, Nevada, and Washington are individually
permitted by the  state.  The wells in Colorado and Texas are permitted by rule, although the wells in
Colorado must have a construction permit.  In Idaho, wells less than 18 feet deep are permitted by rule
and wells greater than 18 feet deep are individually permitted. Although Wisconsin did not report the
existence of any experimental tracer study wells, Wisconsin's administrative rules require that an
approval be obtained for any future wells.  Any approval in Wisconsin would be based on the condition
that the approved experimental injection practice may not exceed the state's numerical ground water
quality enforcement standards. Similarly, even though no active ATES systems or experimental tracer
study wells are reported in Minnesota, that state has issued variances for experimental ATES systems
and tracer studies in the past.

       ATES  System Wells

       Heated or cooled process water, which may originate from native ground water, surface water,
or potable water, are injected into ATES systems. Experimental ATES wells inject water into the same
formation from which it was withdrawn. While no contamination incidents were reported for ATES
system wells, several reports mentioned that the concentration of constituents in ground water receiving
fluids from some ATES wells were higher than background levels.  The wells are not vulnerable to spills
or illicit discharges because injectate quality is controlled by the conditions of the process operation. In
particular, experimental ATES systems inject treated water for which injectate quality must be


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controlled.  No UIC programs reported any operating ATES system wells in the survey responses.
ATES systems, however, were recently operated in Minnesota and New York, and are in operation in
several European countries.

       6.15   Aquifer Remediation Wells

       Aquifer remediation wells (ARWs) are widely used around the country for beneficial uses
associated with the control of ground water contamination. These wells may be used for different
specific purposes, including to:  (1) introduce remediation agents (i.e., chemicals or microorganisms)
into contaminated aquifers to neutralize the contamination; (2) increase ground water flow through the
contaminant zone in an aquifer to aid in contaminant removal; (3) form hydraulic barriers to contain
contaminant plumes; and (4) re-inject treated ground water for aquifer recharge after an onsite pump-
and-treat system.

       Class V aquifer remediation wells are distinguished from Class IV wells, which dispose of
hazardous or radioactive waste into or above a formation which contains a USDW within one-quarter
mile (see 40 CFR 144.6(d)).  Although Class  IV wells are generally prohibited, they are allowed if
they are used to inject treated contaminated ground water that qualifies as hazardous or radioactive
waste and is being reinjected into the same formation from which it was drawn, if approved by USEPA
pursuant to the provisions for cleanup of releases under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) or the Resource Conservation and Recovery Act
(RCRA) (see 40 CFR 144.13(c)).  A well that meets this definition is a Class IV well, not a Class V
aquifer remediation well.

       For many reagents and nutrients injected into ARWs, the concentration in the injectate likely
exceeds MCLs or HALs because higher concentrations of such reagents and nutrients are needed for
them to serve their  intended purposes. The data available about these wells are insufficient to establish
meaningful comparisons between concentrations of injected reagents or nutrients in ground water
monitoring  wells, located downgradient from the ARW where they were injected, and the
corresponding MCLs or HALs. Based on the information reviewed, it appears that ground water
monitoring  activities associated with remediation projects typically focus on the contaminants of concern
for remediation, rather than on the reagents, nutrients, or other substances injected into the affected
aquifer as part of the remedial activity.

       The injectate in ARWs is typically (i.e., in the case of the first three purposes mentioned above)
directed into a contaminated aquifer where constituents of concern exceed MCLs. On the other hand,
re-injection of treated ground water from an onsite pump-and-treat system may occur into a different
formation than that which is being remediated, with the objective of recharging the aquifer. In this last
case, the receiving formation may be a USDW and the injectate is monitored to ensure that constituents
of concern  present  in the injectate do not exceed MCLs.

       One contamination incident associated with an ARW was reported in the state and USEPA
regional survey conducted for this study. The incident occurred at the Hassayampa Landfill Superfund


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Site in Arizona in 1998. A failure in an automatic cut-off valve in a pump-and-treat system, concurrent
with a failure in the treatment unit, resulted in the accidental injection of untreated ground water into a
clean USDW.  The extent of the impact on the USDW or to drinking water wells was not reported.

