United States Office of Ground Water EPA/816-R-99-014f
Environmental and Drinking Water (4601) September 1999
Protection Agency
The Class V Underground Injection
control Study
Volume 6
Food Processing Wells
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Table of Contents
Page
1. Summary 1
2. Introduction 3
3. Prevalence of Wells 4
3.1 States Where Relatively Large Numbers of FPWDWs Are Known to Exist 4
3.2 Other States 7
4. Wastewater Characteristics and Injection Practices 7
4.1 Methodology 7
4.2 Background 9
4.3 Slaughterhouses 9
4.3.1 Slaughterhouse Operations and Drainage Wells 9
4.3.2 Simple Slaughterhouse Raw Wastewater Characteristics 17
4.4 Shellfish, Fish, Poultry and Other Types of Food Processing Facilities 19
4.4.1 Facility Operations and Drainage Wells 19
4.4.2 Facility Raw Wastewater Characteristics 25
4.5 FPWDW Injectate Quality 27
4.5.1 Assumptions Regarding Commercial Septic Systems and the Microbial
Environments Present in the Septic Tank 27
4.5.2 Organic Constituents 28
4.5.3 Inorganic Constituents 30
4.5.4 Microbial Components 31
4.6 FPWDW Construction and Design Characteristics 32
4.6.1 Commercial Septic Systems 32
4.6.2 Drywells 40
4.7 FPWDW Operational Characteristics and Maintenance Aspects 40
5. Potential and Documented Damage to USDWs 42
5.1 Injectate Constituent Properties 42
5.2 Observed Impacts 43
6. Best Management Practices 43
6.1 Alternatives to FPWDWs 44
6.1.1 Discharges to POTW 44
6.1.2 Discharges via a NPDES Permit 44
6.1.3 Discharges via Land Application Systems 44
6.1.4 Wastewater Hauling 45
6.1.5 Closing 45
6.2 Waste Audit 45
September 30, 1999
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Table of Contents (Continued)
Page
6.3 Dry Cleanup 45
6.4 Specific BMPs for Slaughterhouses 46
7. Current Regulatory Requirements 47
7.1 Federal Programs 47
7.1.1 SDWA 47
7.1.2 Food and Drug Administration and the Federal Food, Drug and
Cosmetic Act 49
7.1.3 United States Department of Agriculture - the Federal Meat Inspection
Act and the Poultry Products Inspection Act 50
7.1.4 Exempt Custom Slaughtering Facilities 51
7.2 State and Local Programs 51
Attachment A: Operational and Process Requirements for Exempt Custom Slaughterhouses 54
Attachment B: State and Local Program Descriptions 57
References 67
September 30, 1999
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WELLS USED TO INJECT FLUIDS FROM
FOOD PROCESSING OPERATIONS
The U.S. Environmental Protection Agency (USEPA) conducted a study of Class V
underground injection wells to develop background information the Agency can use to evaluate the risk
that these wells pose to underground sources of drinking water (USDWs) and to determine whether
additional federal regulation is warranted. The final report for this study, which is called the Class V
Underground Injection Control (UIC) Study, consists of 23 volumes and five supporting appendices.
Volume 1 provides an overview of the study methods, the USEPA UIC Program, and general findings.
Volumes 2 through 23 present information summaries for each of the 23 categories of wells that were
studied (Volume 21 covers 2 well categories). This volume, which is Volume 6, covers Class V food
processing wastewater disposal wells.
1. SUMMARY
Food processing wastewater disposal wells (FPWDWs) are essentially commercial septic
systems1 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. These systems usually inject process wastewater that may contain high
levels of organic substances (e.g., food waste), cleaning compound residues, and various inert
substances. FPWDWs are typically found at small facilities that usually have less than ten full time
employees and are located in unsewered, rural areas.
FPWDWs are similar to domestic septic systems, but instead of receiving toilet and shower
water, they receive larger quantities of equipment washdown and process wastewater. As with most
domestic septic systems, FPWDWs have one or two holding (or septic) tanks with attached pipes that
distribute treated wastewater to adjoining drain fields.
The wastewater entering the soil via FPWDWs, called FPWDW injectate, 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 significant levels of nitrate, nitrite,
total coliform, ammonia, turbidity and chlorides. No FPWDW injectate sampling has been performed,
so it is difficult to ascertain what constituents typically exceed drinking water maximum contaminant
1 In this volume a commercial septic system refers to a subsurface wastewater disposal system that
may have a slightly larger septic tank than a domestic sanitary septic system and may have additional
features such as a grease trap (see Section 4.6.1) or additional septic tank access holes. These septic
systems, which are used at the smaller food processing facilities, typically serve less than 20 people per
day and the septic tank volume is usually equal to or less than 2,000 gallons. Though still considered a
Class V injection well, commercial septic systems are not equivalent to large-capacity septic systems
covered in "N&lume 5 of the Class V Study.
September 30, 1999
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levels (MCLs) or health advisory levels (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.
FPWDWs typically inject above USDWs and into a variety of different geological formations,
terrains, and soils. However, one recently closed FPWDW at a fruit processing facility in Hawaii was
injecting directly into a USDW. As with sanitary septic systems, for FPWDWs 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 were being allowed to inject 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 FPWDW.
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 MCLs.
FPWDWs 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 FPWDWs. Therefore, spills may result in the release of
cleaning/disinfecting chemicals into the FPWDW. FPWDWs may also be used for illicit discharges due
to limited oversight and the necessity for rapid and inexpensive disposal of process wastewater.
According to the state and USEPA Regional survey conducted for this study, there are at least
741 documented FPWDWs 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 wells are found in Alaska, Wisconsin, Hawaii and a few other states.
Tennessee (based on discussions with the state Class VUIC coordinator) also has a significant number
of FPWDWs but the inventory has not been finalized. These well totals are considered uncertain
because many of the previously mentioned states do not distinguish between FPWDWs and other kinds
of commercial or industrial wells in their inventories. Overall, it seems that the number of active
FPWDWs throughout the country is decreasing because many UIC program staff are actively
encouraging individuals not to install FPWDWs and the areas served by sewers are expanding.
Additionally, there are some states that are closing all FPWDWs as they are found.
States such as Maine, Alabama and New "Vbrk, which have significant numbers of FPWDWs,
require individual permits or waste discharge licenses prior to construction and operation. However, in
Maine if the FPWDW meets local plumbing codes, no discharge license is required. West Virginia and
Tennessee, on the other hand, authorize these well types by rule but may require more extensive
permitting or closure efforts from the owner or operator if operations result in USDW endangerment.
Additionally, these two states require inventory information and other detailed information to be
September 30, 1999 1
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submitted prior to FPWDW operation. In Oregon, FPWDWs fall under a state general permit.
Hawaii, with only a few wells, prohibits injection into a USDW unless an individual site-specific permit
is issued. Similarly, in Wisconsin, all FPWDWs are permitted individually through the Pollutant
Discharge Elimination System. Depending on the type of food being processed, food processing
facilities must also comply with food handling and preparation regulations put forth by counties, states,
and the federal government. Some of these regulations may affect the quantity and quality of FPWDW
injectate.
2. INTRODUCTION
Shallow wells that dispose of wastewater from food processing operations qualify as Class V
injection wells as long as the wastewater is not a hazardous waste as defined under the Resource
Conservation and Recovery Act (RCRA). Using the existing list of Class V well types in 40 CFR
§146.5(e), food processing wastewater disposal wells could be either "dry wells used for the injection
of wastes into a subsurface formation" (per §146.5(e)(5)), or if the wastewater is disposed via a septic
system, "septic system wells used to inject the waste or effluent from ... a business establishment" (per
§146.5(e)(9)). In the 7957 Class V UIC Report to Congress, food processing wastewater disposal
wells were considered to be industrial process water and waste disposal (5W20) wells (USEPA,
1987).
On July 29, 1998 (63 FR 40586), USEPA proposed revisions to the Class V UIC regulations
that would add new requirements for the following three types of wells that, based on available
information, were believed to pose a high risk to USDWs when located in ground water-based source
water protection areas: motor vehicle waste disposal wells, industrial wells, and large-capacity
cesspools. All other types of Class V wells are to be studied further to determine whether they warrant
additional UIC regulation. In the July 29, 1998 Notice, USEPA proposed to include "wells used to
inject wastewater from food processing operations" within the "other industrial" well category2 which
would be excluded from the more stringent regulations proposed for high-risk industrial wells.
Because the term "well" is not commonly associated with the types of subsurface wastewater
disposal systems typically found at food processing facilities, it is important to clarify what is considered
a FPWDW and what is not. FPWDWs are any systems that accept food processing wastewater and
release it untreated or partially treated (as with septic systems) directly into the subsurface or above
USDWs. FPWDWs do not include septic systems at food processing facilities that are used solely for
the disposal of sanitary waste. The defining criterion for FPWDWs is that the systems are used to treat
2 The wells in the proposed "other industrial well" category are: (1) wells used to inject fluids from
carwashes that are not specifically set up to perform engine or undercarriage washing; (2) wells used to
inject non-contact cooling water that contains no additives and has not been chemically altered; (3) wells
used to inject fluids from laundromats where no onsite dry cleaning is performed or where no organic
solvents are used for laundering; and (4) wells used to inject wastewater from food processing operations.
The other three kinds of wells included in the other industrial well category are addressed in separate
"Volumes of the Class V Study.
September 30, 1999
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and/or dispose of wastewaters that are generated as a result of preparing, packaging, or processing
food products.
3. PREVALENCE OF WELLS
For this study, data on the number of FPWDWs were collected through a survey of state and
USEPA Regional UIC Programs. The survey methods are summarized in Section 4 of "Volume 1 of the
Class V Study. Table 1 lists the numbers of Class V FPWDWs in each state, as determined from this
survey. The table includes the documented number and estimated number of wells in each state, along
with the source and basis for any estimate, when noted by the survey respondents. If a state is not
listed in Table 1, it means that the UIC Program responsible for that state indicated in its survey
response that it did not have any Class V FPWDWs. The Food Processing Sector column provides
information on the particular food processing sectors within a state that are known to use FPWDWs.
Very few UIC coordinators provided this information since most did not have a good handle on how
many of FPWDWs existed in each state or what type of facilities used them.
Based on the inventory of documented wells provided in Table 1, it appears that the use of
FPWDWs in the United States is very common. Based on survey responses, there are 741
documented and almost 1,500 estimated FPWDWs in the U.S. However, several other states indicate
that they believe these wells exist in their state, but they do not have accurate information on the
prevalence of FPWDWs.
Based on the type of survey responses provided and the methods used in estimating the
numbers of wells, there is a large degree of uncertainly associated with the totals provided in the last
row of Table 1. Many UIC coordinators do not know how many FPWDWs actually exist and others
believe that there are many other FPWDWs in addition to the ones that are documented. Though not
many states or USEPA Regions provided information on the types of facilities using FPWDWs, the far
right hand column suggests that a majority of the FPWDWs can be found at small slaughterhouses and
seafood processing facilities.
3.1 States Where Relatively Large Numbers of FPWDWs Are Known to Exist
Conversations with some UIC coordinators combined with the information provided in survey
responses indicates that many of the documented FPWDWs are located in states along coasts. These
states include Maine, Alabama, New %rk, and Hawaii. However, it is not clear whether these coastal
states have a higher number of FPWDWs because there are a larger number of small seafood
processing facilities or because they have simply developed a more complete well inventory. Other
non-coastal states also reported, via survey responses or personal conversations, having a fair number
of FPWDWs. These other states include West Virginia, Tennessee, and Wisconsin.
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Table 1. Inventory of FPWDWs in the U.S.
State
Documented
Number of Wells
Estimated Number of Wells
Number
Source of Estimate and Methodology '
Food Processing
Sector (Provided
When Available)
USEPA Region 1
ME
152
152
Professional judgement and inspection
experience. Suspects more wells than
documented may exist. Maine
Department of Environmental Protection
is gradually discovering small seasonal
facilities that use FPWDWs. These
discoveries are likely to increase the
number of documented wells.
Many small seasonal
facilities (e.g., deer,
and moose
slaughterhouses and
seafood processing
facilities).
USEPA Region 2
NY
1742
500
Best professional judgement, based on
years of inspections and reviews of
business directories.
N/A
USEPA Region 3
MD
WV
1
2232
NR
>223 other
industrial
wells
UIC program staff suspect that more
wells exist.
Best professional judgement.
N/A
N/A
USEPA Region 4
AL
FL
TN
1622
5
1
>162
5
1
Based on field inspections and
discussions with owners of permitted
facilities. State believes that other
industrial wells exist that are not
permitted.
Field visits. State believes more wells
exist, but no statewide inventory is
available.
Suspect many more wells exist in TN.
Some seafood
processing wells.
N/A
Primarily custom
slaughterhouses.
USEPA Region 5
MI
WI
1
6
1
>6
NR
UIC program staff suspects more wells
than documented may exist based on best
professional judgement.
Meat processing
facility.
N/A
USEPA Region 6 - None
USEPA Region 7
September 30, 1999
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Table 1. Inventory of FPWDWs in the U.S.
(Continued)
State
IA
Documented
Number of Wells
NR
Estimated Number of Wells
Number
<100
Source of Estimate and Methodology '
Best professional judgement based on
discussions with trade organizations and
county sanitarians, and from working
with the regulated community.
Food Processing
Sector (Provided
When Available)
N/A
USEPA Region 8
MT
2
>2
Best professional judgement. The
documented number of wells may be
inaccurate. All cities have not yet been
inventoried.
Pork slaughterhouse,
and pork products
facility.
USEPA Region 9
CA
HI
NV
0
6
0
250
6
<10
Best professional judgement.
N/A
Best professional judgement.
N/A
N/A
N/A
USEPA Region 10
AK
OR
8
O2
25
25
Best professional judgement.
Best professional judgement. Many
active wells are not documented.
N/A
N/A
All USEPA Regions
All States
741
+/- 1,468
Total estimated number counts the
documented number when the estimate is
NR or unknown.
1 Unless otherwise noted, the best professional judgement is that of the state or USEPA Regional staff completing the survey
questionnaire.
2 Total includes all "other" industrial wells and not only FPWDWs; state data sources used to provide information for this
table do not readily differentiate between well types.
N/A Not available.
NR Although USEPA Regional, state and/or Territorial officials reported the presence of the well type, the number of
wells was not reported, or the questionnaire was not returned.
Maine has a significant number of documented FPWDWs with a total of 152. According to the
state UIC Class V coordinator and information obtained during a visit to the state, the majority of these
FPWDWs are seafood and shellfish processing plants located along the coast (Gould, 1999). These
small facilities typically process and package shrimp, clams, oysters, lobsters, crab, and fish. It is
important to note that the figure of 152 reported by the State of Maine staff was taken from a state
inventory performed between 1988 and 1992. Therefore, it is possible that some of the inventory data
September 30, 1999
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on FPWDWs in Maine are no longer accurate since some facilities may no longer be in business or
have since made connections to sewer lines.
Though only one FPWDW was reported in Tennessee, a recent visit to the state and
conversations with the state UIC Class V coordinator indicate that many more small slaughterhouses
with FPWDWs do exist in the state (Sorrells, 1999). Like many other states, Tennessee is currently in
the process of developing a much more accurate inventory of FPWDWs and other industrial Class V
wells. Site visits to both Tennessee and Maine also indicate that most of these slaughterhouses are
custom slaughterhouses that on average process less than 15 animals per week, depending on the time
of year and the hunting season. Custom slaughterhouse are facilities that process animals according to
the specific requests of customers. Once the meat is packaged it is returned to the owner of the animal
(see Section 7.1.4 for more detail).
It appears that the majority of FPWDWs are generally found in rural areas that are unsewered.
Conversations with some food processing facility owners/operators using FPWDWs reveal that the
primary reason for installing a FPWDW is the lack of sewer connections. These owners/operators
stated that if sewer connections were available at the time the facility was built, they would have opted
for connecting to the sewer lines instead of building a FPWDW.
3.2 Other States
The survey results in Table 1 show that other states suspect that more FPWDWs exist than
those documented. Those states include Alaska, California, Iowa, Montana, Nevada, and Wisconsin.
4. WASTEWATER CHARACTERISTICS AND INJECTION
PRACTICES
4.1 Methodology
FPWDW "injectate" refers to the wastewater filtering out of the septic system drain lines or out
of drywells and into the soil, as opposed to the "raw wastewater" released into a septic tank via floor
and sink drains. Many of the facilities employing FPWDWs are small operations that do not have the
resources or have not been required to have their raw wastewater or FPWDW injectate characterized.
Additionally, these types of facilities and the wastewaters they generate have not typically been the
focus of many academic or professional studies. Therefore, very little actual FPWDW injectate data
exist in state inspection/permitting records or in published studies.
Some limited slaughterhouse FPWDW injectate quality data were compiled from a Wyoming
permit for the operation of a commercial septic system. These data are discussed in Section 4.5.2 of
this volume (see references to Wyoming Department of Environmental Quality, 1989). However,
because of the overall lack of sampling data, it was necessary to rely on data obtained from other
sources to complete this section. These sources include:
September 30, 1999
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• a few previously published studies on raw wastewaters produced by larger food processing
plants that use other wastewater treatment/disposal methods besides FPWDWs;
• conversations with state UIC program staff; conversations with food processing facility
employees and trade association representatives; and
• personal observations from site visits to ten separate food processing facilities.
