United States       Office of Ground Water      EPA/816-R-99-014g
Environmental       and Drinking Water (4601)    September 1999
Protection Agency
The Class V Underground Injection
Control Study
Volume 7

Sewage Treatment Effluent Wells

-------
                                   Table of Contents
                                                                                       Page

1.     Summary	  1

2.     Introduction	  4

3.     Prevalence of Wells	  5

4.     Sewage Treatment Effluent Characteristics and Injection Practices	  12
       4.1    Injectate Characteristics	  12
              4.1.1   Overview of Injectate Quality	  13
              4.1.2   Inorganic Constituent Concentrations 	  30
              4.1.3   Biological Constituents	  32
              4.1.4   Organic Constituents 	  33
       4.2    Well Characteristics	  34
       4.3    Operational Practices	  47

5.     Potential and Documented Damage to USDWs  	  74
       5.1    Injectate Constituent Properties  	  74
       5.2    Observed Impacts	  78

6.     Best Management Practices	  83
       6.1    Injection Well Siting, Construction, and Design  	  84
              6.1.1   Well Siting and Construction Criteria 	  84
              6.1.2   Well Design Criteria	  85
              6.1.3   Siting and Design for ASR Wells  	  85
       6.2    Injection Well Operation and Maintenance	  86
              6.2.1   Operation and Maintenance	  86
              6.2.2   Well Cleaning and Rehabilitation	  87
              6.2.3   Emergency Response	  87
       6.3    Injectate Treatment 	  87
              6.3.1   Denitrification	  87
              6.3.2   MicrobialRemoval	  88
       6.4    Chlorine Use Reduction	  88

7.     Current Regulatory Requirements	  89
       7.1    Federal Programs	  89
              7.1.1   SDWA  	  89
              7.1.2   CWA  	  91
       7.2    State and Local Programs  	  91

Attachment A: State and Local Program Descriptions	  95
References	 116

-------
                 SEWAGE TREATMENT EFFLUENT WELLS
       The U.S. Environmental Protection Agency (USEPA) has conducted a study of Class V
underground injection wells to develop background information the Agency can use to evaluate the risk
that these wells may 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 22 categories of
wells that were studied (Volume 21 covers two well categories). This volume, which is Volume 7,
covers sewage treatment effluent disposal wells.

1.     SUMMARY

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

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

       Approximately 42 percent of the documented sewage treatment effluent wells are located  in
Florida, and approximately 700 of these wells (35 percent of the total documented inventory) are
located in the Florida Keys and inject into shallow (<50 feet) aquifers that are of extremely poor quality
and that are not likely to be used as sources of drinking water. Approximately  26 percent of the total
documented well inventory are located in California. Other sewage treatment wells in Florida, Arizona,
and other states, are used to inject treated wastewater effluent for  aquifer recharge, and may be

                                                                                           1

-------
injecting into aquifers of drinking water quality. Nearly 19 percent of the documented wells are located
in Hawaii. Hawaii UIC regulations do not allow operation of sewage treatment effluent wells within one
quarter mile of a drinking water source, and it is anticipated that many of these wells inject into aquifers
that are not of drinking water quality. No data were provided by survey respondents concerning the
characteristics of injection zones for other states where sewage treatment effluent wells are currently
operated.

       Several studies and incidents have shown that sewage treatment effluent wells may have
contributed to or caused ground water or surface water contamination.  One study showed nitrate
contamination of onsite ground water at a sewage treatment effluent site in New Hampshire where both
primary treated effluent and septage were released into a leach field. Two sewage treatment effluent
wells on the Island of Maui, Hawaii were thought to be causing surface water contamination through
migration of nitrates in the injectate to surface water bodies.  One of these wells has been shut down
and the other is the subject of an ongoing enforcement action by USEPA. The U.S. Geological Survey
is conducting a long-term study of the operation of sewage treatment effluent wells in the Florida Keys
to assess whether migration of nitrates from injectate is contributing to surface water contamination.

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

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

       Considering that sewage treatment effluent wells are associated with either publicly or privately
owned wastewater treatment plants that are generally required to have operating permits, the inventory
of sewage treatment effluent wells is considered to be relatively accurate compared with other injection
well categories for which wells do not always receive permits.  Nevertheless, there may be a somewhat
larger or smaller number of sewage treatment effluent wells than these results suggest. For example,
New Hampshire did not report any sewage treatment effluent wells in the state in its survey response;
however, two facilities that inject treated effluent into subsurface disposal units, classified as injection

-------
wells for the purpose of this report, were identified through field visits.  Conversely, Maine initially
identified 168 sewage treatment effluent wells in its survey response; however, further investigation
revealed that these facilities are discharging untreated wastewater effluent to subsurface disposal units
and are therefore classified as large-capacity septic systems and not as sewage treatment effluent wells.
Although no state UIC programs other than Maine and New Hampshire are known to have
miscategorized sewage treatment effluent wells, if other states have done so, the reported inventory may
either overestimate or underestimate the true number of sewage treatment effluent wells in the U.S.

        States with the majority of sewage treatment effluent wells have developed and implemented
regulatory programs to permit these wells. Specifically:

•      In Florida, sewage treatment effluent wells are required to have individual permits and to meet
       MCLs.

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

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

•      California requires sewage treatment effluent wells to obtain individual permits.

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

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

       These state regulatory programs are supplemented by regulatory standards and guidelines that
apply to the operation of municipal wastewater treatment plants under the authority of the Clean Water
Act and associated state regulations.  BMPs for wastewater treatment plants have also been

-------
established by USEPA under the Clean Water Act. These BMPs are equally appropriate for treatment
plants that discharge to surface water and those that discharge (inject) into ground water.

2.      INTRODUCTION

        The existing UIC Program regulations in 40 CFR 146.5 do not include a definition of sewage
treatment effluent disposal wells. However, USEPA's 1987Report to Congress (RTC) on Class V
Injection Wells defined such wells as those that are intended to "dispose of the effluent from
wastewater treatment plants by injecting the wastewater into or above USDWs" (USEPA,  1987).
According to the RTC, sewage treatment effluent wells are separate and distinct from aquifer recharge
and salt water intrusion barrier wells, even though aquifer recharge wells and salt water intrusion barrier
wells may inject treated wastewater effluent (USEPA, 1987). This study maintains this distinction,
discussing sewage treatment effluent wells in Volume 7, salt water intrusion barrier wells in Volume 20,
and aquifer recharge and aquifer storage and recovery wells in Volume 21.  Wells that inject solely
sewage treatment effluent are discussed in this volume, even if one of the purposes of the wells is to
provide a salt water intrusion barrier, to recharge an aquifier, or for aquifer storage and recovery.
Therefore, six aquifer storage and recovery well systems that are proposed to inject solely treated
effluent are discussed in this volume, and are not discussed in Volume 21.  On the other hand, wells that
inject sewage treatment effluent mixed with other waters for these other purposes are discussed in
either Volume 20 or 21.

        The definition of "well" includes not only what is generally thought of as a well (i.e.,  a bored,
drilled, or driven shaft) but also "improved sinkholes" and subsurface fluid distribution systems.
Therefore, leach fields and sinkholes used for subsurface disposal of treated effluent are also within the
scope of this study (after Deuerling, 1999).  Further, both publicly owned treatment works (POTWs)
and privately owned treatment facilities receiving solely sanitary waste are addressed in this volume.1
Wells used to inject effluent from a privately owned treatment facility that receives industrial waste,
however, qualify as industrial wells. In addition, wells that inject sewage treatment effluent beneath the
lowermost formation containing a USDW qualify as Class I injection wells rather than Class  V wells
(this study examines only wells that release sewage treatment effluent into or above USDWs). Finally,
large-capacity septic systems that dispose of sanitary waste from multiple dwellings business
establishments are addressed separately in Volume 5, and dry wells used to dispose of raw  (untreated)
sanitary waste are classified as cesspools, which are being addressed in an initial UIC rulemaking on
known high-risk Class V wells.

        Since freshwater can be a costly and limited resource, more communities, especially those in
arid regions of the U.S., are trying to derive some secondary benefits from treated wastewater effluent.
        1 Sanitary waste means liquid or solid waste originating solely from humans and human activities,
such as wastes collected from toilets, showers, wash basins, sinks used for cleaning domestic areas, sinks
used for food preparation, clothes washing operations, and sinks or washing machines when food and
beverage serving dishes, glasses, and utensils are cleaned.

-------
Most sewage treatment effluent wells are designed to also aid in aquifer recharge, subsidence control,
or maintenance of a salt water intrusion barrier (Greeley and Hansen, 1991; Miller, 1991; Mills, 1991;
O'Hare et. al, 1986; USEPA, 1987; Dellinger, 1997).  The use of Class V injection wells that are
designed exclusively for the purpose of sewage treatment effluent disposal appears to be limited.

3.     PREVALENCE OF WELLS

       For this study, data on the number of Class V sewage treatment effluent wells 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 number of Class V sewage treatment
effluent wells in each state, as determined from this survey. The table includes the documented and
estimated number of sewage treatment effluent 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
sewage treatment effluent wells.

       As shown in this table, a total of 1,675 documented Class V sewage treatment effluent injection
wells were reported in 15 of the UIC programs surveyed.  In addition to these documented wells,
USEPA Region 2  estimated less than 50 sewage treatment effluent wells in New York. Oregon UIC
program estimated three sewage treatment effluent wells, and five UIC programs said that the true
number of sewage treatment effluent wells in their states is unknown. The total estimated number of
wells in the U.S. is greater than 1,739.

       Because most Class V sewage treatment effluent wells programs require operating permits, this
inventory information is considered relatively accurate when compared with the inventories for other
types of Class V wells that are not regularly permitted (e.g., agricultural drainage wells). The true
number, however,  may be higher or lower than that shown in Table  1. For example, the total national
inventory may be higher if some of the salt water intrusion barrier wells in New York, New Jersey,
Florida, and Washington are in fact injecting only sewage treatment effluent (these wells are counted as
salt water intrusion barrier wells in Volume 20 because the UIC programs did not indicate whether any
of the wells are injecting treated effluent). Conversely, the total national inventory may be lower if some
programs incorrectly counted large-capacity septic systems as sewage treatment effluent wells.  While
no states are known to have done so, for the final inventory shown in Table 1, the State of Maine
originally classified 168 large capacity septic systems as sewage treatment effluent wells.

       Similarly, competing factors may change the number of sewage treatment effluent wells in the
future.  In particular, the number of wells may decrease as more industrial facilities are able to discharge
their sanitary wastes into municipal sewer systems. Conversely, the number of wells may increase as
sewage treatment effluent is used more broadly for other purposes. The State of Washington has
recently authorized the injection of tertiary treated effluent for aquifer storage and recovery (ASR) on a
pilot basis.  The Washington UIC program indicated that to

-------
Table 1. Inventory of Sewage Treatment Effluent Wells in the U.S.
State
Documented
Number of Wells
Estimated Total Number of Wells-
Number
Source of Estimate and Methodology
USEPA Region 1
NH
MA
ME
29
105
0
unknown
105
0
Information collected by USEPA on two sewage treatment facilities
during 1999 field visits to the New Hampshire Department of
Environmental Services.
Telephone conversation with Ms. Mary Beth Costello, Massachus
Department of Environmental Protection, Bureau of Resource
Protection (Costello, 1999).
Mark Hyland of the Maine Department of Environmental Protectioi
reported that the original estimate of 168 sewage treatment effluent
wells reported in the Maine UIC program survey response were
actually large-capacity septic systems; no sewage treatment effluer
wells exist in Maine (Hyland, 1999).
USEPA Region 2
NY
PR
0
0
<50"
unknown
Best professional judgement of USEPA Region 2.
Territorial UIC program and USEPA Region 2 indicated in the survc
that treatment effluent wells exist in Puerto Rico, but none are
documented and no estimate is available.
USEPA Region 3
WV
9
9
Permit program data.
USEPA Region 4
FL
KY
830=
NR
830=
unknown
Permit program data and telephone conversation with Richard Deue
with the Florida Department of Environmental Protection in
Tallahassee, Florida (Deuerling, 1999).
State officials indicated that these wells do exist in Kentucky, but tl
Kentucky UIC program did not complete the survey, and no
information is available concerning the number or location of such \
in the state (Goodman, 1999).
USEPA Region 5
MI
OH
WI
0
8
3
11
8
3
USEPA Region 5 estimate.
Data from Local Health Departments, UIC program inspections, anc
conversations with personnel from Ohio EPA District Offices, as
reported in the survey response by Ohio EPA.
Surveys conducted by Wisconsin Department of Natural Resource
1989 and 1996.
:ttS
t
y
rling
e
'ells
i in

-------
               Table 1. Inventory of Sewage Treatment Effluent Wells in the U.S.
State
Tribal
Program
Documented
Number of Wells
NR
Estimated Total Number of Wells"
Number
NR
Source of Estimate and Methodology
NA
USEPA Region 6
TX
10
10
Telephone conversation with Steve Musick, Texas Natural Resourt
Conservation Commission, Ground Water Assessment Section, W;
Quality Division (Musick, 1999).
USEPA Region 7
NE
1
Unknown
Permit program data. The Nebraska UIC program reported that it d(
not have the resources available to prepare an estimate of the numl
undocumented wells in the state.
USEPA Region 8
WY
8
8
Permit program data.
USEPA Region 9
AZ
CA
HI
79
205
378
79
unknown
378
Best professional judgement of the Arizona UIC program.
Permit program data.
Permit program data.
USEPA Region 10
ID
OR
8
2
8
>5"
Permit program data.
Onsite and UIC staff estimates and UIC Database (updated 12/98)
provided by Calvin Terada, of USEPA Region 10, per telephone
conversation with Oregon UIC program personnel (Terada, 1999).
All USEPA Regions
All States
1,675
> 1,739
The total estimated number counts the documented number when t
estimated number is unknown or NR
ter
es
er of
le
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 response was not returned.

N/A    Not Applicable.

a       Unless otherwise noted, the best professional judgement for the estimated number of wells is that of the state or
        USEPA regional staff completing the survey response.

b       Including less than 50 "estimated" sewage treatment wells but not including an "estimated" 200 salt water intrusion
        barrier wells for which the source of injectate could not be determined.  These are counted as salt water intrusion barrier
        wells in Volume 20.
                                                                                                     7

-------
c      In addition to the 824 documented sewage treatment effluent wells in Florida, there are six aquifer storage and recovery
       (ASR) facilities that are proposed to use reclaimed water (treated effluent) as injectate. These six wells are counted
       here as sewage treatment effluent wells because treated sewage, in the form of reclaimed water, is the only fluid injected
       below ground as part of the operation of these ASR wells.

d      Including two documented and three estimated sewage treatment injection wells.

their knowledge there are no ASR wells injecting treated effluent, but expect that some such wells may
become operational in the future. Florida has six ASR facilities that propose to use only reclaimed
water (treated effluent) as injectate.    These ASR systems are discussed in this volume and not in
Volume 21.

       Almost 97 percent of the documented sewage treatment effluent wells were reported in only
five of the surveyed states: Arizona, California, Florida, Hawaii, and Massachusetts.  Based on the
estimate provided in the survey, New York may also have a relatively large number of sewage
treatment effluent wells.  A summary of the wells reported in these an other states is provided below.

       Arizona

       Arizona UIC program staff reported 79 sewage treatment effluent wells  operating in the state,
based on best professional judgement.  The state program reported that some of these wells are
believed to be receiving injectate from sources other than domestic wastewater treatment plant effluent;
however, the number of wells receiving sewage treatment effluent mixed with other fluids were not
provided in the  survey response. Therefore, all 79 of the reported wells are included in the sewage
treatment well inventory in Table 1. The Arizona Department of Environmental Quality (ADEQ)
indicated that the majority  of the wells are located in areas in the central and southeastern portions of
the state that are not sparsely populated areas, and that the majority of the wells are located above
state-designated aquifers (Day,  1999).

       California

       The Santa Ana Regional Water Quality Control Board (RWQCB) reported that there are 204
sewage treatment effluent wells operating in the region. The San Diego RWQCB reported that there is
one operating sewage treatment effluent well in the San Diego region.  The Santa Ana RWQCB also
reported that there are an unknown number of privately-owned and undocumented leach fields
(subsurface disposal units)  that discharge treated effluent operating in the region. The other six
RWQCBs in California did not complete survey responses for sewage treatment effluent wells.

       The Chevron El Segundo Refinery has applied for a permit for ground water injection of
recycled water to a liquid hydrocarbon recovery system at the refinery.  Chevron had been injecting
filtered ground water into the contaminated aquifer beneath the refinery as part of an aquifer
remediation and aquifer recharge project.  The RWQCB approved the redesignation of the aquifer,
which would be required under California regulations for the injection of tertiary treated water into an
aquifer.  The West Basin Municipal Water District (WBMWD) which would supply the recycled

-------
water, indicated that approvals by the California Water Resources Control Board and the USEPA for
this proposed project were anticipated in March 1999 (WBMWD, 1999).

       Florida

       Florida UIC program staff reported 824 documented sewage treatment effluent wells in in the
state, based on permit program data, and reported no additional estimated wells that are not
documented.  The Florida UIC program also reported six proposed ASR wells that have applied for
permits to inject only treated effluent; these are included in the inventory of sewage treatment effluent
wells in Table 1.  The permit status of these six ASR facilities, as of December 1998, is summarized in
Table 2.  More than 700 of the 830 sewage treatment effluent wells in Florida are located in the Florida
Keys (Monroe County), mostly in areas where there are no USDWs.

       Florida UIC program staff also reported that there are 34 ASR injection well facilities for which
owners or operators have applied for construction or operating permits.  Five of the 34 ASR facilities
are conducting operational testing, and six have received state operating permits. Besides the six ASR
facilities that are counted in the sewage treatment effluent well inventory because they are proposed to
inject only sewage treatment effluent, the other ASR facilities in Florida are injecting (or will inject) a
mixture of sewage treatment effluent and other fluids.  These other facilities are discussed in Volume 21
on Aquifer Recharge and Aquifer Storage and Recovery Wells.

       Hawaii

       Hawaii UIC program staff reported 378 documented and no additional  sewage treatment
effluent injection wells operating in the state, based on permit records. All 378 injection wells receive
effluent that is solely sanitary wastewater subject to secondary wastewater treatment. The Hawaii UIC
program reported the locations of each sewage treatment effluent well operating in the state in the
survey response.

       Massachusetts

       Massachusetts UIC program staff reported 105 documented sewage treatment effluent wells
operating in the state, and did not report any additional estimated wells in the state that are not
documented.

       Michigan

       Michigan UIC program staff did not provide an estimate of the number  of sewage treatment
effluent wells in its survey response.  The injection well inventory provided by the state UIC program
did not categorize Class V wells by well type. USEPA Region 5 staff, however, estimated that 11
sewage treatment effluent wells exist in Michigan based on a review of its injection well inventory.

-------
                   Table 2. Aquifer Storage and Recovery Facilities Injecting Only Sewage Treatment Effluent in Florida
Facility Name
Venice Gardens
Englewood
Hillsborough County NW
New Smyrna Beach Expl.
Manatee Southwest
St. Petersburg SW
ASR
Type*
RCW
RCW
RCW
RCW
RCW
RCW
Pre-
Application
X





Construction
Application
Received

X



X
Construction
Permit Issued



X
X

Well Constructed


X



Operational
Testing






Operation
Permit






*ASR Types:    RCW-Reclaimed water (i.e., sewage treatment effluent)
                                                                                                                                      10

-------
       New Hampshire

       New Hampshire UIC program staff did not report any sewage treatment effluent wells in its
survey response. However, permit data collected during a USEPA field visit to the New Hampshire
Department of Environmental Services indicate the existence of two domestic sewage treatment
operations that discharge treated effluent into underground leach field systems.  These facilities have
been issued Discharge to Ground Water Permits by the State of New Hampshire Department of
Environmental Services. One of these systems, operated by the Town of Ossipee, discharges both
primary treated effluent and untreated septage2 to ground water through 24 subsurface leach fields.
The other system, located in the Town of Weare and operated by All
Clear Services, discharges tertiary treated effluent from a Solar Aquatics System© (SAS) wastewater
treatment system to a series of five subsurface discharge units.  According to the Class V survey
criteria, these subsurface discharge systems are classified as sewage treatment effluent injection wells.
For the purposes of the inventory in Table 1, therefore, each individual subsurface discharge point is
classified as an individual injection well.

       New York

       New York UIC program staff reported no documented sewage treatment effluent wells
operating in the state, but USEPA Region 2 estimated that less than 50 sewage treatment effluent wells
may exist in the state that are not documented.  USEPA Region 2 did not provide any additional
information concerning this estimate, which is based on their best professional judgement.

       Oregon

       Oregon UIC program staff reported two documented wells.  It also estimated three additional
sewage treatment effluent wells, but stated that this value represents an underestimate of the total
number of such wells likely to exist in the state. The state believes that some facilities may be installing
numerous smaller capacity  injection wells to take advantage of exemptions from permit requirements for
individual injection wells.  These small capacity wells do not require permits and are, therefore, not in
the state program inventory.

       Texas

       Texas UIC program staff reported that there is only one facility in the state that operates
sewage treatment effluent wells, and that 10 such wells are operated at this location.

       Wisconsin

       Wisconsin UIC program staff reported three documented sewage treatment effluent wells. The
Wisconsin Department of Natural Resources (WDNR) indicated that it expects that two of the three
       2 Septage is the sludge material pumped from sewage septic tanks when they are cleaned.
                                                                                           11

-------
documented wells will be abandoned within five years because of the availability of sewer connections
(WDNR, 1999).

       Wyoming

       Wyoming UIC program staff reported a total of eight documented wastewater effluent injection
wells operated at two locations in the state. First, the Teton Village Water and Sewer District operates
three wells that inject treated wastewater from the Teton Village Wastewater Treatment Plant (WDEQ,
1993).  Second, the Aspen/Teton Pines Water and Sewer District operates five wells that inject treated
municipal wastewater from the Aspen/Teton Pines Wastewater Treatment Plant.

4.     SEWAGE TREATMENT EFFLUENT CHARACTERISTICS
       AND INJECTION PRACTICES

       4.1    Injectate Characteristics

       The types and concentrations of injectate constituents for sewage treatment effluent wells will
vary depending on the type of treatment the wastewater undergoes in the sewage treatment plant prior
to injection. The type of treatment, in turn, depends on the quality of the raw wastewater that enters the
treatment plant and the intended method of disposal of the treated effluent. Domestic wastewater may
undergo four levels of treatment as defined by Perry (1975):

•      Preliminary treatment involves equalization, which avoids overloading the treatment system
       during peak flows; neutralization of the pH; oil and grease removal; metallic ion removal; and
       screening/grit removal.

•      Primary treatment removes settleable solids through sediments. Advanced primary treatment
       may involve the addition of chemical compounds that aid in coagulation of solids, removal of
       phosphorous, and increased biological oxygen demand (BOD) removal.

•      Secondary treatment, according to Rhyner (1995), is "biological removal of dissolved organic
       matter and inorganic matter." Inorganic compounds of environmental concern in domestic
       wastewater include phosphate and nitrogen compounds (in the form of ammonia, organic
       nitrogen, and nitrates), which can degrade the quality of receiving waters. These compounds
       can also be removed in the secondary treatment stage of an appropriately designed wastewater
       treatment system. Rhyner states that secondary treatment may reduce BOD  by 90 percent,
       and can significantly reduce nitrogen and phosphorous. Activated sludge and  trickling filter
       processes are the most frequently employed secondary treatment methods in the United States.
       Tertiary treatment is defined as "any process that follows secondary biological systems" (Perry,
       1975). Tertiary treatment may be used in specific instances where phosphorous and nitrogen
       (in the form of ammonia, organic nitrogen, and nitrates) remain at unacceptable levels in an
                                                                                      12

-------
       effluent stream (Perry, 1975), and may also involve the removal of "pathogenic microorganisms
       and viruses" (NC, 1996).  Several state UIC programs reported that sewage treatment effluent
       well operators are employing tertiary treatment systems to meet injectate quality limitations.
       Such systems, which may include sand filtration, reverse osmosis, or microfiltration systems, are
       able to produce a high quality effluent that when injected, poses low risk of ground water
       contamination (NRC, 1996; Horan, 1990). However, the risk to sensitive populations and
       ecological receptors posed by the underground disposal of tertiary effluent continues to be the
       subject of ongoing research (Goldman, 1999).

Injectate quality data provided by state UIC programs and obtained through field visits indicate that
sewage treatment effluent disposed by underground injection is generally subjected to secondary
treatment at a minimum, and in many cases effluent is subjected to tertiary treatment.  However, one
subsurface disposal unit was identified in the study where injectate receives only primary treatment prior
to injection

       Survey respondents provided injectate data for only a few of the sewage treatment effluent
injection wells in their jurisdictions and some respondents did not provide any data for these wells.
Additional injectate data for sewage treatment effluent wells were obtained from follow-up research
and telephone contacts with permitting agencies. Altogether, the available injectate data for sewage
treatment effluent wells represent only approximately 1 percent of the total inventory of more than
1,675 documented wells (six facilities located in three states and comprising 21 wells).  These data are
summarized in Sections 4.1.1 through 4.1.4.

       4.1.1  Overview of Injectate Quality

       The following examples of injectate quality for sewage treatment effluent wells were taken from
the literature, from permit documentation provided by state regulatory agencies through the Class V
injection well survey, and from permit data obtained through field visits and telephone contacts with
state regulatory agencies.  This information is organized by state in order to reflect the specific
monitoring requirements and results in the different states. Because of differences in these requirements,
the injectate quality data obtained from one UIC program may not be directly  comparable to the data
obtained from another program.

       Arizona

       ADEQ staff indicated that there is some variability in injectate quality for sewage treatment
effluent wells, but that approximately 90 percent of these wells operating in Arizona meet drinking water
MCLs at the point of injection. ADEQ staff also indicated that the wastewater treatment plants
discharging to injection wells in Arizona use some type of tertiary treatment system in order to meet
effluent (injectate) quality standards.  Of the 79 sewage treatment effluent wells in Arizona, 41  were
reported to have tertiary treatment including sand filtration, six were reported to have reverse osmosis
systems, and 32 were reported to have microfiltration (Day, 1999).
                                                                                            13

-------
       California

       Representatives of the San Diego and Santa Ana RWQCBs indicated in the survey responses
that the 205 sewage treatment effluent wells operating in their regions (other than the salt water intrusion
barrier wells) receive treated effluent that is subjected to secondary treatment.  However, injectate data
were not provided for these wells.

       Florida

       The Manatee County Public Works Department ASR system well injects exclusively reclaimed
water (treated effluent) and are therefore classified as sewage treatment effluent wells. Table 3
summarizes the injectate data for these wells.   Injectate monitoring data indicate that the effluent
discharged to the Manatee County ASR system well meets primary and secondary drinking water
standards for the constituents monitored.

       Table 4 presents injectate data for secondary treated wastewater effluent injected into sewage
treatment effluent wells in the Pinellas Peninsula in west-central Florida (Rosenshein and Hickey,
1997). In Monroe County (southwest Florida) the Monroe County Health Department (MCHD)
monitors injectate quality for sewage treatment effluent wells operating in the county. Table 5 presents
injectate data for aerobically treated residential wastewater effluent published by the MCHD (MCHD,
1997).

       Hawaii

       The City and County of Honolulu, Hawaii Department of Wastewater Management (HDWM)
published  data on injectate characteristics for wastewater treatment plants injecting treated effluent into
Class V injection wells (HDWM, 1997). The HDWM operates three wastewater treatment plants
(WWTP) on the island of Oahu, including the Kahuku WWTP, Paalaa Kai WWTP, and Waimanalo
WWTP. Each facility injects secondary treated wastewater into systems of injection wells.  Tables 6,
7, and 8 show the constituents found in wastewater injectate for the three injection well systems for
years between 1993 and 1997.  The injectate data for the Kahuku, Paalaa Kai, and Waimanalo
WWTPs show that fecal coliform concentrations exceeded the primary MCL of 1/100 ml, and that
concentrations of TDS exceeded the secondary MCL of 500 mg/1.