       A majority of ARWs appear to be covered under CERCLA cleanups, RCRA corrective
actions, or Underground Storage Tank (UST) cleanup actions.  As with any remedial measure, they
usually require the approval of the appropriate state and/or federal regulatory agencies. There is some
concern for voluntary cleanups that are not approved or completed according to standards typical of
cleanups overseen by a state or federal agency. Limited information from the survey suggests that
voluntary cleanups do occur, but little is known about them based on the information available.
Nevertheless, in some USEPA regions, voluntary cleanups are periodically the subject of inspections by
state or federal regulatory agencies and in Ohio, one of the states with the highest number of ARWs, no
contamination is known to have occurred as a result of the operation of an ARW.

       The survey results indicated that there are  10,222 documented ARWs located in 39 states and
territories. A significant fraction (65 percent) of the total is concentrated in South Carolina (3,409),
Texas (1,177), Ohio (1,170), and Kansas (936). As part of this survey, state and USEPA regional
officials estimated that a slightly higher number of wells, 10,756, actually exists.  Taking into
consideration the fact that a significant number of additional wells were reported as "under
construction" at the time of survey (e.g., 2,170 wells in South Carolina alone), the actual total number
of wells could be between  12,000 and 14,000. This also suggests a potential future increase in the
number of ARWs.

       Based on a review of relevant regulations for the states where ARWs are most prevalent and
for a limited set of additional states that constitute a broad geographical sample,  it was established that
individual permits are required for these wells in at least Arizona, California, Kansas, Nevada, Ohio
(required for those wells expected to exceed MCLs), and South Carolina, which collectively have
approximately one-half of the documented wells. ARWs may be authorized by rule in New Hampshire
and Texas.  At the federal level, ARWs are subject to the federal UIC standards, and, as indicated,
may be additionally regulated under CERCLA cleanups, RCRA corrective actions, and the UST
Program.

       6.16  Geothermal Electric Power Wells

       Several dozen power plants located in four western states use geothermal energy to produce
electricity.  At these power plants, hot (>100C (212F)) geothermal fluids produced from subsurface
hydrothermal systems serve as the energy source.  Following the recovery of heat energy from the
produced fluids, the liquid fraction (if any) is reinjected into the same hydrothermal system through one
or more electric power geothermal injection wells.

       The temperature and chemical characteristics of geothermal fluids vary substantially.  For
example, TDS concentrations  are about 1,000 mg/1 at The  Geysers (in northern California) but about
250,000 mg/1 at the Salton Sea geothermal field (in southern California). Despite these variations,


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however, concentrations of some metals (e.g., antimony, arsenic, cadmium, lead, mercury, strontium,
zinc) and other constituents in the produced and injected geothermal fluids routinely exceed primary
MCLs or HALs at one or more geothermal fields.  The specific constituents that exceed the standards
and the magnitude of the exceedences varies from site to site, with substantial variations observed
within some fields.  Sulfate, chloride, manganese, iron, pH, and TDS also frequently exceed secondary
MCLs.

       At some geothermal power plants, other fluids associated with power plant operation, such as
condensate and cooling tower blowdown, are injected along with the geothermal fluids. In a few
situations, supplemental water from additional sources, such as surface waters, storm waters, ground
water, and wastewater treatment effluent, is also injected.  Concentrations of metals and other
constituents in these supplemental water sources are typically lower than in the geothermal fluids. An
exception is biological constituents (e.g.,  coliforms) that are sometimes present in injected surface water
and treated wastewater at concentrations above drinking water standards.  The Geysers geothermal
field in California is the principle example of injection of surface waters and treatment plant effluent
along with geothermal fluids.  Ground water is injected (in  addition to geothermal fluids) to replace mass
lost through condensate evaporation at the Dixie Valley geothermal field in Nevada.

       Geothermal fluids used for electric power generation are normally injected into the same
subsurface hydrothermal system from which they were produced.  In fact, a majority of geothermal
injection wells were drilled as production wells and subsequently converted to injection wells.  Both
production and injection wells are carefully engineered because power production depends on the wells
and drilling costs are substantial, frequently exceeding $1  million per well.

       Despite this care, well failures have occurred during both drilling and operation, due to the high
pressures and temperatures encountered, exposure  of well  equipment to the corrosive geothermal
fluids, and seismic activity that sometimes bends or breaks  well casings. In some cases, well failures
have occurred at sites where no USDW is present.  At a geothermal power plant site in Hawaii,
however, ground water monitoring data indicate that temperature, chloride  concentrations, and
chloride/magnesium ratios increased following a blowout3 during drilling of an injection well.