The above sources were useful in gaining a better understanding of the types of wastewaters
entering FPWDWs, but they were not always useful in determining the quality of the FPWDW injectate
after treatment (i.e., septic tank treatment). Therefore, for those FPWDWs that are commercial septic
systems, this report makes a distinction between raw wastewater characteristics (before entering the
septic tank) and injectate characteristics (after exiting the septic tank). This distinction is made because
the biological treatment occurring in a septic tank can significantly alter the characteristics of the raw
wastewater if the septic system is operated effciently. Therefore, the raw wastewater and the
FPWDW injectate can have very different characteristics (for more information on septic tank
treatment processes, refer to Section 4.6 of this volume).
The majority of information regarding raw wastewater characteristics and FPWDW injectate
came from personal interviews with facility owners/operators conducted during site visits to food
processing facilities using FPWDWs. These site visits, in Tennessee and Maine, were arranged by
state UIC program staff. During these visits, interviews with the facility owners/operators were
conducted, inspection of wastewater operations were carried out by UIC staff, and digital pictures of
the facility were taken. Because FPWDW injectate sampling was not conducted during site visits, the
information obtained was qualitative in nature. Pictures of particular facilities and specific operations
are provided to help the reader gain a better understanding of the particular operations that generate
wastewaters.
As stated above, the majority of facilities employing FPWDWs are small slaughterhouses and
seafood processing facilities. There are various other food processing facilities, such as sandwich
makers, dog food manufactures, vegetable and fruit processing facilities, and poultry processors that
also use FPWDWs. However, information regarding the prevalence of these types of facilities
throughout the country is not readily available. Therefore, this volume focuses on those food processing
facilities using FPWDWs, that, according to the survey responses and conversations with state UIC
authorities, are the most prevalent in the United States.
The following three sections (4.2 - 4.5) are presented in a manner that highlights the differences
in wastewater quality before and after septic tank treatment. In addition, because very few wastewater
sampling data are available for small food processing facilities using FPWDWs, the following sections
provide a fairly comprehensive summary of specific food processing procedures that take place at these
types of facilities, thereby enabling the reader to ascertain what types of substances are likely to be
found in the raw wastewater. Specifically, the following four sections are organized in the following
manner:
• Section 4.2 - general background discussion,
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Section 4.3 - information on the raw wastewater characteristics from slaughterhouse
operations,
• Section 4.4 - information on the raw wastewater characteristics from shellfish, poultry and other
types of food processing facilities, and
• Section 4.5 - information on the general characteristics of FPWDW injectate (after septic tank
treatment).
4.2 Background
Food processing wastewaters vary according to the raw food material used at the facility,
particular processing techniques, and other facility procedures such as recycling and use of best
management practices (BMPs) (see Sections 6.2, 6.3, and 6.4). In general, the raw wastewater
contains organic and inorganic dissolved and suspended solids. The organic component may include
fats, oils, grease, animal debris, blood, and vegetable and fruit matter. The inorganic portion may
include minerals (from dirt and preserving solutions), phosphates, ammonia, other nitrogenous
compounds, and chlorinated compounds from cleaning and disinfection solutions. In addition, the
wastewater will also probably contain bacteria, viruses, and other possibly harmful pathogens,
depending on the processes used in the facility. Finally, pesticides may be found in the raw wastewater
if large quantities of vegetables or fruit are washed.
Like raw wastewater, the principal component in FPWDW injectate is water. In cases where
it is released from a septic system, FPWDW injectate will likely contain lower concentrations of all the
constituents than are found in the raw wastewater.
The strength or concentration of the organic component in a wastewater is often measured
BOD. BOD measures the amount of oxygen required by bacteria and other microorganisms to
decompose organic matter. A high BOD level usually indicates that a large amount of oxygen will be
used to stabilize the organic portion, thereby lowering the quality of the receiving water (Peavy et al.,
1985). Typically, BOD levels are reported as BOD5 which represents the amount of oxygen used in
the first five days of decomposition (Vesilind, 1997). Another less commonly used measurement of
wastewater strength is chemical oxygen demand (COD), which is a measure of the levels of non-
biodegradable organics (Peavy et al., 1985). Other wastewater indicators include total suspended
solids (TSS), volatile suspended solids (VSS), and dissolved solids. These water quality terms are
used throughout the remainder of this volume.
4.3 Slaughterhouses
4.3.1 Slaughterhouse Operations and Drainage Wells
A slaughterhouse is defined as "a plant that slaughters animals and has as its main product fresh
meat as whole, half or quarter carcass or smaller meat cuts" (USEPA, 1974). According to the
September 30, 1999 9
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"Development Document for Effluent Limitations Guidelines and New Source Performance Standards -
Red Meat Processing Segments of the Meat Products," slaughterhouses can be grouped according to
the amount of secondary processing they perform and the complexity of their operations (USEPA,
1974). Secondary processing includes processing or rendering of carcass remnants (non-meat
products like blood and viscera) into products resulting in more concentrated wastewaters. These
secondary products include dog foods, hide products, and some pharmaceutical preparations produced
from processed blood. Those slaughterhouses that perform no secondary processing and have
relatively simple operations are called "simple" slaughterhouses. Conversations with state UIC
coordinators and observations made during site visits reveal that most of the slaughterhouses that use
FPWDWs can be considered simple slaughterhouses because they do not perform secondary
processing. Figure 1 provides a flow diagram of the typical operations taking place at simple
slaughterhouses.
Figure 1. Process Flow Diagram for Simple Slaughterhouses
Animals
Live Stock
Hide Removal.
Hog Dehariig
Eviscerating
Trinming
To Outside
Processing
Minor
Processing
Cooling
->• Carcasses
Source: USEPA, 1974
September 30, 1999
10
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Each of the processes listed in the left hand column of Figure 1 usually take place at the simple
slaughterhouse itself. Most of these processes do result in the generation of varying quantities of
wastewater, with killing and eviscerating probably generating the highest volumes of wastewater. The
right hand column of Figure 1 lists processes that use the wastes generated at the slaughterhouse as raw
materials. Generally, these processes occur offsite.
Most of the facilities that use FPWDWs do not typically do any "minor product processing" but
instead collect the hides, viscera, and blood, and ship it out for processing elsewhere. Because
different kinds of wastewater are generated at different locations within a simple slaughterhouse, it is
useful to describe the slaughtering, meat cutting, and packing processes. As the slaughtering and meat
packaging process is described, aspects related to the generation of wastewater are highlighted.
The slaughterhouses that were visited during the development of this volume slaughter primarily
cattle, hogs, lamb, deer, and sheep. Five of the six slaughterhouses visited are classified as "custom
slaughterhouses" and therefore they are exempt from many of the more stringent United States
Department of Agriculture (USD A) regulations (see Section 7 for more details). Because of this
exemption, custom slaughterhouses are operated in a different manner than most of the larger USDA-
inspected slaughterhouses or meat processing facilities. The one remaining slaughterhouse visited was
not a custom slaughterhouse and was regularly inspected by the USD A. It is important to note that the
information regarding slaughterhouse procedures presented in the following paragraphs was compiled
as a result of visiting particular slaughterhouses and therefore, the operational descriptions may not
apply to all custom or small slaughterhouses.
Animal slaughtering includes killing, evisceration, washing, meat cutting, cooling and packaging,
not necessarily in that order (USEPA, 1974). At custom slaughterhouses, animals are usually kept in
small pens or gated enclosures. These pens usually have concrete floors with metal or wooden gates
and often have floor drains. Figure 2 shows a floor drain, without a perforated drain cover, inside one
of these animal pens.
September 30, 1999 11
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Figure 2. Floor Drain Inside of Animal Pen
These floor drains are used to collect pen washdown that typically contains animal urine, fecal
matter, high levels of nutrients, sediments, and other solid particles such as hay and hair (USEPA,
1974). Because the floor drain shown in Figure 2 has no cover, it has the potential of receiving larger
solids that could affect the treatment efficiency of the FPWDW. During a visit to one slaughterhouse,
large amounts of fecal material, dirt, and hay were seen clogging the entrance of the pen floor drain
leading to the FPWDW. Some facilities employ dry pen animal clean-up procedures where very little
pen washdown is produced. No information on how often dry cleanup procedures for animal pens are
used at simple slaughterhouses was available.
From the pen, the animal is walked into the facility via a gated path and into the killing area.
The killing area has raised concrete edges along the floor to contain any blood and is shaped like a
shallow tub. Figure 3 shows a killing area in the middle of picture (only half of the killing area is visible).
September 30, 1999
12
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Figure 3. Killing Area and Main Floor
After the animal is killed by some means, it is washed with water to remove dirt and other hide-
borne contaminants. It is then either raised by its hind legs or left in the killing area and its jugular vein is
cut (this is known as "sticking") to allow the blood to flow out of the animal. During this procedure a
large amount of blood, depending on the type of animal, is released and approximately two-thirds to
three-fourths of the blood is collected for offsite disposal. The killing area contains a separate floor
drain (not seen in the picture since it is inside killing area) that is used to collect the blood released from
sticking or that is spilled during blood collection. This floor drain also collects washdown water
associated with clean-up of the killing area. Because of the particular activities that take place in the
killing area, the killing area floor drain has the potential of channeling large amounts of relatively
concentrated blood directly to the FPWDW, if the blood is not collected as is sometimes the case.
Though blood recovery practices are supposed to be employed at all slaughterhouses, it is not
clear that this is always the case at custom slaughterhouses. During one visit to a custom
slaughterhouse, blood from a cow's jugular vein was observed flowing directly into the floor drain
because blood recovery practices were not being used. This animal's concentrated blood was
therefore flowing directly into the FPWDW. Figure 4 shows the accumulated blood flowing into a floor
drain located near the killing area.
September 30, 1999
13
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Figure 4. Blood Being Allowed to Flow Directly Into a Floor Drain
It is not known how often events, like those seen in Figure 4, occur at small custom
slaughterhouses. According to one facility owner, once the blood reaches the floor, it is usually
collected in buckets with the aid of a squeegee. If large amounts of blood are left to accumulate on the
floor as seen in Figure 4, the resulting wash water could have relatively high concentrations of blood.
After the animal is bled, the hides and/or hairs are removed. At smaller facilities deluding is
done manually with the aid of conventional or sometimes air-driven knives. Deluding activities result in
the release of additional blood, meat/tissue waste, and other hide-related particles such as dirt. These
liquids and solids typically fall to the ground where they are supposed to be collected for proper
disposal. If not collected, it is possible that this waste also is washed down into the floor drains. The
water used to wash the areas where dehiding takes place will produce a wastewater that usually
contains blood, small pieces of tissue, and other smaller inorganic particulate.
To remove the hair from hogs, some facilities use mechanical devices. Two of the more
commonly employed machines used for dehairing are the scalding and dehairing machine, both of which
are shown below in Figure 5. The operator first inserts the dead hog in the scalding tub (seen in the
rear of the picture) and the hot water works to loosen the hair on the hog's hide. The hog is then
transferred over to the dehairing machine (seen in the center of the Figure 5) where rotating rubber fins
are used to remove the hair via abrasion. Wastewater from both of these processes contains hair, soil,
mineral oil (used for lubrication of machinery), and manure. Due to the nutrient levels, this wastewater
may have high levels of BOD, ranging up to 3,000 mg/1 (USEPA, 1974). The floor drain used to
collect spill water and equipment washdown is seen in the middle-bottom of Figure 5. The scalding tub
water is also sent to the FPWDW.
September 30, 1999
14
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Figure 5. Hog Scalding Machine and Floor Drain
After deluding and/or dehairing (if necessary), the carcass is opened and eviscerated. The
carcass is then trimmed and inspected and the balance of the viscera and trimmings are kept in
containers that are eventually sent to Tenderers. Great care is used when eviscerating the animal to
avoid rupturing the animal's stomach, which contains acids and other fluids that can affect the quality of
the meat and also have a very high BOD content. Figure 6 shows the area where eviscerating take
place and shows the containers used to collect animal parts that are sent to the Tenderers. The
equipment and tables seen in Figure 6 are cleaned at the end of every day with disinfectants and/or
soaps and rinsed with large quantities of hot water. In general, the wash water entering the FPWDW
from these areas contains blood, tissue solids, and residues of cleaning compounds. Hoses are used to
wash the carts and equipment and the wash water flows into the floor drain seen below The blood and
tissue pieces from the evisceration and trimming process may find their way into sink drains, which are
typically connected to FPWDWs, or this
September 30, 1999
15
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Figure 6. Floor Drain Receiving Wash Water From Equipment Washdown
waste will be allowed to fall to the floor where water streams from large hoses are used to push the
wastes toward the floor drains.
According to one facility owner, most custom slaughterhouses attempt to collect as much of the
remaining tissue or scrap trimmings that remain on the tables or floors, so usually only very small pieces
are allowed to enter sink or floor drains. Figure 7 shows an accumulation of fat/meat trimming wastes
on the floor that will eventually be scooped up and placed in buckets. If the covers are removed, larger
solids will drain into the FPWDW.
Figure 7. Accumulation of Fat/Meat Trimming Wastes Near a Floor Drain
September 30, 1999
16
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After evisceration and trimming the animal carcass is either cut in half or left whole and hung in a
cooler where it stays for a predetermined period of time. After hanging the carcass in the cooler, the
carcass is washed with large amounts of water and then drip dried. This washing step results in the
highest production of wastewater throughout the facility (USEPA, 1974). The fluid that drips from the
carcasses contains relatively high concentrations of grease, small amounts of blood, tissue solids, and
other fluids. Figure 8 shows animal carcasses hanging inside a cooler and the receiving floor drain.
Figure 8. Carcasses in a Cooler with Pooled Grease/Fatty Fluids Near Floor Drain
After cooling, or aging, the carcasses are cut into smaller sections or individual pieces,
according to the requests of the original owner of the animal. As with the evisceration process, tissue
and small amounts of fluids usually drip to the floor or into a sink during this final step. After cutting, the
meat pieces are packaged and wrapped. At the end of the day all the equipment is thoroughly cleaned
with large amounts of water and the washdown water along with bone dust and other fluids (e.g.,
blood, cleaning solutions) enters the floor drains.
4.3.2 Simple Slaughterhouse Raw Wastewater Characteristics
As described in the previous section, wastewaters entering FPWDWs from custom
slaughterhouses usually contain water, organic matter (including grease), suspended solids, and
inorganic materials such as phosphorous, nitrogen, and chlorine or other disinfecting chemicals. These
compounds enter the waste stream and eventually the FPWDW as blood, meat and fatty tissue, meat
extracts, stomach contents (only if ruptured), manure, hair, dirt, lubricating oils, and cleaning
compounds (USEPA, 1974). Bacteria are also present in the raw wastewater at most probable
number (MPN) levels between 2 to 4 million per 100 ml (USEPA, 1974). Some bacteria, such as
salmonella and shigella, can be found in the raw wastewaters and are considered pathogens (World
Bank, 1997). In addition to bacteria, there is the potential for viruses and parasite eggs to be found in
September 30, 1999 17
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wastewater. Table 2 shows the typical raw wastewater characteristics of a simple beef slaughterhouse,
assuming blood and stomach liquid collection methods are employed. MCLs are also included to
enable comparisons.
Table 2. Characteristics of Slaughterhouse Raw Wastewater
Constituent
PH
Total suspended solids
BOD5
Grease
Kjeldahl nitrogen
Chlorides as CL
Nitrates and nitrites
Ammonia nitrogen
Total phosphorous as P
Hot water
Simple Slaughterhouse
(mg/1 unless otherwise indicated)
7 (units)
1051
1126
394
128
487
0.01 - 0.85
7-50
9
typically above 150 °F
MCL
(mg/1 unless otherwise indicated)
6.5 - 8.5 (units)1
NA2
NA
NA
NA
2501
10 and 1, respectively
NA
NA
NA
Secondary MCLs
2 NA is not applicable
Source: USEPA, 1974
The data presented in Table 2 were calculated by dividing the average constituent
concentrations from 24 different facilities by the average wastewater flow of the same 24 facilities (for
more information see USEPA, 1974). The high levels of organic matter in the wastewater can result in
high BOD5 levels in the raw wastewater. BOD5 is the wastewater component that is most commonly
used in characterizing slaughterhouse wastewater. It is the best measure of the organic load entering the
waste stream and it provides a useful measure of the overall strength of the wastewater. The major
contributor to BOD5 levels in the wastewater is blood. Blood is rich in chlorides and nitrogen and has
an ultimate BOD of 405,000 mg/1 and a BOD5 between 150,000 and 20,000 mg/1. Ultimate BOD is a
measure of the microbial oxygen consumption after 20 days. Cattle typically contain up to 50 pounds
(5.7 gallons, assuming blood density of 1.52 g/cm3) of blood per animal and only 35 pounds of the
blood are typically recovered during the blood recovery process (USEPA, 1974). The remaining 15
pounds (1.7 gallons) are lost with wastewater. Stomach manure, which contains partially digested feed
material, has a BOD5 of 50,000 mg/1 (USEPA, 1974). In addition, the raw wastewater also contains a
high grease/fat content.
