CLASS V UNDERGROUND INJECTION FACILITIES

Class V injection facilities are those that inject commercial, industrial, or municipal waste or non-waste products directly into or above a usable aquifer. This department purposely calls these injection "facilities" and not "wells" since Class V facilities include a very wide variety of wells, drainfields, drywells, and leachfields.  ("When is a Septic System Regulated as a Class V Well?")

Class V facilities inject various substances for a multitude of reasons, and almost any type of fluid may be injected into class V wells. By definition, none of these wells inject regulated hazardous wastes since they would be a Class IV facility if they did. At the present time there are over 600 active class V injection facilities in Wyoming and many hundreds of abandoned class V facilities.

Facilities which inject industrial wastes, directly into a useable aquifers have been high priority cases.  In the past, WQD has requested that the owners of industrial class V facilities sample and analyze their waste approximately every 3 years.  As a result of those efforts, we know that the most common problem contaminants are Perchloroethene, Trichloroethene, Dichloroethane, Trichloroethane, various Chlorobenzenes, and Cadmium, Chromium and Lead. When highly contaminated effluent is discovered through the analyses, WQD usually issued a Letter of Violation - requesting that corrective actions be undertaken. In the event that the owner is uncooperative or if the waste is very highly concentrated WQD issued Notices of Violation and Administrative Orders.  This was always done if the results of the waste analyses fail the hazardous waste characteristics. Some letters of violation and all Administrative Orders have required that groundwater investigations be done to determine if the discharge of the waste has created a groundwater contamination problem.

As a result of these investigations, it is now clear that about 30% of high priority class V facilities cause some degree of groundwater contamination. While some of the largest groundwater contamination plumes in Wyoming were caused by high priority class V facilities, few of the required groundwater investigations have found contaminant plumes of any size. At this time, one company has performed a remediation project, and several other companies have monitored plumes. Approximately 30 companies have performed groundwater investigations for one reason or the other. Some of these investigations have been instigated by the companies without WQD request or enforcement.

There are many more acceptable alternatives to subsurface disposal of this type of waste: Many Publicly Owned Treatment Works (POTW's) will now take these wastes, although the analyses requirements are expensive. Commercial class I injection wells can also accept most of these wastes.

With the promulgation of Chapter 16, Wyoming Water Quality Rules and Regulations, injection of industrial wastes in existing Class V facilities without a permit (i.e. General, Individual, or Permit-by-Rule), and all new injections of industrial wastes in Class V facilities has been formally banned.  There are only three Class V facilities injecting industrial waste under permit, and all those facilities are complying with stringent annual monitoring requirements.  If you are reading this and you are injecting any form of industrial waste, you should check to see if you are covered by a permit.  If you are not, you must cease injection immediately and contact the department to register your facility.

There are currently known to exist 451 industrial waste disposal wells in Wyoming. Of these, 442 have been permanently abandoned as a result of our efforts over the last 15 years. 6 of the remaining wells are currently un-used because the buildings they are in are currently vacant. This leaves 3 industrial discharge wells in active use.

Other Class V wells. There are other types of class V wells many of which are quite beneficial. Under W.S. 35-11-301, all of these facilities require a permit under this program. The following table shows some of the many types of permits issued:

 

TYPE

DESCRIPTION

TYPE OF PERMIT

PERMIT EXPIRES

5A1

Direct Heat Re-injection Facilities

General Permit

NA

5A2

Heat Pump/Air Conditioner Return Flow Facilities

General Permit

NA

5A3

Cooling Water Return Flow Facilities

Individual Permit

NA

5B1

Mining, Sand or Backfill Facilities

General Permit

NA

5B2

Aquifer Recharge Facilities

Permit by Rule

NA

5B3

Saline Water Intrusion Barrier Facilities

Individual Permit

NA

5B4

Subsidence Control Facilities

Permit by Rule

NA

5B5

Facilities used to prevent, control or remediate aquifer pollution, which are not owned or controlled by the Department of Environmental Quality.

Individual Permit

NA

5B6

Department Controlled Facilities

Permit by Rule

NA

5B7

Air Sparging Facilities

Permit by Rule

NA

5C1

Air Scrubber Waste Disposal Facilities

Individual Permit

NA

5C2

Water Treatment Brine Disposal Facilities

Individual Permit

NA

5C3

Industrial Process Water and Waste Disposal Facilities

Individual Permit

NA

5C4

Existing Automotive Waste Disposal Facilities

General Permit

Expired

5C4

New Automotive Waste Disposal Facilities

Banned

NA

5C5

Coal Bed Methane Produced Water Injection Facilities

General Permits by Location

5C5-1

5C5-2

5C5-3

NA

5C6

Small Commercial Disposal Systems

General Permit

NA

5D1

Agricultural Drainage Facilities

General Permit

Individual Permit

General Permit Expired May 18, 2000

5D2

Storm Water Drainage Facilities

Individual Permit

NA

5D3

Improved Sinkholes

Individual Permit

NA

5D4

Industrial Drainage Facilities

Individual Permit

NA

5D5

Special Drainage Facilities

Permit by Rule

NA

5E1

Aquaculture Return Flow Facilities

Individual Permit

NA

5E2

Existing Untreated Domestic sewage Disposal Facilities (Cesspools)

Banned

NA

5E3

Domestic Subsurface Fluid Distribution Systems

General Permit

Individual Permit

General Permit Expired August 11, 1999

5E3

Existing Domestic Subsurface Fluid Distribution Systems - Permitted as a small wastewater facility

Permit by Rule

NA

5E4

New Domestic Wastewater Treatment Plant Disposal Facilities

Individual Permit

NA

5E5

Small Domestic Subsurface Fluid Distribution Systems

General Permit

NA

5F1

Cathodic Protection Facilities

Permit by Rule

NA

5F2

All other facilities that inject fluids into or above an underground source of drinking water which do not fall into Classes I, II, III, or IV injection facilities.

Individual Permit

NA

Each of the above types of injections requires that a permit be written specifically for that type of injection. Effort is required to tailor the application to the type of injection and the hazard caused by that type of injection.

Public notice is currently not required for injections which do not require an individual permit.  In the event that any injection is to be done near an existing public water supply well, this department can require an individual permit.  Any facility operator may be required to obtain an individual permit if the circumstances justify that requirement.  Most of these cases are required to report, either quarterly or annually a very short list of monitoring parameters.  Some of the more innocuous cases do not require monitoring and reporting except in the case of a spill.

Average permitting time for Individual Permits varies from 45 to 75 days with most wells being done in less than 60 days. If a potential permittee wishes to insure that the permit will be processed in the shortest amount of time there are certain items which can be done in preparing the application:

1. A minor holdup in a few cases has been the lack of current registration to do business in Wyoming for non-resident corporations. Potential corporate permittees should insure that their status with the Secretary of State is up to date.

2. Application forms must, under both federal and state regulations be signed by qualified individuals. Potential permittees should insure that proper signatures are obtained prior to applying for a permit.

3. All questions on the application form and attachments should be addressed in some form or the other. This department realizes that some information may be difficult to obtain. Applicants should address all information even if that means making estimates rather than obtaining exact information. For example estimating TDS from SP curves on the electric logs.

Coverage under General Permits takes between one week and 30 days, depending on our workload.  Since there is no public notice required for these approvals, the process may take very little time.

Permit by Rule authorizations are automatic as soon as the document is submitted.  The department will issue a formal letter stating that the system is rule authorized, but those letters are not a priority.  It may take several months to obtain such a letter.  The important thing to remember is that you are authorized to inject into rule authorized facilities as soon as you file the paperwork with the department.

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