Compliance of Class V Injection Wells a High Priority for NPS

You may have heard that National Park Service (NPS) managers have been gathering information on Class V wells to create a servicewide database. Read on to find out what a Class V well is and why NPS is concerned about identifying and determining the compliance status of Class V wells.

What is an injection well?

The Safe Drinking Water Act (SDWA) regulates the nation’s public drinking water supplies and requires action to protect drinking water at its sources, including:

• Rivers

• Lakes

• Reservoir

• Springs

• Groundwater

One sub-set of the SDWA regulations establishes underground injection control programs to protect groundwater aquifers that are drinking water sources. As defined in these regulations, an injection well is simply a well that contains injected fluids. A well includes:

• A bored, drilled, or driven shaft
• A dug hole
• An improved sinkhole
• A subsurface fluid distribution system

What is a Class V injection well?

Injection wells are categorized into six classes, Class I through Class VI. Class V wells are the most common class and are used to inject non-hazardous fluids underground, either above or within aquifers. Based on EPA injection well inventory data for fiscal year (FY) 2016, Class V wells comprise approximately 70% (498,190) of all underground injection wells (708,051) throughout the country. Most Class V wells dispose of wastes such as:

• Sanitary wastes
• Storm water
• Cooling wastewater
• Floor drain discharges from vehicle maintenance shops or car washes

The most common type of regulated Class V well in national parks is the large-capacity septic system (serving 20 or more people per day).

Because Class V wells release fluids near underground sources of drinking water and are so numerous, they can pose significant threats to drinking water if not properly managed. Class V wells are regulated by the U.S. Environmental Protection Agency (EPA) or the state regulatory authority that is authorized by the EPA. At a minimum, owner/operators must provide information about existing Class V wells to the regulatory authority. In many cases, a wastewater discharge permit is required to operate a Class V well, and some states require approval prior to installation. The intention of such requirements is that owners construct, operate, and close Class V injection wells in a manner that protects underground sources of drinking water. More details on identifying Class V wells and understanding compliance requirements can be found in the guidance document, Guidance on EPA Underground Injection Control (UIC) Requirements for Class V Wells.

Why are Class V wells important to NPS?

The Office of Inspector General (OIG) conducted an evaluation from November 2012 to June 2013 to evaluate the Department of the Interior’s effectiveness in managing Class V wells due to their possible impact on ground water. OIG released a final report in March 2014 (U.S. Department of the Interior Underground Injection Control Activities). The OIG provided recommendations to:

• Improve Class V well management
• Ensure compliance with EPA regulations
• Immediately close any banned Class V injection wells

One of these recommendations was to identify all NPS Class V wells and develop a centralized system for tracking existing and new wells. In response to the OIG recommendations, the NPS Headquarters Environmental Management System team has been coordinating efforts over the past four years to:

• Identify non-compliant Class V wells through environmental audits.
• Bring these Class V wells into compliance or properly close them.
• Create a Servicewide database of all Class V wells.

What can concessioners do to support NPS?

First, check to see if Class V wells are part of your concessioner operations. If yes, determine whether they are the responsibility of the park or the concessioner. Next, communicate this information to your park concession specialist and confer with them to confirm responsibility for compliance of the Class V well. Finally, follow through to make sure the Class V well is managed in accordance with applicable requirements.

• Check: To identify Class V wells, conduct a walkthrough and review of the concessioner operations to see if any assigned facilities appear to be Class V wells. The most recent environmental audit report may also contain pertinent information.
• Determine responsibility: To determine whether the concessioner is responsible for maintaining any Class V well system used in operations, you can refer to the NPS concession contract. As specified by the contract, the concessioners must follow and adhere to all applicable EPA and other regulations, including those pertaining to Class V wells. If the contract indicates that the concessioner is not responsible for maintaining assigned facilities that are Class V wells, then NPS will take the lead on compliance with Class V well requirements.
• Communicate: If you have determined that Class V wells are part of the assigned operations, contact the park concession specialist to make sure the park is aware of the existence of the Class V well and together determine appropriate actions.
• Follow through: If the concessioner is responsible for compliance, the concessioner staff should proceed at the direction of, and with involvement of, the park. Keep in mind that NPS or the prior contract holder may have already taken steps with the regulatory authority to register or permit the Class V well. If NPS is responsible for compliance, concessioner staff must still contact and consult with the park to determine what NPS requirements and discharge limitations are applicable to the concessioner’s use of the wastewater system. Finally, any prohibited or banned well that concessioners discover must be reported to the park so that it can be properly and expeditiously closed.

Where can I find additional information?

If you are still not certain whether a new or existing septic system, storm water infiltration system, or other wastewater disposal system that is part of concessioner operations is a Class V well as defined by EPA and associated state regulations, contact your park concession specialist or GreenLine for assistance at 303-987-6820.