From the available publications and observations during site visits, it does not appear that any
types of hazardous materials (e.g., heavy metals, pesticides) are discharged by slaughterhouses
September 30, 1999
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(USEPA, 1974). Because hazardous compounds are not typically found in slaughterhouse premises, it
is highly unlikely that they will find their way into FPWDWs. Though not classified as hazardous
substances, the USD A3 does permit the use of certain enzymatic compounds for use as cleaning agents
in sewage and/or drain lines (U.S. Department of Agriculture, 1986). During site visits, no facility
owner stated that they used any type of drain cleaner or septic system enzymatic activator.
As stated earlier, simple slaughterhouse raw wastewater may contain residues of strong
cleaning or disinfecting compounds. The concentrations in the raw wastewater vary according to
frequency of use, amounts used during cleaning procedures, and frequency and severity of spills near
the floor drains or in the sinks. Most of the slaughterhouses that were visited were using food service,
USDA-approved cleaning compounds. Others were simply using commonly found household cleaning
solutions, like Clorox Bleach and Tide, to clean equipment floors and hands. Most of these domestic
cleaning solutions are approved by the USDA and most county public health offices. Household
strength bleach usually contains 5 percent sodium hypochlorite and 95percent inert ingredients.
In general, slaughterhouses use large quantities of water for various cleaning operations. A
commercial septic system permit for a slaughterhouse in Wyoming states that approximately 60 gallons
of water are needed for every animal slaughtered (Wyoming Department of Environmental Quality,
1989). Water usage at slaughterhouses varies according to the rinsing and washing operations that take
place at the facility. According to one facility, 7,000 gallons per month of water were being used for all
operations. As expected, the use of water and the generation of wastewater is entirely dependent on
the number of animals that are slaughtered, cut, and prepared.
4.4 Shellfish, Fish, Poultry and Other Types of Food Processing Facilities
4.4.1 Facility Operations and Drainage Wells
Other types of food processing facilities also employ FPWDWs to dispose of their
wastewaters. As with custom slaughterhouses, these other types of food processing facilities usually
rely on commercial septic systems. These facilities are also small, operate seasonally, and usually have
less than 10 full-time employees. Although there are probably other types of food processing facilities
using FPWDWs throughout the country, this section presents information which was either retrieved
from facility visits or collected via telephone conversations with state UIC coordinators. Non-
slaughterhouse food processing facilities for which sufficient information was collected, include food
processing facilities that:
3 Some small slaughterhouses are inspected by the USDA and therefore must abide by all relevant
sections of the Federal Meat Inspection Act (see Section 7.1.3 for more information). Custom
slaughterhouses are exempt from certain sections of the Federal Meat Inspection Act and therefore abide
by different regulations (see Section 7.1.4 for more information) and are typically inspected by county
public health representatives.
September 30, 1999 19
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clean, prepare, and package shellfish (e.g., shrimp, crabs, clams);
prepare fish-related products (e.g. salmon processing facility);
process and package/can fruits and vegetables;
process poultry; and
prepare packaged sandwiches.
Shellfish and Fish Processing
Shellfish processing facilities were visited because, according to a few UIC representatives and
survey responses, they are probably the most common type of food processing facility using
FPWDWs besides custom slaughterhouses. The seafood and shellfish processing facilities using
FPWDWs are usually located near the coast in unsewered areas. These facilities receive various kinds
of shellfish at different times throughout the year and employ a variety of manual shucking4 and
packaging procedures. Shellfish processed at these facilities include crabs, clams, shrimps, oysters, and
lobsters. According to one shellfish processing facility owner, during shrimp season the facility can
process between 1,000 to 1,200 pounds per day of shrimp. During clam season, the clam processing
rate falls between 500 to 1000 pounds per day of clams.
Shellfish processing facilities usually receive shellfish, whole, on ice directly from fishing boats.
Depending on the type of shellfish being processed, facilities will use different manual procedures for
removing the shell, the head, and the veins from the meat. Figure 9 shows a typical room and the tables
where shucking, deveining, and deheading occur.
Figure 9. Room and Equipment Used in Manual Shucking of Shellfish
4 Shucking is the action of removing the shell of the animal.
September 30, 1999
20
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The tables in Figure 9 have holes, with trash cans underneath (not seen), where workers can
throw away shells and other larger solids. As with all food processing equipment, the tables are
cleaned and disinfected with cleansing compounds (e.g., dishwashing soap, bleach, or other USDA-
approved cleaning products) and rinsed off with large quantities of water. The wash water finds its way
to the floor drains located throughout the room. Figure 10 shows the location of floor drains in the
main processing room of a much smaller facility than that shown in Figure 9.
Figure 10. Floor Drains leading to FPWDWs at a Shellfish Processing Facility
At the shellfish processing facilities visited, the raw wastewater entering the drains and the
FPWDW usually contains animal shell material, grit, sand, tissue solids, and large quantities of hot
water. It also contains residues of cleaning compounds (e.g., bleach), seawater, and possibly trace
levels of other organic compounds. According to one facility owner, the wastewater coming from shell
processing facilities has qualities similar to that of domestic wastewater.
The floor drains leading to FPWDWs vary in design and size. However, they usually have a
trap, or a lip, under the perforated cover to catch any of the larger solids that may make it through the
perforations in the cover. The floor drains found in most of the shellfish processing facilities that were
visited had removable covers. Floor drains leading to FPWDWs are also found in cooling or chilling
rooms. These coolers contain the peeled and prepared shellfish, and because the temperature is below
freezing most of the time, little wastewater enters these floor drains except when they are cleaned.
Figure 11 shows a close-up of a floor drain at a shellfish processing facility.
September 30, 1999
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Figure 11. Floor Drain in Shellfish Shucking Room
The number of floor drains in a particular facility varies according to the size of the facility and
the expected amount of wastewater the facility is going to generate. In some cases, sinks used to rinse
food products and other equipment were also connected to the FPWDW.
Fish processing facilities using FPWDWs were not visited. However, according to the
manager of a fish processing facility that did use a FPWDW at one of its smaller locations (not visited
due to time constraints), a FPWDW was being used to collect equipment washdown water. This
smaller facility processed salmon and produced salmon-cheese pate. Therefore, it is likely the raw
wastewater entering the FPWDW contained fish meat, cheese residues, spices, cleaning compound
residues, large quantities of grease, and large volumes of hot water. According to the owner, the raw
wastewater from the facility closely resembled the qualities of raw domestic wastewater. Unlike
domestic septic systems, the FPWDW at this facility was handling much larger quantities of raw
wastewater. This fish products facility was using a USDA-approved disinfecting/cleaning compound
produced by a company named ECOLAB. The exact chemical makeup of this cleaning compound is
not known, but it is likely to contain a disinfectant like chlorine and/or a surfactant chemical.
Fruit and Vegetable Processing and Packaging/Canning
No vegetable or fruit processing facilities were visited but detailed information was collected on
two particular facilities of this type. One facility, located in Hawaii, up until recently was using an
injection well to dispose of its pineapple processing and canning wastewaters. Prior to injection the
wastewater passed through a settling pond where some of the larger solids settled out. After exiting the
pond, the wastewater was then mechanically pumped directly into an underlying aquifer 100 feet below
the surface. The injectate still contained high concentrations of fruit juices, small pieces of fruit, and was
generally high in BOD. According to a Hawaii Department of Health representative, this facility
September 30, 1999 22
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recently switched to a wastewater land application strategy because dangerous methane accumulations
were occurring in the injection well and in a few of the surrounding areas (Wong, 1999). However, the
facility has opted to keep the injection well operational, in case problems are encountered while land
applying the wastewater.
Another facility, located in Wisconsin, is currently using a combined commercial septic system
to dispose of mushroom pickling wastewater and sanitary waste from one bathroom (Wisconsin
Department of Natural Resources, 1996). This combined system is unique since most facilities visited
had separate systems to handle sanitary and food processing wastewaters. This particular facility
releases less than 400 gallons per day of wastewater that contains primarily water from mushroom
soaking and blanching, mushroom juices, facility wash down water, and sanitary waste. The Wisconsin
Department of Natural Resources issued a permit for the operation of this FPWDW under the
condition that no pickling brine or non-biodegradable substances be allowed to enter the system. It is
not known if problems have occurred at this site.
Poultry Processing
Only one poultry processing facility was visited and it is not known how many other similar
types of poultry processing facilities using FPWDWs exist in the country. However, it is possible that
similar facilities do exist in rural unsewered areas throughout the country. The facility that was visited
processes chickens, turkeys, and other fowl brought in by individuals.
As with slaughterhouses, the animals are first killed in the killing area. At this particular site
there were no floor drains in the killing area. According to the owner, the blood generated during the
killing process is collected and sent to Tenderers for further processing. After killing, the animals are
defeathered and eviscerated. The unusable poultry wastes (e.g., feathers, intestines) are also collected
and sent to rendering facilities. The meat of the animals is then prepared, packaged if necessary, and
chilled. All of the cutting, preparation, and packaging activities occur in a separate room next to the
killing area. Figure 12 (next page) shows the poultry meat, preparation, packaging and chilling room of
the facility that was visited (refrigerator not in view). Figure 12 also shows a preparation table and a
window-like opening in the wall above the table that leads to the adjoining killing area. The entire area,
including floors and all equipment, is washed down at the end of the day with the large hoses that are
seen lying on the floor under the table. Additionally, some equipment may be rinsed prior to use. At
this facility there was no septic system in place and wastewater was allowed to flow directly into two
drains located in the middle of the preparation room seen in Figure 12. These floor drains lead directly
to two drywells under the floor. The floor drains, leading to the drywells, had no covers, so
presumably larger solid wastes could also enter the well.
September 30, 1999 23
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Figure 12. Poultry Processing Room - Meat Cutting and Preparation Table
The wastewater produced at these types of poultry facilities typically contains small pieces of
animal tissue, feathers, grit, blood and other meat fluids, bone dust wastewater, grease, oils, and small
quantities of cleaning and disinfectant solutions (USEPA, 1975a). In addition, large quantities of hot
water are flushed down the drain with the waste compounds. At the visited site a large container
(approximately 15 gallons) of a USDA-approved chlorinated disinfectant called "Swell" was being
stored at ground level very near the uncovered drywells. This container was closed and did not appear
to have a spout for pouring, but instead had a removable plastic lid.
Sandwich Preparation
For this study, one sandwich preparation facility was visited in Tennessee. This facility
produced a variety of hot and cold sandwiches for resale in convenience stores. The facility used a
commercial septic system to treat wastewater collected through various floor drains and one sink. The
wastewater is generated as a result of washing sandwich preparation equipment (e.g., tables, conveyor
systems), cooking equipment (pots and pans), and the employee's hands. No hazardous chemicals
were observed in the room where the floor drains were located. The facility had been family-owned
for many years and employed 20 people. According to the facility owner, the washdown water
contained mostly water, bleach (used in disinfecting), dish soap, spices, grease, and organic solids,
including pieces of sandwich filling (tuna, chicken) and bread. This facility had not installed a grease
trap5 to contain the fats entering the commercial septic system.
5 See Section 4.6 for more details regarding a grease trap.
September 30, 1999
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4.4.2 Facility Raw Wastewater Characteristics
Food processing operations, as a whole, use and discharge large quantities of water since
water is the most commonly used rinsing and washing substance. The raw wastewaters from the
facilities described in Section 4.4.1 can contain high concentrations of biodegradable organic material
and high levels of suspended solids (Beszedits and Netzer, 1982). Effluents from fish and poultry plants
can also contain substantial levels of fat and grease. Raw wastewaters from poultry processing facilities
usually contain a bacterial component (e.g., fecal coliform, salmonella) and some inorganic materials,
such as phosphates, nitrates, and nitrites (USEPA, 1975a; Beszedits and Netzer, 1982). Raw
wastewaters from shellfish and fish processing facilities can also contain high levels of proteins
(Beszedits and Netzer, 1982). In some cases, pH fluctuations may occur at food processing facilities,
due to use of strong caustic or acidic cleaners used to wash floors and equipment, but for the most part,
the pH of the raw wastewaters is neutral (pH 6.8 to 7.2) (Beszedits and Netzer, 1982).
Table 3 presents typical raw wastewater characteristics for three different types of food
processing facilities. The data presented in Table 3 for poultry and crab processing facilities represent
the effluent quality from larger, more sophisticated food processing facilities, so they may not accurately
reflect the actual qualities of the raw wastewater generated at the smaller facilities using FPWDWs that
employ more manual processes. MCLs are also shown in Table 3 to allow for comparisons.
Table 4 provides a more accurate characterization of the raw wastewater produced at the
smaller, family-owned shellfish processing facilities that manually hand shuck oysters and clams.
As can be seen in both Table 3 and Table 4, all effluents generated during specific food
processing activities typically have high levels of BOD5, COD, and solids (dissolved and suspended).
It is important to remember that the many food processing plants operate on a seasonal basis and this is
reflected in the quantity and quality of the wastewaters discharged (Beszedits and Netzer, 1982). The
shellfish facilities using FPWDWs process a variety of shellfish depending on the season, so these
facilities will most likely discharge raw wastewater, similar to wastewater described in the above tables,
at different times throughout the year.
Although food processing wastes are generally free of toxic chemicals, certain cleaning
compounds, if improperly used, can exert a strain on the microbial activities taking place in the soil or in
the septic tank. The concentrations of cleaning compounds in the raw wastewater vary according to
frequency of use, amounts used during cleaning procedures, and frequency and severity of spills near
the floor drains or in sinks. Most of the facility owners stated they only used household quality bleach,
household quality floor cleaners, dishwashing soap for cleaning food processing equipment, and hand
cleaning solutions.
September 30, 1999 25
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Table 3. Wastewater Characteristics of Three Food Processing Sectors
\\astewater Indicator
BOD5
COD
Total solids
Dissolved solids
Volatile solids
Total suspended solids
Ammonia nitrogen
Chloride
Sodium
Magnesium
Calcium
Phosphorous
Nitrate nitrogen
Total alkalinity
Kjeldahl Nitrogen
Oil and Fat residues
Hot water
Poultry
(mg/1)
500
800
800
300
700
500
&
300
37
8
32
4
&
&
&
300
Shrimp Processing
(mg/1)
207
228
530
&
&
130
8
&
&
&
&
5.1
9.0
99 (mg/1 as CaCO3)
46
&
Crab Processing
(mg/1)
608
1076
400
1161
898
400
14
386
&
&
&
&
1
284 (mg/1 as CaCO3)
72
0
Typically greater than 150 °F
MCL
(mg/1)
NA1
NA
NA
5002
NA
NA
NA
250
NA
NA
NA
NA
10
NA
NA
NA
NA
1 NA is not applicable
2
Secondary MCL
* No data available in publication.
Sources: USEPA, 1975; Horn andPohland, 1973
Table 4. Raw Wastewater Characteristics for Oyster and Clam Processing Facilities
Wastewater Indicator
BOD5 (mg/1)
COD (mg/1)
Total suspended solids (mg/1)
Ammonia nitrogen (mg/1)
Organic nitrogen (mg/1)
Oil and fat residues (mg/1)
Hot water
Oyster Processing
(For facilities in the East
and Gulf Coast Region )
455
601
416
3
49
20.4
Clam
Processing
1130
2142
2240
6
220
31.7
Typically greater than 150 °F
Sources: USEPA, 1975; Horn and Pohland, 1973
September 30, 1999
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4.5 FPWDW Injectate Quality
FPWDW injectate quality varies according to the construction of the well, design of the well,
and facility operations. Based on the site visits conducted during the development of this volume and
the additional information retrieved from state UIC offices, it appears that most food processing
facilities are employing commercial septic systems. Therefore, this section focuses on the qualities of
the typical effluent being released into the soil by the average food processing septic system. In a
properly functioning septic system, no wastewater is released by the tank itself, but through drain lines
that are attached to the tank.
Site visits revealed that use of drywells is not very common in small food processing facilities
since most facilities are required to comply with county or state regulations that often prevent use of
drywells at industrial/commercial facilities. Of the ten facilities that were visited, only one poultry facility
was using a drywell. Drywells allow wastewater to flow directly into the soil and because no biological
treatment occurs, the same raw wastewater that enters the drywell is considered to be FPWDW
injectate. Sections 4.3 and 4.4 describe the qualities of the raw wastewaters generated at specific
types of food processing facilities; these same qualities would apply to the drywell injectate. It is highly
unlikely that custom slaughterhouses would use drywells since drywells do not have the capacity to
handle large volumes of high strength wastewater.
4.5.1 Assumptions Regarding Commercial Septic Systems and the Microbial Environments
Present in the Septic Tank
As mentioned earlier, little is known about the actual quality of the injectate released by
FPWDWs. Therefore, to determine the kinds of compounds present in the injectate, it is necessary to
make some assumptions about the degree of biological treatment occurring in the septic tank. Because
most of the facility operators stated that they had not encountered too many difficulties with their septic
systems (except for a few events that are described in Section 4.6), it will be assumed that food
processing facility owners/operators have installed properly designed septic tanks (e.g., properly sized,
leveled, and constructed), are discharging raw wastewater into the septic system at accepted flow
rates, and are employing reasonable blood recovery procedures (even though, as discussed in Section
4.3.1, some facilities may let blood drain directly into floor drains). It can then be assumed that a
certain amount and type of microbial degradation is taking place in the septic tank and the injectate
quality will most likely be of better quality than the raw wastewater entering the septic tank.
