What You Need to Know About UIC Class

What You Need to Know About UIC Class V Applications and Updates UIC Class V Application Overview and Discussion of Common Issues and How to Avoid Them Carol Dye, P. G. Underground Injection Control Permits Section Texas Commission on Environmental Quality

UIC Started as a Federal Program UIC is a federal program. UIC was established by the Safe Drinking Water Act (SDWA), passed in 1974. The purpose of UIC is to prevent contamination of underground sources of drinking water (USDW).

Texas Has Primacy EPA has granted primary enforcement authority (“primacy”) for UIC to several states, including Texas.

Class V Wells There are several classes of wells. This presentation focuses on Class V wells.

Texas Rules and Statute State rules have to be at least as rigorous as Federal rules; this means State rules can be more rigorous. Therefore, referring only to Federal rules may result in an application or project that is insufficient to meet the UIC program’s requirements. Texas UIC Class V rules: § Title 30 of the Texas Administrative Code, Chapter 331 (30 TAC 331) § Texas Water Code (TWC) Chapter 27 Remember our purpose is to: 30 TAC 331. 1(a) maintain the quality of fresh water… and …prevent underground injection that may pollute fresh water…

Where Do I send My Application/Correspondence? Physical Address Ms. Lorrie Council, P. G. , Manager Underground Injection Control Section Texas Commission on Environmental Quality MC 233 12100 Park 35 Circle Austin, Texas 78753 or Mailing Address Ms. Lorrie Council, P. G. , Manager Underground Injection Control Section Texas Commission on Environmental Quality MC 233 P. O. Box 13087 Austin, Texas 78711 -3087

TCEQ’s Class V UIC Program Total # of incoming Class V documents for 2017 # of staff reviewing Class V documents # of staff dedicated solely to Class V

Definitions TWC 27(11) • "Injection well" means … a well used for the injection of any other fluid. . . TWC 27(7) • "Fluid" means a material or substance that flows or moves in a liquid, gaseous, solid, semi-solid, sludge, or other form or state. 30 TAC 331. 1(a): • maintain the quality of fresh water… and …prevent underground injection that may pollute fresh water…

Common Mistakes Identity Number of Injection Wells Missing in Action Starting before Receiving Authorization (don’t) Injectate

Identity TCEQ Central Registry relates • facilities (sites) • owners/operators • permits and authorizations • licenses and registrations RN identifies sites • Application data must match the data associated with the RN in Central Registry CN identifies owners/ operators • Application data must match the data associated with the CN in Central Registry DCRP contractors use • Site operator = TCEQ DCRP program manager • CN 604361659

Central Registry Look up your facility in TCEQ’s Central Registry to check the identifying information. https: //www. tceq. texas. gov/

Changes: Core Data Form (TCEQ-10400) https: //www. tceq. texas. gov/permitting/central_registry/guidance. html

Number of Injection Wells, Trenches, Galleries and Temporary Injection Points Count § Temporary injection points, injection trenches and galleries, and permanent injection wells all count against the number you’ve been authorized for. § You can only construct/convert the number we have authorized you for. § If you want to construct more than that number, you must request– and get approval for– an amendment to the number. § If you have not constructed the number you’ve been authorized for, you do not need to request an amendment (to the number).

Number of Injection Wells, Trenches, Galleries and Temporary Injection Points cont’d. Plugging § If you plug an injection well, it still counts. § We will need plugging reports for all the injection wells, etc. you construct before the site can be closed. Replacements § If you inject, find injection is not satisfactory, move over, construct a replacement, and inject in the replacement, this counts as 2. § If you find it’s not satisfactory before you try to inject in it, move over, construct a replacement, and inject in the replacement, this counts as 1.