       Massachusetts

       Massachusetts UIC program staff provided injectate quality data for three wastewater
treatment plants that inject treated effluent; these include a municipal wastewater treatment plant, a
school complex, and a condominium complex. Monthly monitoring report summaries were provided
by the Massachusetts Department of Environmental Protection (MDEP) for the Edgartown
Wastewater Treatment Facility in Edgartown, The Easton School Complex in Easton, and the Fuller
Pond Condominiums Trust in Middleton, Massachusetts. Injectate quality monitoring and monthly
                                                                                          14

-------
               Table 3.  Injectate Data for the ASR System at Manatee County
         Public Works Department Water Treatment Plant, Manatee County, Florida
Parameter
Total Trihalomethanes (TTHMs)
Gross Alpha
Dissolved Oxygen
Total Iron
Conductivity
Total Dissolved Solids (TDS)
PH
Chloride
Sulfate
Total Alkalinity
Drinking Water
Standard"
(mg/1, unless otherwise
indicated)
0.08 (P)
15pCi/l(F)
NA
Secondary MCL: 0.3 (F)
NA
Secondary MCL: 500 (F)
Secondary MCL: 6.5-8.5
Secondary MCL: 250 (F)
500 (P)
Secondary MCL: 250 (F)
NA
Health Advisory Level
(mg/1, unless otherwise
indicated)
NA
15pCi/l(C)
NA
NA
NA
NA
NA
NA
D
NA
Range of Concentrations
(mg/1, unless otherwise
indicated)
0.012-0.015
1.0-1.5pCi/l
5.61-8.11
<0.02 - 0.03
250 - 360 uhmos
180-205
7.1 -8.0
16.4-21
79-90
12.2-21.8
Data Source: Manatee County Public Works Department, 1996

Regulatory Status:      D - Draft; F - Final; P - Proposed

       means no discharge limit, MCL, or HAL specified
16.     indicates primary MCL
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
NA    means Not Applicable
                                                                                              15

-------
       Table 4. Constituents of Injected Wastewater Effluent, Pinellas Peninsula, Florida
Constituent
Boron, dissolved
Cadmium, dissolved
Cadmium, total recoverable
Copper, dissolved
Copper, total recoverable
Iron, dissolved
Iron, total recoverable
Lead, dissolved
Lead, total recoverable
Zinc, dissolved
Mercury, total
Silica
Total Nitrogen
Organic Nitrogen
Nitrite, as N
Ammonia, NH4 as N
Nitrate, as N
Total Phosphorus, as P
Dissolved Solids
pH
Dissolved Oxygen
Chemical Oxygen Demand
Biochemical Oxygen Demand 5-day
Biochemical Oxygen Demand 20-day
Total Organic Carbon
Concentration (mg/L)
NO -0.36
ND
ND
ND
ND
ND-0.08
ND-0.13
ND
ND -0.001
ND-0.05
ND - 0.0002
5-22
12-25
1.6-11
0-3.4
5-23
0-3.2
2.5-9.3
460 - 2,200
6.4-8.6
4-8.2
59 - 120
2-49
19-150
7-28
MCL (mg/1)
-
0.005
0.005
1(S)
1(S)
-
-
0.015
0.015
5(S)
0.002
-
-
-
-
—
10
-
500.0 (S)
6.5-8.5(8)
-
-
-
-
-
HAL (mg/1)
0.6 (NC)
0.005
0.005
-
—
-
—
—
—
-
0.002
—
—
-
—
—
—
-
-
-
-
-
-
-
-
Source: Rosenshein and Hickey, 1997.
-              means no discharge limit, MCL, or HAL specified
(S)             indicates secondary MCL (no notation means the value is a primary MCL)
(NC)           means the reported health advisory level is for non-cancer effects
ND            means Not Detected
                                                                                                 16

-------
   Table 5. Constituents of Injected Aerobically Treated Effluent, Monroe County, Florida
Constituent
CBOD5
TSS
Total Nitrogen
Total Phosphorus
PH
Chlorine
Concentration (mg/L)
1995
ND - 30.6
ND - 276
1.04-92.65
ND-13.4
7.4-7.8
0-0.05
1996
ND-72
ND-820
ND-85.6
ND-72
NR
NR
1997
ND- 150
ND- 131
1.1-68
ND - 0.42
NR
NR

MCL (mg/1)
-
-
-
-
6.5-8.5(8)
250 (S)
HAL (mg/1)
-
-
-
—
-
-
NR - Not Reported
ND - Not Detected

Source: MCHP, 1997.
                                                                                       17

-------
Table 6. Constituents of Secondary Treated Wastewater Injectate, Kahuku WWTP Oahu, Hawaii 1993-1997
Constituents
BOD5
Suspended Solids
Turbidity (NTU)
PH
Chloride
Total Kjedahl
Nitrogen
Ammonia as N
Dissolved
Oxygen
Fecal Coliform
(CFU/100ML)
Nitrate + Nitrite
Total
Phosphorous
Ortho-
phosphorous
TDS
Surfactants
Concentration Ranges mg/L (except as noted)
1993
98-99
98-99
NR
6.61-7.32
0.5-3.98
NR
NR
NR
NR
NR
NR
NR
NR
NR
1994
NR
NR
NR
6.59-7.27
0.28-2.28
<0.05 - 6
<1. 0-5.2
NR
NR
0.8-1.56
2.24-3.1
NR
NR
NR
1995
1-4
1-2
0.3-0.88
6.77-7.11
0.15-0.9
0.3-1.6
<0. 1-0.46
1.9-4.31
1-58
2-15
1.94-3.91
1.87-3.21
292 - 463
0.25-0.5
1996
1-3
1-4
0.2-2.4
6.58-6.82
0.14-0.48
0.1-0.8
0.1-0.3
2.83 - 8.67
1-4
13.5-27.5
2.56-2.82
2.24-2.71
420 - 4,586
0.25-0.5
1997
1-6
1-2
0.07-1.3
6.59-7.06
0.10-0.81
0.3-0.5
0.1-0.2
4.7-5.12
2-7
26.0 - 27.2
2.87-3.1
2.61-3.1
420 - 449
NR

MCL (mg/1)
-
-
-
6.5-8.5(8)
250.0(8)
1 0 (Hawaii state
standard)
-
-
1/1 00 ml
-
-
-
500.0
0.5(8)
HAL (mg/1)
-
-
-
-
-
-
-
-
-
-
-
-
—
-
Source: HDWM, 1997.




NR - Not Reported
                                                                                                                    18

-------
         Table 7. Constituents of Secondary Treated Wastewater Injectate, Paalaa Kai WWTP, Oahu Hawaii 1993-1997
Constituents
BOD5
Suspended Solids
Turbidity (NTU)
PH
Chloride
Total Kjedahl
Nitrogen
Ammonia as N
Dissolved
Oxygen
Fecal Coliform
(CFU/100ML)
Nitrate + Nitrite
Total
Phosphorous
Ortho-
phosphorous
TDS
Surfactants
Concentrations mg/L (except as noted)
1993
98 - 100
97 - 100
NR
6.53-7.2
4.12-12.6
NR
NR
NR
NR
NR
NR
NR
NR
NR
1994
99 - 100
99 - 100
NR
6.5-7.39
1.44-7.25
8.2
6.2
NR
NR
1.72
2.31
NR
NR
NR
1995
2-6
1-6
0.8-3.3
6.82-7.3
0.86-3.92
5.9-10.2
2.7-7.1
3.45-5.63
1-155.5
0.7-2.8
3.0-4.51
2.09-4.51
430 - 532
0.25-0.5
1996
3-7
2-6
0.6-2.1
6.87-7.4
0.22 - 257
1.9-8.8
1-7.4
4.05 - 8.02
1-10
0.05-6.8
2.7-5.2
2.7-4.76
425 - 460
0.25
1997
3-6
1-4
1.1-3.5
6.84 - 7.28
0.98-3.38
5.6-10.1
3.7-8.4
2.34-3.99
1-170
0.26 - 8.4
2.29-3.7
2.06-3.7
397-456
NR

MCL (mg/1)
-
-
-
6.5-8.5(8)
250.0(8)
1 0 (Hawaii state
standard)
-
-
1/1 00 ml
-
-
-
500.0
0.5(8)
HAL (mg/1)
-
-
-
-
-
-
-
-
-
-
-
-
—
-
Source: HDWM, 1997.




NR- Not Reported
                                                                                                                     19

-------
        Table 8. Constituents of Secondary Treated Wastewater Injectate, Waimanalo WWTP Oahu, Hawaii 1993-1997
Constituents
BOD5
Suspended Solids
Turbidity (NTU)
PH
Chloride
Total Kjedahl
Nitrogen
Ammonia as N
Dissolved
Oxygen
Fecal Coliform
(CFU/100ML)
Nitrate + Nitrite
Total
Phosphorous
Ortho-
phosphorous
TDS
Surfactants
Concentrations mg/L (except as noted)
1993
5-69
4-69
NR
6.94-7.31
0.23-1.55
NR
NR
NR
NR
NR
NR
NR
NR
NR
1994
3-39
2-47
NR
6.89-7.28
0.16-1.67
2.3-10.6
1.9-9.0
NR
NR
0.2 - 7.4
1.8-2.56
0.64-12.0
NR
NR
1995
65-99
4-48
1.8-27.5
6.81-7.21
0.15-2.48
1.8-11.1
0.1-8.2
1.34-2.86
58 - 14,300
0.3-0.17
1.64-2.23
1.8-1.92
232-359
0.25-0.5
1996
6-44
3-22
1.8-9.5
6.88-7.3
0.08-2.97
6.3-17.1
4.7-12.6
1.47-2.33
170-48,000
0.06-2.6
1.58-2.7
1.5-2.6
256-491
0.25-1.0
1997
5-235
2-202
1.5-11.3
6.69-7.33
0.52-2.05
5.3-13
2.9-9
2.16-5
36 - 25,002
0.3-4.2
1.3-3.42
1.0-2.72
305-337
NR

MCL (mg/1)
-
-
-
6.5-8.5(8)
250.0(8)
1 0 (Hawaii state
standard)
-
-
1/1 00 ml
-
-
-
500.0
0.5(8)
HAL (mg/1)
-
-
-
-
-
-
-
-
-
-
-
-
—
-
Source: HDWM, 1997.




NR - Not Reported.
                                                                                                                     20

-------
reporting is required for these facilities as a condition of each facility's ground water permit. Ms.
Marybeth Costello of MDEP's Bureau of Resource Protection indicated that although the reported
parameters differ somewhat from one ground water permit to another, the requirements for the three
facilities for which data were provided represent the "usual" requirements for discharge to ground
water.  Effluent (i.e., injectate) quality data and influent quality data (i.e., the wastewater treatment plant
influent prior to treatment) are provided for the three facilities in Tables 9,  10, and 11 (Costello, 1999;
MDEP 1999a; MDEP 1999b).

       Nebraska

       The single documented well in the state, operated by the Deuel County POTW, receives
wastewater effluent that is subjected to secondary treatment prior to injection.  The Nebraska UIC
program did not provide any injectate data for this injection well.

       New Hampshire

       The New Hampshire program did not provide any injectate quality data for sewage treatment
effluent wells operating in the state.  However, information collected for two facilities that discharge
effluent from domestic sewage treatment systems into leach fields or subsurface disposal systems
indicates that one facility discharges teritary treated effluents and the other discharges primary treated
effluents.

       Texas

        The ten injection wells operated by the El Paso Public Service Board (PSB) inject sewage
treatment effluent that is treated to drinking water standards.  Injectate data for the El Paso PSB
injection well field are included in Table 12.

       Wyoming

       Table 13 summarizes injectate monitoring data provided by the Wyoming UIC program for the
Teton Village Wastewater Treatment Plant injection wells. For parameters not specifically identified in
the facility's permit, effluent concentrations must not exceed Class I ground water standards listed in
Chapter Vm of the Wyoming Water Quality Rules and Regulations.  Injectate monitoring data indicate
that the effluent discharged to the Teton Village injection wells meets  state UIC permit limits and meets
primary and secondary drinking water standards.  In fact, primary and secondary drinking water
standard parameters, including  chlorinated and nonchlorinated organic compounds, were not detectable
in the effluent. Metals concentrations and total coliform data were not reported for the effluent.
Concentrations of chloride, ammonia, nitrate, BOD, TDS, cyanide, and total phenols were below state
permit limits and Class I ground water standards (WDEQ, 1994).

       Table 14 summarizes injectate monitoring data provided by the Wyoming UIC program for the
Aspen/Teton Pines Wastewater Treatment Plant. For parameters not specifically identified in the UIC

                                                                                           21

-------
         Table 9.  Monthly Injectate Data Report Summary - Edgartown Wastewater
             Treatment Facility, Ground Water Pollution Control Permit UIC 24-1
January 1999 Report
Parameter
Fecal Coliform
Total Dissolved Solids
Total Suspended Solids
Total Solids
5-Day Biological Oxygen
Demand
Chlorides
Ammonia (as N)
Nitrates (as N)
Total Nitrogen
Oil and Grease
Sodium
Total Volatile Organic
Compounds (VOC)
PH
Concentration (mg/1)
Influent
NR
NR
117.75
402.0
192.26
NR
NR
NR
24.5
11.0
NR
NR
6.38
Effluent
1/1 00 ml
299.75
2.15
337.0
3.37
155.0
0.10
0.95
1.89
4.9
116.4
NR
6.88
MCL (mg/1)
1/100 ml
500.0 (S)
-
—
--
250.0(8)
-
10.0
-
-
-
--
6.5-8.5(8)
HAL (mg/1)
-
-
-
—
-
-
—
—
—
-
—
-
—
Monitored Wastewater Influent Flow Rate 84,484 gallons per day.
NR    means not reported
-      means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)    means the reported health advisory level is for a 10"4 cancer risk
ND    means Not Detected
                                                                                             22

-------
    Table 10. Monthly Injectate Data Report Summary - Fuller Pond Condominiums Trust,
                      Ground Water Pollution Control Permit UIC 1-250
January 1999 Report
Parameter
Fecal Coliform
Total Dissolved Solids
Total Suspended Solids
Total Solids
5-Day Biological Oxygen
Demand
Chlorides
Ammonia (as N)
Nitrates (as N)
Total Nitrogen
Oil and Grease
Sodium
Total Volatile Organic
Compounds (VOC)
(annual average - ppb)
MBAS (foaming agents)
(quarterly test)
pH (maximum)
pH (minimum)
pH (sampled)
Concentration (mg/1)
Influent
NR
NR
166.0
496.0
264.0
NR
6.48
NR
NR
NR
NR
NR
NR
6.92
6.54
6.74
Effluent
NR
NR
18.7
440.0
14.1
NR
0.56
7.50
10.9
<3.0
NR
NR
NR
7.05
6.51
6.86
MCL (mg/1)
1/1 00 ml
500.0 (S)
-
—
--
250.0(8)
—
10.0
—
-
—
--
--
8.5 (S)
6.5 (S)
6.5-8.5(8)
HAL (mg/1)
-
-
-
—
-
-
—
—
—
-
—
-
-
-
—
—
Average Wastewater Effluent Flow Rate 23,840 gallons per day.
NR    means not reported
-      means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)    means the reported health advisory level is for a 10"4 cancer risk
                                                                                             23

-------
  Table 11.  Monthly Injectate Data Report Summary - Easton Schools Complex Treatment
                Facility, Ground Water Pollution Control Permit UIC SE-0-615
February 1999 Report
Parameter
Fecal Coliform
Total Dissolved Solids
Total Suspended Solids
Total Solids
5-Day Biological Oxygen
Demand
Chlorides
Ammonia (as N)
Nitrates (as N)
Total Nitrogen
Oil and Grease
Sodium
Total Volatile Organic
Compounds (VOC)
PH
Concentration (mg/1)
Influent
NR
NR
<10.0
430.0
42.0
NR
9.8
NR
NR
<5.0
NR
NR
7.17
Effluent
16/100 ml
NR
<10.0
410.0
3.0
NR
NR
3.6
6.9
<5.0
NR
NR
7.34
MCL (mg/1)
1/1 00 ml
500.0 (S)
-
—
--
250.0(8)
—
10.0
—
-
—
--
6.5-8.5(8)
HAL (mg/1)
-
-
-
—
-
-
-
-
-
-
-
-
-
Monitored Maximum Wastewater Influent Flow Rate 10,610 gallons per day.
NR    means not reported
-      means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)    means the reported health advisory level is for a 10"4 cancer risk
                                                                                             24

-------
     Table 12. El Paso Water Utilities Public Service Board Permit Limits and Monitoring
                      Requirements for Sewage Treatment Effluent Wells

Parameter
Chlorides
Sulfates
Nitrates (as N)
Turbidity
Arsenic
Barium
Cadmium
Chromium(total)
Copper
Iron
Lead
Manganese
Mercury
Selenium
Silver
Zinc
Total Dissolved
Solids
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2, 4, 5-TP Silvex
Monitoring
Frequency
Twice Weekly
Twice Weekly
Every Eight Hours
Every EightHours
Every Two W eeks
Every Two Weeks
Every Two Weeks
Every Two Weeks
Every Two Weeks
Every Two Weeks
Ev ery Two Weeks
Every Two Weeks
Every Two Weeks
Every Two W eeks
Every Two Weeks
Every Two Weeks
Twice Weekly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Monitoring Data
12/98
236.0
70.0
7.01
0.31
JTU
0.002
0.027
0.0005
0.005
0.0054
0.02
0.005
0.01
0.0005
0.01
0.001
0.01
722.0
0.001
0.001
0.01
0.03
0.00
0.0
1/99
201.0
79.0
5.03
0.2
JTU
0.002
0.023
0.0005
0.005
0.008
0.03
0.005
0.02
0.0005
0.01
0.001
0.5
650.0
NR
NR
NR
NR
NR
NR

Discharge
Limit (mg/1)
300.0
300.0
10.0
1.0 NTU
0.05
1.0
0.005
0.05
1.0
0.3
0.05
0.05
0.002
0.01
0.05
5.0
1000.0
0.0002*
0.0002*
0.04*
0.005*
0.1*
0.01*
MCL (mg/1)
250.0(8)
500.0
10.0
-
0.05
2.0
0.005
0. 1
1.3
0.3 (S)
0.015
0.05 (S)
0.002
0.05
0.1 (S)
—
500.0 (S)
0.002
0.0002
0.04
0.003
0.07
0.05
HAL (mg/1)
-
-
--
-
0.002 (C)
2.0 (NC)
0.005 (NC)
0.1 (NC)
--
--
-
--
0.002 (NC)
--
0.1 (NC)
2.0 (NC)
--
0.002 (NC)
0.0002 (NC)
0.04 (NC)
0.003 (C)
0.07(NC)
0.05 (NC)
*      Annual Average
       means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
NR     means Not Reported
ND     means Not Detected
MCL)
                                                                                              25

-------
               Table 13. Injectate Data from Wyoming UIC Program - Teton Village Water and Sewer District
WASTEWATER EFFLUENT (INJECTATE) MONITORING DATA - WYOMING UIC PROGRAM
Monthly Average Data (mg/1)
Parameter
Chloride
BOD (5-day)
Ammonia (N)
Nitrate (N)
IDS
Total Phenols
Total Cyanide
Effluent (Injectate) mg/1
7/94
81.0
3.99
0.149
2.17
160.0
O.01
0.001
8/94
38.0
4.3
0.172
2.60
200.0
O.01
0.001
9/94
87.0
0.45
0.140
1.63
310.0
O.01
0.001
UIC Permit Number 93-168
Instantaneous
UCL (Permit)
Limit
200.0
15.0
1.5
15.0
600.0
0.050
0.30
4-Week Avg
UCL Permit
Limit
150.0
10.0
0.50
10.0
-
-
--
Annual Avg.
Permit Limit
—
--
-
--
450.0
0.10
0.20
Class I
Standard
250.0
--
0.50
10.0
1.0
0.001
0.2
November 21, 1994
Monitoring Report
MCL (mg/1)
250.0(8)
--
-
10.0
500.0 (S)
-
0.2
HAL (mg/1)
-
--
-
--
-
4.0 (NC)
0.2 (NC)
Source: WDEQ, 1994
                                                                                                                  26

-------
Table 13. Injectate Data from Wyoming UIC Program - Teton Village Water and Sewer District (continued)
WASTEWATER EFFLUENT (INJECTATE) MONITORING DATA - WYOMING UIC PROGRAM
Annual Summary Data (mg/1)
Parameter
Benzene
Carbon Tetrachloride
1 ,2-Dichloroethane
1 , 1 -Dichloroethene
Trichloroethene
1,1,1 -Trichloroethane
Vinyl Chloride
o-Dichlorobenzene
(Cis) 1,2-Dichloroethene
(Trans) 1,2-Dichloroethene
p-Dichlorobenzene
1 ,2-Dichloropropane
Ethylbenzene
Chlorobenzene
Styrene
Tetrachloroethene
Toluene
Effluent (mg/1)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
UIC Permit Number 93-168
Instantaneous UCL
(Permit) Limit
0.01
0.01
0.01
0.014
0.01
0.3
0.005
0.6
0.07
0.1
0.075
0.01
0.7
0.1
0.1
0.01
1.0
Annual Avg.
(Permit) Limit
0.005
0.005
0.005
0.007
0.005
0.2
0.002
0.6
0.07
0.1
0.075
0.005
0.7
0.1
0.1
0.005
1.0
Class I
Standard
—
--
-
—
--
-
--
-
-
—
--
-
—
--
-
--
--
November 21, 1994
Monitoring Report
MCL (mg/1)
0.005
0.005
0.005
0.007
0.005
0.2
0.002
0.6
0.07
0.1
0.075
0.005
0.7
--
0.1
0.005
1.0
HAL (mg/1)
0.1 (C)
0.03 (C)
0.04 (C)
0.007 (NC)
0.3 (C)
0.2 (NC)
0.0015 (C)
0.6 (NC)
0.07 (NC)
0.1 (NC)
0.075 (NC)
0.06 (C)
0.7 (NC)
--
0.1 (NC)
0.07 (C)
1.0 (NC)
                                                                                                         27

-------
           Table 13.  Injectate Data from Wyoming UIC Program - Teton Village Water and Sewer District (continued)
WASTEWATER EFFLUENT (INJECTATE) MONITORING DATA - WYOMING UIC PROGRAM
Annual Summary Data (mg/1)
Parameter
Total Xylenes
Total Trihalomethanes
Effluent (mg/1)
ND
ND
UIC Permit Number 93-168
Instantaneous UCL
(Permit) Limit
10.0
0.08
Annual Avg.
(Permit) Limit
10.0
0.08
Class I
Standard
—
--
November 21, 1994
Monitoring Report
MCL (mg/1)
10.0
--
HAL (mg/1)
10.0 (NC)
-
-      means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
Source: WDEQ, 1994
                                                                                                                                   28

-------
               Table 14.  Injectate Data from Wyoming UIC Program - Aspen/Teton Pines Water and Sewer District
WASTEWATER EFFLUENT (INJECTATE) MONITORING DATA - WYOMING UIC PROGRAM
1991 - 1996 Effluent Data (mg/1)
Parameter
Chloride
BOD (5-day)
Ammonia (N)
Nitrate (N)
IDS
Sulfates (SO4)
Total Coliform
Total Cyanide
Total Phenols
UIC Permit Number 89-391
Maximum Effluent (Injectate) Quality (mg/1)
1991
117.7
1.0
ND
4.20
407.0
27.0
0.0
ND
0.060
1992
75.6
2.0
0.43
4.95
343.0
42.0
2.5
ND
ND
1993
99.3
16.0
0.98
3.16
334.0
22.0
0.01
ND
ND
1994
65.0
3.0
0.33
4.48
327.0
25.0
0.06
ND
0.060
1995
81.7
ND
0.19
3.29
324.0
22.0
0.0
ND
ND
1996
66.8
ND
0.09
2.99
324.0
19.0
0.0
ND
ND
Instantaneous
UCL (Permit)
Limit
250.0
10.0
0.5
10.0
500.0
250.0
1/100 ml
0.20
0.001
Class I
Standard
250.0
-
0.50
10.0
1.0
--
-
0.2
0.001
Five Year Review of Operations 1996
Monitoring Report
MCL (mg/1)
250.0 (S)
—
--
10.0
500.0 (S)
500.0
1/1 00 ml
0.2
--
HAL (mg/1)
--
—
--
-
—
--
-
0.2 (NC)
4.0 (NC)
-      means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
Source: WDEQ, 1996
                                                                                                                                    29

-------
permit, effluent concentrations must not exceed state Class I ground water standards listed in Chapter
Vm of the Wyoming Water Quality Rules and Regulations. Monitoring data indicate that the effluent
discharged to the Aspens/Teton Pines injection wells meets state permit limits and Class I ground water
standards. In particular, concentrations of total coliform, chloride, ammonia, nitrate, BOD, TDS,
cyanide, and total phenols were below state permit limits and Class I ground water standards (WDEQ,
1996). Concentrations of other primary and secondary parameters, including chlorinated and non
chlorinated organic compounds and metals, were not reported.

       4.1.2  Inorganic Constituent Concentrations

       Effluent from plants treating domestic wastewater can contain inorganic compounds such as
nitrates, ammonia, phosphorous, chlorides, and sulfates.  Other parameters of importance include total
dissolved solids (TDS) and total suspended solids (TSS), and fecal coliform and other biological
constituents.

       Nitrates/Ammonia

       As summarized below, almost all available injectate data for nitrates and ammonia indicate that
total nitrate concentrations are less than 10 mg/1, the MCL for nitrate (as N), and ammonia
concentrations are less than 30 mg/1, the draft health advisory level for ammonia. The only exception is
one sample from the Fuller Pond Condominiums Trust Facility in Massachusetts, which had a total
nitrogen result that is slightly above the MCL of 10 mg/1.

•      Data for the Teton Village Wastewater Treatment Plant in Wyoming indicate total ammonia
       concentrations (as N) ranging from 0.140 to 0.172 mg/1 and total nitrate concentrations (as N)
       ranging from 1.63 mg/1 to 2.17 mg/1 (three data points, maximum monthly value).

•      Data for the Aspen/Teton Pines Wastewater Treatment Plant in Wyoming indicate total
       ammonia concentrations (as N) ranging from non detectable to 0.98 mg/1, and total nitrate
       concentrations (as N) ranging from 2.99 mg/1 to 4.95 mg/1 (five data points, maximum annual
       value).

•      Data for the Edgartown Wastewater Treatment Facility in Massachusetts indicate a total
       ammonia concentration (as N) of 0.10 mg/1, a total nitrate concentration (as N) of 0.95 mg/1,
       and a total nitrogen concentration of 1.89 mg/1 (single data point, maximum monthly value).

•      Data for the Fuller Pond Condominiums Trust Facility in Massachusetts indicate a total
       ammonia concentrations (as N) of 0.56 mg/1, a total nitrate concentration (as N) of 7.50 mg/1,
       and a total nitrogen concentration of 10.9 mg/1 (single data point, maximum monthly value).

•      Data for the Easton Schools Complex Treatment Facility in Massachusetts indicate a total
       nitrate concentration (as N) of 3.6 mg/1 and a total nitrogen concentration of 6.9 mg/1 (single
                                                                                            30

-------
       data point, maximum monthly value). Injectate ammonia concentrations were not reported for
       this facility.

•      Data for the El Paso Utilities Public Service Board facility in Texas indicate total nitrate (as N)
       concentrations of 7.01 mg/1 and 5.03 mg/1 for consecutive monthly samples. Injectate
       concentrations for ammonia were not reported for this facility.

       Sulfates

       Available injectate data for sulfates indicate that total sulfate concentrations are less than 500
mg/1, the proposed primary MCL, and less than 250 mg/1, the secondary MCL. Specifically:

•      Data for the Manatee County ASR Facility in Florida indicate total sulfate concentrations
       ranging from 79 mg/1 to 90 mg/1.

•      Data for the Aspen/Teton Pines Wastewater Treatment Plant in Wyoming indicate total sulfate
       concentrations ranging from 19 mg/1 to 42 mg/1.

•      Data for the El Paso Utilities Public Service Board facility in Texas indicate total sulfates
       concentrations of 70.0 mg/1 and 79.0 mg/1 for consecutive monthly samples.

       Chloride

       As listed below, available injectate data for chloride indicate that total chloride concentrations
are less than 250 mg/1, the secondary MCL, with the exception of one reported value in Hawaii.

•      Data for the Manatee County ASR Facility in Florida show total chloride concentrations
       ranging from 16.4 mg/1 to 21 mg/1.

•      Data for the three Oahu County WWTP facilities in Hawaii show total chloride concentrations
       ranging from 0.22 mg/1 to 257 mg/1. The highest reported value for the Paalaa Kai WWTP
       exceeds the 250 mg/1 secondary MCL for chlorides.

•      Data for the Edgartown Wastewater Treatment Facility in Massachusetts show a chloride
       concentration of 155 mg/1.

•      Data for the El Paso Utilities Public Service Board facility in Texas show chloride
       concentrations of 236 mg/1 and 201 mg/1 for consecutive monthly samples.  While these values
       do not exceed the secondary MCL of 250 mg/1, the discharge permit limit for this facility for
       chlorides is 300 mg/1, which exceeds the secondary MCL.

•      Data for the Teton Village Wastewater Treatment Plant in Wyoming show total chloride
       concentrations ranging from 38 mg/1 to 87 mg/1.

-------
•      Data for the Aspen/Teton Pines Wastewater Treatment Plant in Wyoming show total chloride
       concentrations ranging from 65 mg/1 to 118 mg/1.

       Total Dissolved Solids

       Available injectate data for TDS indicate that total TDS concentrations are less than 500 mg/1,
the secondary MCL with the exception of the El Paso Public Service Facility and the Kahuku WWTP
in Hawaii, where maximum TDS concentrations exceeded the secondary MCL.  Specifically:

•      Data for the Manatee County ASR Facility in Florida indicate TDS 1 concentrations ranging
       from 180 mg/1 to 205 mg/1.

•      Data for the three Oahu County WWTP facilities in Hawaii indicate TDS concentrations
       ranging from 232 mg/1 to 4,586.0  mg/1. The highest reported value for the Kahuku WWTP
       exceeds the 500 mg/1 secondary MCL for TDS.
•      Data for the Edgartown Wastewater Treatment Facility in Massachusetts indicate a TDS
       concentration of 300 mg/1.

•      Data for TDS were not reported for the Fuller Pond Condominiums Trust Facility in
       Massachusetts.  Total solids concentration (including 18.7 mg/1 total suspended solids, or TSS)
       was reported as 440 mg/1.

•      Data for TDS were not reported the Easton Schools Complex Treatment Facility in
       Massachusetts. Total solids concentration (including < 10 mg/1 TSS) was reported as 410
       mg/1.

•      Data for the El Paso Utilities Public Service Board facility in Texas indicate TDS concentrations
       of 722  mg/1 and 650 mg/1 for consecutive monthly  samples.  These values exceed the secondary
       MCL for TDS of 500 mg/1, but do not exceed the discharge permit limit for this facility of 1,000
       mg/1 TDS.

•      Data for the Teton Village Wastewater Treatment Plant in Wyoming indicate TDS
       concentrations ranging from 160 mg/1 to 310 mg/1.

•      Data for the Aspen/Teton Pines Wastewater Treatment Plant in Wyoming indicate TDS
       concentrations ranging from 327 mg/1 to 407 mg/1.

       4.1.3  Biological Constituents

       Effluent from wastewater treatment plants that treat sanitary wastes contain biological
constituents, including viral and bacterial pathogens. In general, the indicator parameter used for
monitoring pathogens in wastewater treatment plant effluent is total fecal coliform. According to the
Arizona Department of Environmental Quality, Best Available Demonstrated Control Technology

                                                                                          32

-------
(BADCT) Guidance Document for Domestic and Municipal Wastewater Treatment (ADEQ, 1998),
the drinking water standard for total coliform, 1 CFU/100 ml, is set as an indicator below which
pathogenic bacteria, viruses, and protozoa are assumed to be absent.  Other parameters of importance
to wastewater treatment plant effluent are 5-day biological oxygen demand (BOD).

       Fecal Coliform

       Available injectate data for sewage treatment effluent wells indicate that fecal coliform
concentrations do not necessarily meet drinking water standards.  The ADEQ defines BADCT for fecal
coliform for direct discharge to ground water as the "the absence of these pathogens in the discharge"
and Idaho UIC regulations prohibit the injection of effluent containing any detectible coliform.

       Total coliform monitored between 1991 and 1996 for the Aspen/Teton Village Wastewater
Treatment Plant effluent were generally non-detectable, with the exception of two reported samples of
2.5/100 ml and 1.9/100 ml, both values exceeding the drinking water standard for fecal coliform of
1/100 ml.  Injectate data provided by the Massachusetts UIC program indicated fecal  coliform
concentrations of 1/100 ml and  16/100 ml for the Edgartown and Easton Schools Complex
Wastewater Treatment Facilities.  The fecal coliform concentration for the Easton Schools Complex
exceeded the drinking water standard of 1/100 ml, however this value represents only  a single data
point.