It is important to note that the FPWDW injectate quality is dependent on septic
tank/wastewater retention times, raw wastewater concentrations, food processing facility operational
procedures, and other factors. If blood collection mechanisms are not used in custom slaughterhouses
or if the treatment capacity limitations of the commercial septic system are exceeded, FPWDW
injectate quality will most likely decrease dramatically.
According to information obtained from a Wyoming permit to operate and construct a small
slaughterhouse septic system, the microbial degradation taking place in a septic system holding tank
September 30, 1999 27
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resembles the microbial actions occurring in an anaerobic lagoon (Wyoming Department of
Environmental Quality, 1989). The comparison to an anaerobic lagoon was chosen by the engineer
who installed the septic system, since often the grease and oils in the raw wastewater that enter the tank
work to form a "scum blanket" on the top of the wastewater in the holding tank (see Figure 15 in
Section 4.6.1 for schematic of a commercial septic system). As a result of the formation of a scum
blanket, little oxygen diffuses into the wastewater below, creating an anaerobic system where anaerobic
and facultative bacteria6 will thrive. The assumption regarding anaerobic environments most likely
applies to other types of food processing facilities, besides slaughterhouses, because most food
processing procedures generate appreciable quantities of grease. However, if a grease trap is installed
the assumption that an anearobic environment exists in a septic tank may not be valid. Another reason
to assume an anaerobic process is that the temperature of the incoming wastewater can be quite high,
which works to maintain an environment favorable to anaerobic activity. Additionally, the wastewaters
from food processing facilities generally are of neutral pH and contain high concentrations of
carbohydrates, proteins, and nutrients that also work to create an environment favorable to anaerobic
or facultative microorganisms (USEPA, 1975b). It is important to note that anaerobic lagoons with an
artificial cover or a scum blanket are commonly used at food processing facilities, such as poultry plants
and larger slaughterhouses, as the first step in biological treatment or as pretreatment prior to discharge
to a municipal system (USEPA, 1974; USEPA, 1975b).
4.5.2 Organic Constituents
The Wyoming permit and several USEPA documents state that anaerobic lagoons are effective
at reducing the levels of BOD5 and suspended solids in the wastewaters prior to release (Wyoming
Department of Environmental Quality, 1989; USEPA, 1974). According to information found in the
permit, approximately 80 percent to 92 percent of the BOD5 in the raw wastewater can be removed at
temperatures of 75°F and 90°F, respectively. The engineer who designed the septic system for a
custom slaughterhouse in Wyoming determined that a BOD5 removal efficiency of approximately 85
percent could be accomplished in the septic tank, assuming the facility owner stayed under the
suggested wastewater flow rate thereby maintaining an adequate retention time. For this particular
slaughterhouse, the BOD5 concentration in the FPWDW injectate is 135 mg/1.
Two USEPA effluent limitations guidelines development documents stated that up to a 95
percent reduction in suspended solids could be achieved via a properly operated anaerobic lagoon
used to treat poultry processing plant and slaughterhouse wastewaters (USEPA, 1974; USEPA,
1975a). If anaerobic conditions are maintained in a food processing facility septic tank (e.g., grease
layer present and a high temperature), the flow rate of the incoming raw wastewater is low enough to
maintain an average wastewater retention time of at least 5 days, and if the septic tank is properly sized,
it is possible to assume that a septic tank and an anaerobic lagoon will probably operate in a similar
fashion and therefore, treat wastewaters similarly. Because information on food processing facility
wastewater flow rates was not readily available during site visits, it is not possible to determine if a
6 Facultative bacteria can adapt themselves to grow and metabolize in the presence, as well as the
absence, of free molecular dissolved oxygen.
September 30, 1999 28
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sufficient retention time is typically achieved in food processing commercial septic tanks. However, if a
food processing facility maintains the necessary conditions, as describe above, it can be assumed that
on average an 85 percent reduction in BOD5 loading and an average 95 percent reduction in TSS
loading can be achieved in a properly operating FPWDW septic tank. Therefore, it is possible to
make some approximations regarding what the BOD5 and TSS concentrations in the FPWDW
injectate will be. Table 5 presents the typical BOD5 and TSS levels found in the raw wastewater, as
presented in Section 4.3.2 and 4.4.2, for some of the food processing facilities considered in this
volume and the expected FPWDW injectate concentrations after BOD5 and TSS removal.
Table 5. Estimated Injectate BOD5 and TSS Levels for Food Processing Facilities
Food Processing
Facility
Poultry
Shrimp
Crab
Clam
Oyster
Slaughterhouse
(with blood
collection)
BOD5 in
Raw
Effluent
(mg/1)
500
207
60S
1130
455
1126
Estimated FPWDW BOD5
Injectate Concentrations,
assuming 85% removal
efficiency
(mg/1)
=75
=32
=91
=170
=68
=169
TSS in Raw
Effluent
(mg/1)
800
530
400
416
2240
1051
Estimated FPWDW TSS
Injectate Concentrations,
assuming 95% removal
efficiency
(mg/1)
=40
=27
=20
=21
=112
=53
The characteristics of the raw wastewater from different types of food processing facilities can
vary significantly. These different wastewater characteristics in turn affect septic tank treatment
performance and therefore the percent reduction levels for BOD5 and TSS may vary. There are no
primary or secondary MCLs for either BOD5 or total suspended solids. However, high BOD5 levels
are often associated with poor water quality, possibly poor odor, and high turbidity. It is not known
whether the estimated BOD5 levels in the injectate would normally result in exceedances of the
secondary MCLs for or turbidity. Odor can be caused by organic and some inorganic chemicals.
Turbidity is caused by suspended matter such as clay, silt, finely divided organic matter, and soluble
colored organic compounds.
According to a public information fact sheet sponsored by the University of Florida, a properly
operating septic tank will also remove much of the COD as well (Brown, 1998). The other less
biodegradable organic and/or inorganic solids that make up some of the TSS portion of the wastewater
will most likely settle to the bottom of the septic tank and accumulate there until the tank sludge is
pumped out.
September 30, 1999
29
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Table 3 also shows that dissolved solids may be present in raw wastewater generated at crab
and poultry processing facilities. It is not known what happens to these dissolved solids in food
processing septic tanks, but it is likely that many of the dissolved solids are used as substrate for
bacteria during microbial decomposition. As stated earlier, a few of the food processing facilities were
using grease traps to prevent large volumes of grease from entering the septic tank. Grease and oils
that may enter the septic tank eventually decompose in the tank or they will liquify slightly and enter the
drain lines where they will become part of the injectate.
4.5.3 Inorganic Constituents
As can be seen in Tables 2, 3, and 4, there are various nitrogen compounds present in the raw
wastewaters generated at food processing facilities entering the septic tank in the form of ammonia,
organic nitrogen, nitrate, and nitrite. The types of nitrogen compounds ultimately entering the soil
through the drain lines are functions of the treatment occurring in the septic tank (Brown, 1998).
Typically, only 10 percent of the total nitrogen in the raw wastewater is removed as sludge that
accumulates at the bottom of the septic tank (Brown, 1998). Because no FPWDW injectate data are
available and there is a fair amount of variation in raw wastewater quality from the different food
processing facilities, it is difficult to accurately determine what forms of nitrogen will be present in the
injectate and at what concentrations. Nitrite (NO2") and nitrate (NO3") are chemicals of concern since
there are adverst health effects associated with drinking water that has high levels of these compounds.
However, some assumptions concerning the transformation of nitrogen compounds in the septic tanks
can be made in order to estimate the levels of nitrate and nitrite in FPWDW injectate.
Because nitrate and nitrite are usually converted to ammonium and other organic forms in an
anaerobic environment, such as that possibly found in a FPWDW septic tank, FPWDW injectate may
contain primarily soluble ammonium and significant amounts of nitrogen in the organic form (Brown,
1998). According to Tables 2 and 4, the typical raw wastewater from slaughterhouses, shrimp, and
crab processing facilities entering the septic tank contains a lower amount of nitrate and nitrite than the
primary MCL for both of those compounds, which is 10 and 1 mg/1, respectively. Thus, it may be
possible to assume that even if no nitrite or nitrate transformation occurs (which is the case in aerobic
environments), the levels of nitrate and nitrite in the injectate, for these three types of facilities, will also
be below the MCL. However, if ammonia is present in the wastewater, as is shown in the previous
tables, and if an aerobic environment exists in the tank (possible in septic systems where treatment
capacity is being exceeded and flow rates are high), some of the ammonia and organic nitrogen in the
raw wastewater may be oxidized to nitrite and nitrate, and therefore exceedances in the FPWDW
injectate for these two chemical substances may be possible. For additional information on nitrogen
reactions and chemical conversions associated with septic tank treatment, refer to Volume 5 of the
Class V Study, Large-Capacity Septic Systems Information Summary.
As explained above, exceedances of the MCL for nitrate and nitrite are possible under certain
circumstances. However, it is more likely, due to the septic tank conditions, HAL for ammonia of 30
mg/1 is exceeded more frequently at some types of food processing facilities. Once ammonia reaches
September 30, 1999 30
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the upper soil horizons, where oxygen may be more plentiful, it is converted back to the more
dangerous nitrate and nitrite which easily leaches into ground water (Brown, 1998).
Phosphorous may also be present in the wastewaters entering the septic tank. The most likely
originates from either animal manure, blood, or bone. In the anaerobic environments found within the
septic tank, it can be expected that phosphorous will be converted into soluble phosphate ions (Brown,
1998). Because of the slow degradation rate of phosphate ions, USDWs could be affected.
Phosphate ions typically affect the TDS concentration of the wastewater.
Chlorides originating from blood also present the raw wastewater. The degradation or
transformation rates, if any, of chlorides in a septic system are unknown. From Tables 3 and 4 it can
be seen that the chloride concentrations in raw wastewater typically exceed the secondary MCL for
chloride of 250 mg/1. Therefore, if no chlorides are removed in the septic tank, it is possible that
chlorides may be found in the injectate at or above MCLs.
4.5.4 Microbial Components
None of the tables on raw wastewater characteristics presented earlier include any information
on bacteria levels because the documents from which the data were extracted did not include this
information. However, it is very likely that bacteria, and some viruses, are found at varying
concentrations in the raw wastewaters and the injectate. Slaughterhouse injectate will undoubtedly
have the highest concentrations of bacteria in the injectate since certain procedures result in the mixing
of water with fecal material (e.g., washdown from animal pens), blood, and animal body fluids.
Seafood processing facilities will most likely also have a certain amount of bacteria. Because small
amounts of fecal material are present in the raw wastewaters from slaughterhouse and seafood
processing facilities, it is very likely that fecal coliform bacteria are present in the FPWDW injectate.
As stated in Section 4.3.2, bacterial levels in raw slaughterhouse wastewater are in the range of 2 to 4
million per 100 ml. These average levels do exceed the primary MCL for fecal coliform of zero.
According to a USEPA document, the most commonly found harmful bacterial constituents in
slaughterhouse raw wastewaters are the shigella and salmonella bacteria (USEPA, 1974). Of the two,
salmonella is probably the most common bacteria found in raw wastewaters from slaughterhouses since
it is also present in the feces of most animals and sometimes found on the surfaces of food processing
equipment and floors. Salmonella bacteria thrive in wet environments shielded from the sun and have a
remarkable ability to survive under adverse conditions. Salmonella survive between pFfs of 4 to 8, and
can grow under a relatively wide temperature range. Salmonella are facultative anaerobic bacteria that
can survive under low oxygen conditions such as those found in manure slurry pits, and possibly septic
tanks. Due to the general resilience of these bacteria, it is likely that if the raw wastewaters do contain
salmonella, some portion of the salmonella bacteria will most likely exit the septic tank and enter the soil
with the injectate. However, according to one source, "salmonella can survive but may not actively
grow in many environmental waters" (Cornell University, 1997).
September 30, 1999 31
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Though some animal viruses may be found in the raw wastewater entering septic tanks, it is
likely most of those viruses are killed or deactivated due to the unfavorable conditions present in the
septic tank. If for some reason viruses were to be in the injectate, it is unlikely that those viruses will
survive long enough to pose a threat to USDWs.
4.6 FPWDW Construction and Design Characteristics
There are two main categories of FPWDWs: septic systems and drywells. Because septic
systems are the most common types of Class V well employed, the focus of Section 4.6.1 below is on
the design and construction of septic systems. A brief discussion on drywells is provided in Section
4.6.2. For more detailed information on the construction of septic systems, refer to \blume 5 of the
Class V Study, Large-Capacity Septic Systems Information Summary.
4.6.1 Commercial Septic Systems
The commercial septic systems used at food processing facilities closely resemble domestic
septic systems, but instead of being connected to bathrooms and showers, commercial septic systems
are usually connected to floor drains and commercial grade food processing sinks. Also, unlike
domestic systems, most commercial systems are designed to handle large amounts of wastewater, and
some systems have a grease trap installed between the floor drains and the septic tank to collect the
greases and fats that are usually generated during food processing.
Floor Drains, Sinks, and Other Equipment
The pathway by which most of the wastewater enters a FPWDW is through floor drains
located throughout a food processing facility. The number of floor drains in a particular facility
connected to the pipes leading to the commercial-sized septic tank, depends on the size of the facility,
the number of rooms where wastewater is generated, and the quantity of wastewater generated in those
rooms. Based on observations during site visits, food processing facilities using an FPWDW have
approximately 800 to 2000 square feet of plant space. On average 2 to 8 floor drains are placed in the
middle of rooms throughout a facility and a slope of about 1/4 to 1/8 inch per foot is built into the floors
to allow the wastewater to flow toward the floor drain. For USDA-regulated slaughterhouses, it is
recommended that one drain be provided for each 400 square feet of floor area (U.S. Department of
Agriculture, 1986). These floor drains are constructed either of PVC or stainless steel and often have
and inner diameter of approximately 3 to 4.5 inches. The floor drains have removable, perforated drain
covers that are used to prevent the entrance of large solids that could clog up pipes, which the floor
drains are connected to, or the drain lines exiting the septic tank. In some types of drains there is a u-
shaped trap running along the inside of the drain, directly below the cover, which traps any of the larger
solids that manage to pass through the perforated cover. The pipe that is connected to the floor drain
usually drops approximately 2 feet before it bends and connects to another pipe laid in the direction of
the septic tank.
September 30, 1999 32
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The sinks that are connected to commercial septic systems are large stainless steel,
commercial-grade sinks that have u-shaped elbows in the drain pipes to collect solids and to prevent
the release of odors. Most of the sink drains observed during site visits did have perforated covers to
prevent the entrance of larger solids that could clog the drains leading to the septic tanks. Other food
processing equipment that generates wastewater or that requires the use of water may also be
connected directly to drains that lead to septic tanks.
Floor Drain Pipes and Grease Traps
Pipes connected to floor drains are either made out of cast iron, galvanized steel, or PVC and
are laid down in the facility foundation soil at a slight angle to enable the wastewater to flow to the
septic system. Slaughterhouses regulated by the USDA are required to have drain lines made out of
cast iron or galvanized steel. These drain lines must have a minimum diameter of at least four inches
(U.S. Department of Agriculture, 1986). Larger diameter drain pipes may be necessary to handle
wastewater generated from certain eviscerating procedures. Most of the other non-slaughterhouse
food processing facilities visited, such as seafood processing facilities, also had drain lines with a
diameter of least 4 inches. The drain pipes connect to the floor drains or sinks which lead to one main
pipe that runs the length of the facility. The main drain line usually has a sufficient diameter to handle the
wastewater volumes from several floor drains or sinks. At some facilities, specifically those that were
USDA regulated, the main drain lines have vent pipes that lead outside of the facility, to allow for
proper wastewater flow and to prevent the formation of odors.
Some facilities, such as slaughterhouses, opt to install a grease trap on the main drain pipe in
order to collect greases or fats that are generated during particular food processing or preparation steps
(Sorrells, 1999). Grease traps can be placed either inside the facility, but away from the food
processing area, or outside of the facility closer to the septic tank. They are usually rectangular
structures made out of precast concrete with removable covers to allow for periodic cleaning and
removal of grease. The devices range in size from 200 gallons to 500 gallons or more. Grease traps
work by slowing down the flow of hot greasy water and allowing it to cool. As the hot water cools, the
grease and oil separate and float to the top of the trap. The cooler water continues to flow down the
pipe to the septic tank. The grease is trapped by baffles that cover the inlet and outlet of the tank,
preventing grease from flowing out of the trap. Periodically, or when enough grease accumulates on the
water surface, the grease trap is cleaned out or flushed and the grease is removed and disposed of.
Figure 13 shows a schematic of a typical grease trap found at a slaughterhouse or food processing
facility that generates large amounts of grease-laden wastewater.
