Title Lorem Ipsum Sit Dolor Amet Who are we? We’re the staff of the

Underground Injection Control Program

at the Department of Environmental Protection Presenter:

Chuck Gentry UIC Inspector Why are we taking part in your training? Because you’re in charge of the Onsite Sewage Disposal Program in your counties and... We can’t do our job without

YOU EPA implements the Underground Injection Control Program, but they’ve delegated administration to West Virginia. States with Enforcement Primacy Versus EPA Direct Implementation

• Primary enforcement authority, often called primacy, refers to state, territory, or tribal responsibilities associated with implementing EPA approved UIC programs.

• A state, territory, or tribe with UIC primacy, or primary enforcement authority oversees the UIC program in that state, territory, or tribe. UIC Well Classes

• Class I industrial and municipal waste disposal wells (WV geology) • Class II oil and gas related injection wells • Class III solution mining wells (Uranium, Sulphur, Copper extraction) • Class IV shallow hazardous and radioactive waste injection wells • Class V wells that inject non-hazardous fluids into or above underground sources of drinking water (USDW) • Class VI geologic sequestration wells (Sequestration of Carbon Dioxide) Class I UIC Well – St. Petersburg Water Reclamation The fluids from this well are injected to a depth of at least 700 feet, below the USDW.

Approximately 30 percent of Class I wells are municipal wastewater disposal wells. These wells are located exclusively in Florida.

A combination of non- hazardous, treated wastewater and make- up water from desalination is injected below the surface.

The predictable local geology is very well suited to this practice. What is our role here at the DEP Groundwater/UIC Department?

EPA regulates the discharges from large scale septic systems to protect groundwater.

Since they delegated the program to WV… we regulate the discharges. What is a large- scale septic system?

It’s a system that serves 20 or more people in a day. So, what does 20 or more people in a day mean anyway? Exactly that - 20 people a day, any day, but maybe not every day. What do we do?

We write permits.

Based on? Your permits!

We implement our program through permits that include federal and state criteria, but we rely on your expertise and authority for the required hardware and installation requirements for the septic system. So you can see why we want to get to know you and work with you because you’re vital to our program. So, the first question we have for a potential applicant is:

Do you have an install permit from the Sanitarian? Once we receive a copy of the permit you issued, we have what we need to start an evaluation of the UIC requirements. Is a permit always required? Well, it might be easiest to answer that question by using actual scenarios instead of bureaucratic gobbledygook.

In fact, a Sanitarian suggested we use scenarios. Smart fellow. We liked his idea so much, we decided to use LOTS of scenarios. Scenarios Campgrounds CAMPGROUND SCENARIO #1

A proposed developer wants to have 10 tent sites at a campground. No water or sewer will be provided at the tent sites, but a bathhouse will be built.

a. Is the magic number 20 for DEP? YES b. Are we still assuming 3 people per tent site? YES c. Why? This is based on the standards the Sanitarian goes by to determine the system is adequate. So the bath-house septic system would need a UIC permit. CAMPGROUND SCENARIO # 2

A developer wants to start a campground that will have 18 RV/campers for yearly rentals that will have water and sewage hookup at each site. No bathhouse. What is the process of approval if all 18 campers are put on one sewage system? The magic number with DEP is 20 people. We assume the number of people per camper based on the permit from the Sanitarian. So this site would need a permit from our program. CAMPGROUND SCENARIO # 3.

In this picture we have 5 RV campsites in each area. What if we install sewage systems to serve each area which is less than 20 people?

Does DEP still need to approve? Yes, but we might not require a permit. Why? Septic systems are intended for domestic sewage only. DEP would need to verify no other waste goes in the system. Wastes include RV toilet chemicals and antifreeze (sometimes used improperly to keep drain lines, pipes, etc. from freezing in winter months.

Generally 6 campers or less per leach field will not require a UIC permit but would require a Groundwater Protection Plan (GPP) that details how alternative wastes are kept from entering the system. What other waste is DEP concerned with?

We’re concerned with all other wastes. Scenario # 3 Continued:

But this scenario brings up another regulatory concept we should incorporate early into our discussion:

the state Groundwater Protection Rule.

Actually, there are 3 rules we need to tell you about today.

