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The Class V Underground Injection Control Study Volume 3 Storm United States Office of Ground Water EPA/816-R-99-014c Environmental and Drinking Water (4601) September 1999 Protection Agency The Class V Underground Injection Control Study Volume 3 Storm Water Drainage Wells Table of Contents Page 1. Summary ...............................................................1 2. Introduction .............................................................4 3. Prevalence of Wells .......................................................5 3.1 Review of Literature .................................................6 3.2 General Data Collection ..............................................6 3.3 Inventory Model ...................................................9 3.4 Factors Affecting Use and Prevalence of Wells ............................11 3.4.1 Housing and Population Density .................................11 3.4.2 Development ...............................................12 3.4.3 Historical and Political Practices .................................12 3.4.4 Geological Characteristics and Rainfall ............................12 3.5 Future Use of Storm Water Wells ......................................13 4. Injectate Characteristics and Injection Practices .................................14 4.1 Injectate Characteristics .............................................14 4.1.1 Inorganic Constituents ........................................21 4.1.2 Organic Constituents .........................................25 4.1.3 Biological/Microorganism Constituents ............................27 4.2 Well Characteristics ................................................27 4.2.1 Dug Wells .................................................28 4.2.2 Bored Wells ................................................33 4.2.3 Lake Level Control Wells .....................................35 4.2.4 Improved Sinkholes ..........................................36 4.3 Operational Issues and Concerns ......................................37 4.3.1 The Impacts of Siting and Land Use on Injectate .....................37 5. Potential and Documented Damage to USDWs .................................40 5.1 Injectate Constituent Properties .......................................40 5.2 Observed Impacts .................................................41 5.2.1 Storm Water Drainage Well Contamination Incidents .................41 5.2.2 Storm Water Drainage Wells: Other Contamination Incidents and Studies .........................................44 5.2.3 Lake Level Control Wells Contamination Incidents ...................45 6. Best Management Practices ................................................46 6.1 Siting BMPs ......................................................46 6.1.1 Minimum Setback Distance from Surface Waters ....................47 September 30, 1999 Table of Contents (cont’d) Page 6.1.2 Minimum Setback Distance from Drinking Water Wells ...............48 6.1.3 Minimum Separation from Water Table ...........................48 6.1.4 Prohibition from Some Areas of Critical Concern ....................48 6.1.5 Minimum Engineering Design/Soil Performance Specifications ...........48 6.2 Design BMPs .....................................................49 6.2.1 Sediment Removal ...........................................49 6.2.2 Oil and Grease Separators .....................................51 6.2.3 Additional Pretreatment System BMPs ............................55 6.2.4 Studies on the Effectiveness of Pretreatment System BMPs .............57 6.3 Operational BMPs .................................................59 6.3.1 Source Separation ...........................................59 6.3.2 Pollution Prevention Planning ...................................61 6.3.3 Spill Response ..............................................63 6.3.4 Operational BMPs for Common Site Activities ......................63 6.3.5 Monitoring BMPs ...........................................64 6.3.6 Maintenance BMPs ..........................................65 6.4 Education and Outreach BMPs to Prevent Misuse .........................65 6.5 BMPs for Properly Closing, Plugging and Abandoning Storm Water Drainage Wells ..............................................67 7. Current Regulatory Requirements ............................................68 7.1 Federal Programs ..................................................68 7.1.1 SDWA ...................................................68 7.1.2 CWA ....................................................70 7.1.3 CZMA and CZARA .........................................71 7.1.4 FHWA Guidance ............................................72 7.2 State and Local Programs ...........................................72 7.3 Survey of Local Storm Water Utilities ...................................73 Attachment A: State and Local Program Descriptions ...................................74 References ...................................................................88 September 30, 1999 STORM WATER DRAINAGE WELLS The U.S. Environmental Protection Agency (USEPA) conducted a study of Class V underground injection wells to develop background information the Agency can use to evaluate the risk that these wells pose to underground sources of drinking water (USDWs) and to determine whether additional federal regulation is warranted. The final report for this study, which is called the Class V Underground Injection Control (UIC) Study, consists of 23 volumes and five supporting appendices. Volume 1 provides an overview of the study methods, the USEPA UIC Program, and general findings. Volumes 2 through 23 present information summaries for each of the 23 categories of wells that were studied (Volume 21 covers 2 well categories). This volume, which is Volume 3, covers Class V storm water drainage wells. 1. SUMMARY Storm water drainage wells are used extensively throughout the country to remove storm water or urban runoff (e.g., precipitation and snowmelt) from impervious surfaces such as roadways, roofs, and paved surfaces to prevent flooding, infiltration into basements, etc. The primary types of storm water drainage wells are bored wells, dug wells, and improved sinkholes. In addition, “lake level control wells” are used to drain lakes to prevent overflow following heavy precipitation. Subsurface disposal of storm water is prevalent in places where there is not enough space for, or site characteristics do not allow, retention basins; where there is not a suitable surface water to receive the runoff; or where near-surface geologic conditions provide an attractive drainage zone. The runoff that enters storm water drainage wells may be contaminated with sediments, nutrients, metals, salts, fertilizers, pesticides, and/or microorganisms. Storm water sampling data indicate that concentrations of antimony, arsenic, beryllium, cadmium, chromium, cyanide, lead, mercury, nickel, nitrate, selenium, and certain organics (e.g., benzene, benzo(a)pyrene, bis(2- ethylhexyl) phthalate, chlordane, dichloromethane, pentachlorophenol, tetrachloroethylene, and trichloroethylene) in storm water runoff have exceeded primary maximum contaminant levels (MCLs). Available sampling data also show that concentrations of aluminum, chloride, copper, iron, manganese, total dissolved solids (TDS), zinc, and methyl tert-butyl ether have exceeded secondary MCLs or health advisory levels (HALs). Water quality data from Florida indicate that lake level control well injectate has exceeded primary MCLs or HALs for turbidity, arsenic, pentachlorophenol, and fecal coliforms, as well as secondary MCLs for iron, manganese, pH, and color. Some of these same studies, however, report that no adverse effects on ground water were detected. In addition, some industry representatives assert that the quality of storm water drainage should be better today than reported in some of these studies, which predate the use of best management practices (BMPs) required under the National Pollutant Discharge Elimination System (NPDES) program. In general, the point of injection for most storm water drainage wells is into sandy, porous soils, a permeable coarse-grained unit, karst, or a fractured unit because these types of formations can September 30, 1999 1 readily accept large volumes of fluids. Such hydrogeologic characteristics usually allow contaminants to migrate readily into ground water without significant attenuation. Contamination related to storm water drainage wells has been reported to various degrees in Ohio, Kansas, Wisconsin, California, Washington, Arizona, Oklahoma, Tennessee, New York, Indiana, Florida, Kentucky, and Maryland. Several studies, however, do not clearly distinguish contamination from storm water drainage wells versus more general, nonpoint source pollution. The following three examples demonstrate cases in which storm water drainage wells have contributed to or caused ground water contamination. • In 1989, a commercial petroleum facility in Fairborn, Ohio accidentally released 21,000 gallons of fuel oil that overflowed a diked area and entered two storm water drainage wells. • In 1980, organic solvent contamination was discovered in drinking water supply wells for Lakewood, Washington following the disposal of organic waste solvents and sludge in leach pits and storm water drainage wells at McChord Air Force Base. • In 1998, the Oak Grove, Kentucky water plant (a ground water system) was shut down due to a sharp increase in raw turbidity following a severe storm event. Lake level control wells have been associated with two documented contamination incidents. The first occurred
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