In addition to the grease trap the main drain line leading to the septic tank may also have clean-
out pipes that lead to the soil surface. These clean-out pipes allow facility owners/operators to access
the main drain line and unplug or clean out the line if necessary. Main drain lines are usually placed
under 1 to 1.5 feet of soil. Figure 14 shows the main drainage line exiting the slaughterhouse facility and
a shallow clean-out access area. Though not discernable in Figure 14, the liquid running along the main
drain line is primarily blood. Blood was entering the tank because, during the slaughter taking place at
that time, no blood collection procedures were being used.
September 30, 1999 33
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Figure 13. Schematic of a Grease Trap
SIDE VIEW
1 CLEAN OUT
*;.:_-•
"ffWI,
•i
n
I
PL
-
INLET OUTLET
BAFFLE BAFFLE
0 '•'•'iV\'- ''•-••• :°
T\T
Source: Reid, 1999
Figure 14. Main Drain Line leading to Septic Tank and Line Cleaning Access Area
September 30, 1999
34
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If constructed properly, floor drain pipe connections and main drain line connections or joints
are fitted with oil resistant compression rings to prevent leaks at the joints (New Hampshire Department
of Environmental Services, 1989).
Septic Tanks and Distribution Boxes
After draining through the floor drains or sinks and flowing through the drain lines to the grease
separator (if installed) and past the clean-out pipe, raw wastewater flows into the upper portion of the
septic tank. The pipe carrying raw effluent is usually placed below the scum line to prevent disruption
of the flow dynamics in the tank and to prevent disruption of the scum layer. Within the septic tank, the
heavier solids in the raw wastewater will separate from the liquids and will settle to the bottom and
become sludge. Some of the lighter solids, such as soap scum or fat, will float to the top of the tank to
form a scum layer. The ceiling of the septic tank also contains baffles that are placed near the inflow
pipe and near the out flow pipe. These baffles work to stabilize the scum layer and hold back the
floating scum from moving past the outlet and into the outflow pipe. The septic tank ceiling also
contains a manhole that allows for pumping of the accumulated sludge and periodic servicing if
necessary. The scum layer that works to form an anaerobic environment, allows facultative anaerobic
bacteria in the tank to break down or digest solids and organic compounds. The remaining liquids then
flow out of the tank through the outflow pipe to a distribution box located in the drainfield. Figure 15
shows a cross-sectional diagram of a typical commercial septic system.
Figure 15. Cross Section of Commercial Septic System
Inlel
From
Facility
Manhole
Cower
Outlet to
Distribution
Box and
Drainfield
Baffles
All of the food processing facilities visited, except one (a sandwich making facility), had two
different septic tanks: one for handling sanitary sewage and the other for handling food processing
wastewater. In some cases, the volume of food processing wastewater generated was large enough to
require use of two separate but connected septic tanks. When two tanks were used, a flow splitter box
September 30, 1999
35
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was installed on the main drain pipe to channel off equal amounts or raw wastewater to each tank.
However, the typical layout observed was one tank connected to one main drain line.
Sizes of septic tanks vary according to the wastewater flow rates and the necessary retention
time to properly treat the wastewater before releasing into the soil. The food processing facilities visited
were using septic tanks of varying sizes that had been installed behind the main facility structure at a
distance of approximately 15 to 30 feet away from the facility wall. The larger slaughterhouses were
using 2000 gallon tanks while some of the smaller facilities were using 750 gallon tanks with dimensions
of approximately 4 feet by 8 feet. For example, for one smaller slaughterhouse in Wyoming, a 900
gallon septic tank was chosen to handle an estimated wastewater flow of 252 gallons per day with a
BOD5 loading of 1.5 pounds per day.
For the most part, commercial septic tanks are constructed out of concrete, have no seams,
and usually have one or two manholes on the top with steel covers. Facility owners/operators usually
decide to install a septic system that has a higher treatment capacity than what is actually required, just
in case larger than expected wastewater flows are generated and to allow for facility expansion. Figure
16 shows one of the larger slaughterhouses that was visited and in the foreground three manhole covers
can be seen. One manhole cover is used to access the smaller septic tank and the other two manholes
are used to access the larger tank that was connected to the smaller tank to achieve sequential
treatment.
Figure 16. Location of Septic Tanks Behind Slaughterhouse and Manhole Covers
i^HtS^^^^^Hfc-^.
Septic tanks are usually installed by digging out the necessary volume of soil and placing the
already constructed septic tank in place and anchoring it to the surrounding soil to avoid shifting. The
septic tank is then covered with approximately one to three feet of top soil. The septic tanks seen in
September 30, 1999
36
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Figure 17 were installed by blasting underlying limestone and laying the tanks within the blasted area.
Little to no top soil existed at this location.
Once the wastewater has been detained in the septic tank for a sufficient period of time, the
partially treated wastewater exits the septic tank through the outflow pipe. The outflow pipe then
carries the wastewater to a simple device called a distribution box. The distribution box serves the
purpose of evenly distributing the volume of wastewater to the drain lines that are attached to the box.
Typically, a distributor box has 4 to 5 evenly spaced outlets connected to drain lines in the drainfield. A
few food processing facilities with two separate septic tanks opted to join the outflow pipes from both
septic tanks so as to have only one pipe leading to the distributor box. The distribution box is usually
made out of concrete, has a small access cover, and is typically buried under a few inches to a few feet
of soil depending on the depth at which the drain lines are laid.
Drainfield and Drain Lines
Once the treated wastewater reaches the distribution box, it is channeled into drain lines that
are laid in the backyard. The bottom of the drain lines are perforated at even intervals. As the
wastewater passes through the drain lines, it exits the lines through the perforations and percolates into
the soil or backfill material that is under the lines. The flow process through the drain lines allows the
partially treated wastewater to be distributed evenly throughout the soil. Drain lines are typically made
of PVC pipe or specially manufactured, large-diameter corrugated plastic tubing with a diameter of 3 to
4 inches. It is common to lay the lines within a rectangular area in the soil with the outermost drain line
forming a rectangular boundary within which the other drain lines are laid in smaller and smaller
rectangles. All the drain lines are usually connected at the ends but some facility owners stated that they
had not connected the ends of the drain lines. Figure 17 shows the drainfield and one approach to
laying out the drain lines.
September 30, 1999 37
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Figure 17. Drainfield and Drain lines Layout
Adapted from: Reid, 1999
The food processing facilities visited had drainfields of varying sizes because the wastewater
flow rates, wastewater compositions, and soil percolation rates were different. However, most facilities
had drainfields measuring approximately 25 to 40 feet in length and 20 to 30 feet in width. One
slaughterhouse in Wyoming has a drainfield measuring 20 by 30 feet which handles the pretreated
wastewater from a 1000 gallon tank. Drainfields are constructed in a variety of ways and with different
soils and/or backfill material. In general, trenches are dug in the top soil according to the arrangement
in which the drain pipes will be laid. Usually, an attempt is made to have the bottom of the drainfield be
at least three feet above the seasonally high water ground water table, or bedrock (Brown, 1998). To
help infiltration, small stones or other similar media is laid at the bottom of trenches. The drain pipes are
then laid on top of the infiltration media and another layer of infiltration media is poured on top of the
drain lines. Typically, drain lines are laid with approximately 5 to 8 feet between them, but spacing
varies according to the design. The original top soil that was removed is then placed over the drain
lines to fill the trenches. In some cases a layer of hay or other similar material is laid on top of the
infiltration trenches and the top soil is then placed on top of the hay. The hay works to prevent the
infiltration media from clogging up with soil particles from the upper layer of top soil. Typically, a few
feet to 5 inches of soil or backfill material is placed on top of the drain lines. In some cases, the site
where the drainfield is placed does not contain enough top soil to construct a proper drainfield with
adequate soil infiltration and subsurface treatment. In these cases, clean backfill, such as soil or sand, is
brought in to raise the level of the soil surface. With a higher volume of soil, trenches of adequate depth
can be built (Minnesota Pollution Control Agency, 1996)
September 30, 1999
38
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Commercial Septic System Permitting and Siting
All of the commercial septic systems that were observed at food processing facilities had been
designed by engineers that had followed the county's environmental or health department standards.
According to a few of the permits obtained from state agencies, counties usually require that a test be
performed prior to installing a commercial septic system. These tests and analyses usually include:
• depth to ground water;
soil infiltration/percolation rate;
setback distance (distance to nearby wells and other structures);
• absorptive capacity of entire drainfield; and
• adequacy of soil type.
If the test results demonstrate that the site is suitable, the septic system is permitted and
installation is allowed. Typically, acceptable percolation rates vary from 2.5 to 3 minutes per inch.
Though little information was obtained verifying that drain lines injected wastewater above the ground
water level, it can be assumed that most if not all the commercial septic systems at food processing
facilities are discharging above the ground water level since they were permitted by the county or state
agency. In designing a commercial septic system, the most important aspect is determining whether the
soils in the drainfield are well drained but yet still retain water long enough to allow for proper
wastewater treatment (Brown, 1998). From conversations with facility owners, it appeared that in
most cases the septic system had been installed properly according to county regulations. However, a
few FPWDWs at particular facilities did not appear to be situated in very suitable areas. For example,
one custom slaughterhouse situated on a hill had installed a septic system and a drain filed on the
backside of the hill which had a severe slope. In addition, according to a state UIC representative that
was on hand, there was very little top soil in that area because of the prevalence of limestone bedrock.
Figure 18 shows the highly sloped hillside where the drainfield had been laid.
September 30, 1999 39
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Figure 18. Sloped Drainfield on Hill with Underlying Karst Geology
•
The danger with laying a drainfield and a septic tank on such a sloped surface is that the
wastewater will flow too quickly through the septic tank and the drain lines to receive adequate
treatment. In addition, once the wastewater reaches the drain lines, there is a very high possibility that
the wastewater will not infiltrate into the soil in a vertical fashion, but will infiltrate horizontally and reach
the surface of the hill where it can flow to surface waters below
4.6.2 Drvwells
Drywells were also observed during the site visits. The drywells seen at one poultry processing
facility were essentially holes in the ground with floor drains covering the entrance. These drywells had
been placed in the middle of the cutting and preparation room and had openings that were
approximately 4 inches wide. According to the facility owners/operators, the wells were approximately
6 feet deep with a layer of gravel on the bottom to aid in the infiltration process. The drywell was
approved by the plumbing code official from the county health department. The well itself seemed to
be constructed of PVC piping. However, the owner was unsure whether the drywell at this facility was
simply a hole in the ground or if it resembled the more common pre-cast concrete drywells. Because
there is no treatment taking place, the wastewater generated at the facility was simply flowing into the
soil below.
4.7 FPWDW Operational Characteristics and Maintenance Aspects
Because FPWDWs are relatively simple devices, the associated operation and maintenance
procedures are also straightforward. One of the most important operational aspects of FPWDWs is
maintaining a correct raw wastewater flow rate. At a typical family-owned slaughterhouse that
slaughters approximately 3 to 4 animals a day, a flow rate of 250 gallons per day can be expected.
September 30, 1999
40
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Approximately 100 gallons of this flow is associated with carcass washing and the remaining 150 are
associated with cleanup for a 400 square foot facility (Wyoming Department of Environmental Quality,
1989). The wastewater flow rates for other types of food processing facilities are not known because
the facility owners did not have information on how much water they were using each month.
However, one can assume that wastewater flow rates for most of these small, food processing facilities
varies from 100 gallons to over 1000 gallons a day.
To keep a commercial septic system from malfunctioning or clogging, the system has to be
periodically cleaned out and the sludges, fats, and sediments from the septic tank have to be removed.
The frequency and type of cleaning varied among the different facilities visited. Some owners/operators
stated that the septic systems were cleaned once a year and others stated they were cleaned out every
four or five months. One shellfish processing facility owner stated that the septic tank onsite was
cleaned out three times a year to remove sand that had settled to the bottom. The sand enters the
wastewater stream since there is sand accumulation in the fresh shellfish brought to the facility. Some
facility owners stated that they had no knowledge of whether their tank or system had been cleaned in
the recent past. Other facility owners/operators stated that their tanks had not been cleaned out for
three or six years. One slaughterhouse operator stated that it was common practice among smaller
custom slaughterhouses to clear the floor drain pipes and septic system of grease and sediment by
injecting very hot water from the hose directly into the floor drain.
Out of the ten facilities visited, three facility owners stated that their septic system had plugged
at one point or another and two other owners stated that their system (including drain lines) had to be
completely cleaned and are in some cases replaced because the system had failed.
One seafood processing facility operator stated that their commercial septic system was severely
malfunctioning due to the high wastewater flow rates and the large quantities of greases and food solids
that were in the wastewater. In addition, the system had been plugging so it was necessary to pump the
septic tank every three weeks to remove the accumulated sludges. This facility processed salmon meat
to produce salmon pate.
Those facility owners that acknowledged they were using grease traps (mostly slaughterhouses)
stated that they frequently cleaned out their grease traps to remove the accumulated greases and fats.
They stated that the grease is simply scraped off the top of the surface of the wastewater and if any
grease remains, hot water is used to temporality dissolve the grease so it can flow out to the septic tank.
Two different facility owners stated that not enough grease was generated in their process to require a
grease trap while another slaughterhouse facility owner acknowledged that a degreaser solution was
sometimes injected into the septic system to dissolve the accumulated grease and prevent backups or
clogging. No further information was provided by the owner as to what type of degreaser was used.
According to one state UIC program representative, one solvent that was occasionally used in rural
areas to break up the accumulated greases in the commercial septic systems was trichloroethylene
(Sorrells, 1999). However, no actual proof of such an event occurring had been documented.
September 30, 1999 41
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5. POTENTIAL AND DOCUMENTED DAMAGE TO USDWs
5.1 Injectate Constituent Properties
The primary constituent properties of concern when assessing the potential for Class V
FPWDWs to adversely affect USDWs are toxicity, persistence, and mobility. The toxicity of a
constituent is the potential of that contaminant to cause adverse health effects if consumed by humans.
Appendix D to the Class V study provides information on the health effects associated with
contaminants found above MCLs or HALs in the injectate of FPWDWs and other Class V wells. As
discussed in Section 4.5, the contaminants that are most likely to be found above primary MCLs or
FIALs in FPWDW injectate are nitrate, nitrite, and possibly total coliform and ammonia. Turbidity and
chloride also have the potential of exceeding secondary MCLs. Because of a lack of sampling data, it
is not possible to confirm that on average these contaminants exceed drinking water standards. Table 6
presents the reference level for these particular contaminants.
Table 6: Reference Levels for Contaminants That Are Likely to
Be Found in FPWDW Injectate
Contaminants
Ammonia
Chloride
Nitrate
Nitrite
Total Coliform
Turbidity
Reference Levels (mg/L)
30
250
10
1
<5%f
Not to Exceed 5 NTUs 1
Level Source
HAL*
Secondary MCL
MCL
MCL
MCLf*
MCL
* Draft as of October 1996, (USEPA, 1998)
f Treatment technique mandates less than 5% positive samples
1 Nepholmetric turbidity units
As stated in Section 4.4.2, high levels of bacteria (2 to 4 million MPN) can be found in the raw
wastewater from some food processing facilities and it is likely that these bacteria are fecal coliforms.
Fecal coliforms are ubiquitous in the environment and generally are not considered harmful, but their
presence in treated drinking water supplies points to deficiencies in either water treatment or in the
water distribution system. The presence of coliforms is an indication that other more harmful
microorganisms also may be present. The MCL for total coliforms is based on sampling results, rather
than a specific density or other quantification, and allows no more than 5.0 percent of samples collected
during a month to be positive for coliforms (USEPA, 1998).
Persistence is the ability of a chemical to remain unchanged in composition, chemical state, and
physical state over time. Appendix E to the Class V study presents published half-lives of common
constituents in fluids released in FPWDW and other Class V wells. All of the values reported in
Appendix E are for ground water. Caution is advised in interpreting these values because ambient
September 30, 1999
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conditions have a significant impact on the persistence of both inorganic and organic compounds.
Appendix E to the Class V study also provides a discussion of mobility of certain constituents found in
the injectate of FPWDW and other Class V wells.
5.2 Observed Impacts
In January of 1998, a private drinking water well owner in Maine reported to state authorities
that a water sample taken from his drinking water well had elevated levels of chloride (1,040 mg/1). At
first, it was believed that the road salt applied by the nearby town of Kennebunk was the source of the
contamination. However, after further sampling and analysis, bromide, at a concentration of 8.57 mg/1,
was detected in the drinking water. This finding eliminated road salt as the source because bromide
was not found in the road salt used by Kennebunk. The presence of bromide indicated that trapped
seawater was probably causing the contamination. After further monitoring well sampling and analysis
and other studies conducted with a terrain conductivity meter, it was determined that the source of the
seawater was a lobster processing facility.
This lobster processing/holding facility was using a large tank full of seawater to hold lobsters
that were still in their traps. Installed around the tank were nine floor drains that were connected to the
facility's septic system. As the lobsters were pulled out of the tank for processing, seawater would fall
to the ground and flow to the floor drains. The facility operators would also washdown the floors of the
facility every day. Throughout the day the floors accumulated large amount of seawater that would also
flow to the floor drains. In addition, the facility owner had in the past sprayed salt water on the facility's
dirt road to keep the dust down.