       In general, electric power geothermal injection wells are not vulnerable to receiving spills or
illicit discharges because geothermal fluids are handled in closed piping systems that are managed as an
integral part of the power plant system.  At some facilities, contaminants could be added to the injectate
as a result of leaks or spills of lubricants, fuels, or chemicals at the power plant site. For example,  at
sites that collect and inject storm water, such as the power plants at The Geysers, injectate could
include fuel, transformer oil, lubricants, or chemicals that leak or spill on the site.  To help prevent
injectate contamination from such sources, potential sources of leaks and spills are covered and/or are
bermed separately from other parts of the facility.  In addition, oil/water separators are provided for
some plant areas (e.g., the electric switch yard) to provide further assurance that leaked or spilled oil is
not injected.
       3 Uncontrolled release of gas and/or fluids from a well.

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       According to the state and USEPA Regional survey conducted for this study, four states
 California, Utah, Hawaii, and Nevada  have a total of 234 electric power geothermal injection
wells, with most of the wells reported in California (174, or 74 percent) and Nevada (53, or 23
percent).  The number of geothermal power injection wells is not expected to increase substantially in
the foreseeable future because gas-fired power plants can generally produce power at a lower cost
than geothermal plants. However, if marketing of geothermal power as a "green" energy source is
successful as the utility industry is deregulated, a modest increase in the number of geothermal power
plants and associated injection wells may occur. Additional geothermal power plants are currently
being considered in California and have been proposed previously in Oregon.  Seven additional
injection wells  have recently been permitted in Hawaii.

       Individual permits are required for electric power geothermal injection wells in  all four states
that have this type of Class V injection well. The permits are issued by state agencies, U.S.  Bureau of
Land Management (BLM), and/or the USEPA Regional Office, depending on the state and whether
the well is located on state, federal, or private land.  In general, the permits are similar to those issued
for Class n injection wells. They establish requirements and oversight for design and construction,
operating conditions, monitoring and mechanical integrity testing, financial responsibility, and  plugging
and abandonment.

       6.17  Geothermal Direct Heat Wells

       Geothermal fluids are used to heat individual homes and/or communities or to provide heat to
greenhouses, aquaculture, and other commercial and industrial processes in several (primarily western)
states. Following use of geothermal fluids for such heating application, some facilities use geothermal
direct heat return flow wells to return these geothermal fluids to the subsurface.

       The temperature and chemical characteristics of geothermal fluids used for heating vary
substantially from site to site. At some sites, the geothermal fluids are of drinking water quality and, in
fact, are used as drinking water and not reinjected. More commonly, concentrations of some
constituents exceed MCLs or HALs. Available data indicate that arsenic, boron, sulfate, and fluoride
exceed primary MCLs or HALs and that TDS, chloride, iron, manganese, and sulfate  exceed
secondary MCLs.  TDS concentrations are generally <10,000 ppm except in the comparatively rare
situations where high temperature geothermal fluids used for power production are also used for
heating.

       When geothermal fluids used for heating are reinjected into the subsurface following use (rather
than discharged to surface water or used for drinking, irrigation, or livestock watering), they  typically
are reinjected into the same hydrothermal formation from which they were produced. In addition, the
composition of the geothermal fluids normally does not change appreciably as a result of use for
heating, although traces of pump lubricating oil may be added in some cases.
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       No documented cases of USDW contamination by geothermal direct heat return flow wells
have been reported.  In addition, the wells typically are not vulnerable to receiving accidental spills or
other illicit discharges, because the geothermal fluids are handled in closed piping systems. Typically,
the geothermal fluids are produced from a well, passed through a heat exchanger, and injected down
another well.

       The survey results indicate that there are 31 documented geothermal direct heat return flow
wells and another 17 more wells estimated to exist. Although these wells exist in as many as 11 states,
more than 80 percent of the documented wells are in only five states: Oregon (8), Nevada (7), Utah
(4), New Mexico (4) and Idaho (3). All of the 17 estimated wells are in Oregon, but Alaska also
indicated the potential presence of these wells without providing an estimated number.

       Individual permits are required for geothermal direct heat return flow wells in all five of the
states that have most of these wells.  In Idaho, an individual permit is not required if the well is <18 feet
deep, but all of the geothermal direct heat return flow wells are substantially deeper than 18  feet.
Individual permit requirements,  which also apply in California, are similar in many respects to those for
Class n wells. Further, for wells located on federal land, BLM approval of well drilling, testing, and
abandonment is also required by regulations promulgated under the Geothermal Steam Act  of 1970.