The UIC rule delegated from EPA is just 1 that affects DEP permitting decisions. The 2nd rule, the Groundwater Protection Rule requires…

Groundwater Protection Plans

We rely heavily on these plans to bridge the gap between permitting a site versus having no protection for the groundwater at all.

Let’s continue with Scenario # 3 to explore the concept of a GPP versus a UIC permit. So, what should we do with Scenario 3?

• But… A UIC permit is not If there’s only Can anything be domestic waste required done to avoid the UIC Permit when this other waste is a concern? But if there’s something else of A UIC permit is concern in the required waste The answer is…Maybe

Let’s look a closer at this site The on-site sewage disposal plan will be designed for 15 people.

That’s less than 20 for the “magic DEP number”.

So what else matters?

Alternate waste Alternate Waste

We’ll talk quite a bit about alternate waste today. For Scenario # 3, the alternate waste we’re referring to is from the products used to control odor and speed up digestion in the on-board toilets for the RVs.

We can’t say all these products are a worry, but we just don’t know which product an RV owner might use. Some of the products are harmless, others contain chemicals that damage the septic system. How to avoid the UIC Permit for Scenario # 3

Keep the chemicals out of the septic waste, that’s how… but it’s easier said than done.

And truthfully, sometimes its all about… location, location, location! Some RV campgrounds are near commercial or free dump stations.

• The campground operator can insist on the RV waste tank being empty before hook-up to the sewer stub-out. • No chemicals would go into the septic system because they’re dumped beforehand. • The GPP would be drafted to reflect this. But many campgrounds are far from the beaten path…

• These campground operators may not have the option of insisting on empty RV waste tanks. These sites are too far from commercial dump stations. • These are the types of facilities DEP would permit even if less than 20 people are served, unless… Unless, the WV DHHR grants a permit for a holding tank to serve as a dump tank.

• DHHR permits are granted for 6 months at a time and from the website, it looks like the applications are comprehensive. • Some campground operators tell us they’d rather go with the UIC permit. • So what does that entail? UIC Permit requirements for RV campground septic systems

1. Protect the septic area from damage – don’t allow parking over the area. 2. Monthly examination of the leach-field to look for signs of failure or pending failure. 3. Annually, check the sludge build-up in the septic tank, empty the tank when 1/3 full of sludge or at least every five years, whichever comes sooner. 4. Sample and analyze the wastewater after it leaves the septic tank and before it’s released to the underground. 5. Make sure the lab that tests the wastewater is certified by DEP and turn in the lab report to DEP. 6. Be prepared to upgrade the system if chemicals are found during the lab tests. What does it mean to “upgrade” a system?

Usually, it means to increase the size of the leach-field and provide dosing, or alternately sending wastewater to different parts of the field to give an opportunity for evapotranspiration during the “rest period”. Benefits of upgrading the septic system

Transpiration accounts for the movement of water Evaporation accounts for the movement of within a plant and the subsequent loss of water as water to the air from sources such as the soil, vapor through stomata in its leaves in vascular canopy interception, and water bodies. plants and phyllids in non-vascular plants. With evapotranspiration, there’s a better chance the chemical bearing wastewater won’t soak into the ground and wind up in someone’s drinking water well. CAMPGROUND SCENARIO # 4

This campground is for mud-fun enthusiasts In this example, the campground operator has no RV waste concerns, serves less than 20 people a day, but wants to install a coin-operated laundry for his guests. Oops, this brings up another rule, the 3rd one we mentioned a moment ago. This one is called “Special Regulations”. The Special Regs prohibit

discharges from Coin Operated Laundries to septic systems. Scenarios Multi-Family Residences Housing Developments Sometimes, the volume of waste requires the construction of a treatment plant. Usually, the treated wastewater is discharged to a nearby stream authorized by a different type of permit other than UIC.

But

What happens if another permit is not an option? What if the developer has enough land to install a leach-field? Oh, we’re back to “magic number 20”. So, if your standards call for 3 to a household or 4 to a household, we will look at the number of houses times the number of people per home that your permit authorizes and see if that adds up to 20.

If yes, a UIC permit is required. How about an apartment complex that houses 20 or more people? Or a trailer park with 20 residents? Remember the Special Reg? That means we must consider the… laundry.

Some apartments have washer/dryer hookups in the units.