As a result of allowing large quantities of seawater to enter the septic system, seawater was
exiting the drain lines and infiltrating down to the USDW. Over the years, the USDW became
contaminated with high levels of chloride and detectable levels of bromide. The situation was resolved
when the owner of the lobster processing facility, under the direction of the Maine Department of the
Environment, closed the floor drains leading to the commercial septic system and connected all
remaining drains to the local sewer line.
6. BEST MANAGEMENT PRACTICES
The adoption of BMPs or alternative wastewater management strategies may reduce the risk of
USDW contamination posed by food processing facilities using Class V injection wells. Alternatives to
injection wells, discussed in Section 6.1, include connecting to a publicly-owned treatment works
(POTW), discharging to surface waters via a National Pollution Discharge Elimination System permit
(NPDES), applying the wastes to land, trucking off-site for proper disposal, and closing the well. Most
of the BMPs available to food processing facilities, discussed in Sections 6.2 through 6.4, are aimed at
reducing the rates of water utilization, and as a result, reducing the amounts of wastewater generated.
Many of these BMPs, which integrate basic waste minimization and recycling strategies, are becoming
increasingly important in the food processing industry as a whole and can have significant, beneficial
effects on the nature and quantity of the wastewater (Carawan, 1996b). Unfortunately, most of the
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facility owners/operators who were interviewed during site visits acknowledged that they were not using
any BMPs or pollution prevention methods, except for the few slaughterhouses that were collecting
blood.
6.1 Alternatives to FPWDWs
6.1.1 Discharges to POTW
Discharging wastewaters to POTWs is the most common waste disposal method throughout
the food processing industry, when sewer service is available. It allows for the safe and regulated flow
of wastewaters directly into facilities that are dedicated to handling such types of wastewaters. At
larger food processing facilities that generate wastewater with high BOD5 loadings, pretreatment prior
to discharge is often required to meet local minimum water quality treatment standards and to avoid a
surcharge for excessively dirty water. Pretreatment can include techniques designed to remove fats,
proteins, carbohydrates, and other materials with secondary market value (Walsh and Ray, 1996).
Preatement units also generate sludges that must be disposed of properly. Unfortunately, discharging to
a POTW is an option that the majority of the food processing facilities currently using FPWDWs do not
have since these facilities are located in rural areas that are unsewered.
6.1.2 Discharges Via a NPDES Permit
Another option for some of the larger food processing facilities currently using FPWDWs is to
attempt to obtain an NPDES permit under the Clean Water Act. The permit would then allow food
processing facilities to discharge directly to surface waters. A permit would require monitoring of
pollutant levels and would place limits on the amount of pollutants discharged and the amount of
wastewater discharged. In some cases (e.g., larger slaughterhouses with high BOD5 pollution loads),
the NPDES permit would most probably require installation of a small wastewater treatment unit to
treat the wastewater prior to discharge. As with POTW discharges, it may be necessary to properly
dispose of sludges that accumulate in these pretreatment units (Walsh and Ray, 1996).
6.1.3 Discharges Via Land Application Systems
One alternative strategy that could potentially be used by certain types of food processing
facilities is that of applying wastewater to the land via land application systems. Some food processing
facilities are currently spraying their wastewaters on land where an agricultural crop such as hay or trees
are grown (Walsh and Ray, 1996). The crops utilize the wastewater and the carbohydrates and
nutrients in the wastewater. As with all wastewater disposal methods, land application requires a
permit. The permit in turn often requires monitoring of ground water and limitations on the amounts of
pollutants discharged onto the land (Walsh and Ray, 1996). This alternative would not be suitable for
slaughterhouses due to the potential for pathogens to be transmitted and other associated odor and
aesthetic issues. However, land application could be suitable for those types of food processing
facilities that generate wastewater that is appropriate for crops. Typically, wastewaters suitable for
crop application meet the agronomic needs of the specific crop and contain the appropriate levels of
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nitrogen. Additionally, wastewaters used for land application contain low levels of metals and fecal
coliform. For more information on land application of wastewaters, refer to USEPA biosolids rules in
40 CFR Part 503. Since most of these facilities are located in rural areas, the potential for finding
suitable open land is higher than in more urban areas. For example, in New Hampshire, a land
application strategy was used for the wastewater generated from a food processing facility that
processed honey and maple syrup. This particular facility had been experiencing severe clogging
problems with their septic system (due the high BOD and phosphorus levels in the injectate) because
excessive biological/bacterial mats had formed under the drain lines. After some research, it was
determined that the facility's wastewater could be safely sprayed onto a nearby hayfield (New
Hampshire Department of Environmental Services, 1989).
6.1.4 Wastewater Hauling
Another option for small food processing facilities located in unsewered area is to have their
wastewater collected and transported offsite. This can be accomplished by containing the generated
wastewater in a holding tank and having an authorized wastewater hauler pump the tank and transport
the wastewater to a facility that can adequately treat it (Walsh and Ray, 1996).
6.1.5 Closing
Finally, there is the option of simply closing the FPWDWs found at food processing facilities
and finding an alternative wastewater disposal method, such as the ones described above.
6.2 Waste Audit
Some food processing wastewater specialists recommend that facilities complete wastewater
audits to determine what practices lead to excessive water consumption or wastewater generation
(Powell, 1997). As the first step, owners/operators identify and understand the sources and
destinations of all plant wastes. During this step, all inflows and outflows of water are identified, and the
path of water through the plant is traced from beginning to end. Water meters can be installed
throughout food processing plants to accurately record water use. Once water usage has been fully
documented, the potential sources of waste can be investigated. Often, ineffective equipment,
personnel, and sanitation procedures are the largest waste generators in plants (Powell, 1997). The last
step of the wastewater audit is to sample and characterize the plant's effluent to identify problems
(Powell, 1997).
6.3 Dry Cleanup
Once a waste audit is performed, or even if that step is bypassed, owners/operators can begin
implementing a variety of BMPs that can in the long run work to protect the environment and reduce
costs associated with water utilization. Probably the single most effective method of reducing
wastewater generation rates is to employ dry cleanup methods throughout the facility. The goal of dry
cleanup methods is to attempt to capture all non-liquid waste (e.g., pieces of meat, shells, etc.) and
September 30, 1999 45
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prevent this type of waste from entering the wastewater (Carawan, 1996a). Capturing non-liquid
waste can greatly reduce the BOD5 levels in the wastewater. Michael Powell, from the University of
Georgia, summarized the goals of dry cleanup accurately in the statement "if you don't put product into
the waste stream, you don't have to pay to take it out" (Powell, 1994). Dry cleanup methods can be
adapted to various procedures at food processing facilities and often include taking the following steps:
• installing trays and other devices below tables to collect solid wastes;
• instructing employees to remove dry wastes from the floor and equipment before cleaning with
water;
cleaning and storing dry cleanup tools and utensils separate from regular wet cleanup gear;
• keeping screens on all floor drains at all times; and
• making every effort to contain liquid or wet wastes, thereby reducing the quantities of water
used to washdown dirty areas (Carawan, 1996b).
Dry cleaning alone can cut BOD levels in wastewater by significant amounts (Carawan, and
Stengel, 1996). However, to reap the benefits of dry cleanup, facility owners/operators will have to
train their employees to follow new procedures. In addition to training employees, it is crucial that
managers and owners show an interest in reducing water utilization and work to heighten employee
awareness (Carawan, 1996b). For example at one plant, procedural changes implemented through
employee training resulted in a 33 percent reduction in BOD and a 25 percent reduction in water
utilization at a Maryland dairy processing plant (Carawan and Stengel, 1996). In addition to dry
cleanup procedures, there are other BMPs that can be implemented to minimize water use. These
proven methods include:
• waste minimization training for employees;
rigorous equipment maintenance and monitoring;
• wastewater recycling; and
• use of high-pressure, low-volume cleaning equipment (Carawan and Stengel, 1996).
6.4 Specific BMPs for Slaughterhouses
As with most industries, BMPs within the food processing industry vary according to the type
of end product that is being produced. This section describes specific BMPs and pollution prevention
methods applicable to operations involving the slaughter of animals.
As described above, the meat industry has the capacity of generating significant quantities of
solid waste (in the form of wastes destined for rendering plants) and wastewaters with excessively high
BOD5 levels (World Bank, 1997). Most of the organic load, dissolved solids, and suspended solids in
slaughterhouse wastewater are soluble proteins, solid tissues (blood, flesh, and fat), and debris
(feathers, scales, and slimes) from product processing. Much of this material can be recovered and
sold to external markets (as animal feed or for rendering) or reused within the plant. In addition to
collecting solid wastes for recycling, there are other measures that small slaughterhouses can take to
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reduce the concentration of liquid wastes and the generation of wastes in general. Theses measures
include:
• recovering and processing blood;
allowing up to 7 minutes for blood draining (this lowers the amount of blood found in the
carcass thereby minimizing blood releases during evisceration and meat cutting);
• minimizing water consumption by using taps with automatic shut-offs;
• using high water pressure in hoses (less time required to clean equipment);
preventing solid wastes and concentrated fluids (animal fluids) from entering the wastewater
stream;
• separating cooling waters from process wastewaters and recirculating cooling water;
• instituting dry cleanup procedures prior to wet cleaning;
installing grease traps and screens on main drain lines leading to septic tanks to recover fats and
small solids;
• optimizing the use of detergents and disinfectants in washing water; and
• removing manure from pens in solid form (World Bank, 1997).
If high levels of bacteria are found in the wastewaters leaving the slaughterhouse or in the
FPWDW injectate, facilities could adopt procedures to disinfect wastewaters prior to discharge.
7. CURRENT REGULATORY REQUIREMENTS
Several federal, state, and local programs exist that either directly manage or regulate Class V
FPWDWs. On the federal level, management and regulation of these wells falls primarily under the
UIC program authorized by the Safe Drinking Water Act (SDWA). Some states and localities have
used these authorities, as well as their own authorities, to extend the controls in their areas to address
endemic concerns associated with FPWDWs.
7.1 Federal Programs
7.1.1 SDWA
Class V wells are regulated under the authority of Part C of SDWA. Congress enacted the
SDWA to ensure protection of the quality of drinking water in the United States, and Part C specifically
mandates the regulation of underground injection of fluids through wells. USEPA has promulgated a
series of UIC regulations under this authority. USEPA directly implements these regulations for Class
V wells in 19 states or territories (Alaska, American Samoa, Arizona, California, Colorado, Hawaii,
Indiana, Iowa, Kentucky, Michigan, Minnesota, Montana, New York, Pennsylvania, South Dakota,
Tennessee, Virginia, Virgin Islands, and Washington, DC). USEPA also directly implements all Class
V UIC programs on Tribal lands. In all other states, which are called Primacy States, state agencies
implement the Class V UIC program, with primary enforcement responsibility.
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FPWDWs currently are not subject to any specific regulations tailored just for them, but rather
are subject to the UIC regulations that exist for all Class V wells. Under 40 CFR 144.12(a), owners or
operators of all injection wells, including FPWDWs, 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 the health of persons."
Owners or operators of Class V wells are required to submit basic inventory information under
40 CFR 144.26. When the owner or operator submits inventory information and is operating the well
such that a USDW is not endangered, the operation of the Class V well is authorized by rule.
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.
Sections 144.12(c) and (d) prescribe mandatory and discretionary actions to be taken by the
UIC Program Director if a Class V well is not in compliance with section 144.12(a). Specifically, the
Director must choose between requiring the injector to apply for an individual permit, ordering such
action as closure of the well to prevent endangerment, or taking an enforcement action. Because
FPWDWs (like other kinds of Class V wells) are authorized by rule, they do not have to obtain a
permit unless required to do so by the UIC Program Director under 40 CFR 144.25. Authorization by
rule terminates upon the effective date of a permit issued or upon proper closure of the well.
Separate from the UIC program, the SDWA Amendments of 1996 establish a requirement for
source water assessments. USEPA published guidance describing how the states should carry out a
source water assessment program within the state's boundaries. The final guidance, entitled Source
Water Assessment and Programs Guidance (USEPA 816-R-97-009), was released in August
1997.
State staff must conduct source water assessments that are comprised of three steps. First,
state staff must delineate the boundaries of the assessment areas in the state from which one or more
public drinking water systems receive supplies of drinking water. In delineating these areas, state staff
must use "all reasonably available hydrogeologic information on the sources of the supply of drinking
water in the state and the water flow, recharge, and discharge and any other reliable information as the
state deems necessary to adequately determine such areas." Second, the state staff must identify
contaminants of concern, and for those contaminants, they must inventory significant potential sources
of contamination in delineated source water protection areas. Class V wells, including FPWDWs,
should be considered as part of this source inventory, if present in a given area. Third, the state staff
must "determine the susceptibility of the public water systems in the delineated area to such
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contaminants." State staff should complete all of these steps by May 2003 according to the final
guidance.7
7.1.2 Food and Drug Administration and the Federal Food. Drug and Cosmetic Act
The U.S. national regulatory authority for public protection and seafood regulation is vested in
the Food and Drug Administration (FDA). The FDA operates an oversight compliance program for
fishery products under which responsibility for the product's safety, wholesomeness, identity, and
economic integrity rests with the processor or importer, who must comply with regulations promulgated
under the Federal Food, Drug and Cosmetic (FD&C) Act, as amended, and the Fair Packaging and
Labeling Act. Some states have entered into agreements with the FDA concerning regulatory
oversight of shellfish processing facilities. In these states, FDA provides financial support by contract to
state regulatory agencies for the inspection of food plants, including seafood. Most of the seafood
processing facilities visited for this study were inspected by the state. A few relevant FDA regulations
are summarized and presented below because the process and steps outlined in these regulations can
affect the quantity and quality of wastewater being injected via FPWDWs.
Most FDA in-plant inspections consider product safety, plant/food hygiene and economic fraud
issues, while other inspections address subsets of these compliance concerns. Samples may be taken
during FDA inspections in accordance with the agency's annual compliance programs and operational
plans or because of concerns raised during individual inspections. These analyses are for a vast array
of defects including chemical contaminants, decomposition, net weight, radionuclides, various microbial
pathogens, food and color additives, drugs, pesticides, filth and marine toxins such as Paralytic Shellfish
Poison and domoic acid. FDA conducts both mandatory surveillance and enforcement inspections of
domestic seafood harvesters, growers, wholesalers, warehouses, carriers and processors under the
authority of the FD&C Act.
A more recent FDA program, called the Hazard Analysis and Critical Control Point, or
HACCP, aims to further ensure seafood's safety. This program requires seafood processors,
repackers and warehouses-both domestic and foreign exporters to this country~to follow a modern
food safety system. This system focuses on identifying and preventing hazards that could cause food-
borne illnesses rather than relying on spot-checks of manufacturing processes and random sampling of
finished seafood products to ensure safety. The hazards can involve bacteria, viruses, parasites, natural
toxins, and chemical contaminants.
Also, under FDA's HACCP regulations, seafood companies will have to write and follow basic
sanitation standards that ensure, for example, the use of safe water in food preparation; cleanliness of
food contact surfaces, such as tables, utensils, gloves and employees' clothes; prevention of cross-
contamination; and proper maintenance of hand-washing, hand-sanitizing, and toilet facilities. Some of
these HACCP requirements can end up affecting the quality and quantity of wastewater exiting the
7 May 2003 is the deadline including an 18-month extension.
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facility. This is especially true in areas where there are no local effluent limitations on the wastewater
entering the septic system (above information from U.S. Food and Drug Administration, 1995).
7.1.3 United States Department of Agriculture - The Federal Meat Inspection Act and the
Poultry Products Inspection Act
Most meat and poultry processing facilities are regulated by the USD A, specifically by the
Food Safety and Inspection Service (FSIS). However, many of the slaughterhouse facilities using
FPWDWs that were visited during the development of this study were not inspected by the FSIS, but
by the local county health department (see Section 7.1.4 below). Those facilities falling under the
purview of the USDA are advised to follow specific guidelines regarding the preparation and handling
of food products. Many of these guidelines do have an effect on the quality and quantity of
wastewaters generated. Some of the operational guidelines that affect wastewater quality and quantity
include the use of appropriate cleaning/disinfecting solutions and minimum temperatures for waters used
in rinsing and cleaning equipment.
The USDA also has more detailed guidelines (not enforceable) for slaughterhouses regarding
facility plumbing design and wastewater management. Some of the wastewater management guidelines
specifically address those facilities using Class V wells. These guidelines are found in 62 CFR 164 and
the USDA Agricultural Handbook 570. In general, these guidelines aim to prevent the contamination
of food products through proper design of plumbing systems and proper management of wastewaters.
Specifically, the guidelines state that if a septic system is chosen as the method of handling wastewaters,
it must be designed and operated to conform with all local, state, and USEPA regulations. Also, the
USDA recommends that all parts of a floor where wet operations are conducted, be well drained, and
as a general rule, it is recommended that one drainage inlet be installed for each 400 square feet of floor
area. In addition, the USDA has specific guidelines for slaughterhouses regarding:
• floor drain pipe diameters;
design of floor drains;
accessibility and design of sewer pipes;
• location of wastewater treatment (siting of septic tank); and
• installation of grease traps.