       6.18   Heat Pump/Air Condition Return Flow Wells

       Ground-source heat pump/air condition (HAC) systems heat or cool buildings by taking
advantage of the relatively constant temperature of underground hydrogeologic formations.  They
extract heat energy from ground water for use in heating buildings, and use ground water as  a heat sink
when cooling buildings.  Two types of ground-source HAC systems are generally used: closed-loop
systems and open-loop systems. Closed-loop systems circulate water entirely within a system of
closed  pipes, involve no subsurface injection of wastewater, and are therefore not subject to oversight
and regulation by the UIC program.  Open-loop HAC systems withdraw ground water from a source
well, pass it through the HAC heat exchanger, and then discharge the water. Many open-loop HACs
return used ground water to the subsurface via injection wells. These "return flow wells" are classified
as Class V wells under the UIC program, and are covered in this study.

       Because water is not consumed by HAC systems,  the quantity of return flow water (injectate) is
generally the same as that withdrawn.  The quality of HAC injectate also usually reflects the
characteristics of the source ground water. However, HAC injectate may differ from source water in
several ways. HAC injectate is generally 4 to 10 degrees Fahrenheit cooler or warmer than the source
water (depending on whether the HAC is in heating or cooling mode). In some cases, the temperature
drop can cause salts and other dissolved solids to precipitate into suspension, or the temperature
increase can cause suspended solids to dissolve into solution.  HAC injectate can also contain: metals
leached from  the pipes and pumps; bacteria (where oxygen, nutrients, and a source of bacteria are
present); precipitated ferric iron solids (where dissolved iron is present in source water, and the HAC
system introduces oxygen); and chemical additives (sometimes used for disinfection or corrosion
prevention). Very little data on injectate properties were available for this study. However, the


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available data indicate that HAC injectate has in some cases exceeded the primary drinking water
MCLs for lead and copper and the secondary MCLs for chloride and TDS.

        HAC systems most commonly re-inject ground water into the same formation from which it is
withdrawn. The aquifer used is relatively porous in order to provide adequate ground water flow to
source wells and from return wells. Dual-aquifer systems may be feasible where another formation (a
different formation from which source water is withdrawn) is more readily accessible for return flow
discharge, and is capable of handling HAC return flow. Dual-aquifer systems that withdraw from
contaminated aquifers and re-inject into USDWs can contaminate the receiving USDWs. As a result,
several states prohibit dual-aquifer HAC systems, or require that HAC source aquifers be of higher
quality than return aquifers.

       A few USDW contamination incidents  have been reported for HAC return flow wells. In
1996, a well in New York was found to have contaminated a USDW with chloride and TDS above the
secondary MCLs.  The incident was attributed to leaking well casings and inter-aquifer contamination.
In Minnesota, a water sample from a well in 1984 indicated high levels of lead,  while another sample
taken from a different well in 1985 showed high levels of lead and copper (all above the primary
standards). This was attributed to leaching of metals from the HAC system pipes and pumps. In North
Carolina, well samples have been reported to contain high levels of iron and coliform, attributed to poor
HAC well construction and operation allowing introduction of oxygen and contaminants. As the quality
of HAC injectate industry-wide is unknown, it is not clear whether these known contamination cases
are isolated cases,  or indicative of a wider problem with this type of well.

       HAC return flow wells are generally part of systems that are completely closed above ground,
and are generally located on private property. Therefore, the likelihood of USDW contamination by
spills or illicit discharges at HAC return flow wells is very low.

       According to the state and USEPA Regional survey conducted for this study, there are 27,921
documented HAC return flow wells in 34 states.4 The estimated number of wells existing in the U.S. is
more than 32,804  wells (but probably not more than 35,000), in over 40 states. Approximately 88
percent of all documented wells  are in four states: Texas (12,828 wells, or 46 percent), Virginia (7,769,
or 28 percent), Florida  (3,101, or 11 percent),  and Tennessee (1,000, or 4 percent). Another 30
states collectively account for the remaining 11  percent of the total documented U.S. inventory, with
each state having less than 3 percent of the total. However, many states do not have accurate well
counts and the definitions of closed-loop and open-loop wells used by some states differ from the
USEPA definitions.