Others & also some trailer parks offer the coin-operated laundry option. We can’t allow those to discharge to a septic system. SCENARIOS Restaurants Restaurant Scenario # 1 The Sanitarian receives a call about a new Pizza restaurant to be built out near the highway and there’s no public sewer out there. The restaurant is branded by a national chain, will have carry- out, drive-thru, and inside seating for 18. The facility will have public restrooms and because it will be open 7 days a week, there’ll be 24 part-time and 4 full-time employees. This is a facility we permit based on the number of people served by the system.

We would also be concerned, just like you, about grease control. You, of course, would decide on the requirements for a grease trap.

We would call for a grease trap inspection & clean-out schedule and we would require sampling of the wastewater for Oils & Grease. Over time, if the operator demonstrated the ability to keep grease out of the wastewater, sampling requirements might be reduced.

Is that likely? Well maybe not for this scenario but smaller operations have been successful controlling grease. Some restaurant managers insist on wiping down pans and other implements and disposing of the waste in the trash bin. Restaurant scenario # 2

This time a country store owner wants to start selling Pizza. You determine public restrooms are not required because this is a carry-out operation only. The hours are limited and there are only 2 employees. No other businesses and no homes are served by the septic system. But you are concerned about grease getting into the septic system, so you require a grease trap. This is not a facility we would permit, provided the operator controls grease.

This is based on the limited number of people served by the septic system.

Instead, we would ask the operator to prepare a Groundwater Protection Plan that includes a grease trap inspection schedule and emptying protocol.

We would ask that the septic tank be pumped out every five years. SCENARIOS Kennels Kennel Scenario #1 Large kennels like the type found at Humane Societies often get lots of visitors. The Humane Society works very hard to find kind, loving homes for dogs and cats and sometimes this leads to advertised adoption events that draw big crowds.

There can still be a lot people found at the shelters, even when special promotions are not taking place. Not only are there actual employees, but plenty of people volunteer their time to help take care of the animals.

The first question the UIC staff would ask about a site like this is will the system serve 20 or more people in a day? If the answer is yes, a UIC permit is required. Kennel Scenario #2

This kennel is smaller. It might be on a farm or other private land where an animal enthusiast makes a little extra cash by operating a kennel. At a site like this, the animals might be kept in a barn during cold weather. The operator’s office may be in the home. A UIC permit would not be required.

There’s less than 20 people served by the system in a day, and the only waste is domestic. Kennel Scenario # 3 Let’s say at this kennel, there are less than 20 people involved, but the owner decides to plumb the kennel to the septic system. What about that concern we expressed earlier about Alternate Waste?

Though we would not require a permit at this site, we would not want dog waste going to the septic system.

Most commercial dog food is largely made up of plants.

Before dogs were domesticated, they primarily lived off wild game or meat, and their diets contained little plant food. Meat is expensive, so today’s dog food contains plants as “fillers”.

The dog gets full, but… plant-based food is not digested by a dog the same way its digested by humans.

This means fibrous materials pass through the dog’s system and ends up as waste.

Septic systems are not efficient treatment systems for dog waste. What to do? Oh, yeah! We go by your permit!

Your install permit is for human waste only.

So we go back to basics and don’t allow the alternate waste, that is, the dog waste to go into the septic system. Remember Kennel Scenario # 1?

We have the same concerns with the non-human waste there too.

So how do we keep dog waste out of the septic system?

Its simple, really. Just ask them to pick up the waste! Are there any other concerns for kennels?

Well, how about dogs that shed?

All that hair could clog up the drains. Actually there’s a solution for dog shedding.

Install fine mesh filter screens in the drains and clean the screens regularly A word about pesticides such as flea killers...

We would ask all kennels to agree to use products that do not contain harmful constituents.

There are plenty of shampoos, sprays, and other products on the market today that aren’t harmful. The UIC requirements for a permit at a kennel are:

1. Protect the area of the septic system – no parking over the system.

2. Examine the area of the system every month to look for signs of failure or pending failure.

3. Yearly, measure the sludge buildup in the septic tank and empty the tank when the sludge fills 1/3 of the tank, or every five years whichever comes sooner.

