1. 8/27/2015 ENDANGERING TYPES OF CLASS V WELLS GEOLOGY SECTION 2012 SEMINAR September 6, 2012 Wichita, KS

2. 8/27/2015 I. Introduction Description of the Underground Injection Control Program (UIC). II. Description of the Problem Class V Wells receiving industrial waste. III. Kansas Department of Health & Environment Requirements Prohibition of directing industrial waste to septic tank-leachfield disposal systems. IV. Resolving the Problem Course of Action. V. Summary Assistance of industry and business, local agencies and the public is needed. A TYPE OF CLASS V UNDERGROUND INJECTION CONTROL (UIC) WELL-DISPOSAL SYSTEM RECEIVING INDUSTRIAL WASTE

3. 8/27/2015 UIC HISTORY Underground Injection Control  Since the 1930’s oilfield brines have been injected into formations containing naturally occurring mineralized water.  Kansas has regulated the injection of oilfield brine since the 1930’s.  Industrial wastes have been injected into deep formations since the 1950’s.  Kansas has regulated the deep injeciotn of industrial waste since the 1950’s. Several incidents nationwide involving pollution were traced to the use of injection wells. It was realized injection activities could contaminate groundwater if not conducted under strict controls. Congress developed the Federal Underground Injection control Program.

4. 8/27/2015 Purpose of the UIC Program Function of the UIC program is to ensure that the injection of fluids is done in a controlled manner that will:  Protect the soils and waters of the state, especially groundwater, from contamination. In Kansas, 90% of the water used is supplied from groundwater.  Protect public health.  Conserve the water resources of the state.

5. 8/27/2015 UIC DEFINITIONS  INJECTION The subsurface emplacement of fluids through a well.  INJECTION WELL A bored, drilled or driven shaft whose depth is greater than the largest surface dimension; or, a dug hole whose depth is greater than the largest surface dimension; or, an improved sinkhole; or, a subsurface fluid distribution system.  SUBSURFACE FLUID DISTRIBUTION SYSTEM An assemblage of perforated pipes, drain tiles, or other similar mechanisms intended to distribute fluids below the surface of the ground. This includes a leachfield system.  FLUID Any material that flows or moves whether it is semi-solid, liquid, sludge or gas.

6. 8/27/2015 Class I Class II Class III Class IV Class V Class VI There are Six Injection Well Classifications

7. 8/27/2015 Class I Injection Wells Regulated by KDHE  These wells inject hazardous waste as defined under the Resource Conservation and Recovery Act (RCRA) and non-hazardous wastes into deep rock formations that are separated vertically from the lowermost source of fresh or usable water by many layers of impermeable shales and limestones.

8. 8/27/2015 Class II Injection Wells Regulated by KCC  These wells are used for injection of fluids brought to the surface in connection with oil and natural gas production. The Kansas Corporation Commission regulates Class II wells.

9. 8/27/2015 Class III Injection Wells Regulated by KDHE  Class III wells inject steam or water into mineral formations, which dissolves or loosens minerals, which are then pumped to the surface and extracted. More than 50 percent of the salt and 80 percent of the uranium extracted in the U.S. are produced this way.  In Kansas the only mineral mined in this manner is salt.

10. 8/27/2015 Class IV Injection Wells  These wells inject hazardous waste as defined under RCRA or radioactive wastes into or above the fresh or usable water zone. These wells are prohibited because they directly endanger the environment and human health. Regulated by KDHE

11. 8/27/2015 Class V Injection Wells Regulated by KDHE  These injection wells are not included in Class I, II, III or IV. Typically Class V wells are shallow wells used to place a variety of nonhazardous fluids, that is those wastes which are not hazardous waste under RCRA, directly below the land surface. The fluid injected into certain types of Class V wells can be non-hazardous, but still contain contaminants.

12. 8/27/2015 I Class VI Injection Wells Regulated by EPA at this time. Class VI wells are used for injection of carbon dioxide for geologic sequestration (geosequestration).