       Nearly all  of the states with HAC return flow wells have statutory and regulatory requirements
at the state level, some of which  regulate the size, design, and/or additives used in these systems. Of
the states in which the largest numbers of HAC wells are found, USEPA directly implements the UIC
       4 This number includes some closed-loop systems, as not all states use the same definitions as
USEPA for "open-loop" and "closed-loop" systems.

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program for all Class V injection wells (including HAC return flow wells) in Arizona, Michigan,
Minnesota, New York, Pennsylvania, Tennessee, and Virginia. The other states with many HAC
return flow wells are UIC Primacy States for Class V wells, and authorize the wells by rule (Illinois,
Kansas, Nebraska, North Dakota, Ohio, South Carolina, Texas, West Virginia, and Wyoming) or
issue individual permits (Delaware, Florida, Maryland, Missouri, Nevada, North Carolina, Oregon,
Vermont, and Washington). In Wisconsin, which is also a Primacy State for Class V wells, discharge
to a shallow absorption system located in unsaturated soils is allowed under a general permit, but
discharge directly into a saturated soil  or aquifer is prohibited.

        A number of relatively straight-forward best management practices are available that can
virtually ensure that HAC wells do not contaminate USDWs.  Judging by the very low incidence of
recorded USDW contamination (relative to the number of wells), it appears that HAC owners and
operators are aware of and generally apply best management practices.

        6.19   Salt Water Intrusion Barrier Wells

        Salt water intrusion barrier wells are used to inject water into a fresh water aquifer to prevent
the intrusion of salt water.  Control of salt water intrusion through the use of these wells may be
achieved by creating and maintaining a "fresh water ridge." This fresh water ridge may be achieved with
a line of injection wells paralleling the  coast.  Another method used to control salt  water intrusion is
through the use of an injection-extraction system.  Such a system may be used to  inject fresh water
inland, while salt water intruded into the aquifer is being extracted along the coast.

        Waters of varying qualities are injected to create salt water intrusion barriers, including
untreated surface water, treated drinking water, and mixtures of treated municipal wastewater and
ground or surface water. Injectate typically meets primary and secondary drinking water standards.
Ground water monitoring and lexicological, chemical, and epidemiological studies have found no
measurable adverse effects on either ground water quality or the health of the population ingesting the
water, when the injectate was treated wastewater effluent.

        Salt water intrusion barrier wells are  drilled to various depths depending on the depth of the
aquifer being protected.  They inject into fresh ground water aquifers used as drinking water supplies
that are in hydraulic connection with an extensive salt water body, such as a sea, a salt lake, or an
ocean.

       No contamination incidents associated with the operation of salt water intrusion barrier wells
have been reported.

        Because protection of drinking water supplies is the major goal of a salt water intrusion barrier
well and the injectate typically meets drinking water standards, salt water intrusion barrier wells are
unlikely to receive spills or illicit discharges of potentially harmful substances.
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        According to the state and USEPA Regional survey conducted for this study, there are 315 salt
water intrusion barrier wells documented in the United States.  The number of salt water intrusion
barrier wells in the nation is estimated to be greater than 609, but unlikely to be higher than 700. All
documented salt water intrusion barrier wells are located in California (308), Florida (1), and
Washington (6). In addition, as many as 200 salt water intrusion barrier wells are believed to exist in
New York.  There also may be some wells in New Jersey, which indicated in its survey response that it
has salt water intrusion barrier wells but did not provide any numbers.

        The statutory and regulatory requirements differ significantly among California, Florida,
Washington, and New York.  In California and New York, USEPA Regions 9 and 2, respectively,
directly implement the UIC program for Class V injection wells. However, both states  have additional
jurisdiction over salt water intrusion barrier wells through state regional water quality control boards in
California and state pollutant discharge  elimination system permits in New York. In contrast, Florida
and Washington are UIC Primacy States for Class V wells.  Both of these states require individual
permits for the operation of salt water intrusion barrier wells.

        6.20   Aquifer Recharge Wells and Aquifer Storage and Recovery Wells

        Aquifer recharge and aquifer storage and recovery (ASR) wells are used to replenish water in
an aquifer for subsequent use. While an aquifer recharge well is used only to replenish the water in an
aquifer, ASR wells are used to achieve two objectives: (1) storing water in the ground;  and (2)
recovering the stored water (from the same well) for a beneficial use. Both of these types of wells,
however, may have secondary objectives,  such as subsidence control and prevention of salt water
intrusion into fresh water aquifers. Aquifer recharge and ASR wells are found in areas of the U.S. that
have high population density and proximity to intensive agriculture; dependence and increasing demand
on ground water for drinking water and agriculture; and/or limited ground or surface water availability.
ASR wells are also found in areas that have no freshwater drinking water supplies, or in coastal areas
where salt water intrusion into freshwater aquifers is  an issue.