4. Make sure to keep the drain filter screens cleaned.

5. Pick up dog waste and put it in the trash.

6. Use shampoos and other products that do not contain harsh chemicals. SCENARIOS Churches There’s no question that some churches with on-site septic systems are going to need a UIC permit, based on the number of people that attend services.

But what about churches with smaller congregations?

We don’t want to be iffy, but in this situation a permit may not be needed if: the membership exceeds the attendance records and there really are less than 20 people a day served by the system.

On the other hand, regardless of membership and attendance, if the church holds or allows large gatherings that would end up being served by the septic system, then a permit would be appropriate. Look at this lovely chapel. Can you picture a quaint outdoor wedding on the lawn followed by a reception in the shade? But weddings and receptions out in the country can require a long drive.

Some drives are longer than others, but we can picture folks needing a restroom break sometime during the course of this event.

So, we’re back to whether the septic system serves 20 or more people in a day. The permit requirements for facilities that accommodates large crowds are:

Monthly, examine the area of the septic tank & leach-field to look for signs of failure or pending failure.

Annually, measure the sludge buildup in the tank. Empty when 1/3 full of sludge or every 5 years, whichever come sooner.

Always, protect the septic area from damage – prevent parking over the system. Ok, so our We’ve mentioned Groundwater Protection Plans several times today. Let’s talk about them in more detail now.

• To satisfy the GPP Rule, a facility operator would need to identify the risk posed to groundwater. We identified several of those today.

• There are chemicals found in some products used onboard RVs.

• There are pesticides at kennels and there are the specific issues related to laundries; surfactants getting into groundwater as a concern. Now comes the tough part:

The operator has to explain how groundwater will be protected from the risk he just identified. We try to help operators by giving suggestions such as the examples provided in the discussion today:

• Pick up dog waste.

• Maintain your grease trap.

• Use environmentally friendly products.

But, its up to the operator to decide on a plan to protect groundwater. Next, provide the procedure for adding new equipment or operations.

Most often, folks say they’re not going to add any new equipment and they ask what new operations are you talking about?

So, the simplest answer is to just ask them to write this down:

I will contact my Sanitarian and the DEP to get approval for any new equipment or operations. Though we work together to get the facility properly permitted, no matter how proud we are of our work… the operator still has to summarize all activities carried out under other regulatory programs that have relevance to groundwater protection. The GPP requires the operator to describe all available groundwater quality information for the site. Most people say they don’t have any information like this.

But what if there’s a well on the property? That information should be listed. There’s more…

The operator has to make a statement in the GPP that no waste will be used for de-icer or fill.

Huh?

Yeah, we know…we just ask them to make the statement. Almost finished…

In the GPP, the operator has to include training provisions for employees. The training would explain how to protect groundwater while carrying out their work. Finally, the last element of the GPP!

Quarterly inspections are required. The operator examines all the aspects of his plan, equipment, and procedures that are designed to protect groundwater – and – makes and keeps a record of each inspection. That’s a lot! We’ve talked about permits and GPPs today…but only as they relate to on-site sewage disposal systems. We realize Sanitarians are all-around Protectors of Groundwater

So we want to tell you more about the UIC program so you have as much information as possible about what’s going on in your counties. Oh, but first we found a couple more scenarios. SCENARIOS Roadside Monument The county commission wants to provide restroom facilities at a roadside monument/rest stop off the beaten path for tourism purposes. They have no idea the amount of people that will utilize this facility. Does DEP get involved?

Yes, we would want to be involved. The idea of a permit is doubtful, but we could ask the commission for a Groundwater Protection Plan wherein they state they’ll empty the septic tank on a frequency you and we agree is reasonable. SCENARIOS Dental Offices Metals in wastewater are pretty serious business. There aren’t many dental offices on septic systems, but its common that the wastewater testing shows metals are a problem.

Usually, the dentist installs a small tank to capture the wastewater from patients’ rinsing and then has the wastewater transported to a sewage plant for treatment.

Fillings are made of amalgam. Dental amalgam is a mixture of metals, consisting of liquid (elemental) mercury and a powdered alloy composed of silver, tin, and copper. SCENARIOS Car Washes Remember the Special Regs that prevent discharges from coin-operated laundries to septic systems?

