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GeoInsighter
Spring/Summer 2005 Newsletter Understanding UNDERGROUND INJECTION CONTROL Return to the Newsletter Index The Massachusetts Department of Environmental Protection (MADEP), in addition to federal and local agencies, regulates discharges from facilities to protect surface water and ground water resources. The Underground Injection Control (UIC) program regulates discharges to shallow injection wells typically found in industrial settings, auto garages, municipalities, and other businesses throughout Massachusetts. Shallow “injection wells” in Massachusetts may include drywells, septic systems tied to floor drains from an industrial/commercial process, leaching catch basins, and oil/water separators connected to leaching fields. Septic systems used solely for sanitary waste disposal (serving less than 20 persons per day) do not qualify as shallow injection wells and, therefore, are not regulated by the UIC regulations, but are, however, regulated by Title 5 (310 CMR 15.000).
UIC History In 1974, the United States Environmental Protection Agency (USEPA) established the UIC program under the Safe Drinking Water Act. In 1982, the USEPA authorized the MADEP to administer and enforce the UIC program. In 1991 and 1992, the MADEP discovered that shallow injection wells were not being installed in accordance with UIC regulations and state plumbing codes and, subsequently, filed legislation to remove inconsistencies between the two programs. In December 1994, the MADEP revised UIC closure requirements to include Massachusetts Contingency Plan (MCP) assessment and response actions. The closure requirements are currently under review and are anticipated to be final in calendar year 2005. On September 13, 2002, the MADEP published UIC regulations 310 CMR 27.00 that required businesses with Class I through Class V shallow injection wells to register prior to use of these wells. The notification deadline for Class V shallow injection well usage was January 1, 2003. According to conversations with representatives of the MADEP, enforcement actions were suspended for a one-year period (until January 1, 2004) to allow municipalities to comply with the new regulations. Regulatory Information According to UIC regulations, use of shallow injection wells is prohibited where the potential exists for oil or hazardous materials to discharge to the subsurface at concentrations that may exceed Massachusetts drinking water standards or, in the opinion of the MADEP, adversely affect human health. Additionally, if a facility is already registered with a ground water discharge, Title 5, or other legal discharge permit, it does not have to register under the UIC program. According to these regulations, unauthorized discharges from shallow injection wells must be discontinued (through a closure process) unless permitted through the appropriate agency and appropriate controls are established. During closure of Class V shallow injection wells, it is important to note that documentation relating to waste disposal (waste water, sludge, etc.) and characterization around the shallow injection well must be provided to the appropriate regulatory agency. With incorporation of MCP closure requirements into the UIC regulations, owners of shallow injection wells must document (during closure) the presence or absence of oil or hazardous material in soil and ground water. If oil or hazardous material is observed, the provisions of the MCP and guidance prepared by the MADEP Bureau of Waste Site Cleanup apply. Depending upon the nature and extent of contamination observed, there are several mechanisms for moving forward with the shallow injection well closure and reporting to the MADEP under the MCP. For instance, prior to a 120-day reporting notification to the MADEP for soil (only) and depending upon the contaminant, a Limited Removal Action (LRA) may be implemented. In some instances, a LRA will reduce concentrations of oil and hazardous materials to below reporting thresholds. Otherwise, the release has to be reported and Release Abatement Measure activities implemented. If a reporting threshold is categorized as a 2‑hour or 72‑hour condition, Immediate Response Actions must be implemented due to the potential risks involved (i.e., human health, environment, public welfare, etc.). Owners and operators of facilities with Class V shallow injection wells may rely upon a Licensed Site Professional to interpret data and identify the appropriate course of action for reporting to the MADEP or remediating a release.
Jarrod P. Yoder, P.G. Return to the Newsletter
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