13. 8/27/2015 Examples of Class V Wells In Kansas Open loop heat pump return flow wells. Air conditioning return flow wells. Aquifer remediation wells such as air sparging, pump and treat, remedial compound injection. Large capacity septic systems – potential to serve 20 or more people per day during the year. Aquifer recharge wells. Any septic system receiving motor vehicle or industrial wastes.

14. 8/27/2015 The Problem  Septic tank-leachfield disposal systems receiving industrial or motor vehicle wastewater, pose a significant threat to groundwater supplies. This is due to their construction design which places contamination directly into or just above the groundwater supplies via the leachfield.

15. 8/27/2015 Definitions  DOMESTIC WASTEWATER Is defined as wastewater originating primarily from kitchen, bathroom, and laundry sources, including waste from food preparation, dishwashing, garbage grinding, toilets, baths, showers and sinks.  INDUSTRIAL WASTEWATER Is defined as essentially any wastewater that is not a domestic wastewater.  MOTOR VEHICLE WASTE FLUIDS Is defined as fluids from vehicular repair or maintenance activities.

16. 8/27/2015 Description of the Problem  Contrary to common belief, neither the septic tank or the leachfield provides removal or treatment of most chemicals or contaminants. Most inorganics and organic pollutants are not removed and can migrate into the soil and groundwater.  The primary purpose of a septic tank is to condition wastewater so that it will reduce clogging of the soil in the leachfield.  The leachfield provides further treatment of the effluent by the removal of disease producing organisms by the percolation through the soil, exposure to air and filtration.

17. 8/27/2015 TYPICAL SEPTIC TANK - LEACHFIELD

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19. Description of the Problem – Cont.  Chemicals that may enter and contaminate groundwater through a septic tank-leachfield disposal system include: Volatile Organic Compounds (VOCs), heavy metals, and waste oil.  To put the risk or threat to the public health and environment into perspective, consider that 0.25 gallons of the chemical trichloroethylene (TCE) can contaminate the annual amount of water consumed by 4,000 average households.

20. 8/27/2015 Description of the Problem – Cont. EXAMPLES OF FACILITIES THAT MIGHT DIRECT INDUSTRIAL WASTEWATER TO A SEPTIC TANK- LEACHFIELD  Vehicle repair shops  Implement dealers  Furniture strippers  Vehicle washes  Metal finishers  Laundromats  Laboratories

21. 8/27/2015 Description of the Problem – Cont.  Floor Drains and Mud Traps connected to a septic tank-leachfield receiving, or with the potential to receive, industrial wastes creates a prohibited Class V well.

22. 8/27/2015 A sink connected to a septic tank – leachfield receiving, or with the potential to receive industrial wastes creates a prohibited Class V well. Description of the Problem – Cont.

23. 8/27/2015 Description of the Problem – Cont. Locations where septic tank-leachfield disposal systems receiving industrial wastewater might be found:  Rural Areas.  Unsewered areas on the edge of municipalities.  Areas within municipalities that did not connect to a sewer system.

24. 8/27/2015 Resolving the Problem  If unsure the system is a Class V well, contact KDHE UIC Program.  First and foremost is to cease directing the industrial or motor vehicle waste fluids wastewater to the disposal system.  Report this type of Class V well to KDHE for inventory purposes as required by regulation. (Inventory forms available on KDHE website)  Based on inventory information, KDHE will determine if investigation is warranted to determine the impact to the environment.  Identify and implement KDHE approved alternative methods for disposing of the waste.

25. Applicable Regulations: K.A.R. 28-46-26a:Prohibits Class V motor vehicle waste disposal wells. K.A.R. 28-46-27:Used by KDHE to prohibit Class V industrial waste disposal wells. This regulation also used to establish closure requirements. K.A.R. 28-46-34a:Establishes closure requirements for motor vehicle waste disposal wells. K.A.R. 28-46-37:Requires submittal to KDHE of an inventory form. 8/27/2015 Resolving the Problem

26. Alternative waste handling options could include one or more of the following: Connect to municipal sewer system Collect in KDHE approved tank and haul to a municipal wastewater treatment facility. Change operations, no longer produce the wastewater/fluids. Operate dry shop. Recycle/reclamation/reuse. KDHE permitted artificially lined lagoon. 8/27/2015 Resolving the Problem