       Fecal coliform concentrations in injectate for the three WWTP facilities in Oahu County,
Hawaii ranged from 1 - 48,000  CFU/100 ml. Fecal coliform concentrations  in the injectate exceeded
the primary MCL of 1/100 ml for fecal coliform at all three WWTP facilities in Hawaii in each year for
which data were reported.

       BOD

       For the Aspen/Teton Pines Wastewater Treatment Plant, all injectate data reported in the
1991- 1996 five-year review of operations were below  10 mg/1 5-day BOD with the exception of one
value of 16 mg/1. For the Teton Village Wastewater Treatment Plant in Wyoming, 5-day BOD was
controlled to less than 5 mg/1, as compared to the permit discharge unit of 10 mg/1. Injectate data
provided by the Massachusetts UIC program indicated 5-day BOD concentrations of 3.0 mg/1 and
3.37 mg/1 for the Edgartown and Easton Schools Complex Wastewater Treatment Facilities, and a 5-
day BOD concentration of 14.1  mg/1 for the Fuller Pond Condominiums Trust.

       4.1.4  Organic Constituents

       The injectate released in sewage treatment effluent wells should not be typically contaminated
with non-chlorinated organic compounds, or chlorinated organic compounds, as demonstrated by the
available sampling results summarized below. While significant concentrations of pesticides also would
not be expected, available sampling data suggest that they may be present above levels of concern at
some facilities.

                                                                                          33

-------
       Chlorinated and Non-chlorinated Organic Compounds

       Available monitoring data indicate that injectate to sewage treatment effluent wells meets
primary and secondary drinking water standards for chlorinated and non-chlorinated organic
compounds. Trihalomethanes and other chlorinated organic compounds were not detected in effluent
from the Teton Village Wastewater Treatment Plant.  Injectate data for the Manatee County ASR
Facility in Florida indicate that injectate concentrations of total trihalomethanes range from 0.012 mg/1
to 0.015 mg/1.  Injectate data provided by the Wyoming UIC program for Teton Village and
Aspen/Teton Pines Wastewater Treatment Plants indicate that concentrations of non-chlorinated
organic compounds were below method detection limits.

       Pesticides

       Concentrations of pesticides in the El Paso Public Service Board facility injectate exceeded
(based on a single quarterly sample) MCLs and HALs for lindane and toxaphene.  The data indicate a
lindane concentration of 0.001 mg/1, which exceeds the primary MCL and HAL for lindane of 0.0002
mg/1, and a toxaphene concentration of 0.03 mg/1, which exceeds the primary MCL and HAL for
toxaphene of 0.003 mg/1.

       4.2    Well Characteristics

       Most survey respondents did not provide data on well characteristics.  However, information
on a few operating  sewage treatment effluent wells was obtained from literature sources and field visits.
Figure 1 shows a schematic of a typical sewage treatment effluent injection well located in Florida.  The
characteristics of the well illustrated in Figure 1 are typical of sewage treatment effluent wells elsewhere;
however, because the particular well is located in Florida where ground water tends to be shallow, the
specific depths shown in the figure may not be appropriate for most sewage treatment effluent well sites
across the United States.

       Note also, as previously discussed in Section 2, that not all of the sewage treatment injection
wells discussed in this volume are actually "wells" of the type depicted in Figure 1.  Facilities that
dispose of treated effluent through underground leach fields or other subsurface disposal units are also
classified as sewage treatment effluent wells for the purpose of this report.

       To help illustrate the characteristics of sewage treatment effluent wells, the following sections
provide an overview of injection well siting, design, and construction criteria that are used in different
state UIC programs. These characteristics are a function of the geology and hydrogeology of the area
in which the well is constructed. As a result, the  characteristics described below may  be considered
examples, but not necessarily representative of the total inventory of 1,675 documented sewage
treatment effluent wells.
                                                                                           34

-------
                  Figure 1. Typical Wastewater Effluent Injection Well
                                                 Sea|
                   Vacuum Va|re
               Surface
                    5.71
                   5' —   12"DJP.
                          Effluent Lfie
                   9.13*
Pressure Gauge
                                                       " Concrete Pad
  Cement Grout
                                                        14" x 15'Stee|
                                                        Casing
                                                        Packer
                                                        12"x30'StaMess
                                                        Stee|Screen
                                                        12"x3'Btmk
                                                        Stee| Cas|ig
Source: USEPA, 1987
                                                                                     35

-------
       Florida

       As mentioned in Section 3, more than 700 of the 830 sewage treatment effluent wells in Florida
are located in the Florida Keys. These wells in the Florida Keys are typically installed in areas where
the ground water is less than 50 feet in depth and contains more than 10,000 mg/1 TDS, making it
unsuitable for drinking water purposes.  There are only two USDWs in the Florida Keys, on Key West
and Big Pine Key, and the deepest ground water in these two USDWs is less than 50 feet deep.
Drinking water is provided to the Florida Keys by aqueduct from mainland Florida.

       The Florida UIC program  provided well siting and construction data for two proposed sewage
treatment effluent well facilities and for one facility that is in operation.  The existing facility and one of
the two proposed facilities are publicly-owned aquifer recharge system wells, and the other facility is a
privately-owned wastewater treatment plant. Well characteristics for these three facilities are described
in this section.

       Ocean Harbor Estates Wastewater Treatment Plant. Ocean Harbor Estates, located in
Ocean Ridge, Florida, applied for  permits to construct two Class V Injection Wells to dispose of
treated effluent from a privately owned treatment facility serving 15 single family homes. Figure 2 is a
diagram of the proposed injection well.  The proposed well is 4 inches in diameter with a  10-inch steel
surface casing.  The 4-inch PVC casing depth is 60 feet and the open borehole extends to 120 feet
deep (Murray Consultants, 1998).  The applicant proposes  to inject the effluent into salt water at a
depth of 100 to 120 feet.  According to the permit applicant, there is a confining unit above the injection
zone and the injectate is not anticipated to affect any USDW.

       According to the permit application information provided to the Florida UIC program, the wells
in Ocean Harbor Estates will be constructed in accordance with SFWMD Chapter 40E-3, with the
casing and cementing requirement of FAC Chapter 62-532.  Geophysical logging data will be taken
during construction of the injection well and the data will be  used to identify the 10,000 mg/1 (drinking
water quality) TDS ground water interface, along with the depth, thickness, and physical characteristics
of the confining zone. After construction is completed, but prior to well operation, the well casing will
be pressurized with an inflatable packer placed to within 5 feet of the well casing. The well will be
pressurized to 55 psi  and held at that pressure for one hour,  with a 5 percent (2.8) maximum pressure
decline required to meet FDEP requirements for well construction.  After the mechanical integrity test is
completed, a  4-hour constant rate discharge test will be performed on each well. The discharge test
will be conducted at a constant rate of 30 gpm.

       After the pumping test is completed, an 8-hour pre-operational injection test will be performed
using the discharge water obtained from the pumping test. Water levels will be measured hourly  for 24
hours prior to the test, at set intervals during the test, and for two hours after the test is completed.
Water will be pumped into the injection well at a rate of 15 gpm during the injection test.  Background
ground water quality data will be obtained from the injection well and from monitoring wells prior to
injection of treated wastewater. Background ground water samples will be tested for primary and
secondary drinking water standards and minimum criteria parameters.

                                                                                            36

-------
                  Figure 2. Typical Injection Well Construction Details,
                         Ocean Harbor Estates at Ocean Ridge
                     FOUR (4) - INCH INJECTION WELLS
     FEET BELOW
    LAND SURFACE
        D-
        20—

        40—

        SO-

        SO—

       100—

       120—
10-INCH STEEL SURFACE CASING
(OD: 10.75 in. THICKNESS: 0.365 in)

 GROUT W/51t BENTONITE

4-INCH PVC PRODUCTION CASING
(SCH 40-OD: 4.5 in, THICKNESS: 0.23? in)
OPEN iOREHOLE
Source: Murray Consultants, Inc., 1998.
                                                                                  37

-------
       Hillsborough County ASR Reclaim Project. The total depth of the Hillsborough County
ASR Reclaim Project injection well is 400 feet, with casing diameters of 28 inches at 50 feet depth, 24
inches at 180 feet depth, and 16 inches at 200 feet deep.  The pilot hole for the well is 425 feet deep.
Three monitoring wells will be constructed with the injection well, one of which is to have a monitoring
interval depth of 300 - 400 feet (in the Lower Suwannee formation).  The two other wells will have a
monitoring depth of approximately 150 feet (in the Tampa Member formation).  The casing diameter
for the monitoring wells is six inches (FDEP, 1998).

       The well will be constructed under the supervision of a licensed Florida engineer, and daily
progress reports will be submitted to the FDEP. As-built drawings of the injection well will be
submitted to the FDEP after completion of construction.  Data to be submitted to the FDEP prior to
operational testing include lithologic/geophysical logs, injection zone background water quality,
monitoring well background water quality, reclaimed water quality analysis, short term pump test data
and evaluation, well completion specifications, and mill certificates for casings.

       The operator will conduct operational testing of the injection well system to demonstrate that
the well can assimilate the design daily flows before the FDEP will grant approval for operation.
Monitoring equipment required for operational testing includes pressure gauges, flow meters, and
recorders.

       Manatee County Public Works Department Wastewater  Treatment Plant — Aquifer
Storage and Recovery System. The Manatee County Public Works Department operates an ASR
system consisting of two aquifer recharge and recovery  wells.  The well injects exclusively reclaimed
water (treated effluent) into a limestone formation for storage and recovery (Pyne,  1995). Figures 3
and 4 illustrate the construction characteristics of the two wells and the  characteristics of the formations
in which the wells are  constructed (Manatee County, no date).  The two ASR system recharge wells
each consist of a 24 inch inner diameter steel casing from ground level  to a depth of 100 feet, a 16 inch
inner diameter steel casing from ground level to a depth of 400 feet, and a 16 inch diameter open hole
from 400 feet to 700 feet depth. Each 24 inch steel casing and 16 inch steel casing are grouted with
cement.   The Hawthorne formation, ranging in depth from 100 feet to 350 feet, is characterized by clay
and medium hard limestone, and is a confining unit. At  depths below 400 feet the Tampa formation is
characterized by very hard limestone.  At depths below 450 feet, the Suwannee formation ranges from
hard white limestone, to soft tan limestone, to hard brown limestone  at 700 feet. Below 700 feet, the
Ocala limestone formation is a confining unit.

       Pinellas Peninsular and Monroe County Aquifer Studies.  The Pinellas Peninsula, an area
in west-central Florida, contains numerous injection wells that introduce wastewater into saline
limestone aquifers. Water stored in aquifers is used for various nonpotable uses, including recycling of
wastewater effluent for sprinkler irrigation and aquifer storage for later  nonpotable uses.  Pinellas
County plans call for a maximum storage capacity of 565 megaliters per day of treated effluent by 2002
(Rosenshein and Flickey, 1997).  The Monroe County  Health Department has estimated that there are
currently 300 wastewater effluent injection wells that dispose of aerobically treated residential
                                                                                           38

-------
Figure 3. Well Characteristics for Manatee County ASR System Recharge Well B-2
           ilfTl" T^^i"-. llMIVl, ftf
                           J	L
                          zzi
                                    i  r
                                      J	I
               ^ Di-iqr-riin — Well Df-2. IMim-me-e C ounw Unime
                                                                                      39

-------
       Figure 4. Well Characteristics for Manatee County ASR System Recharge Well B-l
                                                    1,055'-
1,008
1,130
                                             Well Completion Diagram—We;Is B-l, C, and A, :
                                                                                         ICH2M
                                                                                                       40

-------
wastewater, with an average daily injectate volume of 200 to 300 gallons per well. The MCHD
considers the injectate volume range to be an estimate, since the population of the county varies
seasonally. Injection generally occurs into limestone aquifer formations that are approximately 90 feet
deep. The aquifer formation is characterized by saline ground water that is not suitable for drinking
water purposes because of high dissolved solids content.

       Hawaii

       The Honolulu, Hawaii Department of Wastewater Management operates the Kahuku WWTP,
Paalaa Kai WWTP, and Waimanalo WWTP in the island of Oahu. Each facility injects secondary
treated wastewater to wells with depths ranging from 40 to 220 feet. Kahuku injects 0.4 million gallons
per day (mgd) into six wells, Paalaa Kai injects 0.144 mgd into ten wells,  and Waimanalo injects 0.7
mgd into seven wells.

       New Hampshire

       Well siting and construction data were collected for two facilities that discharge treated effluent
from domestic sewage treatment systems to subsurface disposal units. These systems operate under
State Discharge to Ground Water permits, and  are classified as underground injection wells for the
purposes of the survey.

       Town of Ossipee Wastewater Treatment Facility Subsurface Treatment Facility. The
Town of Ossipee Subsurface Treatment Facility was  constructed in 1981, and consists of 24 leach
fields that discharge primary treated wastewater effluent to ground water,  and two septage lagoons that
discharge untreated septage to ground water. The septage facility consists of two unlined septage
lagoons, each 30' x 100' in area, one 20' x 30' evaporation basin, and a 3-acre septage burial site.  The
wastewater discharge facility consists of 12 leaching areas, each 96' x
100' in area,  and each containing two leach fields. The 24 leach fields are supplied by six 12,000
gallon capacity siphon chambers. Primary treated effluent is suppled by a force main to an equalization
chamber and distribution box, which supplies the siphon chambers and leach fields.

       A plot plan of the Subsurface Disposal  Facility is shown in Figure 5. Five ground water
monitoring wells are situated around the Subsurface Treatment Facility, and there is also one surface
water monitoring point located downstream of the facility on Peavey Brook upstream of the Plains
Road Crossing. The closest leach fields are 500 feet from Peavey Brook and 200 feet from the facility
boundary and the Ossipee Town Line. The 3 acre septage burial area is 400 feet from the closest
facility boundary. The locations of the ground water monitoring wells are not clearly depicted in the
facility plot plan, but the Discharge to Ground Water Permit for the facility indicates that all ground
water monitoring wells are located within the Subsurface Treatment Facility Boundary (NHDES,
1997).

       All Clear Services Solar Aquatics Wastewater Treatment System. The Solar Aquatics
System© operated by All Clear Services is designed to treat domestic septage using a system of solar

                                                                                           41

-------
         Figure 5.  Plot Plan For Town of Ossipee Subsurface Treatment Facility
                               ->  'Vx--,
                                             I  !
                              Ill/     \\  \     \

                               /  *' /       I \ \    '1

                               "  / /  s~---   '•  \  \
                                 /  .'  /   '.   V  \    %
                                             \\   '
Source:  State of New Hampshire Department of Environmental Services, 1997.
                                                                           42

-------
tanks and a greenhouse.  The characteristics of the SAS are described in the permit and permit
application for the All Clear Services facility and in a literature article that describes a similar pilot-scale
system located Harwich, Massachusetts (NHDES, 1996b; Teal and Peterson, 1993; EEA, 19993).  A
plot plan of the All Clear Services SAS facility is shown in Figure 6.

       Tertiary treated effluent is discharged to five subsurface disposal units.  Each unit is 115 feet
long,  5 feet in diameter, with 2.7 foot sidewalls, and filled with 1 1A inch clean stone. The subsurface
disposal units are buried under 12 inches to 18 inches of clean permeable backfill.  The total effective
area of the five subsurface disposal unit is 5,980 square feet.  The subsurface disposal units are located
on an approximately 111,000 square foot lot with an effective area of approximately 102,000 square
feet (2.35 acres).  The "effective area" does not include areas with greater than 35 percent slope or
areas that are perennially wet. The subsurface disposal unit area is graded to  shed storm water away
from the subsurface disposal unit system. A typical cross section of a subsurface disposal unit system is
shown in Figure 7 (Keyland, no date).

       Texas

       The ten injection wells operated by the El Paso Public Service Board (PSB) are positioned
approximately three-quarters of a mile upgradient and one-quarter of a mile downgradient from the
PSB's existing water system production wells.  This position allows for  a two-year retention time in the
aquifer before the injected water is pumped into the El Paso water system by  the PSB's production
wells. The Hueco Bolson aquifer, which contains fresh water to a depth of 1,200 feet, provides more
than 55% of El Paso's municipal water supply.

       Figure 8 shows the schematic of a typical well design used for the injection wells located in El
Paso. These wells have the following characteristics in common. First, each well has a gravel
envelope, or pack, consisting of graded particles around the well screen.  These particles are placed
opposite to the  production zones and are above the water table.  This position prevents the pumping of
particles  during backwashing.  The screen design for the wells are designed in  such a way as to limit the
discharge velocity of the effluent to 0.01 ft/s. This design was incorporated into the wells in order to
limit (1) the occurrence of erosion within the aquifer's sand and clay layers; (2) the turbulence that
could displace the gravel pack; and (3) the potential for well screen corrosion.  Each well  consists  of a
3 %-inch injection line that is used to recharge the reclaimed water.  In addition, a 2-inch transducer
pipe is used to measure the hydrostatic buildup in the well. Lastly, treated water from the Fred Hervey
Water Reclamation Plant is pumped through a 30-inch pipe and then  is distributed into each well
through 8-inch  diameter pipes.
         Literature sources indicate that there are several Solar Aquatics System© facilities operating in Massachusetts that
discharge to ground water, including a facility in Weston, Massachusetts (EEA, 1999).  SAS facilities that would discharge to
ground water have recently been proposed for Grand Traverse County, Michigan and San Juan Island, Washington (Grand
Traverse County, 1999; San Juan County, 1999); however, state UIC programs did not provide injectate data or other permit
data for these existing and proposed facilities.
                                                                                              43

-------
          Figure 6. Plot Plan For All Clear Services Solar Aquatic System Facility
         t
                                        .•fv-snzr.
                                        ' I ••«• f'*r>


                                       ' r~^r~j (
             i i
             • i
                             A;
qa '
                                          •., *,
                         r^^\ f. h"
                    \     ,  \\\\\r-r^-
                    \    \  \\\\',  !•  =^u
                     \     ",  \ ^ i\  V

                  "  \    ^   WinS
                                                                  ^o
Source:  State of New Hampshire Department of Environmental Services, 1996b.
                                                                                  44

-------
                    Figure 7.  Cross Section of Subsurface Disposal System, Solar Aquatic System Facility
                                                     4 -      *
                                                       *   i    f
Source: Keyland Enterprises, No Date.
                                                                                                                      45

-------
Figure 8. Typical Recharge/Sewage Treatment Effluent Well Used For FHWRP/Hueco
                   Bolson Recharge Project, El Paso, Texas
        o—i
      100
      2DO-
      3OO'
      400 —
      50O —
      eoo—
      BQQ
32" HOLE ,j 25' OF 26"
_ 2C" SLRFACE CASWG __

3 1/2" ^
INJECTION —^
LftlE
COLUMN
10" D1A. >"
PUMP BOWLS
QBAW6L -^"
RACK
g
^
^(r
«s
1
J^
rai
^ —
*
-

-_•


--

HI
1 — 1
—

jif""
jf
-


—
(
i
x— ^
>•_•<
	

• —
	
7=
f- -
j •_
'
- 4- - -
?r_-_-_-_7^^

-_ 	


	 	 ^
m^
-----

_ __
. 	
— ^

"_•

]
:-

/
-:-;

— _ _ _ .
	

T..-^-_-

• • s
- _"\ 	
-."•?---••

r»--:^^
..._
^ 16- CA31MQ
24" HOUE
£
n
m

	 k
{JfcMtNlfcU
CASING TYP.
If
- y TRANsm.ir FR
PIPE
j — 3 AS1 STATIC
/ WHIH?
1C TftJBUE
>- STBEL EWLIlHiC
/^ LINER TYP,
"-- GALV. WIRE
WRAPFED
•HfOB^tJ wn
^^n^^np 1 mwr.
                                                                           46

-------
       Wyoming

       According to the UIC permit for the Aspen/Teton Pines Wastewater Treatment Plant Injection
Wells, all injection wells will be constructed using 12-inch interior diameter 0.250-inch wall thickness
pipe either driven or installed in a borehole and sealed at the surface with concrete grout. Injectate is
delivered to the wells using a 10-inch diameter subsurface delivery line equipped with a subsurface
control valve. The top of the well casing extends a minimum of 24 inches above grade and equipped
with a locking cap, which must remain locked at all times except when measurements are being made.

       4.3    Operational Practices

       State Class V UIC permits for sewage treatment effluent wells generally include requirements
for operational practices. Well operators are generally required to monitor injectate quality and operate
a ground water monitoring system. Injectate quality permit limits and associated monitoring, reporting,
and record keeping requirements have been set for sewage treatment effluent wells for chlorinated and
non-chlorinated organic compounds, inorganic compounds and metals, and biological constituents.
Examples of these operational practices in several states are described below.

       California

       Chevron El Segundo Refinery Aquifer Recharge and Remediation Project. The
Chevron El Segundo Refinery has applied for a permit for the injection of recycled water to a liquid
hydrocarbon recovery system. Until 1993, Chevron had been injecting filtered ground water into the
contaminated aquifer beneath the refinery as part of an aquifer remediation and aquifer recharge
project.  This injection was conducted to establish hydraulic control of the ground water gradients and
containment of floating liquid hydrocarbon (LHC) contamination, under a USEPA Permit Exemption to
the "Toxicity Rule" which otherwise prohibits the injection of water failing hazardous waste criteria.
The exemption expired in 1993, and since that time Chevron has been injecting potable water into the
contaminated aquifer (WBMWD, 1999).

       The California Department of Health Services determined that Chevron's proposal to inject and
extract treated recycled water constitutes a ground water recharge project, and therefore, the tertiary
treated water would be subject to more stringent reverse osmosis treatment requirements to protect
potential Municipal Beneficial Uses (MUN) of drinking water supplies. The California Department of
Health Services indicated that the ground water beneath the Chevron refinery is on the seaward side of
the West Coast Basin Barrier Project. The aquifers west of the Barrier Project are intruded by
seawater, and drinking water production wells are no longer operated west of the project.

       The California Department of Health Services de-designated (to Non-MUN) a portion of the
aquifer beneath and adjacent to the Chevron refinery after which time the aquifer could not be used as a
drinking water supply. The RWQCB removed the MUN designation of the aquifer in the Basin Plan,
amended the West Basin Municipal Water District's (WBMWD's) Water Recycling Permit, and issued
injectate discharge permit requirements to Chevron.  The WBMWD indicated that approvals by the

                                                                                           47

-------
California Water Resources Control Board and the USEPA for this proposed project were anticipated
in March 1999 (WBMWD, 1999; Reich, 1999).

       Malibu Water Pollution Control Plant.  The Los Angeles County Department of Public
Works owns and operates the Malibu Water Pollution Control Plant, which treats domestic wastewater
from three condominium complexes in Malibu. Treated effluent from this facility is discharged to a
series of seepage basins.  The Los Angeles RWQCB has issued a tentative order requiring the Malibu
Water Pollution Control Plant to be upgraded to achieve compliance with revised discharge limits by
June 1, 2000, including limits  for fecal coliform (LA RWQCB, 1998).  The Malibu Water Pollution
Control Plant is currently designed to provide secondary-treated effluent for the seepage pits.  As of
October 1998 the secondary treatment system had not been tested for effectiveness with respect to
removal of BOD or suspended solids.  The secondary treatment system consists of bar
screening/communition, extended aeration, and secondary clarification, followed by dual media sand
filtration.

       The discharge to ground water area for the Malibu Water Pollution Control Plant consists of 16
seepage pits, 12 of which are located in an eastern disposal area and four of which are located in a
western disposal area. The plant has a capacity of 37,500 gallons per day, and the average flow rate
during 1997 was 28,348 gallons per day.  The locations of the facility wastewater treatment plant,
seepage pits, and ground water monitoring wells are shown in
Figure 9.

       According to the tentative order, the facility is currently subject to a permit that limits the total
discharge from the facility to no more than 37,500 gallons per day and is required to maintain a
minimum vertical distance between the bottom of the seepage basin and the top of the saturated ground
water table of 5 feet.  The facility has violated both of these permit limits in the past. According to the
tentative order, no part of the treatment plant or seepage pit disposal system shall be closer than 150
feet to any water well, or closer than 100 feet to any watercourse. Under the tentative order, the
facility will not be required to maintain a minimum distance between the saturated ground water table
and the base of the seepage pits after the facility is upgraded to meet effluent limits for fecal coliform.

       The RWQCB expressed concern that the local ground water could not continue to assimilate
subsurface wastewater effluent discharges from the existing Malibu facility and from several new
residential and commercial subsurface disposal facilities that have been proposed for the area.  The
current permit conditions for the facility, developed in 1987, do not contain requirements for the
removal of nitrogen or other nutrient loads or pathogens from the effluent. The facility intends to
upgrade the wastewater treatment plant to meet new discharge limits for fecal coliform contained in the
tentative order. As of 1998, the Malibu Water Pollution Control Plant was not monitoring the effluent
discharge to the seepage pits for pathogens. Under the  conditions of the tentative order, the facility
would upgrade the wastewater treatment train to add disinfection capability, as  ground water beneath
the plant may be in hydraulic connection with beaches down gradient of the facility.  Under the tentative
order, the County Department of
                                                                                            48

-------
               Figure 9.  Plot Plan For Malibu Water Pollution Control Plant,
                    Seepage Pits, And Ground Water Monitoring Wells
Source: County of Los Angeles Department of Public Works, No Date
                                                                                       49

-------
Public Works would initiate a study of water quality impacts from discharges of wastewater effluent in
the Malibu Valley area.

       Revised effluent limitations for the Malibu Water Pollution Control Plant included in the tentative
order are summarized in Table 15.  According to the tentative order, waste discharged to the facility
shall be limited to treated domestic wastewater. Wastewater effluent that does not meet the revised
effluent limitations would be held in impervious containers prior to discharge at a permitted facility.  The
facility would also notify the RWQCB of any exceedance of influent or effluent permit limits under the
tentative order. The facility would establish a baseline of nutrient levels in the effluent by monitoring
effluent and ground water conditions, and would establish a ground water monitoring program to
determine whether discharges have been or are impacting ground water quality. The facility indicated
that although the current water quality objective for ground water beneath the plant is 2,000 mg/1 TDS,
ground water in wells upgradient of the facility show ambient TDS concentrations greater than 3,000
mg/1.

       Florida

       The Florida UIC program provided information for two proposed underground injection well
systems that have received permits to construct but have not received permits to  operate.  These
permits include proposed operating requirements for the injection wells.  One facility is a privately
owned domestic wastewater treatment plant, and the other is a POTW that is proposed to use treated
municipal wastewater treatment plant effluent as injectate for an aquifer recharge  system. The Florida
UIC Program also provided permit data for an aquifer storage and retrieval well  system operated by a
municipal wastewater treatment plant.

       Ocean Harbor Estates Wastewater Treatment Plant. As mentioned in Section 4.2, the
permit applicant reports that there is a confining layer above the proposed injection zone. The applicant
will construct one ground water monitoring well above the confining layer and one monitoring well
below the confining layer to determine ground water quality prior to and during operation of the
injection wells. The permit  application indicates that the injectate will meet primary and secondary
drinking water standards for all parameters with the possible exception of fecal coliform, nitrate, total
nitrogen,  ammonia, and BOD.

       The proposed Ocean Harbor Estates Class V injection well project will serve  15 single family
homes. Effluent will be treated by an extended aeration treatment process followed by TSS reduction
and chlorination. The proposed injection rate for each well is 6 gpm at a pressure not greater than 10
psi.  The plant design incorporates a flow meter and pressure gauge on each well and a pressure switch
set to alarm whenever injection pressure exceeds the limit of 10 psi.   The plant design also includes a
pressure relief valve.  Ground water quality testing will be performed monthly for each monitoring well
for TDS, ammonia, total nitrogen, nitrate, chloride, fecal coliform, pH, temperature, and conductivity.
The injectate will be monitored for total daily flow, daily average injection pressure, and primary and
secondary drinking water parameters and minimum criteria parameters.  The monitoring results will be
submitted on an annual basis. A controlled quarterly test of well injectivity (rate/pressure) will be

                                                                                            50

-------
Table 15.  Revised Effluent (Injectate) Permit Limits for
        Malibu Water Pollution Control Plant
Parameter
PH
5-day BOD
TSS
Turbidity
Oil and Grease
IDS
Sulfate
Chloride
Boron
Fecal Coliform
Units
PH
mg/1
mg/1
NTU
mg/1
mg/1
mg/1
mg/1
mg/1
MPN/lOOml
Monthly
Average
--
30
30
10
--
--
—
—
—
—
Maximum
between 6. 5 - 8.5
at all times
45
45
15
15
2,000
500
500
2.0
200
MCL (mg/1)
6.5-8.5(8)
-
-
-
-
500 (S)
500 (S)
250 (S)
-
1/100 ml
HAL (mg/1)
-
-
-
-
-
-
—
—
—
—

The wastewater effluent is required to be "oxidized, clarified, and filtered." Oxidized wastewater
means wastewater in which the organic matter has been stabilized and is not putrescible, and which
contains dissolved oxygen.
The wastewater effluent is prohibited from containing any salts, heavy metals, or organic pollutants at
levels that would impact ground water used for irrigation or ground water that is in hydraulic
connection with surface waters designated for marine aquatic life.
                                                                    51

-------
conducted in accordance with FAC 62-528.430(2)(c), including injection flow rate (MGD), injection
pressure (psig) wellhead pressure with no flow (psig) and monitor zone water levels (feet) before,
during, and after the injection test.

       Hillsborough County ASR Project. The source water for this proposed ASR project is
domestic wastewater treatment effluent from the Hillsborough County Northwest Water Reclamation
Facility (WRF) (May, 1999). The Southwest District of the Florida UIC program has issued a permit
to construct the WRF injection. A permit to operate has not been issued.  The Florida UIC program
requires that the wastewater effluent (injectate) from the WRF meet primary and secondary  drinking
water standards.  The draft permit for the WRF states that any permit noncompliance constitutes a
violation  of the Safe Drinking Water Act.