The FSIS also requires that wastewater lines carrying sanitary waste not be connected to
drainage lines within a facility that handles slaughterhouse wastewaters. In other words, if FPWDWs
are being used, two separate septic systems must be installed to handle the different kinds of
wastewater.
In addition to the above guidelines, the FSIS has created a new regulatory system for meat and
poultry safety within the meat and poultry plants it regulates. The new, science-based system has two
major components that directly affect facilities. First, the FSIS is requiring the plants it regulates to
implement Hazard Analysis and Critical Control Points (HACCP) systems as a tool for preventing and
controlling contamination so products meet regulatory standards. Second, the FSIS established food
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safety performance standards that plants must meet and is currently conducting testing and other
activities to ensure those standards are being met. Implementation of HACCP systems allows
regulated slaughterhouses the flexibility to meet the performance standards through a variety of means.
This added flexibility may in turn affect slaughterhouse wastewater generation rates and constituent
levels.
Small plants, defined as having 10 or more employees, but fewer than 500, are required to
implement HACCP by January 25, 1999. "Very small plants (like those most likely to use FPWDWs)
with fewer than 10 employees or annual sales of less than $2.5 million, must implement HACCP by
January 25, 2000 (U.S. Department of Agriculture, 1998).
7.1.4 Exempt Custom Slaughtering Facilities
Many of the slaughterhouses visited during the development of this volume were exempt from
the more stringent regulations found in 9 CFR 303 through 307, providing for inspections conducted by
the FSIS. These facilities were inspected by county health department officials who presumably were
checking for compliance with the regulations for exempt facilities. Specifically, 9 CFR Part 303
exempts custom slaughterhouses that cut, prepare, and package meat exclusively for the individual who
brought the animal to the facility. Part 303 provides that, "the requirements of the Act and the
regulations in this subchapter for inspection of the preparation of products do not apply to the custom
preparation by any person of carcasses, parts thereof, meat or meat food products derived from the
slaughter by any individual of cattle, sheep, swine, or goats of his own raising or from game animals,
delivered by the owner thereof for such custom preparation, and transportation in commerce of such
custom prepared articles, exclusively for use in the household of such owner, by him and members of
his household and his nonpaying guests and employees." However, the custom slaughterhouse still must
abide by some provisions found in 9 CFR Part 308 and other provisions found in 9 CFR Part 316 and
Part 317. For details on the operational requirements for exempt custom slaughtering facilies, refer to
Attachment A of this volume.
7.2 State and Local Programs
As discussed in Section 3, approximately 95 percent of the documented FPWDWs in the
nation exist in four states: Alabama, Maine, New "fork, and West Virginia. Attachment B of this
volume describes in greater detail how these states and six other states currently control FPWDWs.
This section briefly summarizes the key regulatory strategies adopted by the four states with the largest
number of FPWDWs.
Alabama
Alabama, a UIC Primacy state for Class V wells, requires the owner or operator operating of
an existing or proposed Class V well to submit a permit application to the Alabama Department of
Environmental Management (ADEM) (335-6-8-. 14(a)-(e) Alabama Administrative Code). The owner
or operator must provide the following information in the permit application:
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construction plans,
site hydrogeology,
• wastewater characteristics (constituents and physical properties), and
• name of facility and other related information.
ADEM can require further efforts from the owner or operator of the FPWDW in order to
protect USDWs and prevent violations of primary drinking water regulations. If a permit is issued, the
permit typically describes BMPs, and may require monitoring of wastewater and ground water
monitoring. Additionally, the permit may require modifications in the construction plans of the
FPWDW to prevent contamination of the receiving USDW.
Maine
Maine, a UIC Primacy state for Class V wells, requires anyone disposing of waste or
wastewater through a Class V well to obtain a waste discharge license from the Maine Department of
Environmental Protection (DEP). (Title 38, Water Statutes Section 413). A waste discharge license is
also needed for installation, operation, and maintenance of a subsurface wastewater disposal system,
unless the system is designed and installed in conformance with the Maine Subsurface Wastewater
Disposal Rules (144 CMR 241). Typically if subsurface discharges are not licensed under 144 CMR
241, they are ineligible for a wastewater discharge under Section 413.
Maine has categorized food processing wastewater entering FPWDWs as "Fligh Risk" and
therefore the DEP provides the following options to food processing facilities:
seal entrances to FPWDWs (e.g, floor drains),
connect to sewer lines if available,
• install a holding tank and properly dispose of wastewater, or
• separate the facility into two areas where "High Risk" wastewaters can be contained and
treated safely (Department of Environmental Protection - State of Maine, 1998).
Typically, guidance regarding use of BMPs is provided to the owner or operator after a discharge
license has been issued or a subsurface wastewater disposal permit has been approved. BMP
guidance is also offered to the owner or operator during facility inspections.
New \brk
USEPA Region 2 directly implements the UIC program for Class V injection wells in New
York. Region 2 attempts to classify a well in the highest appropriate risk category. Therefore, septic
systems receiving industrial wastes (like some food processing facilities) are classified as industrial wells.
In addition, New York, under the authority of the state's Environmental Conservation Law, requires
that dischargers using FPWDWs obtain permits. These State Pollution Discharge Elimination System
(SPDES) permits specify effluent limitations, monitoring requirements, and schedules of compliance. In
general, industrial wells are not allowed to inject contaminants at concentrations above the MCLs.
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West Virginia
West Virginia, a UIC Primacy state for Class V wells, generally authorizes FPWDWs by rule,
unless the West Virginia Office of Water Resources requires an individual permit (West Virginia Code
of State Regulations Title 47-13). Injection is authorized initially for five years under the permit by rule
provisions. Rule-authorized wells, such as most FPWDWs, are required to meet monitoring schedules.
Facilities must meet MCLs at the point of injection. West Virginia generally prohibits any underground
injection activity that causes or allows the movement of fluid containing any contaminant, if that
contaminant may cause a violation of any primary drinking water standard.
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ATTACHMENT A
OPERATIONAL AND PROCESS REQUIREMENTS FOR EXEMPT CUSTOM
SLAUGHTERHOUSES
Custom slaughterhouses, which are exempt from FSIS inspections, are required to abide by the
following requirements. Those requirements which have the potential of affecting the quantity and
quality of wastewater are listed below:
(1) Manual cleaning and sanitizing:
(A) For manual washing, rinsing and sanitizing of utensils and equipment, a sink with not fewer
than three compartments shall be provided and used. Sink compartments shall be large enough
to permit the accommodation of the equipment and utensils, and each compartment of the sink
shall be supplied with hot and cold potable running water. Fixed equipment and utensils and
equipment too large to be cleaned in sink compartments shall be washed manually or cleaned
through pressure spray methods.
(B) Drain boards or easily movable dish tables of adequate size shall be provided for proper
handling of soiled utensils prior to washing and for cleaned utensils following sanitizing and shall
be located so as not to interfere with the proper use of the dishwashing facilities.
(C) Equipment and utensils shall be preflushed or prescraped and, when necessary, presoaked
to remove gross food particles and soil.
(D) Except for fixed equipment and utensils too large to be cleaned in sink compartments,
manual washing, rinsing and sanitizing shall be conducted in the following sequence: (1) Sinks
shall be cleaned prior to use. (2) Equipment and utensils shall be thoroughly washed in the first
compartment with a hot detergent solution that is kept clean. (3) Equipment and utensils shall be
rinsed free of detergent and abrasives with clean water in the second compartment. (4)
Equipment and utensils shall be sanitized in the third compartment according to one of the
methods prescribed in this section.
(E) The food-contact surfaces of all equipment and utensils shall be sanitized by: (1) Immersion
for at least !/2 minute in clean, hot water at a temperature of at least 170 °F; or (2) Immersion
for at least 1 minute in a clean solution containing at least 50 parts per million of available
chlorine as a hypochlorite and at a temperature of at least 75 °F; or (3) Immersion for at least 1
minute in a clean solution containing at least 12.5 parts per million of available iodine and having
a pH not higher than 5.0 and at a temperature of at least 75 °F; or (4) Immersion in a clean
solution containing any other chemical sanitizing agent allowed under 21 CFR 178.1010 that
will provide the equivalent bactericidal effect of a solution containing at least 50 parts per million
of available chlorine as a hypochlorite at a temperature of at least 75 °F for 1 minute; or (5)
Treatment with steam free from materials or additives other than those specified in 21 CFR
173.310 in the case of equipment too large to sanitize by immersion, but in which steam can be
September 30, 1999 54
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confined; or (6) Rinsing, spraying, or swabbing with a chemical sanitizing solution of at least
twice the strength required for that particular sanitizing solution.
(F) When hot water is used for sanitizing, the following facilities shall be provided and used: (1)
An integral heating device or fixture installed in, on, or under the sanitizing compartment of the
sink capable of maintaining the water at a temperature of at least 170 °F; and (2) A numerically
scaled indicating thermometer, accurate to ± 3 °F, convenient to the sink for frequent checks of
water temperature; and (3) Dish baskets of such size and design to permit complete immersion
of the tableware, kitchenware, and equipment in the hot water.
(G) When chemicals are used for sanitization, they shall not have concentrations higher than the
maximum permitted under 21 CFR 178.1010 and a test kit or other device that accurately
measures the parts per million concentration of the solution shall be provided and used.
(2) Mechanical cleaning and sanitizing:
(A) Cleaning and sanitizing may be done by spray-type or immersion dishwashing machines or
by any other type of machine or device if it is demonstrated that it thoroughly cleans and
sanitizes equipment and utensils. These machines and devices shall be properly installed and
maintained in good repair. Machines and devices shall be operated in accordance with
manufacturers' instructions, and utensils and equipment placed in the machine shall be exposed
to all dishwashing cycles. Automatic detergent dispensers, wetting agent dispensers, and liquid
sanitizer injectors, if any, shall be properly installed and maintained.
(B) The pressure of final rinse water supplied to spray-type dishwashing machines shall not be
less than 15 nor more than 25 pounds per square inch measured in the water line immediately
adjacent to the final rinse control valve. A 1/4-inch IPS valve shall be provided immediately up
stream from the final rinse control valve to permit checking the flow pressure of the final rinse
water.
(C) Machine or water line mounted numerically scaled indicating thermometers, accurate to ± 3
°F, shall be provided to indicate the temperature of the water in each tank of the machine and
the temperature of the final rinse water as it enters the manifold.
(D) Rinse water tanks shall be protected by baffles, curtains, or other effective means to
minimize the entry of wash water into the rinse water. Conveyors in dishwashing machines shall
be accurately timed to assure proper exposure times in wash and rinse cycles in accordance
with manufacturers' specifications attached to the machines.
(E) Drain boards shall be provided and be of adequate size for the proper handling of soiled
utensils prior to washing and of cleaned utensils following sanitization and shall be so located
and constructed as not to interfere with the proper use of the dishwashing facilities. This does
September 30, 1999 55
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not preclude the use of easily movable dish tables for the storage of soiled utensils or the use of
easily movable dish tables for the storage of clean utensils following sanitization.
(F) Equipment and utensils shall be flushed or scraped and, when necessary soaked to remove
gross food particles and soil prior to being washed in a dishwashing machine unless a prewash
cycle is a part of the dishwashing machine operation. Equipment and utensils shall be placed in
racks, trays, or baskets, or on conveyors, in a way that food-contact surfaces are exposed to
the unobstructed application of detergent wash and clean rinse waters and that permits free
draining.
(G) Machines (single-tank, stationary-rack, door-type machines and spray-type glass washers)
using chemicals for sanitization may be used Provided that; (1) The temperature of the wash
water shall not be less than 120 °F. (2) The wash water shall be kept clean. (3) Chemicals
added for sanitization purposes shall be automatically dispensed. (4) Utensils and equipment
shall be exposed to the final chemical sanitizing rinse in accordance with manufacturers'
specifications for time and concentration. (5) The chemical sanitizing rinse water temperature
shall be not less than 75 °F nor less than the temperature specified by the machine's
manufacturer. (6) Chemical sanitizers used shall meet the requirements of 21 CFR 178.1010.
(7) A test kit or other device that accurately measures the parts per million concentration of the
solution shall be available and used.
(H) Machines using hot water for sanitizing may be used provided that wash water and pumped
rinse water shall be kept clean and water shall be maintained at not less than the following
temperatures:
(1) Single-tank, stationary-rack, dual-temperature machine: Wash temperature =150 °F, Final
rinse temperature =180 °F;
(2) Single-tank, stationary-rack, single-temperature machine: Wash temperature =165 °F,
Final rinse temperature = 165 °F;
(3) Single-tank, conveyor machine: Wash temperature =160 °F, Final rinse temperature =180
°F;
(4) Multitank, conveyor machine: Wash temperature =150 °F, Pumped rinse temperature =
160 °F, Final rinse temperature =180 °F; and
(5) Single-tank, pot, pan, and utensil washer (either stationary or moving-rack): Wash
temperature =140 °F, Final rinse temperature = 180 °F.
(I) All dishwashing machines shall be thoroughly cleaned at least once a day or more often
when necessary to maintain them in a satisfactory operating condition (above information from
9 CFR Part 303 - "Exemptions")
September 30, 1999 56
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ATTACHMENT B
STATE AND LOCAL PROGRAM DESCRIPTIONS
This attachment does not describe every state's program; instead it focuses on 10 states where
the majority of the documented FPWDWs are known to exist or where UIC program staff have
estimated that large numbers of FPWDWs may be present: Alabama, Alaska, California, Hawaii,
Maine, New "Vbrk, Oregon, Tennessee, West Virginia, and Wisconsin. The descriptions highlight the
state's definition of FPWDWs, when available, and outline the licensing and other administrative
requirements FPWDWs must satisfy.
Alabama
Alabama is a UIC Primacy state for Class V wells. The Alabama Department of
Environmental Management (ADEM) has promulgated requirements for Class V UIC wells under
Chapter 335 of the Alabama Administrative Code (AAC).
Permitting
The owner/operator of an existing or proposed Class V well must submit a permit application
to ADEM including the following information (335-6-8-. 14(a)-(e) AAC):
facility name and location;
• name of owner and operator;
• legal contact;
• depth, general description, and use of the injection well; and
• description of pollutant injected, including physical and chemical characteristics.
ADEM is required by the AAC to assess the possibility of adverse impact on a USDW posed
by the well, and to determine any special construction and operation requirements that may be required
to protect a USDW (335-6-8-.15(1) AAC). If ADEM determines that the proposed action may have
an adverse impact on a USDW, the applicant may be required to submit a permit application in the
manner prescribed for Class I and Class in wells. When those permit application requirements are
applied, the permit application processing and issuance procedures will follow the rules set forth for
Class I and HI wells (335-6-8-. 15(3) AAC). The AAC specifies that "Class V wells may be allowed
insofar as they do not cause a violation of primary drinking water regulations under 40 CFR Part 142"
(335-6-8-.07 AAC).
Siting and Construction
The AAC specifies that injection wells shall be sited so that they inject into a formation that is
beneath the lowermost USDW located within five miles of the well (335-6-8-.20 AAC). However,
Class V wells are specifically exempted (335-6-S-.25 AAC).
September 30, 1999 57
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Construction requirements also are specified for all injection wells. However, Class V wells are
specifically exempted (335-6-S-.25 AAC). They are required to be constructed in such a manner that
they may not cause a violation in USDWs of primary drinking water regulations under 40 CFR Part
142, and when required by ADEM must be constructed by a well driller licensed by ADEM (335-6-8-
.25 AAC).
Operating Requirements
Class V wells are required to be operated in a manner that may not cause violation of primary
drinking water regulations under 40 CFR 142. ADEM may order the operator to take necessary
actions to prevent violation, including closure of the well (335-6-8-. 16 AAC).
A method of obtaining grab and composite samples of pollutants after all pretreatment and prior
to injection must be provided at all sites. Spill prevention and control measures sufficient to protect
surface and ground water from pollution must be taken at all sites (335-6-S-.22 AAC).
Monitoring requirements may be specified in the permit, by administrative order, by directive,
or included in the plugging and abandonment plan (335-6-8-.2S AAC).
Plugging and Abandonment
A plugging and abandonment plan may be required by permit or administrative order. If
necessary, it may be required to include aquifer cleanup procedures. If pollution of a USDW is
suspected, ground water monitoring may be required after well abandonment (335-6-S-.27 AAC).
Alaska
USEPA Region 10 directly implements the UIC program for Class V injection in Alaska. In
addition, Chapter 72 of the Alaska Administrative Code AAC addresses wastewater disposal to
ground water.
Permitting
Disposal of non-domestic wastewater is subject to restrictions in 18 AAC 072.500, including
review and approval of a non-domestic wastewater system plan by the Alaska Department of
Environmental Conservation.
California
USEPA Region 9 directly implements the UIC program for Class V injection wells in
California. In addition, the California Water Quality Control Act (WQCA) establishes broad
requirements for the coordination and control of water quality in the state, sets up a state Water Quality
Control Board, and divides the state into nine regions, with a Regional Water Quality Control Board
September 30, 1999 58
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that is delegated responsibilities and authorities to coordinate and advance water quality in each region
(Chapter 4 Article 2 WQCA). A Regional Water Quality Control Board can prescribe requirements
for discharges (waste discharge requirements or WDRs) into the waters of the state (13263 WQCA).