        Aquifer recharge and ASR well injectate consists of potable drinking water (from a drinking
water plant), ground water (treated or untreated), and surface water (treated or untreated).5 Water
injected into aquifer recharge and ASR wells is typically treated to meet primary and secondary
drinking water standards. This is done  to protect the host aquifer and to ensure that the quality of the
ground water to be recovered is adequate for subsequent use.  In addition, most state and local
regulatory agencies require the injectate in  aquifer recharge and ASR wells to meet drinking water
standards in order to prevent degradation of ambient ground water quality. However, it should be
noted that, in some instances, constituents have been measured at concentrations slightly above drinking
water standards.
        5 Aquifer recharge and ASR well injecting wastewater are addressed separately in the sewage
treatment effluent well summary, which is Volume 7 of this report.

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       Aquifer recharge and ASR wells are drilled to various depths depending on the depth of the
receiving aquifer.  They may inject into confined, semi-confined, or unconfmed aquifers, although most
of these wells inject into semi-confined aquifers that have been partially dewatered due to overpumping.

       No contamination incidents associated with the operation of aquifer recharge or ASR wells
have been reported.

       Because the major goal of aquifer recharge and ASR wells is to replenish water in aquifers for
subsequent use and its injectate typically meets drinking water standards, aquifer recharge and ASR
wells are unlikely to receive spills or illicit discharges.

       According to the state and USEPA Regional survey conducted for this study,  there are
approximately 1,185 aquifer recharge and ASR wells documented in the U.S.  This total includes 807
aquifer recharge wells, 130 ASR wells, and 248 wells (in California and Idaho) that cannot be
distinguished among aquifer recharge and ASR wells in the available inventory.  The estimated number
of aquifer recharge and ASR wells in the nation is greater than  1,695, but unlikely to be higher than
2,000.  This estimate does not include 200 wells proposed to be built in Florida as part of the
"Everglades Restoration Project."  Approximately 89 percent of the documented aquifer recharge and
ASR wells are located in ten states: California (200), Colorado (9), Florida (<488), Idaho (48),
Nevada (110), Oklahoma (44), Oregon (16), South Carolina (55), Texas (67), and Washington (12).
Wisconsin has conditionally approved one aquifer storage and  recovery well as part of a pilot study at a
municipal water system in Oak Creek, and a second pilot project in Green Bay, Wisconsin is under
development.  The project in Green Bay is expected to be operational within the next year.

       The statutory and regulatory requirements differ significantly among the ten states where the
majority of the aquifer recharge and ASR wells are believed to exist. In California and Colorado,
USEPA Regions 9 and 8, respectively, directly implement the UIC program for Class V injection wells.
However, both states have additional jurisdiction over aquifer recharge and ASR wells through state
regional water quality control boards in California and permitting of extraction and use of waters
artificially recharged in Colorado.  The remaining eight states are UIC Primacy States for Class V wells.
Oklahoma and Texas authorize aquifer recharge and ASR wells by rule. Florida, Nevada, Oregon,
South Carolina, and Washington require individual permits for the operation of aquifer recharge and
ASR wells.  In Idaho, construction and operation of shallow injection wells (<18 feet)  is authorized by
rule; construction and use of a deep injection well (  18 feet) requires an individual permit.

       6.21   Noncontact Cooling Water Wells

       For the purpose of this study, "noncontact cooling water wells" are limited only to wells used to
inject noncontact cooling water that contains no additives and has not been chemically altered. Wells
that inject contact cooling water or noncontact cooling water that contains additives (e.g., corrosion
inhibitors, biocides) or is contaminated compared to the original source water are considered "industrial
wells."
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       USEPA defines noncontact cooling water (in 40 CFR 418.21 governing fertilizer
manufacturing) as "water which is used in a cooling system designed so as to maintain constant
separation of the cooling medium from all contact with process chemicals...provided, that all reasonable
measures have been taken to prevent, reduce, eliminate and control to the maximum extent
feasible...contamination...."  No sampling data were obtained during the course of this study that can be
used to characterize the quality of fluids injected into noncontact cooling water wells. However, given
the very narrow way that such wells and  noncontact cooling water are defined, it is reasonable to
expect that the quality of the fluids will not threaten USDWs.

