UICs Demystified
2018 Erosion Control and Stormwater Management Summit
January 30, 2018
WHAT YOU REALLY SHOULD KNOW ABOUT UIC S
Keizer, Oregon
Matt Kohlbecker, RG GSI Water Solutions, Inc. 971.200.8531 1
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
2
WHAT IS A UIC? • Definition is found in 40 Code of Federal Regulations (CFR) 144.3, mirrored in Oregon Administrative Rules (OAR) 340-044 • Well (Dug Well, Bored Well, Driven Well, etc.) • Subsurface Fluid Distribution System • Improved Sinkhole
What You Should Really Know About UICs
3
WELLS • A structure that is deeper than its largest surface dimension • Dug, bored, driven, drilled . . . all are wells • NOT “deeper than wide”
What You Should Really Know About UICs
4
SUBSURFACE FLUID DISTRIBUTION SYSTEM
An assemblage of perforated pipes, drain tiles, or other similar mechanisms intended to distribute fluids below the surface of the ground. What You Should Really Know About UICs
5
IMPROVED SINKHOLES
A naturally occurring karst depression or other natural crevice found in volcanic terrain and other settings which have been modified by for the purpose of directing and emplacing fluids into the subsurface
What You Should Really Know About UICs
6
WHAT FALLS UNDER THE UIC REGULATIONS? • High Risk UICs • Have pollutants in stormwater, AND • Bypass shallow soils
What You Should Really Know About UICs
7
WHAT FALLS UNDER THE UIC REGULATIONS? A drywell, improved sinkhole . . . subsurface fluid distribution system . . . used for the subsurface emplacement or discharge of fluids. Exclusions • Residential Roof Drains, Drinking Fountains • Systems with perforated pipe that collects stormwater after it infilitrates through carbon-rich soils (footing drains, tile drains, rain gardens, porous pavers, swales, etc.)
What You Should Really Know About UICs
8
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
9
UICS IN OREGON
What You Should Really Know About UICs
10
HOW COMMON ARE UICS IN OREGON?
Portland: 9,600 public UICs
Keizer: ~85 public UICs 11
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
12
UIC PROGRAM TIMELINE 1974 SDWA Passed
1984 DEQ adopts UIC rules
1999 Federal Rules Change
2005 Portland UIC Permit Issued
2001 DEQ Revises UIC Rules
2011 KJ Report
2008 Portland GWPD
2012 Streamlined Permit Issued
2011 4 More GWPDs: Bend Clackamas Co. Gresham Redmond
2014-2016 1) RA Process Streamlined 2) 35 Indiv. Permits Issued
2013 5 More GWPDs: Eugene Lane Co. Milwaukie Canby Keizer
2015 General Permit Issued
13
BENEFITS OF UICS • Maintain aquifer recharge in the urban environment • Protective of aquatic receptors • Protective of human receptors
What You Should Really Know About UICs
14
STORMWATER QUALITY DATA MUNICIPAL STORMWATER QUALITY
15
GROUNDWATER PROTECTIVENESS DEMONSTRATIONS: CONCEPTUAL OVERVIEW OF ATTENUATION
VOLATILIZATION Concentrations decline as stormwater cascades into the UIC SETTLEMENT Concentrations decline as stormwater solids settle in the UIC sump
FILTRATION Concentrations decline as stormwater solids are filtered out by the soil matrix
SORPTION Concentrations decline as dissolved pollutants sorb to soil surfaces BIODEGRADATION Concentrations decline due to microbial activity DISPERSION Concentrations decline due to differential advection 16
GROUNDWATER PROTECTIVENESS DEMONSTRATIONS MODEL RESULTS
What You Should Really Know About UICs
17
GROUNDWATER PROTECTIVENESS DEMONSTRATIONS MODEL VERIFICATION
What You Should Really Know About UICs
18
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
19
TWO QUESTIONS TO ASK IF YOU OWN A STORMWATER INFILTRATION DEVICE • Does my device fall under the UIC regulations? • What is the best way for my UIC to be authorized?
