NDWAC
UIC/ Source Water Program Integration Working Group Meeting
March 25-26, 1999
Executive Summary
I. BACKGROUND
The second meeting of the National Drinking Water Advisory Council (NDWAC)
Underground Injection Control (UIC)/ Source Water Protection Program Integration
was held on March 25-26, 1999 in Washington, D.C. Twenty-one of the 27
members participated. Members Thomas Crawford, John Gennaro, Kathryn Hohmann,
Gary Jackson, Jim Carlson, and Andrew Bowen were unable to attend. Richard
Deuerling represented Mike Houts.
II. MEETING SUMMARY
The meeting began with an update on the current status of Source Water
Assessment Programs. Discussion focused on implementation of Source Water
protection (Government Performance and Results Act measures). The working
group discussed their role in the source water protection arena and suggested
continuing discussion on measuring protection in future meetings.
The group then reviewed topics from the first meeting relating to the
proposed Revisions to the Underground Injection Control Regulations
for Class V Injection Wells for large capacity cesspools, motor vehicle
waste disposal wells, and certain industrial waste disposal wells (63
FR 40586). The first issue discussed concerned allowing certain motor
vehicle wells to convert to another type of well. The group suggested
that a well inside a motor vehicle facility could be reclassified given
certain conditions and requirements.
The group then discussed the implementation timeline for the regulation.
The group discussed a more detailed version of the phased-in approach
suggested during the first meeting. This approach, which the group recommended,
would implement the rule according to a phased-in structure where States
submit a plan for first focusing rule requirements in source water protection
areas for ground water based community and non-transient water systems
and adding other priority areas over time.
Further, the group discussed the timeline for implementation if a State
has not completed the source water assessments by May 2003. The group
discussed whether requiring statewide implementation was appropriate.
They suggested applying the rule statewide by January 1, 2004 or 42 months
after State source water assessment program approval, whichever is earlier.
The first issue on Friday was classification of stormwater wells at industrial
sites. A representative from the Office of Wastewater Management (OWM)
presented an overview of the National Pollutant Discharge Elimination
System (NPDES). The group discussed the applicability of NPDES to Class
V wells and suggested using a checklist similar to the No-Exposure checklist
to identify stormwater wells at industrial sites, and thus exempt them
from rule. The group encouraged EPA to increase OGWDW and OWM coordination
on stormwater management issues.
Next, background on the "industrial well" category, and what types of
facilities are included, was presented. The group discussed whether the
proposed regulation should require industrial wells in SWPAs to meet MCLs
at the point of injection, as well as the geographic coverage of the rule
affecting industrial wells. The group suggested phasing in the rule in
a manner similar to the approach suggested for motor vehicle wells. In
addition, whether a waiver option should be provided was discussed. The
report submitted by the National Funeral Directors' Association was also
discussed.
In addition to the issues covered above, the group suggested that: (1)
time to comply with the regulation be extended from 90 days to one year
(with a possible extension); (2) pre-closure notification and inventory
requirements proposed for Direct Implementation States be extended to
cover Primacy States; (3) pretreatment (such as that provided by a septic
system) be considered as prior to the point of injection; (4) guidance
be drafted to aid in implementation of the proposed rule; and, (5) funding
be increased to the UIC program.
The group's suggestions will be presented to the full NDWAC for its consideration
in May.
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