Should There Be a Separate Class of Underground Injection Well for Groundwater Replenishment?

Under the Underground Injection Control Program (UIC), injection wells not included in Classes I-IV were lumped into Class V, including some 400,000 to 650,000 injection wells. In 1999, EPA completed a study to evaluate the risk to underground sources of drinking water (USDWs) associated with range and large number of Class V wells.

In 2002, EPA published in the Federal Register its Final Determination that existing federal UIC regulations were adequate to prevent Class V wells from endangering USDWs and federal requirements were adequate.

Conditions have changed since the SDWA was enacted in 1974, and since the 1999 EPA Class V UIC Study. Competing demands for water resulting from increasing environmental regulations, increasing water for the environment, increasing droughts, and climate change all have resulted in a significant increase in groundwater replenishment projects, a trend which is expected to continue to grow in the future. These projects include groundwater storage and banking, aquifer storage and recovery, and seawater intrusion mitigation. Additional, there has been a paradigm shift in managing sheetflow from precipitation events, from one of moving the water quickly to gutters, storm drains and channels, to one of slowing, spreading and sinking sheetflow, an also to managing stormwater by capturing it and replenishing groundwater with as much of it as possible. It would seem useful to consider these changed conditions and growing trends and:

·      Consider that these types of wells, projects and programs are generally under public agency responsibility and that there are political, legal, institutional, technical and economic drivers and incentives for providing a safe and reliable supply of water to the public

·      Recognize groundwater replenishment independently from the other disposal wells by separating these wells into their own Class, while not minimizing the need for pollution prevention, but eliminating the association with “waste” and “disposal”