20
WHAT TYPE OF AUTHORIZATION IS RIGHT FOR ME?
What You Should Really Know About UICs
21
OTHER THINGS TO CONSIDER . . . • How many of your facilities have UICs? • What are your future sampling plans? • Concerns about public comment periods? • Is 25 UICs really your “break point”?
What You Should Really Know About UICs
22
AUTHORIZATION BY RULE
Low Risk
Moderate Risk
High Risk
Provide Inventory Information to DEQ Structural BMPs Required Have Spill Kit at the Facility Prepare a Stormwater Management Plan Minimum Maintenance Requirements Annual Stormwater Sampling Annual Fee of $100 NOTE: Low Risk = Roof-Only Runoff High Risk = Hazardous chemicals used OR parking lot with over 1,000 vehicle trips per day OR municipality with over 50 UICs
What You Should Really Know About UICs
23
AUTHORIZATION BY PERMIT
General Permit
Individual Permit
$559 (Application) $574 + RA (Annual)
$12,449 (Application) $2,635 (Annual)
Maybe
Maybe
Must Own < 50 UICs At Least One UIC Must Be Within 500’ of a Well Sample Stormwater for the Life of the Permit Public Comment Period Authorize UICs at Multiple Facilities Fees Groundwater Protectiveness Demonstration
What You Should Really Know About UICs
24
UIC CLOSURE • Submit a “Pre-Closure Notification” 30 days prior • Sample sediment for disposal purposes • Close it • Remove top ring • Backfill upper 4 feet with 300 psi CDF • Deeper than 4 feet can be filled with gravel
• DEQ will approve alternative closure methods if requested in writing
What You Should Really Know About UICs
25
RESOURCES (DEQ FACT SHEETS)
http://www.oregon.gov/deq/wq/wqpermits/Pages/UIC-Guidance.aspx
26
QUESTIONS?
Matt Kohlbecker, RG GSI Water Solutions, Inc. 971.200.8531
What You Should Really Know About UICs
27
January 30, 2018
WHAT YOU REALLY SHOULD KNOW ABOUT UIC S
Keizer, Oregon
Matt Kohlbecker, RG GSI Water Solutions, Inc. 971.200.8531 1
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
2
WHAT IS A UIC? • Definition is found in 40 Code of Federal Regulations (CFR) 144.3, mirrored in Oregon Administrative Rules (OAR) 340-044 • Well (Dug Well, Bored Well, Driven Well, etc.) • Subsurface Fluid Distribution System • Improved Sinkhole
What You Should Really Know About UICs
3
WELLS • A structure that is deeper than its largest surface dimension • Dug, bored, driven, drilled . . . all are wells • NOT “deeper than wide”
What You Should Really Know About UICs
4
SUBSURFACE FLUID DISTRIBUTION SYSTEM
An assemblage of perforated pipes, drain tiles, or other similar mechanisms intended to distribute fluids below the surface of the ground. What You Should Really Know About UICs
5
IMPROVED SINKHOLES
A naturally occurring karst depression or other natural crevice found in volcanic terrain and other settings which have been modified by for the purpose of directing and emplacing fluids into the subsurface
What You Should Really Know About UICs
6
WHAT FALLS UNDER THE UIC REGULATIONS? • High Risk UICs • Have pollutants in stormwater, AND • Bypass shallow soils
What You Should Really Know About UICs
7
WHAT FALLS UNDER THE UIC REGULATIONS? A drywell, improved sinkhole . . . subsurface fluid distribution system . . . used for the subsurface emplacement or discharge of fluids. Exclusions • Residential Roof Drains, Drinking Fountains • Systems with perforated pipe that collects stormwater after it infilitrates through carbon-rich soils (footing drains, tile drains, rain gardens, porous pavers, swales, etc.)
What You Should Really Know About UICs
8
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
9
UICS IN OREGON
What You Should Really Know About UICs
10
HOW COMMON ARE UICS IN OREGON?