       Available information  suggests that these wells are commonly used in situations in which cooling
water is withdrawn from an aquifer and then injected back into the same formation (so-called "cooling
water return flow wells" as defined in 40 CFR 146.5(e)(3)).  In these situations, the quality of the
fluids injected will be the same as the quality of the fluids in the receiving formation, except for a change
in temperature.

       No contamination incidents associated with noncontact cooling water wells, as defined for the
purpose of this study, have been reported. The only scenario in which noncontact cooling water wells
could be contaminated would  involve pipe leaks that allow process chemicals or other contaminants to
commingle with the cooling water. Illicit discharges into these wells appear extremely unlikely, since
noncontact cooling water systems are operated as closed systems that are virtually inaccessible for
"midnight dumping." No incidents of this or any other kind were uncovered during the course of this
study.

       As for some of the other well  categories addressed in this study, the inventory results for
noncontact cooling water wells are very uncertain because most responses to the state and USEPA
Regional survey did not distinguish these wells from other kinds of commercial or industrial wells. The
survey results suggest that there are more than 7,780 noncontact cooling water wells in the nation, but
this number includes some carwash wells, laundromat wells, and food processing waste disposal wells.
The survey results also  indicate that noncontact cooling water wells may exist in as many as 22 states,
although most appear to be concentrated in Alaska (212), Washington (3,900), and Tennessee
(1,000). Ninety-eight percent  of the documented and estimated noncontact cooling water wells in the
U.S. are found in ten states: Ohio, New York, West Virginia, Alabama, Tennessee, Iowa, Montana,
California, Alaska, and  Washington.

       Of the three states that have the vast majority of noncontact cooling water wells, Alaska and
Washington require the wells to be individually permitted.  Tennessee currently permits them by rule,
following a program like the minimum federal requirements established in USEPA's existing UIC
regulations.

       6.22   Subsidence Control Wells

       Subsidence control wells are injection wells whose primary objective is to reduce or eliminate
the loss of land surface  elevation due to removal of ground water providing subsurface support. These


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wells also may be used to control land subsidence caused by man-induced activities other than ground
water withdrawal (e.g., construction). Land subsidence control is achieved by injecting water into an
underground formation to maintain fluid pressure and avoid compaction.

       Sources of injectate in subsidence control wells include untreated surface water, untreated
ground water, saline water, and surface water treated to drinking water standards. No data on
injectate constituents or concentrations associated with subsidence control wells are available.
However, it is reasonable to assume that injectate in some subsidence control wells exceeds drinking
water standards for  some parameters.

       None of the known, active subsidence control wells inject into USDWs. Some wells are being
used to inject beneath construction zones to minimize damage from settlement caused by construction,
and other wells inject into a salt dome cavity that is used for the storage of oil at the Strategic Petroleum
Reserve Weeks Island site in Louisiana.

       No contamination incidents associated with the operation of subsidence control wells have been
reported.

       Details on the design, construction, and operation of subsidence control wells are not available.
Thus, it is not possible to determine if subsidence control wells are vulnerable to receiving spills or illicit
discharges.

       According to the state and USEPA Regional survey conducted for this study, there are 28
subsidence control wells documented in the United States. All documented subsidence control wells
are located in Louisiana (8), Oregon (14), and Wisconsin (6).  The estimated number of subsidence
control wells in the nation is approximately 158. Of these, as many as 50 wells may be located in New
York.  The documented and estimated numbers of subsidence control wells in the United States do not
include any wells in Alaska.  However, officials responsible for the UIC Program in that state did not
rule out the possibility that some exist.

       The statutory and regulatory requirements differ significantly among the four states where
subsidence control wells are believed to exist.  Louisiana, a UIC Primacy state for Class V wells,
authorizes subsidence control wells by rule.  In New York, USEPA Region 2 directly implements the
UIC program for Class V injection wells.  However, New York has additional jurisdiction over Class
V wells through state pollutant discharge elimination system permits.  Oregon, a UIC Primacy state for
Class V wells, authorizes subsidence control wells by rule. The six wells in Wisconsin were individually
permitted by the Department of Natural Resources.  All six of these wells have either been abandoned
or are in the process of being abandoned.  New subsidence control wells in Wisconsin are now
prohibited.
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