Review of Existing Methods for Addressing Compliance with SDWA in the Permitting of ASR Wells

Wednesday, April 14, 2010: 2:10 p.m.
Lawrence A/B (Westin Tabor Center, Denver)
Chase Hahn, E.I.T. , TRC, Littleton, CO
Catherine Shrier, Ph.D., PG , Watercat Consulting LLC, Washington, DC
Steve Musick , Musick Groundwater Consulting, Wimberley, TX
Review of Existing Methods for Addressing Compliance with
the Safe Drinking Water Act
in Permitting of
Aquifer Storage and Recovery Wells
Chase Hahn (Colorado School of Mines) and Cat Shrier (Watercat Consulting LLC)
ASR injection wells are currently regulated by EPA’s Underground Injection Control (UIC) program as Class V wells, which are all injection wells not included in Classes I-IV.  Many UIC wells are intended for disposal, and involve injection into aquifers where the fluids can be considered “removed from the environment.”[1]  Use of ASR, however, may involve consideration of water quality changes (both negative and positive) during injection and initial mixing of injected water and stored water; over time during storage; or upon recovery.  In situ water quality changes may include creation of disinfection byproducts or mobilization of arsenic, which could result in an exceedence above the maximum contaminant level (MCL) for a National Primary Drinking Water Regulation.  Approaches to UIC permitting, including determination of the point of compliance at which primary drinking water standards must be met, varies among EPA regional agencies and state agencies with primary implementation authority or “primacy.”  This presentation is on a Fall 2009 review of the SDWA UIC program and its application to ASR wells, and current practices in one state within each EPA region with permitted ASR wells.  Conducted with input from the Ground Water Protection Research Foundation and state agency representatives, this review focused on each state addressed potential for “endangerment” under the Safe Drinking Water Act (SDWA).


[1] Voorhees, B. V. (2001). Removed from the Environment. The Environmental Forum , 23-31.