These WDRs can apply to injection wells (13263.5 and 13264(b)(3) WQCA). In addition, the
WQCA specifies that no provision of the Act or ruling of the state Board or a Regional Board is a
limitation on the power of a city or county to adopt and enforce additional regulations imposing further
conditions, restrictions, or limitations with respect to the disposal of waste or any other activity which
might degrade the quality of the waters of the state (13002 WQCA).
Permitting
Although the Regional Water Quality Control Boards do not permit injection wells, the WQCA
provides that any person operating, or proposing to operate, an injection well (as defined in §13051
WQCA) must file a report of the discharge, containing the information required by the Regional Board,
with the appropriate Regional Board (13260(a)(3) WQCA). Furthermore, the Regional Board, after
any necessary hearing, may prescribe requirements concerning the nature of any proposed discharge,
existing discharge, or material change in an existing discharge to implement any relevant regional water
quality control plans. The requirements also must take into account the beneficial uses to be protected,
the water quality objectives reasonably required for that purpose, other waste discharges, and the
factors that the WQCA requires the Regional Boards to take into account in developing water quality
objectives, which are specified in §13241 of the WQCA ((13263(a) WQCA). However, a Regional
Board may waive the requirements in 13260(a) and 13253(a) as to a specific discharge or a specific
type of discharge where the waiver is not against the public interest (13269(a) WQCA).
California counties take a variety of approaches to regulation of food processing and similar
types of wells. For example, Yolo County regulates these wells under the Yolo County Water Quality
Ordinance Sections 6-8.101-6.8.1301. Other counties prohibit these wells. For example, Merced
County prohibits wells from receiving waste from food processing disposal as well as other types of
disposal. Santa Clara Valley Water District also forbids these wells. Glenn County notes that it is very
unlikely that the County would permit the construction of any industrial waste disposal well. Riverside
County applies the requirements in their Plumbing Code and considers flow, soil type, and depth of
ground water in determining whether to approve wells.
Hawaii
USEPA Region 9 directly implements the UIC program for Class V injection wells in Hawaii.
In addition, Chapter 23 of Title 11 of the Hawaii Administrative Rules (HAR), effective July 6, 1984,
amended November 12, 1992, establishes a state UIC program. This program groups Class V wells
for purposes of permitting into 6 subclasses. The subclasses, however, do not specifically address food
processing wells (ll-23-06(b)(3) HAR).
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Permitting
Underground injection through a Class V well is prohibited except as authorized by permit. A
permit for injection into USDW is based on evaluation of the contamination potential of the local water
quality by the injection fluids and the water development potential for public or private consumption.
Permits are issued not to exceed five years. Permit applications must include specified information,
including location, description, and operating plans (11-23-12, 11-23-13, and 11-23-16 HAR).
Siting and Construction
Wells are required to be sited beyond an area that extends at least one-quarter mile from any
part of a drinking water source, including not only the surface expression of the water supply well,
tunnel, or spring, but also all portions of the subsurface collection system (the UIC line).
Special buffer zones are required if the well is located in a caprock formation that overlies a volcanic
USDW under artesian pressure (11-23-10 HAR).
No injection well may be constructed unless a permit application has been made and the
construction has been approved. Construction standards for each type of well are not specified, due to
the variety of injection wells and their uses. If large voids such as lava tubes or solution cavities are
encountered, special measures must be taken to prevent unacceptable migration of the injected fluids
(11-23-09 HAR).
Operating Requirements
A Class V well may not be operated in a manner that allows the movement of fluid containing a
contaminant into a USDW, if the presence of that contaminant may cause a violation of any national or
state primary drinking water rule or otherwise adversely affect the health of one or more persons. All
wells must be operated in such a manner that they do not violate any rules under Title 11 HAR
regulating water quality and pollution, including Chapter 11-20, relating to potable water systems,
Chapter 11-62, relating to wastewater systems, and Chapter 11-55, relating to water pollution control.
The state may also impose other limitations on quantity and quality of injectate as deemed appropriate.
An operator may be ordered to take such actions as may be necessary to prevent a violation of primary
drinking water standards, including cessation of operations (11-23-11 HAR).
Monitoring Requirements
Operating records generally are required for wells, including the type and quantity of injected
fluids and the method and rate of injection (11-23-12 HAR). The operator of an injection well must
keep detailed records of the operation, including but not limited to the type and quantity of fluids, and
method and rate of injection per well (11-23-18 HAR).
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Plugging and Abandonment
An operator wishing to abandon a well must submit an application, and the well must be
plugged in a manner that will not allow detrimental movement of fluids between formations (11-23-19
HAR).
Maine
Maine is a UIC Primacy State for Class V wells. The Maine Department of Environmental
Protection administers the UIC program, with support from EPA Region 1. Title 38 of the Maine
Revised Statutes Annotated (MRSA) establishes, among other programs, the state's ground water
protection program (38 MRSA §§ 401-404), pollution control program, including waste discharge
licensing provisions (38 MRSA §413), and ground water classification standards (38 MRSA §465-C).
Rules controlling the subsurface discharge of pollutants by well injection implemented by the
Department of Environmental Protection are found in 06 Code of Maine Regulations (CMR) Chapter
543.
Permitting
The rules controlling subsurface discharge of pollutants by well injection provide that all
subsurface discharges of fluids into or through a well are prohibited except as authorized in accordance
with the rules. The state recognizes five classes of wells, reflecting the definitions adopted by the
federal UIC program. Any subsurface discharge into or through a Class V well that would cause or
allow the movement of fluid into an USDW that may result in a violation of any Maine Primary Drinking
Water Standard, or which could otherwise advsersely affect human health, is prohibited (06-
096.543.3.D CMR). (The state designates ground water as either Class GW-A, for use as public
drinking water supplies or Class GW-B for uses other than drinking water supplies. However, no
ground water to date has been classified as GW-B. The Primary Drinking Water Standards are set
forth in Department of Human Services rules in 10-144 A CMR 231.)
Class V wells must obtain a waste discharge license issued under 38 MRSA §413 (1-B) prior
to the commencement of the discharge. Specifically 06-096.543.4.B CMR, which implements 38
MRSA §413, states that for Class V wells, "Discharges of fluids into or through Class V wells may be
maintained, provided that (1) a waste therefor is issued by the Board (of Regulations) prior to
commencement of the discharge (or it is determined by the Board that the proposed discharge is
beyond the waste discharging licensing jurisdiction), and (2) any other applicable statutes and
regulations administered by the Board are satisfied, including the requirements of Section (3) D of these
regulations". Section (3) D refers to the prohibition against violating Maine Drinking Water Standards
described in the previous paragraph.
However, there are exceptions to the discharge license requirements of 38 MRSA §413 (1-B).
According to a publication titled "DEP Issue Profile - Underground Injection Control Program"
developed by the State of Maine DEP in June of 1998, "a license is not required for those Class V
September 30, 1999 61
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wells which discharge to a subsurface waste water disposal (septic) system permitted, designed and
installed in conformance with the Maine Subsurface Waste Water Disposal Rules (144A CMR 241)
and used solely for the discharge of waste water". 144 CMR 241 governs the siting, design,
construction and inspection of subsurface waste water disposal systems in order to protect the health,
safety and welfare of the citizens of Maine. According to the introductory language in 144 CMR 241,
"These rules provide minimum State design criteria for subsurface wastewater disposal to assure
environmental sanitation and safety". In 144 CMR 241 waste water is defined as, "... any domestic
waste water, or other waste water from commercial, industrial or residential sources of which is similar
in quality (both constituents and strength) to that of domestic wastewater". The definition continues
with, "domestic waste water is any waste water produced by ordinary living uses, including liquid waste
containing animal or vegetable matter in suspension or solution, or the water-carried waste from the
discharge of water closets, laundry tubs, washing machines, sinks, dish washers, or other source of
water-carried wastes of human origin".
Class V wells also can be redesignated or subject to additional regulatory requirements. Any
Class V well receiving toxic or hazardous compounds is redesignated as a Class IV well and, as such,
is prohibited. The rules controlling the subsurface discharge of pollutants also note that the Maine
Hazardous Waste, Septage, and Solid Waste Management Act (38 MRSA § 1301 et seq.) or the Site
Location of Development Act (38 MRSA § 481 et seq.,) could apply to certain Class V wells.
New \brk
USEPA Region 2 directly implements the UIC program for Class V injection wells in New
York. However, under the state's Environmental Conservation Law, the Department of Environmental
Conservation, Division of Water Resources (DWR) has promulgated regulations in the state Code
Rules and Regulations, Title 6, Chapter X, Parts 703, 750 -758 that establish water quality standards
and effluent limitations and create a state pollutant discharge elimination system requiring permits for
discharges into the waters of the state. Such discharges must comply with the standards in Part 703,
and must be monitored in accordance with requirements in Part 756.
Permitting
Applications for a State Pollution Discharge Elimination System (SPDES) permit must be
submitted on a required form, describe the proposed discharge, supply such other information as the
DWR requests, and are subject to public notice (751.1 DWR). SPDES permits must ensure
compliance with effluent limitations and standards, and will include schedules of compliance, monitoring
requirements, and records and reports of activities (Parts 751 - 756).
Operating Requirements
Effluent limits (Part 703) in the SPDES permit must be met. Monitoring and reporting
requirements in the SPDES permit must be met (756.1 DWR).
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Plugging and Abandonment
Not specified by statute or regulations.
Oregon
Oregon is a UIC Primacy state for Class V wells. The UIC program is administered by the
Department of Environmental Quality (DEQ). Under the state's Administrative Rules (OAR) pertaining
to underground injection, a "waste disposal well" is defined as any bored, drilled, driven or dug hole,
whose depth is greater than its largest surface dimension, which is used or is intended to be used for
disposal of sewage, industrial, agricultural, or other wastes and includes drain holes, drywells, cesspools
and seepage pits, along with other underground injection wells (340-044-0005(22) OAR).
Construction and operation of a waste disposal well without a water pollution control facility (WPCF)
permit is prohibited. Certain categories of wells are prohibited entirely, including wells used for
underground injection activities that allow the movement of fluids into a USDW if such fluids may cause
a violation of any primary drinking water regulation or otherwise create a public health hazard or have
the potential to cause significant degradation of public waters.
Permitting
Any underground injection activity that may cause, or tend to cause, pollution of ground water
must be approved by the DEQ, in addition to any other permits or approvals required by other federal,
state, or local agencies (340-044-0055 OAR). Permits are not to be issued for construction,
maintenance, or use of waste disposal wells where any other treatment or disposal method which
affords better protection of public health or water resources is reasonably available or possible (340-
044-0030 OAR). A waste disposal well, if not absolutely prohibited, must obtain a WPCF permit
(340-044-0035 OAR, 340-045-0015 OAR).
Siting and Construction
Permits for construction or use of waste disposal wells include minimum conditions relating to
their location, construction, and use necessary to prevent migration of fluids into a USDW (340-044-
0035 OAR).
Abandonment and Plugging
Upon discontinuance of use or abandonment, a waste disposal well is required to be rendered
completely inoperable by plugging and sealing the hole. All portions of the well which are surrounded
by "solid wall" formation must be plugged and filled with cement grout or concrete. The top portion of
the well must be effectively sealed with cement grout or concrete to a depth of at least 18 feet below
the surface of the ground, or if this method of sealing is not effective by a manner approved by the DEQ
(640-044-0040 OAR).
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Tennessee
USEPA Region 4 directly implements the UIC program for Class V injection well in
Tennessee. However, the state has enacted a regulation addressing underground injection in Section
1200-4-6-.01 of the Administrative Code (TAG) pursuant to the state's Water Quality Control Act.
The statute protects all waters of the state, including ground water. Although the rules do not explicitly
address food processing wells, the rule defines Class V wells as those that are not Class I, II, m, or IV
(1200-4-6.06(5)0) TAC).
Permitting
Under the Tennessee rules, construction and operation of an injection well is prohibited unless
authorized by an injection well permit or by a rule of the Tennessee Department of Environment and
Conservation (DE&C) (1200-4-6.03 TAC). No permit may be issued or authorization by rule allowed
where an injection well causes or allows the movement of fluid containing any contaminant that would
result in the pollution of ground water. A permit or authorization by rule must include terms and
conditions reasonably necessary to protect ground water classified pursuant to 1200-4-6.05(1) from
pollution (1200-4-6.04(1) TAC). Injection into Class V wells generally is authorized by rule, subject
to compliance and demonstration of mechanical integrity (1200-4-6.07 TAC).
A permit application must provide identification information and list all permits or construction
approvals received or applied for under the UIC program under federal or state law. It must provide a
topographic map extending one mile beyond the property boundary, describe each well where fluids
are injected, and also wells, springs, surface water bodies, and drinking water wells within a quarter
mile of the facility property boundary (1200-4-6-08 TAC).
Siting and Construction
The variety of wells and uses preclude specific construction standards. A well must be
designed and constructed for its intended use, in accordance with good engineering practices, and the
design and construction must be approved by the DE&C. Wells must be constructed so that their
intended use does not violate the water quality standards (1200-4-6-.14(7) TAC).
Operating Requirements
Wells are required to be operated in such a manner that they do not present a hazard to ground
water classified in the state (1200-4-6-. 14(8) TAC). The well operator is required to monitor injection
fluids, injection operations, and local ground water supplies in accordance with monitoring requirements
determined by the type of well, nature of the injected fluid, and water quality of the receiving aquifer
(91200-4-6-. 14(9) TAC).
September 30, 1999 64
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Plugging and Abandonment
The DE&C must approve a proposed plugging method and type of cement. Plugging may be
carried out by any recognized method that is acceptable to DE&C (1200-4-6-. 14(11) TAG). Within
90 days after completion of plugging, the permittee shall provide the DE&C documentation that the well
has been adequately plugged and abandoned (1200-4-6-.14(9)).
West Virginia
West Virginia is a UIC Primacy state for Class V wells. Regulations establishing the UIC
program are found in Title 47-13 West Virginia Administrative Code (WVAC) of state Regulations.
The state does not identify a separate category of Class V industrial wells, but does specify that Class
V includes injection wells not included in Classes I, n, HI, or IV (47-13-3.4.5. WVAC).
Permitting
Class V injection wells are authorized by rule unless the Office of Water Resources of the
Division of Environmental Protection requires an individual permit (47-13-12.4.a. and 47-13-13.2
WVAC). Injection is authorized initially for five years under the authorization by rule provisions.
Operating Requirements
Owners or operators of Class V wells are required to submit inventory information describing
the well, including its construction features, the nature and volume of injected fluids, alternative means of
disposal, the environmental and economic consequences of well disposal and its alternatives, operation
status, and location and ownership information (47-13-12.2 WVAC).
Rule-authorized wells must meet the requirements for monitoring and records (requiring
retention of records pursuant to 47-13-13.6.b. WVAC concerning the nature and composition of
injected fluids until 3 years after completion of plugging and abandonment); immediate reporting of
information indicating that any contaminant may cause an endangerment to USDWs or any malfunction
of the injection system that might cause fluid migration into or between USDWs; and prior notice of
abandonment (47-13-13.6 WVAC).
The rules enact a general prohibition against any underground injection activity that causes or
allows the movement of fluid containing any contaminant into USDW, if the presence of that
contaminant may cause a violation of any primary drinking water regulations under 40 CFR Part 142 or
promulgated under the West Virginia Code or may adversely affect the health of persons. If at any time
a Class V well may cause a violation of the primary drinking water rules the well may be required to
obtain a permit or take such other action, including closure, that will prevent the violation (47-13-13.1
WVAC). Inventory requirements for Class V wells include information regarding pollutant loads and
schedules for attaining compliance with water quality standards (47-13-13.2.d.l WVAC).
September 30, 1999 65
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If protection of a USDW is required, the injection operation may be required to satisfy
requirements, such as for corrective action, monitoring, and reporting, or operation, that are not
contained in the UIC rules (47-13-13.2.C.1.C. WVAC).
Plugging and Abandonment
A Class V well required to obtain an individual permit will be subject to permit conditions
pertaining to plugging and abandonment to ensure that the plugging and abandonment of the well will
not allow the movement of fluids either into a USDW or from one USDW to another. A plan for
plugging and abandonment will be required (47-13-7(f) WVAC).
Wisconsin
Wisconsin is a UIC Primacy state for Class V wells. The Department of Natural Resources
(DNR) has promulgated regulations in Chapter 812 of the Natural Resources Administrative Code
pertaining to well construction. They prohibit injection except in limited cases:
"The use of any well, drillhole, or water system for the underground placement of any waste,
surface or subsurface water or any substance ... is prohibited unless the placement is a
department-approved activity necessary for remediation of contaminated soil, ground water, or
an aquifer (NR 812.05).
Permitting
DNR regulations establish the requirements for discharge permits to discharge from a point
source, including a well, to the waters of the state, including ground waters (NR Chapter 200). The list
of exclusions from the discharge prohibition does not include food processing wells (NR 200.03(3)).
September 30, 1999 66
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New Hampshire Department of Environmental Services. 1989. Class V Injection Well Notification
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