That reg also disallows can washes from sending their wastewater to the systems. We promised to give you more info about UIC permits in your counties. LET’S LOOK AT THE NUMBERS

UIC Sites by County UIC permits

Looks like they’re in every county. These numbers represent UIC Sewage Permits, Stormwater disposal Permits and Industrial Sites. Industrial Sites? Sounds risky… Actually, our program primarily classifies groundwater remediation as “industrial” Permitted UIC Sites by Type in West Virginia

Mining - 49 Stormwater - 34 Industrial -7 Sewage - 238 Underground Injection Control (UIC) Potential Class V Injection Well Form POTENTIAL CLASS V INJECTION WELL/SEPTIC SYSTEM *Submit form to WVDEP only if the facility’s waste is solely sanitary waste that discharges to – Page 1 the subsurface and will serve 20 or more people in a day OR if the subsurface discharge waste stream consists of co-mingled waste, regardless of number of people using the facility. (Co- mingled waste is sanitary waste plus industrial waste, or processed water).

*Submit form for all proposed campgrounds regardless of number of people to be served.

Prohibited subsurface discharges: Auto repair waste, all new large capacity cesspools, new motor vehicle waste disposal wells, coin-operated laundry and commercial laundries.

*Sampling port(s) or distribution boxes with access ways need to be installed on all septic system(s) so that samples can be taken. The sampling port needs to be located right before point of injection to the underground.

*If Sanitarian requires a grease trap on a septic system then routine inspection and necessary clean-out of the grease trap shall be required.

*A groundwater protection plan (GPP) is required for all facilities regardless of needing a UIC permit. The GPP shall outline how the owner will prevent groundwater pollution. If facility does not need a UIC permit then the owner will not need to submit the GPP to this office but rather retain it onsite.

*If waste is stored in a holding tank/dedicated retention tank and not discharged to the underground a UIC permit is not needed. Please refer to appropriate rules & guidelines regarding holding/retention tanks.

Name of Health Department: ______Sanitarian: ______

Sanitarian’s Phone Number: ______Fax Number: ______

Sanitarian’s Email Address: ______Date: ______

Contact Information for Facility

Owner/Operator Person: ______Potential Class V Phone: ______

Injection Well Form Email Address: ______

– Page 2 Mailing Address: ______

Physical address where septic system will be installed: ______

______

Type of facility utilizing the septic system: ______

Number of people using this facility (employees, church members, etc.): ______

Will the facility have restrooms open to the public? ______

Circle the type of waste generated at the facility and describe the common name of waste that will be discharged to the underground:

Solely Sanitary Sewage, Industrial Waste, or Processed Waste? Please describe waste ______

Will the facility prepare food? Yes or No If yes, will fats, oils, & grease be discharged to the subsurface system? ______

Type of appurtenances that is/will be plumbed in to the septic system (grease trap, floor drains, industrial cleaning sinks, etc.): ______

Type of System: Conventional ____Alternative _____

Has a reserve field been designated? ______

Describe how the septic system will operate from beginning to end. For example, facility waste goes grease trap then to septic tank then to the sand filter and onto a dosing chamber with two lines. ______*Has a UIC application/GPP been provided to the applicant by the health department? ______

Potential Class V ______

Injection Well Form Please return this completed form with a copy of the health department application for on-site sewage disposal system to the address listed below. – Page 3

WV DEP – DWWM/UIC 601 57th Street SE Charleston, WV 25304 Fax: 304.926.0497

Industrial, Co-mingled, or Stormwater – Contact Don Criss at 304.354.0474 or [email protected]

Sanitary Sewage Only - Contact Michelle Finney at 304.926.0499 ext. 1047 or [email protected]

WVDEP Application Forms

UIC Sewage Permit Application (Sanitary Sewage only) UIC Industrial Commercial Septic Application (Industrial or Co-mingled) UIC Industrial Commercial Permit Application (Industrial or Co-mingled) UIC Stormwater Permit Application (Stormwater) UIC Groundwater Protection Plan (GPP)

Link to application forms: http://www.dep.wv.gov/WWE/PERMIT/UIC/Pages/default.aspx That’s it, folks. But we would like to give you the names of our team.

A few folks sent their photos so you can recognize them on site. Michelle Finney UIC Permitting Sam Thangasamy

Environmental Resource Analyst James Peterson UIC Inspector Albert Barbery Geologist