Portland: 9,600 public UICs
Keizer: ~85 public UICs 11
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
12
UIC PROGRAM TIMELINE 1974 SDWA Passed
1984 DEQ adopts UIC rules
1999 Federal Rules Change
2005 Portland UIC Permit Issued
2001 DEQ Revises UIC Rules
2011 KJ Report
2008 Portland GWPD
2012 Streamlined Permit Issued
2011 4 More GWPDs: Bend Clackamas Co. Gresham Redmond
2014-2016 1) RA Process Streamlined 2) 35 Indiv. Permits Issued
2013 5 More GWPDs: Eugene Lane Co. Milwaukie Canby Keizer
2015 General Permit Issued
13
BENEFITS OF UICS • Maintain aquifer recharge in the urban environment • Protective of aquatic receptors • Protective of human receptors
What You Should Really Know About UICs
14
STORMWATER QUALITY DATA MUNICIPAL STORMWATER QUALITY
15
GROUNDWATER PROTECTIVENESS DEMONSTRATIONS: CONCEPTUAL OVERVIEW OF ATTENUATION
VOLATILIZATION Concentrations decline as stormwater cascades into the UIC SETTLEMENT Concentrations decline as stormwater solids settle in the UIC sump
FILTRATION Concentrations decline as stormwater solids are filtered out by the soil matrix
SORPTION Concentrations decline as dissolved pollutants sorb to soil surfaces BIODEGRADATION Concentrations decline due to microbial activity DISPERSION Concentrations decline due to differential advection 16
GROUNDWATER PROTECTIVENESS DEMONSTRATIONS MODEL RESULTS
What You Should Really Know About UICs
17
GROUNDWATER PROTECTIVENESS DEMONSTRATIONS MODEL VERIFICATION
What You Should Really Know About UICs
18
OUTLINE • What is a UIC? • UICs in Oregon • What we have learned since 2001 . . . • Oregon’s UIC Program requirements
What You Should Really Know About UICs
19
TWO QUESTIONS TO ASK IF YOU OWN A STORMWATER INFILTRATION DEVICE • Does my device fall under the UIC regulations? • What is the best way for my UIC to be authorized?
20
WHAT TYPE OF AUTHORIZATION IS RIGHT FOR ME?
What You Should Really Know About UICs
21
OTHER THINGS TO CONSIDER . . . • How many of your facilities have UICs? • What are your future sampling plans? • Concerns about public comment periods? • Is 25 UICs really your “break point”?
What You Should Really Know About UICs
22
AUTHORIZATION BY RULE
Low Risk
Moderate Risk
High Risk
Provide Inventory Information to DEQ Structural BMPs Required Have Spill Kit at the Facility Prepare a Stormwater Management Plan Minimum Maintenance Requirements Annual Stormwater Sampling Annual Fee of $100 NOTE: Low Risk = Roof-Only Runoff High Risk = Hazardous chemicals used OR parking lot with over 1,000 vehicle trips per day OR municipality with over 50 UICs
What You Should Really Know About UICs
23
AUTHORIZATION BY PERMIT
General Permit
Individual Permit
$559 (Application) $574 + RA (Annual)
$12,449 (Application) $2,635 (Annual)
Maybe
Maybe
Must Own < 50 UICs At Least One UIC Must Be Within 500’ of a Well Sample Stormwater for the Life of the Permit Public Comment Period Authorize UICs at Multiple Facilities Fees Groundwater Protectiveness Demonstration
What You Should Really Know About UICs
24
UIC CLOSURE • Submit a “Pre-Closure Notification” 30 days prior • Sample sediment for disposal purposes • Close it • Remove top ring • Backfill upper 4 feet with 300 psi CDF • Deeper than 4 feet can be filled with gravel
• DEQ will approve alternative closure methods if requested in writing
What You Should Really Know About UICs
25
RESOURCES (DEQ FACT SHEETS)
http://www.oregon.gov/deq/wq/wqpermits/Pages/UIC-Guidance.aspx
26
QUESTIONS?
Matt Kohlbecker, RG GSI Water Solutions, Inc. 971.200.8531
What You Should Really Know About UICs
27