What to Provide Latitude & Longitude location of the well center of the well field site entrance building location Maps and Tables injection wells, infiltration galleries, etc. wells from which groundwater for injection is being withdrawn clear distinction between wells, etc. that are not being used for injection (for example, monitor wells) and injection wells Analytical Data analytical data on treated groundwater that is being injected analytical data demonstrating how well the remedy is working

Common Map Issues Faded/poor quality copy Symbols are too small Symbols are not distinct enough Well names don’t distinguish between injection and non-injection Shows wells to be constructed in future phases without identifying that they don’t exist currently

Common Map Issues cont’d. Faded/poor quality copy Symbols are too small Symbols are not distinct enough Well names don’t distinguish between injection and non-injection Shows wells to be constructed in future phases without identifying that they don’t exist currently

Missing in Action Well Logs/Construction Diagrams Plugging Reports Status Reports Details in Documents

Well Logs/Construction Diagrams 30 days New Submit request Receive approval construct well, gallery, etc. Submit log or diagram Convert Previously Existing Submit request Submit log or diagram Receive approval Convert well, gallery, etc. Note: Well log name must match the well name. For example, if you’re injecting in “MW-19 A, ” a well log for “MW-19” is not sufficient.

Plugging Reports Site Closure Missing Plugging Reports You can’t close a site until plugging reports have been submitted for all the injection wells, etc! Submit the plugging report within 30 days of plugging If you constructed temporary points (for example, using a push rig), state how the holes were plugged in your status report

Status Reports after the 1 st injection event every 3 months or Status Reports have to be submitted every 6 months or as directed by authorization letter every year even if there have been no activities

Missing in Action: Details for All Documents Send an original + 1 copy of everything Send hard copies; we’re not set up to take e-copies Seals: P. E. or P. G. seals are required by 30 TAC 331. 21 for engineering or geologic work, including applications

Missing in Action: Details for Applications Include the facility county in the application Provide SDS/MSDS (safety data sheet/material safety data sheet) of requested injectates Provide requested well type/construction in addition to requested well number Ensure site does not have an open, pre-existing UIC authorization before requesting a new authorization

Missing in Action: Details for Amendments Provide summary of what has already been authorized Identify re-naming of any well, point, gallery, trench Specify what the requested amendment is seeking

Missing in Action: Amendments Summary Sample Well, etc. Summary Table Sample Injectate Table

Missing in Action: Details in Status Reports Change in owner or operator Change in facility name Change in address for any above Change in consultant or consultant address Provide: § where (which wells were injected in) § when (date) injections occurred § what was injected Core Data Form required

Missing in Action: Details for Revocations Provide status from last status report to present Provide plugging reports If constructed fewer wells, etc. than authorized for, clearly explain how many wells were not constructed Explain variations in plugging report names (for example, INJ-3 A instead of INJ 3 what happened to INJ 3? )

Injectate TWC 27(11) "Injection well" means … a well used for the injection of any other fluid. . . TWC 27(7) "Fluid" means a material or substance that flows or moves in a liquid, gaseous, solid, semi-solid, sludge, or other form or state. For an injectate that hasn’t been authorized under your authorization number, you must request (and get approval for) an amendment to add that injectate. Gasses, such as oxygen and air, are considered injectates and must be authorized before they can be injected. To inject water, you must specify what type of water– for example, municipal potable water, treated groundwater, distilled water.

These Require Authorization! Injectate you’ve used before Gasses, for example: • under a different UIC authorization number • oxygen (for example, i. SOC) • air (for example, air sparging) Water, for example: • treated groundwater • municipal water Solids, for example: • ORC or HRC sock • zero-valent iron

Summary Check Central Registry Injectate • CN & RN • Owner/operator name • Facility name & address • Request an amendment to inject any fluid that’s not on your list of authorized injectates • Oxygen (including i. SOC), hydrogen (including HRC), and air must be authorized • Water must be specified (potable, treated groundwater) and authorized Number of Injection Wells Reports & Applications • Submit well logs/as-builts of authorized wells, etc. within 30 days of constructing • Only construct the number of wells you’ve been authorized for • Submit plugging reports within 30 days of plugging • Plugged wells still count against the total number • Submit an original + 1 copy- with seals- of everything • Clearly distinguish injection wells, etc. & source wells (for groundwater that will be injected) from monitor wells, etc. • Submit status reports on schedule, even if nothing has happened

Contact Information General Contact Information for UIC Underground Injection Control Program MC 233 Texas Commission on Environmental Quality uic@tceq. texas. gov PO Box 13087 Austin TX 78711 -3087 512 -239 -6466

Questions?