       The permit applicant is currently obtaining injectate characterization data to supplement their
Florida UIC operating permit application. Staff of the Southwest District Florida UIC program
indicated that wastewater effluent from the treatment plant currently does not meet drinking  water
standards for all parameters, and that the applicant is working to lower the effluent constituent
concentrations to below primary drinking water standards in order to obtain the operating permit
(Richtar,  1999). In the event the applicant is unable to meet primary drinking water standards for the
effluent, the applicant could apply for a water quality criteria exemption from the Florida UIC program
(Richtar,  1999).

       The Hillsborough County ASR Project will perform monitoring of the reclaimed water every
two months.  Monitoring parameters include primary and secondary drinking water standards, the
minimum criteria for sewage effluent, dissolved oxygen, and pathogens, including fecal coliform,
cryptosporidium, and giardia lamblia (the operator is also required to submit background ground water
quality data for these parameters prior to operation).  The injection well operation will also be
monitored for daily and monthly maximum, minimum, and  average injection pressure, flow rate, and
total reclaimed water volume recharged and recovered. Monitoring parameters for injectate and
ground water included in the draft injection well facility permit are shown in Tables 16 and 17.

       Manatee County Public Works Department Wastewater Treatment Plant — Aquifer
Storage  and Recovery System.  The Manatee County Public Works Department operates an ASR
system consisting of two aquifer recharge and recovery wells. The wells inject exclusively reclaimed
water (treated effluent) into a limestone formation for storage and recovery (Pyne, 1995). The
maximum recharge volume for the ASR system is 316 million gallons (SWFWMD, no date). This
volume was achieved on April 30, 1993.  Stored water may be recovered during the wet season
between June and September if the reservoir elevation is less than 30 feet above mean sea level (MSL).
Water may be recovered during the dry season, October through May, if the reservoir elevation is
below 36 feet MSL. Neither of these conditions were achieved between April 1993 and August 1996,
and therefore no stored water was recovered from the ASR system during this period (MCPWD,
1996).
                                                                                          52

-------
Table 16. Hillsborough County Water Dept. Reclaimed ASR Project Monitoring Parameters
                        for Sewage Treatment Effluent Wells
Operational Testing
Parameters
Minimum Criteria for
Sewage Effluent Analysis
Toluene
1 ,2 Dichlorobenzene
Chloroform
1,2 Dichloroethylene
Chloroethane
Aldrin, Dieldrin
Diethylphthalate
Dimethylphthalate
Butylbenzylphthalate
Napthalene
Anthracene
Phenanthrene
Phenol
2,4,6-Trichlorophenol
2-Chlorophenol
Ammonia (as N)
Organic Nitrogen
Operational Testing Conditions
Class V. Test Injection/Production Well
Monitoring Process
Injection Pressure (psi)
Max., Min., and Avg. Injection Pressure
Flow Rate (gpm)
Max., Min., and Avg. Flow Rate
Total Volume: Recharged and Recovered (gal)
Gross Alpha (pCi/1)*
Cryptosporidium* and Giardia lamblia*
Total and Fecal Coliform (cts/lOOml)
Ammonia (as N) and Sulfate (mg/1)
Bicarbonate (HCO3) and Carbonate (COS) (mg/1)
Calcium, Total Iron, Sodium, and Magnesium (mg/1)
Dissolved Oxygen and Total Dissolved Solids (mg/1)
pH (std. units) and Temperature (Degrees Celsius)
Specific Conductivity (umhos/cm)
Total Alkalinity and Total Kjeldahl Nitrogen (mg/1)
Turbidity (NTU)
Total Trihalomethanes (mg/1)*
Recording
Frequency
Daily/Monthly
Daily/Monthly
Daily/Monthly
Daily/Monthly
Daily/Monthly
Monthly
Monthly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Reclaimed Water
Monitoring Parameters
Nitrate (as N) (mg/1)
Nitrite (as N) (mg/1)
Sodium (mg/1)
Total Dissolved Solids (mg/1)
Turbidity (NTU)
Fecal Coliform (cts/lOOml)
Primary and Secondary DWS
Cryptosporidium
Giardia lamblia








Recording
Frequency
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Annually
Annually
Annually








                                                                                                53

-------
                     Table 16.  Hillsborough County Water Dept. Reclaimed ASR Project Monitoring Parameters
                                             for Sewage Treatment Effluent Wells
Operational Testing
Parameters
Minimum Criteria for
Sewage Effluent Analysis
Total Kjeldahl Nitrogen
Nitrite (as N)
Total Nitrogen
Soluble Orthophosphate
Total Phosphorus
Antimony
Operational Testing Conditions
Class V. Test Injection/Production Well
Monitoring Process
Chloride





Recording
Frequency
Weekly





Reclaimed Water
Monitoring Parameters






The sewage effluent analysis will also include dissolved oxygen, fecal coliform, Cryptosporidium and Giardia lambia
An analysis of the reclaimed water will be performed prior to operational testing approval and every two months for a minimum of one year the
thereafter.
Recording
Frequency







i annually
* Monthly production well monitoring will be conducted during cycle testing and for a minimum of one year, then monitoring will be conducted annually subjec
Department of Environmental Protection's written approval.
                                                                                                                      ; to the
Source: FDEP, 1998.
                                                                                                                     54

-------
     Table 17.  Hillsborough County Water Dept. Reclaimed ASR Project Ground Water
                                     Monitoring Parameters
Ground Water Monitoring Well
System Monitoring Parameters
Maximum Water Level/Pressure*
Minimum Water Level/Pressure*
Average Water Level/Pressure*
Gross Alpha (pCi/1)**
Total Trihalomethanes (mg/1)**
Cryptosporidium **
Giardia lamblia**
Total Fecal Coliform (cts/lOOml)
Ammonia (as N) (mg/1)
Bicarbonate (HCO3) (mg/1)
Carbonate (COS) (mg/1)
Calcium, Chloride, Sodium (mg/1)
Total Iron (mg/1)
Dissolved Oxygen (mg/1)
Total Dissolved Solids (mg/1)
Magnesium and Sulfate (mg/1)
Total Kjeldahl Nitrogen (mg/1)
pH (std. units)
Specific Conductivity (umhos/cm)
Temperature (Degrees Celsius)
Total Alkalinity (mg/1)
Turbidity (NTU)
Ground Water Monitoring Well Number and Reporting Frequency
SZMW-1
Daily/Weekly
Daily/Weekly
Daily/Weekly
Monthly
Monthly
Monthly
Monthly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
SMW-1
Daily/Weekly
Daily/Weekly
Daily/Weekly
none
Monthly
Annually
Annually
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
none
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
14-D
Daily/Weekly
Daily/Weekly
Daily/Weekly
none
none
none
none
none
none
none
none
Monthly (Chloride
Only)
none
none
Monthly
Monthly (Sulfate Only)
Monthly
none
none
Monthly
none
none
* After completion of cycle testing, to be monitored continuously
"Monthly during cycle testing and for a minimum of one year, then annually thereafter with the FDEP's written approval.
During all recharge, storage, and recovery cycles of the injection/production well, the permittee will submit a report entitled
"Summary of the Monthly Monitoring Data" that includes the parameters and recording frequencies shown in this table.
Source: FDEP, 1998.
                                                                                                55

-------
       A 90 day test cycle was conducted between August 14, 1995 and November 1, 1995, and
consisted of a recharge cycle, storage cycle, and recovery cycle.  A total of 57.12 million gallons of
water was stored for 30 days during this period.  Recovery was conducted for 19 days, at which point
98 percent of the stored water had been recovered. The test cycle was designed by the FDEP to
investigate water quality changes in the stored water.  Samples of recharge water, stored water, and
recovered water were collected from the recharge well and recovery wells (B-l and B-2), and ground
water samples were collected from four monitoring wells (A, C-l, C-2, and D). Test cycle monitoring
parameters are summarized in Table 18.

       Monitoring wells C-l and C-2 are constructed above and below a semi-confining unit in the
Suwannee Limestone formation.  Well C-l is constructed to a depth of 500 feet, above the semi-
confining unit, and well C-2 is constructed to a depth of 700 feet, below the semi-confining unit.
Monitoring well A is constructed to a depth of 1,050 feet, below the Ocala Limestone confining unit.
Monitoring well D consists of a two-inch diameter monitoring tube installed into well A in the upper
zone of the Hawthorne formation to a depth of 125 feet (Manatee County, no date). Water levels in
each well were monitored weekly throughout the 90 day test cycle.

       New Hampshire

       The Town of Ossipee, New Hampshire, Wastewater Treatment Facility is permitted to
discharge 375,000 gallons per day of septage and 115,000 gallons per day of primary treated domestic
wastewater effluent to ground water through two unlined septage lagoons and 24 subsurface leach
fields (NHDES, 1997).  (The unlined lagoons are not considered to be injection wells and are not
included in the inventory of wells in Table 1.)  The discharge of primary treated wastewater effluent is
subject to a Discharge to Ground Water permit, and the septage facility is subject to a permit from the
NHDES Office of Waste  Management (NHWSPCC, 1983a).

       According to the Discharge to Ground Water Permit for the Subsurface Treatment Facility, the
Town of Ossipee conducts quarterly monitoring of ground water and local surface water quality and
submits quarterly and annual monitoring reports to the NHDES. However the permit only requires
monitoring of the volume  of septage and treated wastewater effluent discharged to the Subsurface
Treatment Facility. Neither the current permit nor the previously issued permit for the Subsurface
Treatment Facility requires direct monitoring of effluent (i.e., treated wastewater or septage) quality.
Both the previously issued permit, dating from 1983 (NHWSPCC, 1983b), and the current permit
requires the permit holder  to allow access to the NHDES for the purposes of collecting effluent
samples; however, no such data were reported.

       The Discharge to Ground Water Permit for the Subsurface  Treatment Facility establishes a
Ground Water Discharge Zone (GDZ) that represents the "compliance zone" for the facility. The
permit prohibits any violation of New Hampshire Ambient Groundwater Quality Standards (AGQS) at
the boundary of the GDZ,  or violation of any New Hampshire surface water quality standards at the
boundary of the GDZ.
                                                                                         56

-------
    Table 18.  Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
     Department Aquifer Storage and Retrieval System - August 16 - November 1,1995

                             Well B-l - Recharge Water Quality

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well B-l
8/16/95
0.012
1.5
5.51
0.02


360
205


7.1


17.1


90



15.1

Well B-l
8/23/95
0.015
1.0
8.11
<0.02


250
200


8.0


16.4


82



20.3

Well B-l
8/30/95
0.013
1.3
5.83
0.03


300
180


7.4


17.1


79



21.8

Well B-l
9./6/9S
0.014
1.2
6.4
0.03


300
194


7.5


21


81



12.2


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA

All samples were collected during recharge of Well B-l
       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC     means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
NA     means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                          57

-------
     Table 18. Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
      Department Aquifer Storage and Retrieval System - August 16 - November 1,1995
                                          (continued)

                              Well B-l - Storage Water Quality

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well B-l
9/13/95
0.080
1.7
NR
0.07


370
233


7.8


26.6


85



32.7

Well B-l
9/20/95
0.077
2.4
6.5
0.09


340
258


7.8


25.9


93



44.9

Well B-l
9/27/95
0.081
3.5
6.7
0.08


390
271


7.1


23.9


95



52.5

Well B-l
10/4/95
0.075
3.2
7.7
0.03


390
263


8.0


25.6


95



54.8


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA

All samples were collected from Well B-l during the 30 day storage cycle period.
       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC    means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND    means Not Detected
NR    means Not Reported
NA    means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                            58

-------
     Table 18. Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
      Department Aquifer Storage and Retrieval System - August 16 - November 1,1995
                                          (continued)

                              Well B-2 - Storage Water Quality

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well B-2
9/13/95
0.074
2.3
4.2
0.02


370
249


7.9


25


86



38.5

Well B-2
9/20/95
0.052
2.3
3.8
0.08


380
254


8.1


23.3


93



50.2

Well B-2
9/27/95
0.058
2.4
3.0
0.1


415
282


7.2


22.1


95



55.5

Well B-2
10/4/95
0.029
4.3
8.0
0.11


380
240


8.0


23.6


96



56.9


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA

All samples were collected from Well B-2 during the 30 day storage cycle period.
       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC    means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND    means Not Detected
NR    means Not Reported
NA    means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                            59

-------
     Table 18. Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
      Department Aquifer Storage and Retrieval System - August 16 - November 1,1995
                                          (continued)

                             Well B-l - Recovery Water Quality

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well B-l
10/11/95
0.075
3.2
6.0
0.05


410
260


7.8


25.4


96



57.9

Well B-l
10/18/95
0.022
4.8
5.8
0.03


420
285


7.8


21.4


98



69

Well B-l
10/25/95
0.012
4.1
3.8
0.04


410
290


7.7


20.7


110



80.3

Well B-l
11/1/95
NR
NR
NR
NR


NR
NR


NR


NR


NR



NR


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA


       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC     means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
NA     means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                            60

-------
     Table 18. Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
      Department Aquifer Storage and Retrieval System - August 16 - November 1,1995
                                          (continued)

                             Well B-2 - Recovery Water Quality

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well B-2
10/11/95
0.029
4.3
6.0
0.11


410
253


7.4


23.1


97



60.7

Well B-2
10/18/95
0.004
4.8
3.4
0.03


440
264


7.8


19.3


108



81.8

Well B-2
10/25/95
0.001
4.2
1.6
0.09


510
328


7.8


19.3


120



100

Well B-2
11/1/95
ND
5.4
3.5
0.11


450
345


7.8


19.4


123



106


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA


       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC     means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
NA     means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                            61

-------
     Table 18. Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
      Department Aquifer Storage and Retrieval System - August 16 - November 1,1995
                                          (continued)

                                      Monitoring Wells

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well A
9/11/95
0.0005
4.4
0.56
1.58


80
320


6.7


14.5


129



77

Well C-l
9/11/95
0.0036
8.3
0.89
0.042


1,573
419


7.1


15.4


156



127

Well C-2
9/11/95
0.0005
0.6
0.65
0.02


568
308


6.7


20.1


22



197

WellD
9/11/95
0.0035
15.6
5.65
3.7


642
333


7.2


11.5


<2



290


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA

All samples were collected during recharge of Wells B-l and B-2.
       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC    means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND    means Not Detected
NR    means Not Reported
NA    means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                            62

-------
     Table 18. Monitoring Data for 90 Day Test Cycle for Manatee County Public Works
      Department Aquifer Storage and Retrieval System - August 16 - November 1,1995
                                          (continued)

                                      Monitoring Wells

Parameter
TTHMs (mg//l)
gross alpha (pCi/ml)
Dissolved Oxygen (mg/1)
Total Iron (mg/1)


conductivity (uhmos/cm)
IDS (mg/1)


pH (standard units)


Chloride (mg/1)


sulfate (mg/1)



alkalinity (mg/1)

Well A
11/1/95
0.080
1.7
no sample
0.07


370
233


7.8


26.6


85



32.7

Well C-l
11/1/95
0.077
2.4
6.5
0.09


34073
258


7.8


25.9


93



44.9

Well C-2
11/1/95
0.081
3.5
6.7
0.08


390
271


7.1


23.9


95



52.5

WellD
11/1/95
0.075
3.2
7.75
0.03


390
263


8.0


25.6


95



54.8


MCL
(mg/1)
0.08 (P)
15pCi/l(F)
NA
Secondary
MCL: 0.3
(F)
NA
Secondary
MCL: 500
(F)
Secondary
MCL: 6.5 -
8.5
Secondary
MCL: 250
(F)
500 (P)
Secondary
MCL: 250
(F)
NA


HAL (mg/1)
NA
15pCi/l(C)
NA
NA


NA
NA


NA


NA


D



NA

All samples were collected during recovery from Well B-l.
       means no discharge limit, MCL, or HAL specified
P      means proposed MCL
F      means final MCL
D      means draft HAL
NC    means the reported health advisory level is for non-cancer effects
C      means the reported health advisory level is for a 10"4 cancer risk
ND    means Not Detected
NR    means Not Reported
NA    means Not Applicable
Source: Manatee County Public Works Department, 1996.
                                                                                            63

-------
       The Subsurface Treatment Facility is permitted to discharge only domestic wastewater to the
leach fields, and only domestic septage to the septage lagoons.  Any grit, oil, sludge, or other wastes
generated by the facility are required to be disposed of only in NHDES-approved facilities. The facility
is required to submit to the NHDES as-built plans for any alternation, modification, repair, or other
construction activities at the facility, and is required to notify the NHDES of any plans to alter or
abandon the leach fields or septage lagoons.  The facility conducts quarterly monitoring of ground
water and local surface water quality, and reports results to the NHDES on a quarterly and annual
basis. Monitoring parameters for the Subsurface Treatment Facility are summarized in Table 19.
Historical monitoring data and current monitoring data for the Subsurface Treatment Facility ground
water monitoring wells and surface water monitoring location are summarized in Table 20.

       All Clear Services, located in the Town of Weare, New Hampshire, is permitted to discharge
5,000 gallons per day of tertiary treated wastewater to ground water via five subsurface leaching
trenches, each with a discharge capacity of 1,000 gallons per day (NHDES, 1996b). The influent to
the Solar Aquatics Treatment System is septage trucked from residential septic tank units. As
described in Section 4.2, the Solar Aquatics System© (SAS), provides biological  tertiary  treatment of
the influent using solar tanks and a greenhouse system. All Clear Services is required to monitor
effluent (injectate) from the tertiary treatment system on a monthly basis for BOD,  fecal coliform, pH,
total nitrogen, total phosphorus, and nitrate, and on a semiannual basis for VOCs and metals. The
effluent discharge is required to comply with New Hampshire AGQS.  Influent quality data for the
untreated septage and effluent data for the tertiary treated effluent were not provided with the permit
data for the SAS facility.

       The All Clear Services facility receives septage trucked from domestic septic tanks, generally
ranging in size from 400 to  1,200 gallons capacity. The septage trucked from the  septic tanks is first
blended in the truck itself, as the trucks can collect septage from two or more septic tanks serviced  on
a single run. The septage is then mixed further at the All Clear Services facility in one of six storage
tanks ranging in size from 6,000 to 10,000 gallons capacity. The septage is then transferred to a
Receiving Tank through a Bar Screen/Degritter.  In some cases, the septage may be transferred directly
from trucks through the Bar Screen/Degritter to the Receiving Tank.  Septage is pumped from the
Receiving Tank to a Blending Tank, which is always operated at full capacity. After primary
clarification, the septage enters the greenhouse portion of the treatment process. The greenhouse
consists of 24 translucent solar tanks (four sets of six tanks connected in series) that are covered with
floating or racked plants with roots extending into the septage, to allow biological activity and
photosynthetic activity (EEA, 1995; EEA, 1999). Following the solar tanks are a secondary clarifer,
sand filter, and two man-made wetland cells. A portion of the secondary sludge from the  process is
activated sludge recycled into the Blending Tank. Solids processing consists of 700 gallons per day
(GPD) of sludge processed in an aerobic digester followed by composting in three man-made reed
beds that are designed to be cleaned once every four years (NHDES, 1995).

       The Discharge to Ground Water Permit for the Subsurface Treatment Facility does not
establish a GDZ that represents a "compliance zone" for the facility. The permit prohibits any violation
                                                                                            64

-------
  Table 19.  Ground Water and Surface Water Monitoring Parameters for Town of Ossipee
                               Subsurface Treatment Facility
Monitoring
Location
B-101
B-104
B-105
B-108
B-109
S-l
Sample Type
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Surface Water
Sampling Frequency
Quarterly
Semi-Annually
Annually
Quarterly
Semi-Annually
Annually
Quarterly
Semi-Annually
Annually
Quarterly
Semi-Annually
Annually
Quarterly
Semi-Annually
Annually
Quarterly
Semi-Annually
Annually
Parameters
Nitrate
Static Water Elevation, pH
Chloride, Ammonia (N), E. Coli
Nitrate, Nitrite, Total Nitrogen
Specific Conductivity
Total Phosphorus, Phosphate (P)
COD, BOD(5), Temperature
VOCs, (method 8260), SWDA Metals
None Required
As for Ground Water Well B-101
VOCs, (method 8260), SWDA Metals
None Required
As for Ground Water Well B-101
VOCs, (method 8260), SWDA Metals
Nitrate
As for Ground Water Well B-101
VOCs, (method 8260), SWDA Metals
Nitrate
As for Ground Water Well B-101
VOCs, (method 8260), SWDA Metals
Nitrate
As for Ground Water Well B-101
None Required
SWDA Metals include: Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, and Silver.
S-l Monitoring Location is downstream of the site on Peavey Brook and upstream of Plains Road Crossing.
Source: NHDES, 1997.
                                                                                          65

-------
  Table 20. Monitoring Data Illustrating Exceedances of New Hampshire Ambient Ground Water Quality Standards for Town of
                                          Ossipee Subsurface Treatment Facility
Well Number
B-101
B-105
B-108
B-109
Surface Water
Nitrate Concentration (ppm)
10/1989
10
NR
NR
15.5
NR
2/1990
NR
NR
NR
29
NR
11/1990
17
NR
NR
NR
NR
3/1991
14
NR
NR
NR
NR
5/1994
NR
10
11
NR
NR
9/1994
12
NR
11
NR
NR
10/1995
NR
NR
14
NR
NR
Nitrate mg/1
2/1998
18
NR
30
12
0.34
The Ground Water Discharge Zone (GDZ) for the Subsurface Disposal Facility extends to the facility property line.
NR means Not Reported
Source:  Town of Ossipee, 1998a.
        NHDES, 1998a.
                                                                                                                     66

-------
   Table 20. Monitoring Data Illustrating Exceedances of New Hampshire Ambient Ground
   Water Quality Standards for Town of Ossipee Subsurface Treatment Facility (continued)
Parameter
pH (field)
E. Coli (per ml)
Nitrate (N, mg/1)
Nitrite (N, mg/1)
Total Nitrogen (mg/1)
Phosphorus (P, mg/1)
Conductivity (umho/cm)
Ammonia (N, mg/1)
Chloride (mg/1)
COD (mg/1)
5 Day BOD (mg/1)
Ortho-Phosphate (mg/1)
Depth to Water (feet)

Well 101
4/23/98
6.4
< 1/1 00ml
11
O.005
0.29
0.03
369
<0.1
58
10
<6.0
0.02
21.24

Well 105
4/23/98
NR

-------
  Table 20. Monitoring Data Illustrating Exceedances of New Hampshire Ambient Ground Water Quality Standards for Town of
                                       Ossipee Subsurface Treatment Facility (continued)
Parameter
pH (field)
Fecal Coliform per 100ml
Fecal Streptococci Bacteria per 100ml
Nitrate (N, mg/1)
Total Kjeldal Nitrogen (mg/1)
Phosphorus (P, mg/1)
Conductivity (umho/cm)
Ammonia (N, mg/1)
Chloride (mg/1)
COD (mg/1)
Ortho-Phosphate (mg/1)
Depth to Water (ft)
Well 101
7/29/93
6.1
114
0
10
0.10
0.51
270
O.10
42
25
<0.04
22.68
Well 104
7/29/93
6.7
10
0
0.10
<0.10
0.72
30
<0.10
<3.0
46
0.08
18.27
Well 105
7/23/93
5.9
210
0
3.1
0.10
0.13
230
O.10
10
31
0.04
32.40
Well 108
7/23/93
5.9
10
0
82
0.10
0.11
260
O.10
35
51
0.04
41/85
Well 109
7/29/93
6.1
18
0
63
0.95
1.1
190
O.10
35
44
0.04
51.62
MCL (mg/1)
6.5-8.5(8)
1/1 00 ml
-
10.0
-
-
-
—
250 (S)
-
-
NA
HAL (mg/1)
-
-
-
-
-
-
-
—
-
-
-
NA
       means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
NA     means Not Applicable

Source: Town of Ossipee, 1998a.
         NHDES, 1998a.
                                                                                                                               68

-------
of New Hampshire AGQS or surface water quality standards with any discharges associated with the
permit for the facility.

       NHDES staff indicated that typical septic system discharge facilities are required to have a
minimum "setback" distance from the property line such that a GDZ can be established for the
attenuation of nitrates and other constituents in the discharge. The small size of the All Clear Services
facility (2.55 acres) would ordinarily be too small for a conventional septic system discharge facility.
However, because the discharge from the All Clear Services facility meets New Hampshire AGQS, the
NHDES indicated that "conceptually there is no need for a nitrate setback if the discharge meets
AGQS" (NHDES, 1995).

       The All Clear Services SAS Facility is permitted to discharge only treated domestic wastewater
to the subsurface disposal units.  Any grit,  oil, sludge, or other wastes generated by the facility will be
disposed of only in NHDES-approved facilities. The facility will submit to the NHDES as-built plans
for any alternation, modification, repair, or other construction activities at the facility, and will notify the
NHDES of any plans to alter or abandon the treatment system. The NHDES specified both influent
(septage) and effluent (injectate) quality limits for the SAS, and also established permit requirements for
periodic monitoring of influent, effluent, and ground water quality (NHDES, 1995; NHDES, 1996).
Ground water monitoring wells were situated two-thirds of the distance, as ground water flows, from
the subsurface disposal units to the property line. Monitoring wells were established in each possible
direction of ground water flow, as well as at one upgradient location (NHDES, 1995). For the All
Clear Services SAS facility, one ground water monitoring well is situated on site in each of the four
compass directions from the discharge point. Influent and effluent discharge quality limits for the SAS
facility are summarized in Table 21 and ground water monitoring parameters are summarized in Table
22.

       Texas

       The El Paso Public Service Board and the Fred Hervey Water Reclamation Plant (FHWRP)
operate ten underground injection wells for the disposal of treated wastewater effluent. The FHWRP
uses primary, biological, physical-chemical treatment, and disinfection to treat the influent water to meet
drinking water standards. The FHWRP treatment system consists of screens, degritters, a primary
settling basin, a powder activated carbon process aeration basin, first stage clarifiers, second stage
denitrification basins, a second stage clarifer, activated carbon regeneration, a lime coagulation unit, a
recarbonation unit, sand filters, ozone disinfection, granular carbon filters, chlorination, and clear well
storage.

       Most of the operating requirements for the El Paso PSB UIC project relate to operation of the
Water Reclamation Plant, rather than operation of the injection wells themselves.  The Water
Reclamation Plant is operated and maintained by a sewage plant operator who holds a valid certificate
of competency.  The facility is operated and maintained to achieve an optimum efficiency of treatment
capability.  This includes monitoring of effluent (i.e., injectate) flow and quality as well as appropriate
grounds and building maintenance.  In the event that flow measurements reach 75% of the permitted

                                                                                            69

-------
average flow for three consecutive months, the facility will initiate engineering and financial planning for
expansion of the facility. If the flow measurements reach 90% of the permitted average flow for three
consecutive months, the facility will obtain authorization from the Texas Water Commission to
commence construction of the necessary additional treatment and/or collection facilities.

 Table 21.  Influent and Effluent Quality Limits for All Clear Services Solar Aquatics System
                                           Facility
Parameter
Biological Oxygen
Demand (BOD)
Total Suspended
Solids (TSS)
Total Nitrogen (N)
Total Phosphorus (P)
Influent (mg/1)
5000
8000
400
50
Effluent (mg/1)
30
30
10
10
MCL (mg/1)
250
—
—
—
HAL (mg/1)
—
—
—
—
Effluent (injectate) is required to meet New Hampshire AGQS.
Table 22.  Ground Water, Effluent, and Influent Monitoring Parameters for All Clear Services
                                    Solar Aquatics System
Monitoring Location
Ground Water
Monitoring Wells MW
l,MW-2,MW-3,
MW-4
Effluent
Influent
Sampling Frequency
Prior to system startup and
. Semi-Annually
Prior to system startup
Monthly
Semi-Annually
Monthly
Parameters
Static Water Elevation
Fecal Coliform
Nitrate, Nitrite, Total Nitrogen
Specific Conductivity
VOCs, (method 8260), SWDA Metals
BOD(5),pH, Volume
Fecal Coliform
Nitrate, Total Nitrogen
Total Suspended Solids
Total Phosphorus (P)
VOCs, (method 8260), SWDA Metals
BOD(5),pH, Volume
Total Nitrogen
Total Suspended Solids
Total Phosphorus (P)
Monitoring well MW-1 is North, MW-2 is South, MW-3 is East, and MW-4 is West of the discharge location.

SWDA Metals includeArsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, and Silver
                                                                                            70

-------
       Wyoming

       The Wyoming UIC program provided operating data for both sewage treatment effluent well
installations operating in the state. These include the Teton Village Wastewater Treatment Plant and the
Aspen/Teton Pines Wastewater Treatment Plant.  The Wyoming UIC program provided copies of
ground water pollution control permits and ground water monitoring data for these wells (WDEQ,
1989; WDEQ 1993). Each permit contains background ground water quality monitoring data,
wastewater effluent (injectate) quality estimates and permit limits, and injectate monitoring requirements.

       The Teton Village Permit allows the Water and Sewer District to operate only one of the three
injection wells at any one time.  The well used is varied each month.  According to the Permit, the
injection system is controlled such that standing water on the surface does not appear within a radius of
200 feet from the injection wells.  Ground water monitoring wells are sampled each calendar quarter for
the parameters listed in Table 23.  The ground water monitoring wells are sampled for organic
compounds annually for comparison with permit limits. For parameters not specifically identified in the
permit, any violation of a Class I water quality concentration in Chapter VIE of the Wyoming Water
Quality Rules and Regulations is also a violation of the UIC permit. Three hundred gallons of water are
withdrawn from each monitoring well prior to sampling to ensure that a representative ground water
sample is obtained. Ground water monitoring data for the  Teton Village Wastewater Treatment Plant
injection well system are included in Table 24.

       The total injected volume for the five wells is limited to 500,000 gallons per day, and the
operator monitors total injected volume to the wells and also the injection pressure if the injection
pressure is greater than atmospheric pressure.  The injection pressure is limited by the permit to no
more than 17 pounds per square inch gauge (psig). The operator samples the effluent quality once per
week for comparison to effluent quality permit criteria, and once per quarter for comparison to volatile
and semi-volatile organic compounds. The operator controls the discharge volume and pressure of
each well to prevent fracturing of confining strata.

       The operator files a quarterly report of monitoring  data for the injection wells to the WDEQ,
including a summary of any permit exceedances or system upsets that occurred during the quarter. The
operator will report any noncompliance that may endanger health or the environment within 24 hours.

       The operator also will notify the WDEQ 180 days  before abandoning an injection well. The
well abandonment procedures in the permit the well casing to be filled with concrete up to a depth of
36 inches. The top 36 inches of the casing will be cut off and the land reclaimed.  The permit prohibits
the conversion of an injection well to any other purpose. Monitoring wells may be converted to other
purposes with the approval of the WDEQ.

