Water Well Journal
Issue link: http://read.dmtmag.com/i/715953
The most common classes of injection wells are Classes I, II, III, and VI. Class I wells are used to inject hazardous and non-haz- ardous wastes into deep, confined rock formations. Examples of industries using Class I wells include: petroleum refining, metal production, chemical production, pharmaceutical pro- duction, commercial disposal, food production, and municipal wastewater treatment. Class II wells are used only to inject fluids associated with oil and natural gas production, primarily salty produced water. Under EPA rules, Class II wells fall into one of three cate- gories: disposal wells, enhanced recovery wells, and hydro- carbon storage wells. Class III wells are used to inject fluids to dissolve and extract minerals in mining such as salt, uranium, copper, and sulfur. Class IV wells are shallow wells used to dispose hazardous or radioactive wastes into or above a geologic formation that contains an underground source of drinking water. The EPA banned the use of Class IV injection wells in 1984. The only allowable Class IV wells are used to clean up groundwater contaminated by hazardous chemicals. Class VI wells are used as long-term storage to inject car- bon dioxide into deep rock formations to reduce emissions into the atmosphere, also called geologic sequestration. Who regulates them? While there is a broad-sweeping EPA regulation of injec- tion wells, oftentimes the design and construction is regulated at the state level. Since states understand their local lithology and groundwater issues better than federal regulators, EPA grants primacy over regulation to the states. However, states must enforce at a minimum the EPA's standards for injection wells. The EPA says: In general, state and tribal programs must meet minimum fed- eral UIC requirements to gain primacy. If a state or tribe does not obtain primacy, EPA implements the program directly through one of its regional offices. To obtain primacy, the states must meet minimum EPA standards on construction, operation, monitoring and testing, reporting, and closure requirements. According to EPA's website: The EPA has delegated primacy for all well classes to 33 states and three territories; the EPA shares responsibility in seven states; and the EPA implements a program for all well classes in 10 states, two territories, and the District of Colum- bia, and for most tribes. Who designs them? Unfortunately for groundwater contractors, there is no "boilerplate" design for most wells, including injection wells. This can lead to miscommunication of expectations on occa- sion, resulting in frustration for multiple parties. Even though a water well contractor may be more familiar with the job site's subsurface area than a consultant or engi- neer, the contractor gets left out of the design equation at times. "Engineers still rarely contact contractors for their input or info on a project design," says Wayne Westberg, MGWC, of M-W Drilling Inc. in Anchorage, Alaska. "In 48 years, I have only had three approaches where I was offered pay as a sub- consultant." How can groundwater professionals, especially drillers, change the status quo? Westberg stresses changes should be made to the process so groundwater professionals—especially water well contrac- tors—have more input on design. As mentioned earlier, many states have primacy over injection well regulation, so how states regulate them often dictates design issues. Also, some states do not have statewide regulations and therefore refer back to the broad federal rules. Westberg is working to change this near him and give water well contrac- tors in his area a voice in the process. "In Alaska we don't have specific injection well guidelines and even production well guidelines are very skimpy," he says. "This is something we're attempting to address. We just finished, and the association supported BMPs (best manage- ment practices) for non-public wells." Westberg adds better communication should be the goal for everyone. After all, good well design and performance will come from a partnership between all industry professionals. WWJ Lana Straub, with a background in the legal and financial aspects of small business, is the office manager of Straub Corp., Stanton, Texas, an environmental and water well drilling firm owned and operated by her family for more than 50 years. She can be reached at Lana@Straub Corporation.com. Tooling Up View these pages from the U.S. Environmental Protection Agency on injection wells. Main page on injection wells: www.epa.gov/uic Underground injection control classes: www.epa.gov/uic/underground-injection-control-well-classes Class I injection wells: www.epa.gov/uic/class-i-industrial-and-municipal-waste- disposal-wells Class II injection wells: www.epa.gov/uic/class-ii-oil-and-gas-related-injection-wells Class III injection wells: www.epa.gov/uic/class-iii-injection-wells-solution-mining Class VI injection wells: www.epa.gov/uic/class-vi-wells-used-geologic-sequestration-co2 COMMUNICATION from page 43 waterwelljournal.com 44 September 2016 WWJ