From The Sky-Hi Daily News (Travis Poulin):
MEETING WITH WINTER PARK, EPA, UPRR
The Town of Winter Park scheduled a meeting in Denver with the EPA (Environmental Protection Agency), participants from Grand County, CDPHE (Colorado Department of Public Health and Environment), UPRR (Union Pacific Railroad), CDM Smith (UPRR’s consultant), Winter Park Ranch and HRS Water Consultants, Inc. on November 21. The meeting was to address the Class V injection well permitting process regarding the permit that will be submitted by the UPRR for a well near the Moffat Tunnel.
According to Lisa McClain-Vanderpool, Public Affairs Officer for the EPA the purpose of the meeting was to educate the parties on the Class V well permitting process and discuss issues associated with the wastewater treatment plant project for discharges from the Moffat Tunnel to the Fraser River. EPA’s UIC (Underground Injection Control) Class V program has authorized the construction of an onsite waste water system for domestic waste. UPRR will submit a Class V permit application for its wastewater treatment facility. Additional sanitary waste would be dumped into the system as well.
WINTER PARK’S CONCERNS
Winter Park Town Manager Drew Nelson said, prior to the meeting, that with the nature of the soils in the area, the Town is concerned that contaminants could easily move between the septic and leach field into the Fraser River. The meeting was not held to address the contaminants seen discharging into the Fraser River in September, but only concerned waste materials generated by the new water treatment facility. The facility has been under construction for the last few years.
GRAND COUNTY’S CONCERNS
Grand County Water Specialist Katherine Morris expressed the Water Resource Management department’s concerns about the project to the Grand County BOCC (Board of County Commissioners) on November 1.
Morris submitted an update memo stating that the treatment plant has a bathroom and faucet needing treatment, and will produce a certain amount of centrate waste from the plant waste treatment process that needs to be dealt with appropriately. UPRR applied to Winter Park Water and Sanitation District (WPWSD) to accept the waste stream and was granted a variance from the compulsion to connect because the waste will be classified “industrial” and would require reopening WPWSD’s permit and likely redesign of the plant. UPRR then applied to the county for Class V injection permit, which is essentially an OWTS (On-site Water Treatment System). The OWTS was declined because it would include industrial rather than solely domestic waste. Morris said Grand County Water had several concerns about the new application. She said it is unclear if the plant has a source of potable water for the restroom. Because there is no acknowledgment yet in the discharge permit of the organic contamination within the discharge, to the county’s knowledge, the plant was not designed to treat organics, and it is unclear how much of a threat the organics pose. The update states it is not clear what will be the fate and transport of organics through the treatment process, and they don’t know how much of the organic pollutants will end up in the centrate that is destined for the OWTS. Morris referenced the discharge from the Moffat Tunnel in September, stating that events like that are likely to overwhelm the plant. The update asked: if an OWTS is approved, what oversight will there be to ensure that highly concentrated discharges are actually processed through the plant? And is an OWTS adequate to the task of safely breaking down any organics that survive treatment, or will they just concentrate in the vault or travel by groundwater through the relatively close connection to the Fraser River?
WHAT IS A CLASS V INJECTION WELL?
According to the EPA website, a Class V well uses injection techniques different from those used by wells in other classes. Some Class V wells are technologically advanced disposal systems, but most are low-tech holes in the ground. A typical Class V well is shallow and relies on gravity to drain or inject waste into the ground, which is often directly into, or above, an underground source of drinking water. Class V wells are used to inject non-hazardous fluids underground. Most are used to dispose of waste into or above underground sources of drinking water. This disposal can pose a threat to ground water quality if not managed properly.
Examples of simple class V wells are dry wells, cesspools, and septic system leach fields.
REQUIREMENTS
The EPA has established minimum requirements to prevent injection wells from contaminating underground sources of drinking water. According to the EPA website, in most cases Class V wells are authorized by rule—meaning they may be operated without a permit as long as the owners or operators abide by a set of regulations:
Submittal of inventory information to their permitting authority and verify that they are authorized to inject—the permitting authority will review the information to be sure that the well will not endanger drinking water
Operate the wells in a way that does not endanger drinking water.
APPLICATION PROCESS
The process for a Class V application relies on public input, according to McClain-Vanderpool.
First, an applicant submits an application to the UIC unit. The UIC unit will make sure the application is complete. If complete the review process starts.
After the technical and administrative review process is done and the application meets EPA requirements, they continue on to the next step. If it does not meet EPA requirements, a letter is sent to the applicant explaining the reason it was not approved.
The UIC program will draft a permit and submit it for a 30-day public notice on their website and in the local newspaper.
If no comments are received, the UIC unit will finalize the permit and issue it. If they get public comment, they will consider the comments for their decision.
The timeline depends on the complete application and the public notice response.
The UIC unit cannot estimate a timeline for this process, according to McClain-Vanderpool.