       According to the Aspen/Teton Pines Permit, the injection system is controlled such that
standing water on the surface does not appear within a radius of 200 feet from the injection wells.
Wastewater treatment plant design estimates for effluent quality included with the permit
                                                                                           71

-------
   Table 23. Ground Water Monitoring Parameters - Teton Village Ground Water Pollution
                                   Control Permit UIC 93-168
Parameter
Total Dissolved
Solids
5-Day Biological
Oxygen Demand
Chlorides
Ammonia (as N)
Nitrates (as N)
Cyanides (CN)
Total Phenols
Total Coliform
Permit
Ground Water
Quality Limit
(mg/1)
500.0
10.0
150.0
0.5
10.0
-
0.001
1/100 ml
Permit Effluent Discharge Limit mg/1
Instantaneous
Limit (UCL)
600.0
15.0
200.0
1.5
15.0
0.3
0.050
2/100 ml
4 WeekRolling
Avg.
--
10.0
150.0
0.5
10.0
-
0.010
1/100 ml
AnnualAverage
(UCL)
450.0
--
--
--
--
0.2
0.010
--
MCL
(mg/1)
500.0 (S)
--
250.0(8)
--
10.0
0.2
--
1/100 ml
HAL (mg/1)
--
--
--
--
--
0.2 (NC)
4.0 (NC)
-
       means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
                                                                                               72

-------
                Table 24.  Ground Water Data from Wyoming UIC Program - Teton Village Water and Sewer District
GROUND WATER MONITORING DATA FROM WYOMING UIC PROGRAM
Teton Village Water and Sewer District
Teton Village, Wyoming
Ground Water
Parameter
Chloride
BOD (5-day)
Ammonia (N)
Nitrate (N)
IDS
Total Phenols
Monitoring Data in units of mg/1
UIC Permit Number 93-168
Ground Water Monitoring Well Concentration mg/1
OH- 13
55.0
0.00
O.01
1.11
252.0
<0.01
OH- 15
2.0
0.0
0.126
<0.01
162.0
0.01
OH- 18
29.0
00.0
O.01
<0.01
220.0
<0.01
OH- 19
4.0
0.0
<0.01
0.01
160.0
0.01
OH-20
4.0
0.0
O.01
0.01
148.0
0.01
OH-24
1.0
0.0
O.01
0.01
92.0
0.01
4-Week Avg
UCL (mg/1)
150.0
10.0
0.50
10.0
-
-
Class I
Standard
250.0
—
0.50
10.0
450.0
0.001
September 27, 1994
Monitoring Report
MCL (mg/1)
250.0(8)
-
-
10.0
500.0 (S)
-
Health Advisory
Level (mg/1)
-
-
-
-
-
4.0 (NC)
UCL = Upper Control Limit, not to be exceeded in any sample
       means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
Source:  WDEQ, 1994.
                                                                                                                                    73

-------
application are shown in Table 25 (WDEQ, 1989).  Injection of any biological, hazardous or toxic, or
potentially toxic substances in concentrations that exceed primary drinking water standards is a violation
of the permit. The operator samples each monitoring well and any idle injection well each calendar
quarter for the parameters listed in Table 26.  The listed concentrations constitute a "point of
compliance" monitoring system.  Any violation of a water quality concentration in Chapter "VTn of the
Wyoming Water Quality Rules and Regulations is also a violation of the UIC permit.  The operator
withdraws 500 gallons of water from each monitoring well prior to sampling to ensure that a
representative ground water sample is obtained.

       The operator controls the discharge volume and pressure of each well to prevent fracturing of
confining strata.  The operator also samples the effluent quality once per week for comparison to
effluent quality permit criteria, and once per quarter for analysis of volatile and semi-volatile organic
compounds.  The total injected volume for the five wells is limited to 400,000 gallons per day, and the
operator monitors total injected volume to the wells and the injection pressure. The injection pressure is
recorded in the form of static water level in each injection well and each monitoring well. The operator
files a quarterly report of monitoring data for the injection wells to the WDEQ, including a summary of
any permit exceedances or system upsets that occurred during the quarter.  The operator will report
any noncompliance that may endanger health or the environment within 24 hours.

       Three ground water monitoring wells are spaced equally across the south side of the plant site,
and one well is located in the northeast and northwest corners of the site. The monitoring wells are
constructed such that the entire receiver open to the injection wells is penetrated by the monitoring
wells. The facility operator submitted as-built plans for all wells constructed along with a plan map
showing all wells and relative elevation. The operator also constructed a 400,000 gallon emergency
overflow facility  (equivalent to 24 hours of flow) as a condition of the permit.

       The operator will notify the WDEQ 180 days before abandoning an injection well.  The well
abandonment procedures in the permit call for the well casing to be removed from the ground and the
hole filled with bentonite slurry having a 10 minute gel strength of 20 pounds per 100 square feet and
filtrate volume not to exceed 13.5 cc. The top 20 feet  of the hole is to be filled with concrete having a
28-day compressive strength of 3000 psi. The permit prohibits the conversion of an injection well to
any other purpose.

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 sewage
treatment effluent wells 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 of the Class V Study provides information
                                                                                          74

-------
 Table 25. Design Estimate Wastewater Effluent Quality - Aspen/ Teton Pines Ground Water
                              Pollution Control Permit UIC 89-381
PARAMETER
Total Dissolved Solids
5-Day Biological Oxygen Demand
Total Suspended Solids
Sulfates (SO4)
Chlorides
Ammonia (as N)
Nitrates (as N)
Permit Design
Estimate (mg/1)
300.0
5.0
3.0
50.0
55.0
0.5
5.0
Instantaneous (UCL)
Limit (mg/1)
500.0
10.0
--
250.0
250.0
0.5
10
MCL (mg/1)
500.0 (S)
--
--
500.0
250.0(8)
—
10.0
HAL (mg/1)
--
--
--
-
--
—
--
-      means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
                                                                                              75

-------
   Table 26. Ground Water Monitoring "Point of Compliance" Limits - Aspen/Teton Pines
                      Ground Water Pollution Control Permit UIC 89-381
Parameter
Total Dissolved Solids
5-Day Biological Oxygen Demand
Total Suspended Solids
Sulfates (SO4)
Chloride
Ammonia (as N)
Nitrates (as N)
Cyanides
Total Phenols
Static Water Level
Total Coliform
Permit Point of
Compliance Limit
(mg/1)
500.0
10.0
--
250.0
250.0
0.5
10.0
0.2
0.001
No higher than 6 inches
below ground surface
1/1 00 ml
Instantaneous
Discharge Limit
(UCL) (mg/1)
500.0
10.0
--
250.0
250.0
0.5
10.0
0.2
0.001
NA
1/100 ml
MCL (mg/1)
500.0 (S)
--
--
500.0
250.0(8)
--
10.0
0.2
—
NA
1/1 00 ml
HAL (mg/1)
--
--
--
-
--
--
—
0.2 (NC)
4.0 (NC)
NA
-
       means no discharge limit, MCL, or HAL specified
(S)     indicates secondary MCL (no notation means the value is a primary MCL)
(NC)   means the reported health advisory level is for non-cancer effects
(C)     means the reported health advisory level is for a 10"4 cancer risk
ND     means Not Detected
NR     means Not Reported
NA      means Not Applicable
                                                                                              76

-------
on the health effects associated with contaminants found above drinking water MCLs or HALs in the
injectate of sewage treatment effluent wells and other Class V wells. As discussed in Section 4.1, the
contaminants that have been observed above drinking water MCLs or HALs in sewage treatment
effluent wells injectate are fecal coliform, TDS, nitrates, and pesticides.

        Persistence is the ability of a chemical to remain unchanged in composition, chemical state, and
physical state over time.  Appendix E of the Class V Study presents published half-lives of common
constituents in fluids released in sewage treatment effluent wells 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 conditions have a significant impact on the persistence of both inorganic and organic
compounds. Appendix E also provides a discussion of mobility of certain constituents found in the
injectate of sewage treatment effluent wells and other Class V wells.

        In addition to  chemical factors affecting adsorption, physical factors such as ground water
hydraulic gradient, hydraulic conductivity, porosity,  and bulk density also affect mobility. The point of
injection for sewage treatment effluent wells may be within a permeable, coarse-grained unit in some
areas. Such conditions are likely to allow constituents of concern in sewage treatment effluent well
injectate to be highly mobile. For example, one unique characteristic of Hawaii geology is lava tubes
formed by volcanic activity.  Florida hydrogeology is unique in that ground water is located close to the
surface in many parts of the state, and in that the majority of the sewage treatment effluent wells
operating in the state are located in the Florida Keys, a marine environment.   In Arizona, sewage
treatment effluent wells are generally located in the  central and southeastern portions of the state above
state designated aquifers.

        Some of the "sewage treatment effluent wells" reported in the survey are not actually "wells" at
all, but are leach fields that are classified by definition as "sewage treatment effluent wells." These
systems are designed specifically to disperse injectate constituents into soils and ground water.  In
settings where the receiving formation contains substantial clay or silt content, and does  not include
solution cavities or fractures, the mobility of some sewage treatment effluent injectate constituents may
be "retarded." This is especially true for many metals, which, depending on pH and other site-specific
factors,  can undergo fixation and adsorption processes that decrease mobility within the soil-ground
water system.

        Also, the siting and design of sewage treatment effluent wells in some states (e.g., Florida,
Hawaii) may be based on a confining layer between the injection zone and an underlying USDW.
However, geologic "confining units" may not be as effective in confining injectate as may be initially
reported. A geologic confining unit may be shown to be effective in confining the injectate over the
short term, but it may  require 10 to 20 years of observation to observe leakage of the confining unit
(Kwader, 1999).

        Literature data for fecal bacteria and viruses report a wide range of migration potential, and it is
therefore difficult to define the fate and transport characteristics of these biological constituents in
ground water. Depending on soil characteristics, fecal bacteria and viruses that reach ground water

                                                                                             77

-------
tend to not be detectable after traveling a lateral distance of 100 meters from an injection well.
Experiments by Robeck et al. (1962) concluded that natural filtration occurs as a result of ground water
movement.  Their experiments noted that the action of the soil, not bacterial die-off, was responsible for
lowering bacteria counts in their experiments (Fetter and Holzmacher,  1974).  If the injection
environment features fractured or fissured rock formations, pathogens may travel further before
biological soil action reduces their presence to negligible levels. Chlorinating biologically treated effluent
negatively affects the natural removal of coliform in soil (Paling, 1987).  Depending on the exact
features of the receiving aquifer and effluent, treated effluent must spend a given period of time within
the ground water aquifer (and must have  traveled a distance away from the injection site) before the
effects of the injectate on the ground water are no longer detectable. In the event that vadose zone
attenuation calculations are used to support location-specific injectate standards, it may be necessary to
conduct soil column studies or other analytical studies to  provide data to support the attenuation
calculations.

       5.2    Observed Impacts

       No environmental damage cases involving ground water contamination with fecal coliform from
sewage treatment effluent injectate were  reported in the survey responses. However, only a small
amount of data for either injectate concentrations or ground water concentrations  of bacteria and
viruses are available. As noted in  Section 4.1, wastewater treatment effluent used as injectate is
generally treated to secondary  standards, and in some cases is treated to tertiary standards. Bacteria
and viruses are generally not completely  eliminated from  wastewater effluent subjected to secondary
treatment.

       One environmental damage case  was identified for nitrate contamination of ground water
resulting from operation of a sewage treatment effluent well (subsurface disposal unit). In this case, the
injectate receives only primary treatment prior to injection, and the facility operator reported that based
on monitoring data, ground water onsite was contaminated with nitrates at levels exceeding drinking
water standards.  The Hawaii UIC program reported two  environmental damage cases involving
release of nutrient laden injectate to surface water, and the State of Florida and the USGS are
investigating the  potential effects of operation of sewage treatment effluent wells in the Florida Keys on
surface water quality. Available information on the environmental performance of sewage treatment
effluent wells in different states is discussed below.

       Arizona

       The Arizona UIC program reported that the program is unaware of any contamination of
USDWs resulting from operation of a sewage treatment effluent well in Arizona. Mr. Troy Day of the
ADEQ indicated that there have been occasional short-term violations of sewage treatment effluent well
injectate quality standards at the discharge (injection) point, but that to his knowledge, none has
affected ground water quality at the ground water monitoring point (Day,  1999).
                                                                                            78

-------
       California

       The California UIC program has not reported any incidents of USDW contamination from
operation of sewage treatment effluent injection wells in California.

       In addition, a multi-part epidemiological study done in the Los Angeles area tried to determine
if there was any detrimental effect from consuming recovered secondary treated wastewater effluent
that had been used for basin recharge beginning 30 years earlier. The study found no statistically
significant detrimental  effect from consumption of the recovered water (Sloss, 1992).  A study similar to
the Los Angeles basin  recharge study was conducted in California and concluded that there were no
negative short term effects from the consumption of treated wastewater in the study area (Nellor et. al,
1985). Lark, Chang, and others, however, found that a number of hepatitis outbreaks could be traced
to contaminated ground water supplies resulting from wastewater effluent injection.  Their studies
indicated that virus contaminated water traveled several hundred feet through soil, and affected both
deep and shallow drinking water wells. It was discovered that fissured or fractured substrata were
likely responsible for the disease outbreaks (Fetter and Holzmacher, 1974).

       Florida

       The Florida UIC program did not report any incidents of USDW contamination from operation
of any individual sewage treatment effluent injection well in Florida, including aquifer recharge and salt
water intrusion barrier  systems. However,  most of the sewage treatment effluent wells reported to be
operating in Florida are in the Florida Keys, a marine environment. Fresh water sewage treatment
effluent is of lighter density than sea water and will tend to float on sea water and disperse laterally.
Also, chlorine is toxic to lower forms of life, and this potential for ecological toxicity is not reflected in
drinking water standards by which injectate quality is usually evaluated.  The USGS and the State of
Florida are conducting a study of the operation of sewage treatment effluent wells in the Florida Keys.
The study methodology and results to date  are summarized below, along with a separate study by the
University of South Florida examining viral tracers in the Florida Keys.

       USGS Study of Geology and Human Activity in the Florida Keys.  The USGS is
conducting research, supported by the Florida Department of Environmental Protection (FDEP) and
the USEPA, to study the movement of injected water and its potential effects on surface water quality
and coral reef ecosystems.  This research is part of a broader study of geology and human activity in
the Florida Keys being conducted by the USGS.  The USGS reported that the local population, the
USEPA, and the National Oceanic and Atmospheric Administration (NOAA) perceive that excessive
algal growth, coral diseases, and marine grass  and sponge mortality are caused by release of sewage
treatment effluent nutrients migrating from ground water into surface water on both sides of the Florida
Keys (USGS, 1993; USGS, 1998).

       The USGS reported in 1998 that treated sewage effluent is injected into the limestone under the
Florida Keys through onsite disposal systems,  including approximately 25,000 septic tanks,  5,000
cesspools, and 1,000 Class V Injection wells (USGS, 1998). Note that the Florida UIC program

                                                                                           79

-------
reported that approximately 700 of the 830 sewage treatment injection wells reported to be operating
in Florida are located in Monroe County. The USGS reported that the depth of sewage treatment
effluent injection wells in the Florida Keys ranges from 10 to 30 meters. The USGS is conducting a
series of tracer studies to determine the rate and direction of ground water flow and the contamination
levels of saline ground water in the Florida Keys and Florida Bay.

       In 1998, the USGS installed 78 submarine monitoring wells in the Florida Keys reef tract,
Florida Bay, and Shark River Slough, and an additional 14 wells in Biscayne Bay.  Six multi-depth
monitoring wells were also installed on shore at the Florida Keys Marine Laboratory. Twenty of the 84
wells were installed in two 200 foot diameter circular clusters on opposite sides of Key Largo, each
with an injection well at the center.  Each of these wells is screened at 20 feet and at 45 feet depths.
The tracer studies provided data to determine ground water flow direction and flow direction.
Additional studies are planned to collect water from wells in Florida Bay for chemical analysis to
determine whether contaminated waters are entering the bay from below.

       The results to date of this ongoing study have shown that ground water flow direction is
primarily perpendicular to the Florida Keys, toward the east and the reef tract, and the maximum flow
rate toward the east is approximately 100 meters per month (1 kilometer per year). Tidal pumping and
higher sea level in Florida Bay are the two main driving forces for ground water flow. According to the
USGS, the tracer study has already led to modifications of Florida regulations concerning the
installation of sewage disposal wells, and has led USEPA to determine that "the geology of the Florida
Keys is not suitable for the use of waste disposal wells" (USGS, 1998).  The study results reported by
the USGS did not indicate to what extent the operation of septic tanks, cesspools, and sewage
treatment effluent wells may be contributing to the perceived degradation of water quality in Florida Bay
and the reef tract.

       Florida Study of Viral Tracers in Florida Keys Sewage Treatment Effluent Wells. The
University of South Florida (USF) conducted a series of tracer studies at a simulated injection well on
Key Largo and at an existing permitted sewage treatment effluent well on Long Key. For both studies,
the USF researchers developed a viral tracer composed of several types of viruses propagated on
hosts and injected into the simulated well on Key Largo and the operating well on Long Key using tap
water as a carrier.  The site for the Key Largo study consisted of a series of man-made canals that are
lined with residences that operate septic tanks and hotels that operate package wastewater treatment
plants and sewage treatment effluent injection wells. A simulated injection well was constructed 20
meters from one canal.  The injection well consisted of a 1 inch internal diameter PVC pipe in a well
drilled to a depth of 12.2 meters with a screened interval of 10.7 -12.2 meters. One ground water
monitoring well was collocated with the injection well, at a depth of 3 meters. A third ground water
monitoring well was located 50 meters off shore and drilled to a depth of 12.2 meters with a screened
depth of 11 -12.2 meters.  Four surface water sampling sites were located in the man-made canals.

       The site for the Long Key study consisted of an existing Class V sewage treatment effluent well
with a 6 inch internal diameter drilled to a depth of 90 feet and cased to a depth of 60 feet.  The Long
Key injection well receives treated effluent from an activated sludge package treatment plant. The well

                                                                                           80

-------
has a maximum injectate flow rate of 1,500 gallons per day. Ground water monitoring wells were
installed in pairs, one deep (13.7 meters) and shallow (4.6 meters) in the same hole, with the exception
of the offshore monitoring well, which was installed 60 meters offshore (83 meters from the injection
well) at a depth of 4.6 meters.

       For the Key Largo study, the viral tracer was pumped into the well with 20 liters of tap water
over a 4 hour period. For the Long Key study, viral tracer was divided into five equal aliquots and one
aliquot was added to the injection well each hour for five hours while the well was receiving treated
effluent from the package wastewater treatment plant.  For the Key Largo study, ground water
sampling commenced eight hours after the initiation of the tracer study for the on shore monitoring wells,
and 20 hours after initiation of the tracer study for the off shore well. For the Long Key study, sampling
commenced at all monitoring locations eight hours after the initiation of the tracer study.

       For the Key Largo study, the viral tracer was detected in the off shore ground water monitoring
well as early as 20 hours after commencement of the tracer test, which was the earliest time that the off
shore well was sampled. The viral tracer was detected in the shallow ground water monitoring well
collocated with the injection well and surface water 20 meters from the injection well  8 hours after the
initiation of the tracer study, and was also detected in surface water  samples taken "upstream" of the
injection well, as well as in offshore surface water samples.  Viral tracers were detected in off shore
ground water as early as 20 hours after the initiation of the tracer test. Rates of tracer migration to
surface water sample points ranged from 2.5 m/hr to 35.5 m/hr, with an average rate  of 19.5 m/hr, and
migration patterns showed evidence of tidal pumping and a combination of ground water and surface
water flow.  These migration rates are similar to rates reported in previous studies by  Paul,  et.  al.
(1995) in the same environment when tracing septic tank wastewater. Paul, et. al. notes that the
simulated injection well used for the Key Largo study was more shallow and of smaller diameter (1 inch
as opposed to 6 to 9 inches inner diameter) than Class V sewage treatment effluent wells permitted by
current Florida regulations.

       For the Long Key study, viral tracers were detected in on shore ground water monitoring wells
as early as 8 hours after the initiation of the tracer study (the earliest time the monitoring wells were
sampled).  Migration of viral tracers was detected both in the direction of Florida Bay (north of the
injection well site) and towards the Atlantic Ocean (south of the site), and average migration rates were
on the order of 1 m/hr towards the Florida Bay ground water monitoring location and 2 m/hr towards
the Atlantic Ocean surface water monitoring location.  Viral tracers  were detected in the off shore
ground water monitoring well 76 hours after the initiation of the tracer test, and in surface water in the
Atlantic Ocean 53 hours after the initiation of the test.  Average migration rates for the Long Key study
were much lower than for the Key Largo study, possibly  indicating the effect of tidal pumping and
surface water transport pathways for the Key Largo study and the absence of such pathways for the
Long Key study. For the Long Key study, there was no evidence of tidal pumping, and the closest
canal is 106 meters from the injection well. Movement of ground water from the Long Key site through
porous limestone, rather than through surface water, could contribute to the longer travel times for the
Long Key study.
                                                                                            81

-------
       Hawaii

       The Hawaii UIC program did not report any incidents of USDW contamination resulting from
operation of sewage treatment effluent wells in the state.  The program, however, reported two
incidents of surface water contamination related to operation of sewage treatment effluent wells.

       Wailuku-Kahului Wastewater Reclamation Facility. Wailuku-Kahului Wastewater
Reclamation Facility on Maui disposed of treated municipal wastewater through four injection wells
within meters of the ocean.  The reclamation facility is located adjacent to the Kahana Pond Wildlife
Refuge. Inspections in 1992 by the Hawaii Department of Health identified daily spills of wastewater
from the plant and a leaking injection well. The State of Hawaii and USEPA pursued enforcement
action against the reclamation facility, which is ongoing. Individuals reported that one month after the
injection well commenced operation, the water in the adjacent pond turned bright green, which could
indicate an increase in nutrient availability. Ground water monitoring is being conducted through an
USEPA grant to the Hawaii Department of Land and Natural Resources.

       Lahaina Wastewater Reclamation Facility. In  1991, the Lahaina Wastewater Reclamation
Facility in Maui was injecting treated municipal wastewater into four injection wells situated 600 meters
from the ocean. At that time, the west coast of Maui was experiencing algae blooms.  Although a
tracer study did not indicate any large effluent plume from the Lahaina facility, and did not demonstrate
the cause of the algae blooms, USEPA issued a permit to Maui County that promoted the County to
reduce nitrogen levels in wastewater and to begin using the wastewater for irrigation rather than for
injection.

       New Hampshire

       The New Hampshire UIC program did not report any incidents of USDW contamination from
operation of sewage treatment effluent wells  in the survey response. However, permit data for the
Town of Ossipee subsurface treatment facility obtained through a field visit to the permitting agency
indicated that elevated levels of nitrate in ground water were attributable to discharge of treated
wastewater effluent to ground water.

       The New Hampshire Department of Environmental Services (NHDES)  reported that the Town
of Ossipee Subsurface Treatment Facility was issued a five-year Discharge to Ground Water Permit in
1983, and that the facility operated with an expired permit between 1988 and 1994.  The NHDES
received an application for permit renewal from the Town of Ossipee in 1994 (NHDES,  1996a).  The
NHDES required that the Town of Ossipee address several issues prior to the renewal of the permit for
the facility, including exceedances in nitrate levels in monitored ground water at several monitoring
locations.

       The NHDES reported that based on historical ground water sampling data, concentrations of
nitrates exceeded New Hampshire AGQS in on site monitoring wells.  The NHDES required the Town
to submit a new ground water contour map to show the direction of ground water flow within 100 feet

                                                                                         82

-------
of the ground water discharge zone and a revised water quality monitoring program to monitor the trend
of nitrate migration. The NHDES also indicated that a Response Plan under New Hampshire
regulation ENV-WS 410.10(f) may be required if regulated contami-nants (i.e., nitrates) were found to
have migrated significantly from the facility. The NHDES also required monitoring of ground water and
surface water downgradient of the existing monitoring wells. Historical monitoring data and current
monitoring data for the Subsurface Treatment Facility ground water monitoring wells are summarized in
Table 22 in Section 4.3.

       Note that, as discussed above, the Discharge to Ground Water Permit for the Subsurface
Treatment Facility prohibits any violation of drinking water quality standards in the ground water at the
compliance boundary of the facility (i.e., the ground water discharge zone extending to the facility
property line) and the NHDES  did not indicate in the correspondence provided whether any
exceedances of ground water quality standards had occurred in offsite locations.  Also, the Subsurface
Treatment Facility discharges both primary treated wastewater effluent and untreated septage to the
leach field. NHDES has not  determined whether the septage discharge, primary treated effluent
discharge, or combination thereof is primarily responsible for the exceedances of ground water quality
standards for nitrates.

6.     BEST MANAGEMENT PRACTICES

       Best Management Practices (BMPs) associated with sewage treatment effluent injection wells
relate to well design, construction, operation, maintenance, and rehabilitation, and to the design and
operation of the wastewater treatment plant that generates the injectate (effluent) for the well.  There
are two general categories of BMPs, those that affect the potential for operation of the well to affect
ground water (or surface water) quality, and those that affect the physical operating characteristics of
the well itself.

       With respect to protection of ground water or surface water quality, one of the most important
BMPs simply involves the production of appropriate quality effluent at the source (i.e., the wastewater
treatment plant). Injectate that meets primary drinking water standards at the point of injection has a
lower potential to adversely affect ground water or surface water quality than injectate that does not
meet primary drinking water  standards. However, it is possible that even injectate that meets primary
drinking water standards could have adverse effects on ground water or surface water quality, because
of the presence of byproducts for which drinking water standards have not been developed, or because
of the presence of nutrients and other biological constituents that can affect surface water ecosystems.
Conversely, reclaimed water  and untreated ground water that do not meet all drinking water standards
have been successfully injected into ASR wells without rendering the withdrawn water inadequate for
future beneficial use (Dernlan, 1999).

       With respect to well operation, injection of primary drinking water quality effluent does not
necessarily prevent operating and maintenance concerns for sewage treatment effluent injection wells.
It is important to control other characteristics of the injectate, including air entrainment, dissolved solids
content, pH, chlorides, and presence of bacteria, for which there may not be primary drinking water
                                                                                           83

-------
standards, to avoid operating and maintenance problems such as scaling, clogging and corrosion
(Greeley and Hansen, 1991; Driscoll, 1986).  Conversely, reclaimed water and untreated ground water
that does not meet all drinking water standards has been injected into ASR wells without clogging
(Dernlan, 1999). BMPs related to ground water and surface water quality protection and injection
well operation and maintenance are discussed further in this section.

       The USEPA published a draft guidance document for sewage treatment effluent wells, entitled
Draft - Publicly Owned Treatment Works (POTW) Injection Well Systems Guidance (USEPA, no
date). This document contains general guidance concerning design, operating, and maintaining POTW
injection systems (now referred to as sewage treatment effluent wells). The ADEQ has published a
draft guidance document entitled Draft Best Available Demonstrated Control Technology (BADCT) for
Domestic and Municipal Wastewater Treatment that includes guidance on well siting, design, operation,
maintenance, and aquifer protection (ADEQ,  1998). The ADEQ determines BADCT for municipal
and domestic wastewater treatment and disposal facilities on a site specific basis and based on
negotiation with the permit applicant. The guidance document states that BADCT does not mean
simply reducing pollutants to drinking water standards, and states that discharge reduction to an aquifer
that is achieved solely by means of site characteristics (e.g., attenuation of injectate constituents in the
vadose zone) does not in itself constitute BADCT.  The ADEQ is developing an Aquifer Protection
Permit Guidance Document as a companion to the BADCT Guidance Document. Other state UIC
programs, for example, the Idaho UIC program, have incorporated BMPs directly into their UIC
program regulations. Most programs incorporate Best Available Technology or Best Management
Practices into the operating permits for sewage treatment effluent injection wells as part of the Class V
well permitting process.

       The following discussion notes BMPs for sewage treatment effluent wells that are closely
related to the protection of ground water quality.  The discussion is neither exhaustive nor represents an
USEPA preference for the stated BMPs. Each state, USEPA Region, and federal agency may require
certain BMPs to be installed and maintained based on that organization's priorities and site-specific
considerations.

       6.1    Injection Well Siting, Construction, and Design

       6.1.1  Well Siting and Construction Criteria

       Proper design and construction of wastewater effluent injection wells is important because
"minor mistakes in design or construction can result in damage to the well and subsequent economic
loss and potential degradation of the environment"(Warner,  1981). It is important to properly cement,
case, and protect wells from corrosion (Warner, 1981).  For example, one environmental damage
case cited by the Hawaii UIC program involved a sewage treatment effluent injection well that
experienced a cracked casing, allowing effluent to migrate to surface water.

       According to the USEPA Draft Publicly Owned Treatment Works (POTW) Injection Well
Systems Guidance, geologic and hydrologic information should be gathered to the greatest extent

                                                                                          84

-------
possible prior to construction in order to ensure proper performance of the injection wells (USEPA, no
date). Such information may include data on hydraulic gradient, ground water flow direction, and
ground water travel time to drinking water sources or environmental receptors. State UIC programs
generally require that such information be collected prior to well construction as part of the Class V
injection well construction and operating permit process. The engineer or geologist who designs and
supervises installation of the injection well must demonstrate as part of the permit application process
what will happen to the effluent once it is injected, and demonstrate that the well is going to be safe to
operate at design conditions.  Data on the local ground water composition and characteristics can also
be used to determine whether or not injected sewage treatment effluent will affect ground water quality.
The 1987 RTC indicated that background ground water quality tests and injection and pumping tests
are generally performed for new injection wells (USEPA,  1987) and background data and operational
testing are generally required by state UIC program regulations as a condition of the construction and
operating permits for the injection wells.

       6.1.2   Well Design Criteria

       According to Driscoll (1986), injection wells are much more likely to fail than typical water
wells, and the consequences of water chemistry, air entrainment, thermal interference, and presence of
suspended solids are more important for injection wells than they are for water wells. However, with
the exception of injectate entrance velocity and well screen length, general design standards for water
wells are applicable to injection wells, particularly for ASR wells that are used both as injection and
production wells.  For injection wells, fine solids contained in the injectate will collect in the aquifer
formation outside the well screen, and over time the formation may become clogged.  Driscoll reported
that operation of an aquifer recharge well with injectate containing as little as 1 mg/1 of sand can clog the
well within a short time, and pressure build up in recharge wells has been attributed to even lower
injectate solids concentrations. Clogging of screens  is a significant problem in injection well operations,
and therefore screen length and open area should be optimized. Typically, the entrance velocity for an
injection well should be 0.05 ft/sec; those of an injection well are typically designed with well screen
lengths that are twice as long as for a water production well of equal capacity. If the well is used only
for injection (i.e., for sewage treatment effluent disposal or aquifer recharge, but not as an ASR well)
dry sand or gravel zones above the aquifer may also be screened to improve well performance
(Driscoll, 1986).

       6.1.3   Siting and Design for ASR Wells

       Sewage treatment effluent wells used for aquifer recharge or ASR may have somewhat different
design criteria than injection wells used only for the injection of treated effluent for disposal. Operation
of an aquifer storage and recovery well will affect the water table elevation. The water table in the
vicinity of the injection well would "mound" while effluent was being injected, mirroring the drawdown
cone that would be observed while ground water was being recovered (Driscoll, 1986; Uhlman, 1999).
The cone of depression of an ASR well can have a pronounced effect on the static level of an aquifer,
particularly a confined aquifer, when ground water is being withdrawn. An ASR well operates in the
same manner as a drinking water production well, however, the recharge rate of the well will generally

                                                                                            85

-------
not be equal to the production capacity of the well. Because of the potential effects on water table
elevation, the location, spacing, and operation of an ASR well is important to other private and public
utility ground water users in the vicinity (Dwarkanath, 1999).

       6.2     Injection Well Operation and Maintenance

       6.2.1   Operation and Maintenance

       Injection well operators should have standard procedures for well operation and maintenance
as a condition of operation. Maintenance requirements for sewage treatment effluent injection wells
vary depending on the site and the injectate constituents.  Proper well operation and maintenance will
help ensure that the system functions properly for its design life and that the potential for ground water
contamination is minimized.

       Each injection well should be limited to operate at the flow rate and pressure for which it was
designed (USEPA,  1987; Driscoll,  1986). This minimizes the risk of unforseen events, such as casing
failure or seepage of injectate to the surface, that might occur if design limits are exceeded.  Also,
design flow rate, pressure, and other well parameters are specific to the characteristics of both the
injectate  and receiving formation. For weakly consolidated and stratified (e.g., coastal plain) sediments,
injection pressure must be minimized to prevent fracturing of the formation.  Pressures as low as 0.5
Ib/ft can fracture sediment formations.

        For sewage treatment effluent wells, where injectate may meet primary drinking water
standards, operation and maintenance requirements may be less severe than for other categories of
Class V injection wells, such as solution mining wells. However, injection of effluent that meets primary
drinking water standards does not guarantee that operation and maintenance problems will be
minimized (Dernlan, 1999; Driscoll, 1986).  Close control of injectate solids content, chloride
concentration, temperature, pH, and other water quality factors are important to maintain the long term
operation of the injection well. Chloride concentrations in injectate of greater than 500 mg/1 and TDS
concentrations greater than 1,000 mg/1 (i.e., twice the secondary MCLs for these constituents) can
contribute to corrosion. High injectate pH (above 7.5) can contribute to well incrustation and iron
precipitation can occur at iron concentrations as low as 0.25 mg/1 (i.e., below the secondary MCL of
0.3 mg/1). Magnesium can precipitate at concentrations as low as 0.2 mg/1 if the pH is high in the
presence of dissolved oxygen. Dissolved oxygen concentrations greater than 2 mg/1 indicate a
corrosive environment (Driscoll, 1986). Regardless of injectate quality, the injection well facility should
have regularly scheduled maintenance and well inspections that are conducted by the facility operator
and are independent of any scheduled state UIC program inspections.

       Two types of fouling have been reported in sewage treatment effluent wells operating in Florida
(Kwader, 1999).  Injectate containing a high concentration of dissolved oxygen can cause precipitation
of calcium and magnesium from minerals from the injectate which can form scale that can plug screens
and boreholes. Oxygen and elevated levels of reduced iron (iron sulfide)  can promote growth of iron-
reducing bacteria that can also cause plugging of injectate receiving zones.

                                                                                             86

-------
       6.2.2  Well Cleaning and Rehabilitation

       Sewage treatment injection wells are subject to clogging and scaling, and therefore wells and
ancillary equipment should be cleaned regularly. Regular cleaning will reduce the frequency of clogging
and the subsequent possibility of well degradation or failure due to greatly reduced infiltrative capacity
or increase in well pressure.  In some cases, anti-sealants, chlorine, corrosion inhibitors, or
bacteriostatic agents may be injected into wells (Rayburn, 1999; Driscoll, 1986). Mineral deposits
from well incrustation (e.g., calcium carbonate) are typically removed by injecting a strong solution of
hydrochloric, sulfamic, or hydroxyacetic acid into the well to dissolve deposits. Driscoll (1986)
reported that for an 4 inch diameter well, approximately 1 gallon of 30 percent hydrochloric acid
solution would be needed for every foot of well screen, and approximately 15 gallons per foot would
be needed for a 16 inch diameter well.  Chlorine, hypochlorite, chlorine dioxide, potassium
permanganate, and other strong oxidizing agents are used for control of bacterial contamination in wells.

       6.2.3  Emergency Response

       The injection well facility should be prepared to address any evidence of well failure or ground
water contamination. In some cases, emergency response provisions are incorporated into operating
permits for injection wells. Although many sewage treatment effluent injection wells do not normally
inject effluent that can contaminate ground water, systems should be prepared to respond to
emergencies that may occur as a result of a breakdown in the treatment and injection processes.
Indications of contamination may include "surface seeping of wastewater, monitoring well data showing
that the wastewater plume has moved outside of its intended area, algae growth near coastal areas
where a nexus between ground water and surface water exists, mechanical integrity failure, and an
increase or decrease in annular pressure." (USEPA, no date). Environmental  damage cases for the
Hawaii UIC program involved surface seepage of injectate, resulting in contamination of surface water
with injectate nutrients (i.e., nitrogen, phosphorous). If contamination is detected, the injection well
should be removed from operation while the potential contamination and its source are investigated
(USEPA, no date).

       6.3    Injectate Treatment

       6.3.1  Denitrification

       Denitrification is a biological process for the conversion of ammonia or nitrates in wastewater
effluent to elemental nitrogen gas.  This process may be effective in limiting the potential for
environmental damage. Denitrification technologies for Fixed Growth Reactors and Suspended Growth
Reactors  are identified as BADCT in the Draft ADEQ BADCT Guidance Document. Denitrification
occurs through biological reaction of nitrified wastewater in an anoxic environment with bacteria and an
additional source of carbon (e.g., methanol) which may be fed to the reactor along with the wastewater.
Mixing in Suspended Growth Reactor vessels may be accomplished using equipment similar to
standard flocculation equipment. The denitrified wastewater is then aerated for 5 to 10 minutes to strip
out the nitrogen gas which would otherwise inhibit settling of the wastewater sludge.  Settled sludge may

                                                                                            87

-------
either be returned to the denitrification system or disposed of. Denitrification may also be conducted in
a fixed film reactor similar to a pressure filter or a gravity deep bed filter, using either coarse or fine
media and either an upflow or downflow configuration. A supplemental source of carbon (e.g.,
methanol) is also required for Fixed Growth Reactor denitrification, however Fixed Growth Reactors
require less contact for denitrification than do Suspended Growth Reactors, and can accept a higher
hydraulic rate of application than Suspended Growth Reactors.

       The ADEQ Draft Guidance Document indicates that these technologies are well developed at
full scale, but that economic considerations are a factor in the level of denitrification that can be
achieved.  The Guidance Document notes that denitrification processes may readily achieve wastewater
effluent concentration as low as 1 mg/1 total nitrogen, but notes that the ability to achieve these treatment
levels depends upon skilled operators and requires reliably controlled pH, temperature, and chemical
feed rates. The Guidance Document notes that small package treatment plants can readily achieve
wastewater effluent concentrations between 5 mg/1 and 10 mg/1 total nitrogen (ADEQ, 1998).

       6.3.2  Microbial Removal

       The Draft ADEQ Guidance Document notes that certain site characteristics may act to remove
pathogens from wastewater prior to entry into ground water. However, the BADCT for direct
discharge into ground water is defined as the absence of pathogens. Because filtration and sorption of
pathogens are media-specific, and not well-quantified in the literature, the Draft
Guidance Document requires that these properties be tested in situ or in laboratory columns before they
can be applied to BADCT.

       In general, removal of pathogens from sewage treatment effluent has been achieved through
chlorination. The dosage of chlorine required to remove pathogens will depend upon the quality of the
influent to the treatment system and the effectiveness of any prior treatment processes. However,
heavy doses of chlorine to domestic wastewater can cause the formation of chlorinated organic
compounds, including trihalomethanes (Kwader, 1999). For this reason, the ADEQ  does not consider
chlorination to be BADCT for new wastewater treatment systems.

       6.4    Chlorine Use Reduction

       According to the ADEQ BADCT Guidance Document, new wastewater effluent disinfectant
technologies such as ozonation, ultraviolet exposure, and use of other chemicals are gaining acceptance
as alternatives to wastewater chlorination because of concerns over byproducts formed during
chlorination. (ADEQ, 1998).  Chlorination of domestic and municipal wastewater effluent, which
contains high concentrations of organic matter, will result in the formation of trihalomethanes, including
bromoform, chloroform, chlorodibromomethane, and dichlorobromomethane, which are priority
pollutants. ADEQ does not consider wastewater effluent chlorination or treatment with chlorine
derivatives to be BADCT for new wastewater treatment facilities, based on the potential for formation
of carcinogenic byproducts from chlorination, and because equivalent treatment technologies  (e.g.,
ozonation, ultraviolet exposure) for pathogens are available and demonstrated.

                                                                                          88

-------
       Wastewater subjected to secondary treatment may not meet MCLs for biological constituents
such as fecal coliform. Discharges of primary and secondary treated effluent have increased potential
for impacts to ground water and surface water quality.  Discharges of tertiary treated effluent have
lower potential for impacts to ground water and surface water quality; however, treated wastewater
may include chlorination byproducts and other products for which MCLs or injectate discharge
standards have not been established, and the potential for effects from chlorination byproducts and
other byproducts for which drinking water standards have not been developed has not been evaluated
(Goldman, 1999; Wilson,  1999). For example, the MCLs for trihalomethanes and haloacetic acids,
which are common byproducts of chlorine disinfection and which are not commonly found in ground
water, are proposed to be lowered in the future.   In-situ degradation of trihalomethanes and haloacetic
acids has not been studied in detail, but studies of ground water attenuation capabilities for these and
other compounds are being conducted in California and Colorado (Bloetscher,  1999).  Depending
upon the specific degradation characteristics of these compounds in ground water, current operation of
sewage treatment effluent wells may result in elevated concentrations of these compounds in ground
water that could potentially violate the USEPA "non-endangerment" provisions (see 40 CFR
144.12(a), discussed in Section 6.1) in the future (Wilson, 1999).4

7.     CURRENT REGULATORY  REQUIREMENTS

       7.1    Federal Programs

       Several federal, state, and local programs exist that either directly manage or regulate Class V
sewage treatment effluent wells.  On the federal level, management and regulation of these wells falls
primarily under the UIC program authorized by the Safe Drinking Water Act (SOWA). Some states
and localities have used these authorities, as well as their own authorities, to extend the controls in their
areas to address concerns associated with sewage treatment effluent wells.  In addition, USEPA and
states have established regulatory standards, guidelines, and BMPs applicable to municipal wastewater
treatment plants under the Clean Water Act (CWA).

       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, Amerian 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.
        The federal UIC program regulation in 40 CFR 144.12(a) does not generally allow injection of treated water that does
not meet primary MCLs into an ASR well (Wilson, 1999).
                                                                                         89

-------
       Sewage treatment effluent wells 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 sewage treatment effluent wells, are
prohibited from engaging in any injection activity that allows the movement of fluids containing any
contaminant into USDWs, "if the presence of that contaminant may cause a violation of any primary
drinking water regulation ... or may otherwise adversely affect 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 wells, 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
sewage treatment effluent wells (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 which 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 sewage
treatment effluent wells, 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
                                                                                           90

-------
to such contaminants."  State staff should complete all of these steps by May 2003, according to the
final guidance.5

       7.1.2   CWA

       The federal National Pollutant Discharge Elimination System (NPDES) program is predicated
on discharges of effluent to "navigable" waters of the U.S., which are broadly defined (e.g., waters
connected by a culvert to navigable waters are covered). For some states (e.g., Texas), court
decisions have stated explicitly that navigable waters do not include ground water. In contrast, a
number of states define "waters of the state" broadly to include ground water as well as surface water.
Therefore, state Pollution Discharge Elimination System (PDES) Programs frequently are responsible
for permitting injection wells.  When that is the case for state PDES Programs, it is noted and described
in Section 7.2.

       The NPDES program and state PDES programs have established regulatory standards and
guidelines that apply to the operation of municipal wastewater treatment plants under the authority of
the CWA.  BMPs have also been established by the USEPA and the states under the CWA and
associated state laws. These BMPs and state guidelines  are equally appropriate for treatment plants
that discharge to surface water or ground water. Also, as outlined in more detail in Section 7.2, certain
states explicitly classify ground water as "waters of the state" and regulate sewage treatment injection
wells under the state PDES program.   In this case, provisions of the state PDES program apply to both
the treatment facility and the sewage treatment effluent wells.

       7.2     State and Local Programs

       Fifteen states are known to contain sewage treatment effluent injection wells. Arizona,
California, Florida, Hawaii, and Massachusetts each contain a significant number of documented wells.
New York is estimated to have a significant number of wells.

       The statutory and regulatory programs addressing sewage treatment effluent wells in the six
states with the largest numbers of documented or estimated wells, as well as eight other states, vary
widely. USEPA directly implements the UIC Class V program in Arizona, California, Hawaii,
Michigan, and New York. In each  of these states, there is additional state jurisdiction over sewage
treatment effluent wells through state regional water quality boards in California, through the states'
PDES programs in New York and Michigan, through the aquifer protection permit program in Arizona,
and through administration of the UIC program by the state Department of Health (in Hawaii). Florida,
Idaho (for wells deeper than 18 ft.), Massachusetts, New Hampshire, Oregon, and Wyoming are all
UIC Class V Primacy States that issue individual permits for sewage treatment effluent wells.  Idaho
(shallow wells), Texas, and West Virginia, which are also Primacy States, issue either individual permits
or authorize by rule. Attachment A of this volume describes how sewage treatment effluent wells are
addreswed in each of these states.  In brief:
       5 May 2003 is the deadline including an 18 month extension.
                                                                                            91

-------
USEPA Region 9 directly implements the UIC Class V program in Arizona. In addition,
Arizona issues Aquifer Protection Permits to operators of sewage treatment effluent wells, and
requires well operators to meet Best Available Demonstrated Control Technology (BADCT).
The Draft ADEQ BADCT Guidance Document defines the best treatment level or pollutant
concentration which can be achieved by applying BADCT.  BADCT guidelines are discussed
in Attachment A of this volume.  Arizona requires compliance with drinking water standards at
a ground water point of compliance (i.e., ground water depth at site boundary) rather than at
the point of injection, and allows consideration of attenuation characteristics of the formation.
However, the ADEQ reported that in practice, permit applicants for sewage treatment effluent
wells generally propose to meet state ground water quality standards at the point of discharge,
because of the amount of data and associated calculations that applicants would be required to
submit to demonstrate the attenuation of injectate constituents.

USEPA Region 9 directly implements the UIC Class V program in California.  In addition,
Regional Water Quality Boards establish local requirements for underground injection well
siting, construction, and operation.  Injectate is generally required to meet primary drinking
water standards.  In one instance, however, a regional water quality board has permitted at
least one facility to discharge secondary treated wastewater. Regional water quality boards
also set setback requirements for sewage treatment effluent wells on a site-specific basis For
example, the Los Angeles County facility would be required to be a minimum of 150 feet to any
water well, or a minimum of 100 feet from any water course. Counties also may establish their
own requirements. Orange County, for example, prohibits any drinking water well to be
located within 2,000 feet from any sewage treatment effluent well, and has also established a
groundwater protection limit for total nitrogen, rather than only for total nitrates (Olson, 1999).

USEPA Region 9 has direct implementation authority in Hawaii, but the state Department of
Health administers the UIC Class V program.  Hawaii's regulations prohibit the siting of any
new Class V sewage treatment effluent injection well above a USDW, regardless  of the
injectate quality,  and the regulations require that wells be located a minimum of one quarter mile
from any potable drinking water well.  Special buffer zones are required if the well is located in
a caprock formation that overlies a volcanic USDW under artesian pressure, and special
standards apply if the well is constructed above a large void such as a lava tube. Injection wells
in Hawaii may not be operated in a manner that allows movement of a fluid containing
contaminants into a USDW.

USEPA Region 5 directly implements the UIC Class V program in Michigan. In addition, the
Michigan Natural Resources and Environmental Protection Act prohibits discharge of effluent
into "waters of the state". The state defines "waters of the state" to include ground water, and
the state may use this provision to require state permits for sewage treatment effluent wells.

USEPA Region 3 directly implements the UIC Class V program in New York.  In addition,
New York regulations prohibit discharge of effluent into "waters of the state".  The state defines
                                                                                    92

-------
"waters of the state" to include ground water, and the state may use this provision to require
State Pollution Discharge Elimination System permits for sewage treatment effluent wells.

In Florida, a Primacy State for the UIC Class V program, sewage treatment effluent wells must
obtain individual permits.  Class I injection well construction standards may be applied to any
Class V well for which the injectate does not meet primary and secondary drinking water
standards, and operation of an injection well may not violate water quality standards. A
representative of the Florida UIC program indicated that sewage treatment effluent well
injectate in Florida are required to meet primary drinking water standards, but not necessarily
secondary drinking water standards (Wilson 1999).  Sewage treatment effluent wells operating
in Monroe County are required to provide reasonable assurance that the operation of these
wells will not cause or contribute to violation of surface water quality standards.

In Idaho, a Primacy State for the UIC Class V program, wells more than 18 feet deep are
permitted individually permitted, while shallower wells  are permitted by rule. Idaho regulations
specify the minimum distance an injection well may be sited from any ground water source that
may be harmed by bacterial contaminants, based on the flow rate of injectate to the well.
Minimum distance criteria for injection wells with a design flow rate greater  than 5 cubic feet
per second are determined on a case-by-case basis.  However, the location  criteria regulations
do not apply to injection wells that inject fluids that meet all state drinking water standards.
Idaho regulations prohibit contamination of ground water at "any place of beneficial use" with
coliform bacteria, and the regulations allow the Idaho UIC program to recommend BMPs to
reduce coliform concentrations in injected fluids.

In Massachusetts, a Primacy State, facilities discharging effluent to groundwater are required to
obtain either a Major or Minor Ground Water Discharge Permit (GWDP) depending on the
flow rate of injectate. A GWDP requires that no discharge may result in a violation of state
ground water quality standards. Special operating conditions are established in the permit on a
case by case basis.

New Hampshire, a Primacy State, issues permits to discharge to groundwater for at least one
facility for discharge of wastewater effluent that is only subjected to primary treatment and does
not meet drinking water standards. New Hampshire establishes ground water discharge zones
and minimum setback distances for sewage treatment effluent wells, including subsurface
disposal units, on a site-specific basis, depending upon  the quality  of the injectate.  The injectate
is not required to meet primary or secondary drinking water standards at the point of injection,
but ground water at the point of compliance (outside  the ground water discharge zone) is
required to meet ground water quality standards.

Oregon, a Primacy State, has enacted regulations prohibiting operation of any well that would
allow movement of fluids containing contaminants into USDWs or that would cause a significant
degradation of public waters or a public health hazard.  Injection wells in Oregon are subject to
individual permits.  Permit and public notice requirements are less stringent for injection wells

                                                                                     93

-------
with design flow rates less than 5,000 gpd. The Oregon UIC program indicated that facilities
may be constructing systems of injection wells, each with a design flow rate less than 5,000
gpd, for this reason (Eckley, 1999)

Wyoming's UIC Class V program regulates new domestic wastewater treatment plant disposal
facilities that dispose of treated effluent after secondary treatment through individual permits.
The two such systems under development in Wyoming will be required to obtain an individual
permit. Each permit is required to include a "point of compliance" which may be either the
injectate itself or at the location of a down gradient monitoring well. Class V injection wells
may not be located within 500 feet of any active public water supply well, whether or not the
injection well and the public water supply well are located in  different aquifer formations.

Texas is a UIC Class V Primacy State. The single sewage treatment effluent well facility in
Texas received an individual permit to construct.  The Texas Natural Resources Control
Commission (TNRCC) has promulgated specific construction requirements for injection wells,
including sewage treatment effluent wells, but no specific operating requirements, which may be
established by permit on a case by case basis.  A permit may not be issued to any facility that
would allow movement of fluid containing contaminants  into  a USDW, and permits must include
provisions as reasonably necessary to protect fresh water from pollution.

West Virginia is a Primacy State for the Class V UIC  program.  Class V injection wells are
authorized by rule unless the Division of Environmental Protection requires an individual permit
(per state regulations).  Sewage effluent injectate must receive at least secondary treatment
prior to injection.  Owners or operators of wells are required to meet various operating,
monitoring, and reporting requirements, and may be required to take corrective action (e.g.,
closure) if the injection of fluids causes a violation of the primary drinking water rules.
                                                                                     94

-------
                                     ATTACHMENT A
                    STATE AND LOCAL PROGRAM DESCRIPTIONS

       Fifteen states are known to contain sewage treatment effluent injection wells. Collectively,
Arizona, California, Florida, Hawaii, and Massachusetts contain almost 97 percent of the documented
wells. New York may also have a significant number of wells. The following sections summarize the
programs used to control sewage treatment effluent wells in these and other states.

Arizona

       USEPA Region 9 directly implements the UIC Class V program. In addition, under the
Arizona Revised Statutes (Title 49, Chapter 2, Article 3 - Aquifer Protection Permits) any facility that
"discharges" is required to obtain an Aquifer Protection Permit (APP) from the Arizona Department of
Environmental Quality (ADEQ). An injection well is considered a discharging facility and is required to
obtain an APP, unless ADEQ determines that it will be "designed, constructed, and operated so that
there will be no migration of pollutants directly to the aquifer or to the vadose zone."

       Permitting

       The Arizona Aquifer Protection Permit Rules (Chapter 19, sub-chapter 9, October 1997)
defines an injection well as "a well which receives a discharge through pressure injection or gravity
flow." Any facility that discharges is required to obtain an individual APP from ADEQ, unless the
facility is subject to a general permit.  Permit applications must include specified information. This
includes topographic maps, facility site plans  and designs, characteristics of past as well as proposed
discharge, and best available demonstrated control technology, processes, operating methods, or other
alternatives to be employed in the facility.  In  order to obtain an individual permit, a hydrogeologic study
must be performed.  This study must include a description of the geology and hydrology of the area;
documentation of existing quality of water in the aquifers underlying the site; any expected changes in
the water quality and ground water as a result of the discharge; and the proposed location of each point
of compliance.

       Operators must demonstrate that the facility will be designed, constructed, and  operated as to
ensure greatest degree of discharge reduction and aquifer water quality will not be reduced or
standards violated. By  rule, presumptive best available demonstrated control technology, processes,
operating methods or other alternatives, in order to achieve discharge reduction and water quality
standards, are established by ADEQ.

       An APP  may require monitoring, record keeping and reporting, a contingency plan, discharge
limitations, compliance  schedule, and closure guidelines. The operator may need to furnish information,
such as past performance, and technical and financial competence, relevant to its capability to comply
with the permit terms and conditions.  A facility must demonstrate financial assurance or competence
before approval to operate is granted.  Each owner of an injection well to whom an individual permit is
issued must register the permit with ADEQ each year.

                                                                                           95

-------
       ADEQ designates a point or points of compliance for each facility receiving a permit.  The
statute defines the point of compliance as the point at which compliance with aquifer water quality
standards shall be determined and is a vertical plane down gradient of the facility that extends through
the uppermost aquifer underlying that facility. If an aquifer is not or reasonably will not foreseeably be a
USDW, monitoring for compliance may be established in another aquifer. Monitoring and reporting
requirements also may apply for a facility managing pollutants that are determined not to migrate.

       Siting and Construction

       No injection wells may be constructed unless an APP has been completed and approved.
Wells are required to be constructed in such a manner as not to impair future or foreseeable use of
aquifers. Specific construction standards are determined on a case-by-case basis.

       Operating Requirements

       All wells must be operated in such a manner that they do not violate any rules under Title 49 of
the Arizona Revised Statutes, including Article 2, relating to water quality standards, and Article 3,
relating to APPs.  Water quality standards must be met in order to preserve and protect the quality of
waters in all aquifers  for all  present and reasonably foreseeable future uses.  The Arizona UIC program
does not require sewage treatment well injectate to meet primary drinking water standards at the point
of injection, but rather allows applicants for sewage treatment effluent well permits to consider ground
water flow direction, travel time, and attenuation in siting  sewage treatment effluent wells. Mr. Troy
Day of the ADEQ indicated that because a large amount of data are required to conduct the required
attenuation calculations, most sewage treatment effluent well operators in Arizona have accepted permit
conditions requiring injectate to meet drinking water standards at the point of injection (Day, 1999).

       Monitoring Requirements

       Monitoring generally will be required for sewage  effluent treatment wells to ensure compliance
with APP conditions  and that aquifer water quality standards are met as outlined under 49-223 of the
Arizona Revised Statutes. APP establishes, on a case-by-case basis, alert levels, discharge limitations,
monitoring, reporting, and contingency plan requirements. Alert level is defined as a numeric value,
expressed either as a  concentration of a pollutant or a physical or chemical property of a pollutant,
which serves as an early warning indicating a potential violation of any permit condition.  If an alert level
or discharge limitation is exceeded, an individual permit requires the facility to notify ADEQ and
implement the contingency plan.

       The Draft ADEQ Best Available Demonstrated Control Technology (BADCT)  Guidance
Document defines the best treatment level or pollutant concentration which can be achieved by applying
BADCT.  These effluent concentration guidelines are shown in Table A-1.  Site
                                                                                            96

-------
Table A-l. Best Available Demonstrated Control Technology for Domestic and Municipal
               Wastewater Discharges - ADEQ Water Quality Division
PARAMETER
Fecal Coliform
Fecal Coliform
Turbidity
Nitrogen
Fluorides
Hazardous Substances wit
MCLs
Hazardous Substances
without MCLs
Hazardous Substances
pursuant to ARS 49-243. D
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Methoxychlor
2,4,D
2, 4, 5 TP Silvex
Trichloroethane
Carbon Tetrachloride
OPTIMUM REDUCTION
2.2 CFU/100 ml, Geometric Mean
"absence of these pathogenic constituents
the discharge"
1.0 FTU
l.Omg/lto 10.0mg/l
Safe Drinking Water Act MCL
i Safe Drinking Water Act MCL
Action level or concentration representing
E-06 cancer risk
None detectable, based on method detecti
limit
0.05 mg/1
l.Omg/1
0.010 mg/1
0.05 mg/1
0.05 mg/1
0.002 mg/1
0.01 mg/1
0.05 mg/1
0.10 mg/1
0.10 mg/1
0.01 mg/1
0.005 mg/1
0.005 mg/1
NOTES
BADCT for Fecal Coliform for other than
direct discharge to ground water. Drinking
water standard is 1.0 CFU/100 ml
iBADCT for Fecal Coliform for direct
discharge to ground water

Actual value will depend on process type a
size of facility

Except those hazardous substances noted
below
lAction level or concentration, whichever is
lower
iiCategory includes reasonably anticipated a
known carcinogens and "acute hazardous
wastes" per 40 CFR261.33(e) [Discarded
commercial chemical products]
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
Primary MCL
id
id
                                                                                97

-------
characteristics are part of BADCT only to the extent that they control the quality of the discharge
before it reaches the ground water. Dilution of the discharge once pollutants have entered the ground
water is not considered part of BADCT. The Draft Guidance Document describes the types of data
permit applicants may submit to the ADEQ to take into account soil properties, vadose zone
properties, and vadose zone thickness (depth to ground water) in determining BADCT. The ADEQ
reported that in practice, permit applicants for sewage treatment effluent wells generally proposed to
meet state ground water quality standards at the point of discharge, because the amount of data and
associated calculations that applicants are required to submit to the ADEQ to demonstrate the
attenuation of injectate constituents is extremely burdensome to the applicant. As part of the permit
process, permit applicants are generally required to conduct laboratory scale soil column studies and
associated field studies to demonstrate and characterize the attenuation process (Day, 1999).

       Plugging and Abandonment

       Temporary cessation, closure, and post-closure requirements are specified on a case-by-case
basis. The facilities are required to notify ADEQ before any cessation of operations occurs. A closure
plan is required for facilities that cease activity without intending to resume. The plan describes the
quantities and characteristics of the materials to be removed from the facility; the destination and
placement of material to be removed; quantities and characteristics of the material to remain; the
methods to treat and control the discharge of pollutants from the facility; and limitations on future water
uses created as a result of operations or closure activities. A post-closure monitoring and  maintenance
plan is also required. This plan specifies duration, procedures, and inspections for post-closure
monitoring.

       Financial Responsibility

       An individual permit requires that an owner have and maintain the technical and financial
capability necessary to fully carry  out the terms and conditions of the permit. The
owner must maintain a bond, insurance policy, or trust fund for the duration of the permit.

California

       USEPA Region 9 directly implements the UIC program 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 RWQCB that is delegated responsibilities and authorities to coordinate
and advance water quality in each region (Chapter 4 Article 2 WQCA).  A RWQCB 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).
                                                                                           98

-------
       Permitting

       Although the RWQCB 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).

       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).

       Siting and Construction

       Construction standards from Bulletin 74-90 of the Department of Water Resources generally
apply. Orange County, California requires that well operators provide a 2,000 foot distance to the
nearest potable water supply well for all injection wells that inject reclaimed water (treated wastewater
effluent) (Hildebrand, 1999).

       Operating Requirements

       A RWQCB may, in establishing or reviewing any water quality control plan or waste discharge
requirements, or in connection with any action relating to any plan or requirement, may investigate the
quality of any waters of the state within its region (13267(A) WQCA).  The state board may require
any person, including a person subject to a waste discharge requirement, to furnish any information that
may be reasonably required to determine whether the injection well could affect the quality of the
waters of the state  (13267(8) WQCA).

Florida

       Florida has primacy for the  Class V wells. Chapter 62-528 of the Florida Administrative Code
(FAC), effective June 24, 1997, establishes the UIC program, and Part V (62-528.600 to 62-
528.900) addresses criteria and standards for Class V wells.
                                                                                           99

-------
       Class V wells are grouped for purposes of permitting into eight categories. Group 3, Domestic
Wastewater Wells, consists of wells used to discharge effluent or reclaimed water from domestic
wastewater treatment facilities.   The category does not include wells that receive only domestic
wastewater but have the capacity to serve fewer than twenty persons per day, or wells that  receive
non domestic wastewater.  This category therefore can be expected to include most sludge effluent
treatment wells.

       Permitting

       Underground injection through a Class V well is prohibited except as authorized by  permit.  In
addition to other requirements, in Monroe County (the Florida Keys) all Class V Group 3 wells
designed to inject domestic wastewater are required to provide reasonable assurance that operation of
the well will not cause or contribute to a violation of the surface water standards in Chapter 62-302
FAC. Owners and operators are required to obtain a Construction/Clearance Permit before receiving
permission to construct.  The applicant is required to submit detailed information, including well location
and depth, description of the injection system and of the proposed injectate, and any proposed
pretreatment. When site-specific conditions indicate a threat to a USDW, additional information must
be submitted.  Class V Group 3 wells are also required to obtain an  operation permit, not to exceed 5
years. Finally, all Class V wells are required to obtain a plugging and abandonment permit.

       Siting and Construction

       Florida regulation 62-528.605, Well Construction Standards for Class V Wells, contains
construction standards for Class V wells constructed in the state, including wastewater effluent injection
wells that are not Class I wells. The Florida UIC program may apply design standards for Class I wells
to any Class V well "if the Department determines that without the application of Class I permitting
criteria, the Class V well may cause or allow fluids to migrate to an underground source of drinking
water that may cause a violation of a primary or secondary drinking water standard  ... or may cause
fluids of significantly differing water quality to migrate between underground sources of drinking water."
Class I standards will not be required for Class V wells if the injectate meets primary and secondary
drinking water standards. Drilled Class V wells are required to meet the casing  and cementing
requirements of Chapter 62-532 FAC, and wastewater effluent injection wells are required to be cased
at least 60 feet depth with an open hole completion to 90 feet.

       Class V wells are required to be constructed so that their intended use does not violate the
water quality standards in Chapter 62-520 F.A.C. at the point of discharge, provided that the drinking
water standards of 40 CFR Part 142 (1994) are met at the point of discharge.

       Operating Requirements

       All Class V wells are required to be used or operated in such a manner that they do not present
a hazard to a USDW.  Domestic wastewater effluent must meet criteria established in specified rules of
                                                                                           100

-------
the F.A.C.6  Pretreatment of injectate must be performed, if necessary to ensure the fluid does not
violate the applicable water quality standards in 62-520 F.A.C.

       The Florida UIC program classifies aquifers either as USDWs or as "exempted aquifers" for
the purposes of exemption from Class V injection siting requirements or discharge limitations, and uses
a concentration threshold of 10,000 mg/1 for classification of an "exempt aquifer."

       Sewage treatment effluent wells installed in Monroe County are required as part of the Class V
operating permit application to provide reasonable assurance that operation of these wells will not
cause or contribute to violation of surface water quality standards. According to a representative of the
Florida Department of Natural Resources (FDNR), wastewater treatment effluent injected into wells
located above USDWs in Florida is required to meet primary drinking water standards, however
injectate does not necessarily meet secondary drinking water standards (Wilson, 1999).

       Monitoring Requirements

       Monitoring generally will be required for Group 3 wells, unless the wells inject fluids that  meet
the primary and secondary drinking water standards in 62-550 F.A.C. and the minimum criteria in Rule
62-520, and that have been processed through a permitted drinking water treatment facility. Therefore,
sewage effluent treatment wells can be expected to be monitored, unless the state determines that there
is a reasonable assurance that they will comply with the rule without monitoring. Monitoring frequency
will be based on well location and the nature of the injectate and will be addressed in the permit.
Group 3 wells will be required to submit periodic reports.

       Plugging and Abandonment

       The proposed plugging method will be approved as a condition of the permit.

Hawaii

       USEPA has UIC direct implementation authority in Hawaii, but the state Department of Health
administers the UIC Class V program.  Chapter 23 of Title 11 of the Hawaii Administrative Rules
(HAR), effective July 6, 1984, amended November 12, 1992, establishes the state UIC program.

       Permitting

       Class V wells are grouped for purposes  of permitting into 6 subclasses. Both the Subclass A
and Subclass AB well categories include sewage injection wells.  Subclass A wells inject fluids into
USDWs; Subclass AB inject only into exempted aquifers. Nonresidential waste disposal systems that
receive solely sanitary wastes from buildings that generate less than one thousand GPD of wastewater,
however, are excluded from coverage by the UIC rules.
         Rules 62-600.420(l)(d)2, and 62-600.540(2) and (3) or 62-610.660 F.A.C., as appropriate.
                                                                                          101

-------
       No injection well may be constructed unless a permit application has been made and the
construction has been approved.  A permit for injection into USDW will be 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 (11-23-12, 11-23-13, and 11-23-16 HAR). For
injection wells sited "mauka" of the  state-defined UIC line ("mauka" being defined as toward the
Hawaii mountains or toward an encircled protected aquifer) the permit applicant is required to submit
background water quality data, including concentration data for chlorides,  TDS, and coliform, from
several of the water supply wells nearest the proposed location of the injection well.  Permit applicants
are also required to submit a well log, including lithology of injection intervals(s) and confining
formation(s) and physical and structural characteristics of the formations encountered, initial water level,
and subsequent water levels, particularly for artesian conditions, and tidal fluctuations and efficiency.
Permit application documents must be prepared by a licensed Hawaii engineer or geologist.

       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 volcanic USDW
under artesian pressure (11-23-10 HAR).

       State UIC program regulations have prohibited the siting of any new sewage treatment effluent
well directly above  a USDW since 1984.  The Hawaii UIC program classifies aquifers either as
USDWs or as "exempted aquifers" for the  purposes of exemption from Class V injection siting
requirements or discharge limitations, and uses a TDS concentration threshold of 5,000 mg/1 for
classification of an "exempt aquifer."

       The state UIC program also  has Class V injection well siting criteria requiring that any new well
be sited a minimum of 0.25 miles from any drinking water source, and 0.5 miles from existing drinking
water sources drawing from state-designated artesian aquifers. A buffer zone of at least 50 feet of
confining materials  (e.g., caprock) is required between the bottom of an injection well and the top of a
volcanic  aquifer, and injection pressure is required to remain below the pressure of the volcanic aquifer
or below 2 psi,  whichever is greater. The state regulations also require that in the event that an injection
well is constructed in a large void, such as  a lava tube, the permit applicant must demonstrate that the
void does not slope  inland, by constructing test borings, or is required to construct well such that the
solid cased portion of the well passes entirely through the void.

       Specific 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).
                                                                                            102

-------
       Operating Requirements

       The rules pertaining to wastewater systems (Title 11 Chapter 62 HAR) specify wastewater
effluent requirements applicable to treatment works (11-62-26 HAR) for BOD and suspended solids,
adopt by reference USEPA regulations in 40 CFR 125 and 40 CFR 133, and specify a chlorine
residual for treatment works using a subsurface disposal system other than soil absorption.  They also
specify peak flow and backup requirements for proposed subsurface disposal systems (11-62-25
HAR). Hawaii has established a "total nitrogen" limit of 10 mg/1, rather than a limit for nitrates alone.
The basis for the "total nitrogen" limit is that ammonia  can transform into nitrates in the environment.
The "total nitrogen" limit is therefore considered to be more protective than a standard for nitrates alone
(Olson, 1999).

       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 a manner that does 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). 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 human health.

       Monitoring Requirements

       Operating records generally will be required for sewage effluent treatment wells, including the
type and quantity of injected fluids and the method and rate of injection (11-23-12 HAR).

       Plugging and Abandonment

       An operator wishing to abandon a well must submit an application. The well must be plugged
in a manner that will not allow detrimental movement of fluids between formations (11-23-19 HAR).

Idaho

       Idaho is a Primacy  State for UIC Class V wells and has promulgated regulations for the
underground injection control program in the Idaho Administrative Code (IDAPA), Title 3, Chapter 3.
Deep injection wells are defined as more than 18 feet in vertical depth below the land surface
(37.03.03.010.11 IDAPA). Wells are further classified, with Class V Subclass 5W12 defined as
water treatment plant effluent wells (37.03.03.025.01 .r IDAPA).
                                                                                         103

-------
       Permitting

       Construction and use of shallow injection wells is authorized by rule, provided that inventory
information is provided and use of the well does not result in an unreasonable contamination of a
drinking water source or cause a violation of water quality standards that would affect a beneficial use
(37.03.025.03.d. IDAPA). Construction and use of Class V deep injection wells may be authorized
by permit (37.03.03.025.03.c IDAPA). The regulations outline detailed specifications for the
information that must be supplied in a permit application (37.03.03.035 IDAPA).

       Siting and Construction

       Wells must be constructed by state-licensed well drillers if deeper than 18 feet, and must
conform to the state Minimum Well Construction Standards. The plans for wells that are less than 18
feet deep are reviewed by the Idaho Department of Water Resources, and also may be reviewed by
local authorities (37.03.03.045.04 IDAPA). The proposed location of the well must be described in
the permit application, and if operation of the well could cause unreasonable contamination of a drinking
water source or cause a violation of the water quality standards at a place of beneficial use, the well
cannot be permitted at that site.

       Operating Requirements

       Standards for the quality of injected fluids and criteria for location and use are established for
rule-authorized wells, as well as for wells requiring permits. The  rules are based on the premise that if
the injected fluids  meet MCLs for drinking water for physical, chemical, and radiological contaminants
at the wellhead, and if ground water produced from adjacent points of diversion for beneficial use
meets the water quality standards found in Idaho's "Water Quality Standards and Wastewater
Treatment Requirements," 16.01.02 IDAPA, administered by the Idaho Department of Health and
Welfare, the aquifer will be protected from unreasonable contamination. The State may, when it is
deemed necessary, require specific injection wells to be constructed and operated in compliance with
additional requirement (37.03.03.050.01 IDAPA  (Rule 50)). Rule-authorized wells "shall conform to
the drinking  water standards at the point of injection and not cause any water quality standards to be
violated at the point of beneficial  use" (37.03.03.050.04.d IDAPA).

       Monitoring, record keeping, and reporting may be required if the State finds that the well may
adversely affect a  drinking water source or is injecting a contaminant that could have an unacceptable
effect upon the  quality of the ground waters of the State (37.03.03.055 IDAPA (Rule 55)).

       Idaho UIC program regulations prohibit contamination of ground water at "any place of
beneficial use" with coliform bacterial from operation of any injection well.  Regulation IDAPA
37.03.03. Rule 50.02(b) allows the Idaho Department of Water Resources to recommend the use of
BMPs to reduce the concentration of coliform bacteria in injected fluids. Injection of fluid "containing
or suspected  of containing" fecal contaminants of human origin into any Class V well is prohibited under
IDAPA Rule 50.02(b)(vi). The Department may  also require the use of well treatment technology,

                                                                                          104

-------
including ozonation and chlorination devices, sand filters, and settling pond specifications to reduce the
concentration of coliform bacteria in injected fluids.

       Plugging and Abandonment

       The Idaho Department of Water Resources (IDWR) has prepared "General Guidelines for
Abandonment of Injection Wells," which are not included in the regulatory requirements.  IDWR
expects to approve the final abandonment procedure for each well.  The General Guidelines
recommend the following:

•      If possible, the casing should be pulled.  If casing is not pulled, cut casing a minimum of two feet
       below land surface.  The total depth of the well should be measured. If the casing is left in
       place, it should be perforated and neat cement with up to 5% bentonite can be pressure-
       grouted to fill the hole.  As an alternative, when the casing is not pulled, you may use course
       bentonite chips or pellets.  If the well extends into the aquifer, the chips or pellets must be run
       over a screen to prevent any dust from entering the hole. No dust is allowed to enter the bore
       hole because of the potential for bridging. Perforation of casing is not required under this
       alternative. If well extends into the aquifer, a clean pit-run gravel or road mix may be used to
       fill bore up to  ten feet below top of saturated zone or ten feet below the bottom of casing,
       whichever is deeper, and cement grout or bentonite clay used to surface.  The use of gravel
       may not be allowed if the lithology is undetermined or unsuitable.  A cement cap should be
       placed at top of casing if not pulled, with a minimum of two feet of soil overlying filled hole/cap.
       Abandonment of well must be witnessed by IDWR representative.

       Financial Responsibility

       No financial responsibility requirement exists for rule-authorized wells. Permitted wells are
required by the permit rule to demonstrate financial responsibility through a performance bond or other
appropriate means to abandon the injection well according to the conditions of the permit
(37.03.03.35.03.6 IDAPA).

Massachusetts

       Massachusetts is a UIC Primacy State for Class V wells. The definition  of Class V wells states
that Class V includes injection wells not included in Classes I through IV (310 CMR 27.03(5)).
Injection of fluids through wells is prohibited except as authorized, and provided  there is compliance
with the Environmental Code and the Underground Water Source Protection Rules.  The Division of
Water Pollution Control (DWPC) administers the ground water discharge permit program under 314
CMR 5.00, and GWD permits are used to regulate discharge of liquid effluent (314 CMR 5.03(2)(d)).
A permit is required for any facility that discharges a liquid effluent into a Class V injection well.
                                                                                           105

-------
       Permitting

       Discharge of pollutants to the ground water is prohibited without a Ground Water Discharge
Permit issued by the Massachusetts Department of Environmental Protection (DEP). Discharge of
liquid effluent into a Class V injection well is specifically stated to require a Discharge Permit (314
CMR 5.03).

       Systems required to obtain a Ground Water Discharge Permit (GWPD) will obtain a Minor
GWDP if they discharge from 15,000 gpd to 150,000 gpd. Dischargers in excess of 150,000 gpd, or
providing treatment of sewage more advanced than secondary treatment, which includes
nitrification/denitrification and/or phosphorus removal will obtain a Major GWDP. Both must supply a
complete engineering report, including hydrogeological data, from a Professional Engineer, final
engineering drawings, a ground water monitoring well plan, and supporting information.

       Operating Requirements

       A Ground Water Discharge Permit requires that no discharge may result in a violation of the
Massachusetts Ground Water Quality Standards, and other general conditions (314 CMR 5.19) as
well as special conditions established on a case-by-case basis, and creating effluent limitations,
monitoring, recordkeeping, reporting, compliance schedules, and other specific requirements (314
CMR 5.10). Discharges must meet water quality based effluent limits specified in 314 CMR 5.10(3)(a)
through (c), which vary depending on the  classification of the ground water affected by the discharge.
In addition, for POTWs with design flows greater than 15,000 gpd, technology-based effluent limits are
specified that also vary according to the classification of the ground water into which the discharge
occurs. The state's three ground water classes  and designated uses are established according to 314
CMR 6.00.

       Plugging and Abandonment

       The state's rules do not contain explicit  requirements for plugging and abandonment. However,
they provide that if there is any movement of injection or formation fluids into USDW, the DWPC may
prescribe such additional requirements as  may be necessary for corrective action,  including closure
through plugging and abandonment, to prevent  such movement (310 CMR 27.10).

Michigan

       USEPA Region 5  directly implements the UIC Class V program in Michigan. In addition,
Michigan's Natural Resources and Environmental Protection Act (NREPA)(1994  P.A. 451, Part 31)
prohibits  discharge of any waste  or waste  effluent into the waters of the state without a permit (§
324.3112).  NREPA defines "waters of the State" to include ground waters (§3101) and provides  that
a person may not discharge directly or indirectly into the waters of the State a substance that is or may
become injurious to the public health, safety or welfare, or to domestic, commercial, industrial,
                                                                                         106

-------
agricultural, recreational or other uses that are being made or may be made of such waters
(§3109(l)(a)and(b)).

       Permitting

       The Michigan Department of Natural Resources, Water Resources Commission has
promulgated rules under the authority of Part 31 NREPA for the protection of ground water quality that
provide for the nondegradation of ground water quality in usable aquifers, define the requirements for
hydrogeological study before permitting a discharge into ground waters, and establish ground water
monitoring requirements for ground water discharges (Part 22 Rules 323.2201 - 323.2211). The
Water Resources Commission also has promulgated requirements for wastewater discharge permits
(Part 21 Rules 323.2101- 323.2192). According to these rules, a point source discharge includes a
well from which wastewater is discharged CR 323.2104(vi)) Waste and wastewater are defined
broadly under the rules to include wastewater and waste effluent resulting from industrial and
commercial processes and municipal operations ((R 323.2104(q) and (r)).

       Siting and Construction

       There are no siting or construction requirements or operating requirements for wells injecting
treated effluent from wastewater treatment plants treating only sanitary wastewater.

New Hampshire

       New Hampshire is a Primacy State for Class V UIC wells.  Part Env-Ws 410 of the New
Hampshire Administrative Code (NHAC) establishes the  State's ground water protection program,
which includes underground injection registration.   The State has established a policy that, unless due
to a natural condition or specifically exempted, all ground waters of the State shall be suitable for use as
drinking water without treatment, and that ground water shall not contain any regulated contaminant at a
concentration greater than the ambient ground water standards in Env-.Ws 410.05 (Env-Ws 410.03
NHAC).  However, the rules contain a specific exemption for a discharge within a ground water
discharge zone permitted under a ground water management permit (Env-Ws 410.08 NHAC).

       Permitting

       A ground water discharge permit is required to be obtained by certain categories of discharges.
These include discharge of nondomestic wastewater which contains a regulated contaminant and has
received treatment by BAT before discharge (Env-Ws 410.08(a)(5) NHAC).  Discharge of a
nondomestic wastewater that contains regulated contaminants and does not receive treatment by BAT,
and discharge of nondomestic wastewater that contains a regulated contaminant which exceeds the
ambient groundwater quality standards are both prohibited (Env-Ws 410.07 NHAC). However, a
ground water discharge of a nondomestic wastewater that does not contain a regulated contaminant, if
the discharge is regulated in accordance with Env-Ws 410.32, is considered to have a permit by rule
and to be exempt from the requirements of Env-Ws 410.08 (Env-Ws 410.08(c)(5) NHAC).  Under

                                                                                        107

-------
Env-Ws 410.32, owners of facilities that discharge nondomestic wastewater that does not contain a
regulated contaminant must register the discharge with the state. The information that must be supplied
at registration includes a description of the facility and the types of wastewater handled at the facility,
the wastewater's chemical characteristics, a description of the disposal method, and the discharge rate,
volume, and schedule.  Sampling and analysis may be required. Nondomestic wastewater is not
defined in Part 410 Env-Ws; domestic wastewater is defined as wastewater from human sanitary uses.
Discharge of domestic wastewater from a subsurface disposal system with a design flow equal to or
greater than 20,000 gallons per day also requires a permit.

       Siting and Construction

       The NHDES allows for consideration of site characteristics in applying state Ambient Ground
Water Quality Standards for sewage treatment effluent wells. The New Hampshire Department of
Environmental Services (NHDES) indicated that typical septic system discharge facilities (including
facilities that discharge treated effluent to subsurface disposal units) are required to have a minimum
"setback" distance from the property line such that a Ground Water Discharge Zone (GDZ) can be
established for the attenuation of nitrates and other constituents in the discharge. The minimum required
distance for "nitrate setbacks" for conventional septic system discharges and sewage treatment effluent
wells (i.e., leach fields)  located  in New Hampshire is calculated based on the distance between the
discharge point(s) and the facility  property line. Permit applicants are prohibited from any violation of
state ground water quality standards outside of the GDZ. Any monitored exceedances of state ground
water quality standards within the GDZ require initiation of corrective action, but are not in and of itself
a permit violation (NHDES,  1998).

       The NHDES requires permit applicants to prepare a ground water contour map for the
proposed site of a leach field for treated wastewater effluent. The ground water monitoring wells used
to characterize the site geology  and hydrology are required to be installed under the supervision of a
qualified geologist, and the ground water contour map is also required to be prepared by a qualified
geologist. The contour  map is required to be based on a minimum of two rounds of ground water
elevation measurements. The applicant is also required to submit a receptor map, based on an official
tax map,  showing the locations of all properties and water supply wells within 1000 feet of the ground
water discharge zone (GDZ) of the site (NHDES, 1995).

New York

       USEPA Region 3 directly implements the UIC Class V program in New York.  In addition,
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.  These regulations establish water quality
standards and effluent limitations,  create a state pollutant discharge elimination system requiring permits
for discharges into the waters of the state, specify that such discharges must comply with the standards
in Part 703, and provide for monitoring in Part 756. New York defines groundwater as part of the
waters of the state.

                                                                                          108

-------
       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. 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. Only treated effluent may be
discharged to ground water.  Effluent limits for oil and grease are 15 mg/1, total nitrogen (as N) is 10
mg/1, TDS is 1,000 mg/1,  and foaming agents is 1,000 |ig/l.  Monitoring and reporting requirements in
the SPDES permit must be met.

       Siting and Construction Requirements

       New York law requires all well drillers on Long Island to be licensed (Chapter 338).

Oregon

       Oregon is a Primacy State for UIC 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 an 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. In addition, DEQ administers rules
governing on-site sewage disposal systems (340-071-0100 to 0600 OAR).  Oregon regulations
prohibit the use of reclaimed water (treated effluent) for aquifer storage and recharge (Eckley, 1999).

       Permitting

       Subsurface disposal of sewage treatment effluent is addressed by DEQ under its rules for on-
site sewage disposal.  Although the DEQ is authorized to enter into agreements with local governments
for those governments to become the DEQ's agent in permitting such systems, state staff review and
approve permits for sewage effluent wells. Permits are issued as Water Pollution Control Facility
(WPCF) permits pursuant to 340-071-0162 OAR (340-0710100 (157) OAR).
                                                                                         109

-------
       Permit applications under 340-071-0162 OAR must include, among other requirements, a land
use compatibility statement from the local land use planning agency, a copy of a favorable site
evaluation report, and other specified information. For systems with a design flow of 5,000 gpd or
greater, special public notice requirements are imposed.

       Construction and Operation

       The rules pertaining to all underground injection activities provide that permits for use of waste
disposal wells must include minimum conditions relating to their location, construction, or use and a time
limit for authorized use of such wells (340-044-0035 OAR). In addition, any underground injection
activity that may cause, or tend to cause, pollution of groundwater must be approved by DEQ, in
addition to other permits or approvals required by other federal, state, or local agencies (340-044-
0055 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.

Texas

       Texas is a Primacy State for UIC Class V wells.  The Injection Well Act (Chapter 27 of the
Texas Water Code) and Title 3 of the Natural Resources Code provide  statutory authority for the
underground injection control program.  Regulations establishing the underground injection control
program are found in Title 30, Chapter 331 of the Texas Administrative Code (TAG).

       Permitting

       Underground injection is prohibited, unless authorized by permit or rule (331.7 TAG).  By rule,
injection into a Class V well is authorized, although the Texas Natural Resources Control Commission
(TNRCC) may require the owner or operator of a well authorized by rule to apply for and obtain an
injection well permit (331.9 TAG).  No permit or authorization by rule is allowed where an injection
well causes or allows the movement of fluid that would result in the pollution of an USDW.  A permit or
authorization by rule must include terms and conditions reasonably necessary to protect fresh water
from pollution (331.5 TAG). Sewage treatment effluent wells are not specifically identified in the rules
as Class V wells, but the category is not limited to the well types specified in the  rules (331.11 (a)(4)
TAC).

       Siting and Construction

       All Class V wells are required to be completed in accordance with explicit specifications in the
rules, unless otherwise authorized by the TNRCC.  These specifications are:
                                                                                        110

-------
•      A form provided either by the Water Well Drillers Board or the TNRCC must be completed.
       The annular space between the borehole and the casing must be filled from ground level to a
       depth of not less than 10 feet below the land surface or well head with cement slurry.  Special
       requirements are imposed in areas of shallow unconfmed ground water aquifers and in areas of
       confined ground water aquifers with artesian head. In all wells where plastic casing is used, a
       concrete slab or sealing block must be placed above the cement slurry around the well at the
       ground surface; and the rules include additional specifications concerning the slab. In wells
       where steel casing is used, a slab  or block will be required above the cement slurry, except
       when a pitless  adaptor is used, and the rules contain additional requirements concerning the
       adaptor. All wells must be completed so that aquifers or zones containing waters that differ
       significantly in chemical quality are not allowed to commingle through the borehole-casing
       annulus or the  gravel pack and cause degradation of any aquifer zone.  The well casing must be
       capped or completed in a manner that will prevent pollutants from entering the well. When
       undesirable water is encountered in a Class V well, the undesirable water must be sealed off
       and confined to the zone(s) of origin. (331.132 TAG)

       Operating Requirements

       No operating requirements are specified. Chapter 331, Subpart H, " Standards for Class V
Wells" addresses  only construction and closure standards (331.131  to 331.133 TAG). The
Commission retains the authority to abate and prevent pollution of fresh water resulting from any
injection activity by requiring a permit, by instituting appropriate enforcement action, or by other
appropriate action (331.3( c) TAG).

       Mechanical Integrity Testing

       Injection may be prohibited for Class V wells that lack mechanical integrity.  The TNRCC may
require a demonstration of mechanical integrity at any time if there is reason to believe mechanical
integrity is lacking. The TNRCC may allow plugging of the well or require the permittee to perform
additional construction, operation, monitoring, reporting, and corrective actions which are necessary to
prevent the movement of fluid into or between USDW caused by the lack of mechanical integrity.
Injection may resume on written notification from the TNRCC that mechanical integrity has been
demonstrated (331.4 TAC).

       Plugging and Abandonment

       Plugging and abandonment of a well authorized by rule is required to be accomplished in
accordance with §331.46 TAC (331.9 TAC). In addition, closure standards specific to Class V wells
provide that closure is to be accomplished by removing all of the removable casing and filling the entire
well with cement to land surface. Alternatively, if the use of the well to be permanently discontinued,
and if the well does not contain undesirable water, the well may be filled with fine sand, clay, or heavy
mud followed by a cement plug extending from the land surface to a depth of not less than 10 feet. If
the use of a well that does contain undesirable water is to be permanently discontinued, either the

                                                                                          111

-------
zone(s) containing undesirable water or the fresh water zone(s) must be isolated with cement plugs and
the remainder of the wellbore filled with sand, clay, or heavy mud to form a base for a cement plug
extending from the land surface to a depth of not less than 10 feet (331.133 TAG).

       Financial Responsibility

       Chapter 27 of the Texas Water Code, "Injection Wells," enacts financial responsibility
requirements for persons to whom an injection well permit is issued.  A performance bond or other
form of financial security may be required to ensure that an abandoned well is properly plugged (§
27.073).  Detailed financial responsibility requirements also are contained in Chapter 331, Subchapter I
of the State's UIC regulations (331.141 to 331.144 TAG). A permittee is required to secure and
maintain a performance bond or other equivalent form of financial assurance or guarantee to ensure the
closing, plugging, abandonment, and post-closure care of the injection operation.  However, the
requirement, unless incorporated into a permit,  applies specifically only to Class I and Class m wells
(331.142 TAG).

West Virginia

       West Virginia is a Primacy State for the Class V UIC program. Regulations establishing the
UIC program are  found in Title 47-13 West Virginia Code of State Regulations.  In addition, the state
Board of Health has enacted Sewage Treatment and Collection System Design Standards.  Although
the state does not  define a category of Class V wells as sewage effluent disposal wells, its definitions
specify that they are not exclusive, and that the Class V requirements can cover undefined categories of
wells  (47-13-3.4.5 WVAC).  The Board of Health requirements for sewage treatment works include
specifications for effluent lines to sewage stabilization ponds, anaerobic lagoons, and aerated lagoons,
details on lagoon design, and sludge handling and disposal, requirements for sludge dewatering, sludge
disposal methods, and requirements for land application of sewage effluent. The latter requirements
state that land disposal of effluent that has received primary treatment only shall not be permitted (Part
111, Section 16.1). Finally, the state's Water Pollution Control Act (Title 22 Article 11 of the West
Virginia Code) specifies that it is unlawful  for any person, without a permit, to allow sewage, industrial
wastes, or other wastes, or the effluent therefrom, produced by or emanating from any point source, to
flow into the waters of the state (22-11-8 (b) WVC). Waters of the state are defined to include water
on or beneath the surface (22-11-3 (23) WVC). Outlet is defined as the terminus of a sewer system or
the point of emergence of any water-carried sewage, industrial wastes, or other wastes, or the effluent
therefrom, into any waters of the state, and includes a point source (22-1 l-2(b)(14) WVC).

       Permitting

       Class V injection wells are authorized by rule unless the Office of Water Resources of the
Division of Environmental Protection (DEP) requires an individual permit (47-13-12.4.a. and 47-13-
13.2 WVAC). Injection is authorized initially for five years under the permit by rule provisions.
However, under the authority of the Water Pollution Control Act, sewage effluent wells are permitted
under the WPCA (22-11-8 and 9 WVC).  Permits are based  on an application form containing

                                                                                           112

-------
information required by the DEP and are issued for a period not to exceed five years  (22-11-10 and
11 WVC).

       Operating Requirements

       Under the WPCA, sewage effluent injectate must receive at least secondary treatment prior to
injection.  Quarterly monitoring is required. Under the UIC 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.

       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).

       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).

       Mechanical Integrity

       A Class V well required to obtain an individual permit will be required to demonstrate that the
well has mechanical integrity.

       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.

                                                                                          113

-------
       Financial Responsibility

       A Class V well required to obtain an individual permit will be required to demonstrate financial
responsibility for plugging and abandonment.

Wyoming

       Wyoming is a Primacy State for UIC Class V wells. The Wyoming Department of
Environmental Quality, Water Quality Division, oversees the Class V UIC Program.  Wyoming Statute
35-1 l-301(a)(i) & (ii) provides that no person, except when authorized by a permit, may discharge any
pollution or wastes into the waters of the state or alter the physical, chemical, radiological, biological, or
bacteriological properties of any waters of the state.  All groundwater within Wyoming, including water
in the vadose zone, is considered water of the state.

       Permitting

       On April 14,  1998, the Water Quality Division promulgated Chapter 16, Wyoming Water
Quality Rules and Regulations (WWQR&R) establishing the underground injection control program.
Sewage treatment effluent wells are defined either as 5E4 wells (new domestic wastewater treatment
plant disposal facilities that dispose of treated domestic waste after treatment to at least secondary
treatment standards) or wells falling into the residual Class 5F2 of other facilities that inject fluids into or
above an USDW that are not included in Classes I through IV.  Wells in class 5E4 are required to
obtain an individual permit.  Wells in Class 5F2 also are required to obtain an individual permit (16
WWQR&R Appendix A).

       Individual permit applications are required to include,  among other information, a calculation to
determine the maximum area affected by the injected waste and a detailed description of the area of
review. Information  must be provided about the substances proposed to be discharged, including type,
source, and chemical, physical, and toxic characteristics, construction and engineering details;
information about the receiver and any relevant confining zones; water quality information, including
background water quality data that will facilitate the classification of the ground waters which may be
affected by the proposed discharge, topographic maps showing the facility, bedrock and surficial
geology,  and other wells, springs, subsurface fluid distribution systems, and surface water systems (16
WWQR&R Section 6).  A separate permit  to construct is not required for Class V wells (16
WWQR&R Section  5(a)(v)).

       Siting and Construction

       The Class V UIC rules include construction requirements. All wells must meet the design
standards in Chapter  11, WWQR&R, Parts B and G (which establish  design and construction
standards for municipal and domestic sewage systems, treatment works, and disposal systems and well
construction standards).  They must be constructed to allow the use of testing devices and to provide
for metering of the injectate volume (16 WWQR&R Section  10). The requirements in 11 WWQR&R

                                                                                          114

-------
Part G include requirements for well location, sealing the annular space, surface construction, casing,
sealing strata, and plugging and abandonment. Class V facilities may not be located within 500 feet of
any active public water supply well, regardless of whether the well is completed in the same aquifer.
The minimum distance may be increased, or the well may be prohibited entirely, within a wellhead
protection area, source water protection area, or water quality management plan area (16 WWQR&R
Section 10(n)).

       Operating Requirements

       The extent and design of a monitoring program, including pre-discharge, operational, and post-
discharge monitoring,  sufficient to deal with the pollution potential of the proposed discharge may be
required in the permit (WWQR&R Section 1 l(a)).  All permits must include a point of compliance,
which may be either the point of injection or at downgradient monitoring wells. The operator is also
required to develop and implement a written waste analysis plan, which must be approved by DEQ
(WWQR&R Section 11 (c) and (f)).

       Plugging and Abandonment

       Chapter 16 WWQR&R Section 12 establishes  abandonment standards for all Class V wells.
Section 12(a) through (c) provides that Class V facilities may be abandoned in place if the following
conditions are met and if it can be demonstrated to the satisfaction of the administrator that no
hazardous waste has ever been discharged through the facility; no radioactive waste has ever been
discharged through the facility; all piping allowing for the discharge has either been removed or the  ends
of the piping have been plugged  in such a way that the plug is permanent and will not allow for a
discharge; and all  accumulated sludges are removed from any septic tanks, holding tanks, lift stations,
or other waste handling structures prior to abandonment. Facilities which cannot demonstrate
compliance with these requirements may be abandoned in place if tests are run on sludges accumulated
in the septic tanks, holding tanks, lift stations, or other waste handling structures which shows that none
of these materials contain characteristic hazardous waste or radioactive waste; monitoring of the
groundwater in the immediate area of the facility  shows that there are no toxic materials (substances)
present in the groundwater at levels higher than class of use standards, which are present as a result of
the injection; or some other method acceptable to the administrator.  Facilities which cannot make the
demonstrations required under either approach must be  excavated to the point where contamination is
no longer visible in the soil. At that point, samples shall be taken of the soil for all hazardous
constituents which may have been discharged through the system. Materials excavated shall be
removed from the site for disposal under approval of the Solid and Hazardous Waste Management
Division.
                                                                                           115

-------
                                   REFERENCES

Aqua Resources Incorporated and Earth Technology Corporation.  City of Phoenix. 91st Avenue
Wastewater Treatment Plant Reclaimed Water Study: Technical Memorandum of Injection Well
Feasibility. Phoenix, Arizona:  Greeley and Hansen, 1991.

Arizona Department of Environmental Quality (ADEQ), Water Quality Division, Aquifer Protection
Program. Best Available Demonstrated Control Technology (BADCT) Guidance Document for
Domestic and Municipal Wastewater Treatment. Draft. 1998.

Bloetscher, Frederick. 1999.  Class V underground Injection Control Study: Salt Water Intrusion
Barrier Wells Information Study Deliberative Draft for Discussion and Peer Review. Letter to Ms.
Amber Moreen, USEPA Office of Water, from Mr. Frederick Bloetscher, P.E., Director of
Engineering, Operations, and Planning, Florida Governmental Utility Authority, Tallahassee, Florida.
June 16, 1999.

The Cadmus Group. 1999.  State-by-State Notebooks Compiling Results from the Class V
Underground Injection Control Study.  February 1, 1999.

California Department of Health Services, 1997.  Letter from Ms. Vera Melynk-Vecchio, P.E., District
Engineer, Metropolitan District, Drinking Water Field Operations Branch, California Department of
Health Services, to Mr. Larry Kolb, Acting Executive Director, California Regional Water Quality
Control Board, Los Angeles Region Technical Support Unit. Re: West Basin Municipal Water District
System No. 1990001, Amended Title 22 Reports for Phase II of the Barrier Project, April 2, 1997.

California Regional Water Quality Control Board, Los Angeles Region, 1997. Monitoring  and
Reporting Program No. 7485 for West Basin Municipal Water District and Los Angeles County
Department of Public Works, West Coast Basin Barrier Project, File No. 93-009, February 28, 1997.

California Regional Water Quality Control Board, Los Angeles Region, 1997. Order No.  97-069
Amended Water Reclamation Requirements for West Basin Municipal Water District and Los Angeles
County Department of Public Works, West Coast Basin Barrier Project, File No. 93-009, May 12,
1997.

California Regional Water Quality Control Board, Los Angeles Region, 1995. Letter from  Mr. David
A. Bacharowski, Environmental Specialist IV, Subsurface Regulation Unit, to Mr. Richard  W. Atwater,
General Manager, West Basin Municipal Water District.  Re: Water Reclamation Requirements - West
Basin Barrier Project (File No. 93-09), August 10, 1995.

California Regional Water Quality Control Board, Los Angeles Region, 1997. Letter from Mr. Hubert
H. Kang, Senior Water Resource Control Engineer, to Ms. Virginia Grebbien, West Basin Municipal
Water District.  Re: Amended Water Reclamation Requirements for West Basin Municipal Water

                                                                                      116

-------
District and Los Angeles County Department of Public Works - West Coast Basin Barrier Project
(File No. 93-09), May 16, 1997.

Costello, Marybeth. 1999.  Massachusetts Department of Environmental Protection, Bureau of
Resource Protection.  Telephone Conversation with Mr. Michael Browning, ICF Consulting. March
11, 1999.

Crook, J., T. Asano, and M. Nellor.  "Ground Water Recharge with Reclaimed Water in California."
In Municipal Wastewater Reuse: Selected Readings on Water Reuse. 67-74. Washington, D.C.: U.S.
Environmental Protection Agency, 1991. USEPA 43 0/09-91-022.

Day, Troy. 1999.  Arizona Department of Environmental Quality, Water Quality Division, Aquifer
Protection Program. Telephone Conversation with Mr. Robert Lanza, P.E., ICF Consulting. March 3,
1999.

Dellinger, M. and E. Allen. 1997. "The Geysers Pipeline Project." Geo-Heat Center Bulletin. 18:1,
January  1997.

Dernlan, Gary (gdernlan@co.palm-beach.fl.us). (1999, June 2).  Comments on Draft Class V
Underground Injection Well Study, Volume 21, Aquifer Storage  and Recovery Wells. Electronic mail
to Ms. Amber Moreen (MOREEN. AMBER@EPAMAIL.EPA.GOV), EPA Office of Water, from
Mr. Gary Dernlan, Palm Beach County, Florida.

Deuerling, Richard. 1999. Florida Department of Environmental Protection, Headquarters,
Tallahassee, Florida. Telephone Conversation with Mr. Michael  Browning, ICF Consulting. March,
1999.

Deuerling, Richard. 1999. Florida Department of Environmental Protection, Headquarters,
Tallahassee, Florida. Comments concerning definitions in 40  CFR 44.3 and 146.3 (preamble section
V.F.I) Commenter Number G-I-G1.69, no date.

Driscoll, Fletcher G 1986. Ground Water and Wells, 2nd Ed. Published by Johnson Division, St.
Paul, Minnesota, 1986, Pages 454 - 455, 770 - 772.

Dwarkanath, Amar (adwarkan@mail.city.chesapeake.va.us). (1999, June 10). Comments on Draft
Class V  Underground  Injection Well Study, Volume 21, Aquifer Storage and Recovery Wells.
Electronic mail to Ms. Amber Moreen (MOREEN.AMBER@EPAMAIL.EPA.GOV), USEPA Office
of Water, from Mr. Amar Dwarkanath, Chesapeake City, Virginia.

Eckley, Paul. 1999. Review Comments on Deliberative Draft ASR Wells Information Summary.
Letter to Ms. Amber Moreen (MOREEN. AMBER@EPAMAIL.EPA. GOV), EPA Office of Water,
from Mr. Paul Eckley, P.E., Chief Utilities Engineer, City of Salem, Oregon, Public Works
Department, June 9, 1999.

                                                                                      117

-------
FDEP. 1998. Florida Department of Environmental Protection, Southwest District, UIC Program,
1998.  Draft Permit - Hillsborough County Water Department Reclaimed ASR Project, Flillsborough
County Water Department Northwest Service Area, Facility ID FL0041670, Project No. 29951-001-
UC, no date.

FDEP. 1999.  Inventory of Aquifer Storage and Retrieval System Wells in Florida.  Florida
Department of Environmental Protection, 1999.

EEA. 1995. Permit Application for Solar Aquatic System, All Clear Services, Weare, New
Hampshire. Ecological Engineering Associates, Marion, Massachusetts, May 1995.

EEA. 1999. Ecological Engineering Associates, Weston, Massachusetts, Internet Home Page, August,
1999. Available: http://www.solaraquatics.com/sas.html [1999, August 5]

Fetter, C.W., Jr. and R.G.  Holzmacher.  Ground Water Recharge with Treated Wastewater .  Journal
of the Water Pollution Control Federation, Volume 46, No. 2, February 1974, pp 260 - 270.

Gerba, et. al. 1979.  Failure of Indicator Bacteria to Reflect the Occurrence of Enteroviruses in Marine
Waters. American Journal of Public Health, Volume 69, Pages 1116- 1119, 1979.

Gerba, C.P., and Bitton, G. 1984, Microbial pollutants: their survival and transport pattern to ground
water: in Bitton, G., and Gerba, C.P., (eds.) Ground Water Pollution Microbiology, John Wiley and
Sons, Inc., New York.

Goldman, Dennis. 1999. Class V Injection Well: Sewage Treatment Effluent Injection Wells -Peer
Review Comments.  Prepared by Dr. Dennis Goldman, National Ground Water Association,
Westerville, Ohio, April 12, 1999.

Goodman, Peter. 1999. Kentucky Natural Resources and Environmental Protection Cabinet, Division
of Water. Telephone Conversation with Mr. Michael Browning, ICF Consulting  March 10, 1999.

Grand Traverse County. 1999.  Grand Traverse County, Michigan, Internet Home Page.  Available:
http://kermit.traverse.com/govt/gtcounty/solargh.html [1999, August 5]

Greeley and Hansen, 1991. Aqua Resources Incorporated and Earth Technology Corporation. City of
Phoenix. 91st Avenue Wastewater Treatment Plant Reclaimed Water Study:  Technical Memorandum
of Injection Well Feasibility. Phoenix, Arizona, 1991.

Hauge, Carl.  1999.  California Department of Water Resources, Division of Planning and Local
Assistance. Telephone Conversation with Mr. Michael Browning, ICF Consulting. March 12, 1999.

HDWM. 1997. Sample Results for Kahuku. Paalaa Kai. and Waimanalo Wastewater Treatment
Plants. City and County of Honolulu, Hawaii department of Wastewater Management, 1993 - 1997.

                                                                                       118

-------
Herndon, Roy. 1999. Comments Regarding Draft Summary Report on Aquifer Storage and Recovery
Well Class V Underground Injection Control Study.  Letter to Ms. Amber Moreen, USEPA Office of
Water, from Mr. Roy L. Herndon, District Hydrogeologist, Orange County Water District, Orange
County, California.  July 29, 1999.

Hildebrand, Gary (GfflLDEB@dpw.co.la.ca.us). (1999, June 17).  Comments on Draft Class V
Underground Injection Control Study, Volume 20, Salt Water Intrusion Barrier Wells.  Electronic mail
to Ms. Amber Moreen (MOREEN. AMBER@EPAMAIL.EPA.GOV), EPA Office of Water, from
Mr. Gary Hildebrand, Los Angeles County Department of Water.

Horan, N.J. 1999. Biological Wastewater Treatment Systems. Theory and Operation.  New York:
John Wiley & Sons, 1990, Page 41.

Hyland, Mark 1999. Maine Department of Environmental Protection.  Telephone Conversation with
Mr. Michael Browning, ICF Consulting.  March, 1999.

Joy, Charles L. 1994.  Artificial Recharge of Aquifers. Conference Proceedings of the 1994
Conference on Environmental Engineering, Boulder, Colorado. Published in Critical Issues in Water
and Wastewater Treatment - National Conference on Environmental Engineering. 1994. American
Society of Civil Engineers (ASCE), New York, New York, Pages 376-383.

Keyland, No Date. Additional Notes for Design of Trench System, Permit No. 950230, Keyland
Enterprises, Northfield, New Hampshire, No Date.

Kwader, 1999. Class V Injection Well: Sewage Treatment Effluent Injection Wells - Peer Review
Comments. Prepared by Dr. Thomas Kwader, Ph.D., P.G., URS Greiner Woodward Clyde,
Tallahassee Florida, June 18, 1999.

LARWQCB, 1998.  Los Angeles Regional Water Quality Control Board, Order No. 98-xxx
(tentative) Waste Discharge Requirements for County of Los Angeles Department of Public Works
Malibu Water Pollution Control Plant (File No. 64-049), October 22, 1998.

MCPWD. 1996.  Manatee County Public Works Department. 1996 Annual Summary Report for the
Aquifer Storage and Recovery Wells. Submitted: August 28, 1996.

Manatee County Utilities Department, no date.  Well Completion Diagram—Well B-2. Undated.

Manatee County Utilities Department, no date.  Well Completion Diagram—Wells B-l, C, and A.
Undated.

MCHP. 1997. Sample Results for Aerobic Treatment Units Discharging into a Class V Injection Well.
Monroe County Health Department, Monroe County Florida, 1995  - 1997.

                                                                                     119

-------
Manatee County Utilities Department, no date. Well Completion Diagram—Well D.  Undated

MDEP.  1999a.  Massachusetts Department of Environmental Protection, Bureau of Resource
Protection, 1999. Ground Water Permit Monthly Report Summary Sheet, Edgartown Wastewater
Treatment facility, Edgartown, Massachusetts, Permit No. 24-1, January 1999.

MDEP. 1999b. Massachusetts Department of Environmental Protection, Bureau of Resource
Protection, 1999. Ground Water Permit Monthly Report Summary Sheet, Fuller Pond Condominium
trust, Middleton, Massachusetts, Permit No. 1-250, January 1999.

MDEP. 1999c. Massachusetts Department of Environmental Protection, Bureau of Resource
Protection, 1999. Ground Water Permit Monthly Report Summary Sheet, Easton Schools Complex,
Easton, Massachusetts, Permit No. SE, 0-615, February 1999.

May, Joseph.  1999. Florida Department of Environmental Protection, Southwest District, UIC
Program. Telephone Conversation with Mr. Robert Lanza, P.E., ICF Consulting. March 5, 1999.

Miller, K.J.  1991. "U.S. Water Reuse: Current Status and Future Trends."  In Municipal Water Reuse:
Selected Readings on Water Reuse, 18-24. Washington, D.C.: U.S. Environmental Protection
Agency, 1991. USEPA 43 0/09-91-022

Mills, W.R. Jr. 1991,  "Ground Water Recharge Success."  Water. Environment & Technology
February 1991, Pages 40-44.

Montgomery, J., Water Treatment Principles and Design. John Wiley & Sons, 1985

Murray Consultants.  1998. "Re: Ocean Harbor Estates at Ocean Ridge, Application to Construct a
Class V Injection Well." Letter from Gail L. Murray P.G., Murray Consultants, to Silverman, Mark
A., P.G, Florida Department of Environmental Protection, UIC Department, June 15, 1998.

Musick, Steve. 1999.  Texas National Resource Conservation Commission, Ground Water
Assessment Section, Water Quality Division. Telephone Conversation with Mr. Michael Browning,
ICF Consulting.  March 8, 1999.

NRC. 1996. National Research Council. Use of Reclaimed Water and Sludge in Food Crop
Production.  Washington, D.C.: National Academy Press, 1996, Page 49.

Nellor, Margaret H., Rodger B. Baird and John R. Smyth. 1985. "Health Effects of Indirect Potable
Water Reuse." Journal AWWA 77:7, July 1985, Pages 88-96.

NHDES. 1997.  New Hampshire Department of Environmental Services Ground Water Discharge
Permit Number GWP-840446-O-001, issued to the Town of Ossipee Subsurface Treatment Facility
                                                                                     120

-------
by the New Hampshire Department of Environmental Services Water Supply and Pollution Control
Division, June 25, 1997.

NHDES. 1997a. New Hampshire Department of Environmental Services. Letter from Mr. Mitchell D
Locker, Water Supply Engineering Bureau, NHDES, to Mr. Roland Stockbridge, Town of Ossipee
Water and Sewer Department. Re: Town of Ossipee Wastewater Treatment Facility, Elm  Street,
Ground water Discharge Permit DES #840446, June 25, 1997.

NHDES. 1996a. New Hampshire Department of Environmental Services.  Letter from Mr. Mitchell
D Locker,  Ground water Protection Bureau, NHDES, to Mr. Roland Stockbridge, Town of Ossipee
Water and Sewer Department. Re: Town of Ossipee Municipal Wastewater Treatment Facility, Elm
Street, Ground water Discharge Permit Renewal (GWP 8303-010) for the Discharge of 115,000 GPD
of Septic Tank Effluent to the Municipal Subsurface Leach field System (DES #840446), February 2,
1996.

NHDES. 1996b. New Hampshire Department of Environmental Services.  Ground water  Discharge
Permit Number GWP-950230-W-001, issued to the All Clear Services, Weare, New Hampshire, by
the New Hampshire Department of Environmental Services Water Supply and Pollution Control
Division, February 9, 1996.

NHDES. 1995. New Hampshire Department of Environmental Services. Letter from Mr. Mitchell D.
Locker, Ground water Protection Bureau, New Hampshire  Department of Environmental Services, to
Mr. Robert Phillips, All Clear Services. Re: Weare, Number 950230- All Clear Services Application
for Ground Water Discharge Permit - Review Comments, May 2, 1995.

NHWSPCC. 1983a.  New Hampshire Water Supply and Pollution Control Commission.  Ground
Water Permit Number GWP 8303-010, issued to the Town of Ossipee Subsurface Treatment Facility
by the New Hampshire Water Supply and Pollution Control Commission, March 9, 1983.

NHWSPCC. 1983b.  New Hampshire Water Supply and Pollution Control Commission.
Interdepartment Communication from Mr. Dan Allen, P.E., Director, Ground Water Permit Division, to
Mr. William A. Healy, P.E., Executive Director.  Re: Ground Water Permit Application, Town of
Ossipee, New Hampshire, GWP February 22, 1983.

O'Hare, M., D.M. Fairchild, P.A. Hajali, and L.W. Canter. 1986. Artificial Recharge of Ground
Water. Chelsea, Michigan: Lewis Publishers, 1986.

Olson, Gregg (Olson.Gregg@epamail.epa.gov). (1999, June 23).  Comments on draft Class V
Underground Injection Control Study, Sewage Treatment Effluent Wells, Volume 7.   Electronic mail
to Ms. Anhar Karimjee (KARIMJEE.ANHAR@EPAMAIL.EPA.GOV), USEPA Office of Water,
from Mr. Gregg Olson, USEPA Region 9, San Francisco California.
                                                                                     121

-------
Ossipee, Town of. 1998a. Letter from Mr. Roland C. Stockbridge, Superintendent, Town of Ossipee
Water and Sewer Commission, to Mr. Michael D. Locker, Water Supply Engineering Bureau, New
Hampshire Department of Environmental Services, Re: Sampling Reports to comply with DES Permit
No. 19840406 Subsurface Treatment Facility, March 17,  1998.

Ossipee, Town of. 1998b. Letter from Mr. Roland C. Stockbridge, Superintendent, Town of Ossipee
Water and Sewer Commission, to New Hampshire Water Supply and Pollution Control Commission,
Director of Ground Water.  Re: Test Result of our Subsurface Treatment Facility Monitoring Wells,
May 11, 1998.

Ossipee, Town of. 1998c Letter from Office of Superintendent, Town of Ossipee Water and Sewer
Commission, to New Hampshire Water Supply and Pollution Control Commission, Director of Ground
Water.  Re: Test Result of our Subsurface Treatment Facility Monitoring Wells, June 25, 1998.

Ossipee, Town of. 1993. Letter from Mr. Roland C. Stockbridge, Superintendent, Town of Ossipee
Water and Sewer Commission, to New Hampshire Water Supply and Pollution Control Commission,
Director of Ground Water.  Re: Test Result of our Subsurface Treatment Facility Monitoring Wells,
August 10, 1993.

Paling, W. A. J. 1987. Water Quality Aspects of Artificial Recharge with Treated Wastewater.  Water
S.A. Volume 13, Number 2, pp 95-102, 1987.

Paul, J.H. 1995.  Viral Tracer Studies Indicate Contamination of Marine Waters by Sewage Disposal
Practices.  Applied Environmental Microbiology, Volume 61, Pages 2230 - 2234, 1995.

Paul, J.H. et. al.  1997. Evidence for Groundwater and Surface Marine Water Contamination by
Waste Disposal Wells in the Florida Keys. Water Research, Volume 31, No. 6, Pages 1448-1454.
1997.

Perry, Robert H, PhD, ed. 1975.  Engineering Manual: A Practical Reference of Design Methods and
Data in Building Systems. Chemical. Civil. Electrical.  Mechanical, and Environmental Engineering and
Energy Conversion McGraw Hill Book Company,  1975

Pyne, R. David G. Ground water Recharge and Wells: A Guide to Aquifer Storage Recovery.  Boca
Raton, Florida: Lewis Publishers, 1995.

Rayburn, Chris (crayburn@awwarf.com). (1999, June 18). Comments on Draft Class V
Underground Injection Well Study, Volume 21, Aquifer Storage and Recovery Wells.  Electronic mail
to Ms. Amber Moreen (MOREEN. AMBER@EPAMAIL.EPA.GOV), EPA Office of Water, from
Mr. Chris Rayburn, [affiliation].

Reich, Kenneth D. 1999. Comments on Draft Class  V Underground Injection Well Study, Volume 7,
Sewage Treatment Injection Wells. Memorandum to Ms. Amber Moreen, USEPA Office of Water,

                                                                                     122

-------
from Mr. Kenneth D, Reich, Water Quality Manager, West Basin Municipal Water District, March 26,
1999.

Rhyner, Charles R., Leander J. Schwartz, Robert B. Wenger, and Mary G. Kohrell. 1995. Waste
Management and Resource Recovery.  Boca Raton: Lewis Publishers, 1995, Page 186.

Richtar, Judy. 1999. Florida Department of Environmental Protection, Southwest District, UIC
Program.  Telephone Conversation with Mr. Robert Lanza, P.E., ICF Consulting. February 24, 1999.

Robeck, G. G., et. al. 1962.  Effectiveness of Water Treatment Process in Virus Removal.  Journal of
the American Water Works Association. Volume 54, p. 1279, 1962.

Romero, J.C.  1979. The Movement of Bacteria and Viruses Through Porous Media: Ground Water,
Volume 8, Number 2, Pages 37-48.

Rosenshein, J. S., and Flickey, J.J.  1997. Storage of Treated Sewage Effluent and Storm Water in a
Saline Aquifer. Pinellas Peninsula. Florida. Ground Water. Volume 15, No. 4, Page 291.

San Juan County. 1999.  San Juan County, Washington, Public Works Department Internet Home
Page. Available:  http://www.co.san-juan.wa.us/publicworks/index.html [1999, August 5].

Sloss, E.M., S.A.Geschwind, D.F. McCafferty, and B.R Ritz. 1992. Ground Water Recharge with
Reclaimed Water: An Epidemiologic Assessment in Los Angeles County. 1987-1991.  Santa Monica,
California:  Rand Publishers,  1992.

SWFWMD. no date. Southwest Florida Water Management District Individual Water Use Permit
No. 205387.04.

Teal, J. M., and Peterson,  S.  B.  1993. A Solar Aquatic System Septage Treatment Plant.
Environmental Science and Technology, Volume 27, No. 1, 1993, Pages 34 - 37.

Terada, Calvin. 1999.  U.S. Environmental Protection Agency Region 10. Telephone Conversation
with Mr. Michael Browning, ICF Consulting, March 1999.

Uhlman, Kristine. 1999.  Subject: Class V Underground Injection Control (UIC) Wells. Letter to Ms.
Amber Moreen, USEPA Office of Water, from Ms.  Kristine Uhlman, CGWP,  CPG, SCS Engineers,
PC,  June 21, 1999.

USGS. 1997.  United States Geological Survey. Simulation of Subsurface Storage and Recovery of
Effluent using Multiple Wells. St. Petersburg. Florida. Water-Resources Investigations 97-4024. U.S.
Geological Survey, Reston, VA.
                                                                                      123

-------
USGS. 1998.  United States Geological Survey.  Determination of Ground Water Flow Direction and
Rate Beneath Florida Bay, the Florida Keys, and Reef Tract.  United States Geological Survey Center
for Coastal Geology, St. Petersburg, FL, March, 1999. Available:
http://coastal.er.usgs.gov/projects98/7242-37654.html [1999, March]

USGS. 1993. United States Geological Survey. Geology and Human Activity in the Florida Keys.
United States Geological Survey Marine and Coastal Geology Program, St. Petersburg, FL, October,
1993. Available: http://marine.usgs.gov/fact-sheets/florida.title.html [1999, March]

U.S. EPA. 1984. National Secondary Drinking Water Regulations. Publication No. USEPA 570/9-
76-000.

U.S. EPA. 1987.  U.S. Environmental Protection Agency, Office of Water. Report to Congress:  Class
V Injection Wells. [Washington, D.C.]: U.S. Environmental Protection Agency, Office of Water,
September 1987. USEPA 570/9-87-006.

U.S. EPA. 1997. Source Water and Assessment Program Guidance.  Pub. #EP8 816-R-97-009,
August 1997.

U.S. EPA. 1998. National Primary Drinking Water Regulations. 40 CFR §141.32.

U.S. EPA. 1998. National Secondary Drinking Water Regulations. 40 CFR §143.

U.S. EPA. 1999. National Primary Drinking Water Regulations Technical Fact Sheets. Washington,
D.C.: Office of Water, Office of Ground Water and Drinking Water. Available:
http://www.epa.gov/OGWDW/hfacts.html [1999, March].

U.S. EPA. [no date]. U.S. Environmental Protection Agency (Draft). Publicly Owned Treatment
Works (POTW) Injection Well Systems Guidance. Washington, D.C.: U.S. Environmental Protection
Agency, Office of Water, Page 18.

Warner, Don L. and Jay H. Lehr. 1981. Subsurface Wastewater Injection. The Technology of
Injecting Wastewater into Deep Wells for Disposal.  Berkeley: Premier Press, 1981, Page 234.

WBMWD. 1999. West Basin Municipal Water District. Memorandum from Mr. Kenneth D. Reich,
Water Quality Manager, WBMWD, to Ms. Amber Moreen, Environmental Protection Agency, Office
of Water, Re: Ground Water Injection of Recycled Water in a Liquid Hydrocarbon Recovery System:
Regulatory Aspects of Saving 1 MGD of Potable Water in the West Coast Basin, March 26, 1999.

WBMWD. 1998. West Basin Municipal Water District. Letter from Mr. Paul D. Jones H, P.E.,
General Manager, WBMWD, to Mr. Dennis A. Dickerson, Executive Officer, California Regional
Water Quality Control Board, Los Angeles Regional Technical Support Unit, Re: Annual West Coast
Basin Barrier Project Monitoring Report for 1997, March 30, 1998.

                                                                                      124

-------
Wilson, J., and Noonan, JJ. 1984. Mcrobial Activity in Model I Aquifer Systems: in Bitton, G., and
Gerba, C.P., (eds.) Ground Water Pollution Microbiology, John Wiley and Sons, Inc., New York

Wilson, Karen. 1999.  Comments Regarding Draft Summary Report on Aquifer Storage and Recovery
Well Class V Underground Injection Control Study. Letter to Ms. Amber Moreen, USEPA Office of
Water, from Ms. Karen Wilson, USEPA Region 4, Atlanta, Georgia, no date.

WDEQ. 1989. Wyoming Department of Environmental Quality. Ground Water Pollution Control
Permit, Authorization to Discharge into Underground Receivers (Permit to Inject) UIC 89-391, issued
to Aspens/Teton Pines Water and Sewer District, Jackson, Wyoming, September 15, 1989.

WDEQ. 1993. Wyoming Department of Environmental Quality. Ground Water Pollution Control
Permit, Authorization to Discharge into Underground Receivers (Permit to Inject) UIC 93-168, issued
to Teton Village Water and Sewer District, Teton Village, Wyoming, July 14, 1993.

WDEQ. 1994. Wyoming Department of Environmental Quality. Underground Injection Control
Program Reporting Form for Class 5 Treated Effluent Injection, Teton Village Water and Sewer
District, Permit Number 93-168, December 5, 1994.

WDEQ. 1996. Wyoming Department of Environmental Quality, Five Year Review of Operations,
Aspens/Teton Pines Water and Sewer District, Permit Number 89-391, 1996.
                                                                                      125

-------