r" JOHN R. MALOY, Executive Director
BLOOD TRO L
P. 0. BOX V
WEST PALM BEACH
Telephone (305) 686-8800
IN REPLY REFER TO: 9-8-.5
OBERT L. CLARK, JR.
ROBERT W. PAl)RICK
CL LUDE 1. GOD)WIN. D.O.S.
R. HA. R)Y MA THESON
Mr. Joseph W. Landers, Jr., Secretary "
Department of Environmental Regulation
2562 Executive Center Circle, East
Tallahassee, Florida 32301
October 22, 1976
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OCT 23 817
For the past two years or more the District's technical staff has
had an opportunity to assist in the development of criteria and to
play a role in the technical evaluation of permit applications for
the deep well disposal of municipal and Industrial waste effluent.
During this time;,although much progress has been made in developing
a methodology for permitting these installation s hat is technically
relevant and consistent with the public interest, we have concluded
that a significant change in procedure is appropriate at this time.
In order to evaluate the procedureswenow intend to,follow, which
will be detailed below, it is helpful first to review generalized
procedures currently in use and focus attention on the major weak-
ness of those procedures. Inthis review,,we confine our remarks
entirely to the disposal well facility itself.
A permit request for a-deep well disposal facility is usually initiated
With receipt of an application and engineering report, whose title has
the explicit thrust of requesting a "test injection well facility"
which usually includes a test injection well, a deep monitoring well,
and.sometimes a shallow monitoring well, The purpose for which-appli-
cation is made is to determine the feasibility of deep well injection
at a particular site. In reviewing the dimensions of the wells and
other data contained in the report, several facts stand out.
First, proposed depths and attendant hydrogeological parameters, such
as location of confining beds, primary and secondary zones of high
permeability, proposed injection zones, monitoring horizons, and re-
lated quality of the host fluid and potentiometric heads, are always
.e 2 2 H
extrapolated from existing wells many miles away or inferred from existing
general geologic literature not specifically addressingjatters concerned
with the relevance and efficacy of deep well injection.
Second, the dimensionsofr the "test irnj.?ction well" and deep monitoring
well arehydraul ially sized to full on-stream dimensions, and construction
details leave little doubt that t**.e installations are indeed intended to
be permanent facilities. The inconsistency, of course, is in recognizing
the difference between the title of the applicant's engineering report and
the permit ultimately issued by the regulatory agency, as compared with what
is actually emplaced in the ground. It must be recognized in all of the
above that once a construction permit is issued, construction proceeds as a
single operation. No further approvals or input from the regulatory agency
The obvious implication here is that those basic design parameters that were
initially projected are not usually consistent with data derived from the
drilling and testing that follows. Thus, casing points and monitoring hori-
zons are too often placed at less than optimum depths, potentiometric heads f
and chlorides are not as anticipated, and basic well design and construction
(such as grout schedules) are not at their most favorable levels. When the
regulatory agency is confronted with this data (which is a condition to a
test injection'well permit) it in teallty represents an expost facto situ-
ation. There Is essentially no flexibility to address and recommend changes
of those aspects of the proposed well design in light of the site-Specific
data developed in the construction and testing operation. The agencies are
thus essentially Or realistically obligated to accept a system that too often
leaves much to, be desired.' The fact that a' very costly facility has been
emplaced,: which b, its inherent nature is inflexibile to change, makes it
difficult if not impossible to effect needed modifications. .
As a next step the regulatory agency is then petitioned to gpant approval
for a test injection program which essentially involves continued construction
and/or testing of the facility for a 1l2-month period during-whichfcertain
parameters are measured and terminates in a report of operations encompassing
this time frame. Upon acceptance and approval,-an operating permit is issued.
In all of the above, it appears obvious to us that the weakness.jn this pro-
cedure is. focused on the'initial phases of permit consideration and approval.
A case in point is concerned with the meeting of Septembeer6,th, i:Tallahassee
for the purpose of commenting on a presentation by Black, Crw & Eidsness of
a plan tp deep well inject secbndary-treated effluent generated by a proposed
new southern regional sewage'treatment plant of the Miqmi-Dade Water & Sewer
Authority. Prior to the meeting, we received a dat. packet which outlined the
proposal. In brief, the plan involves a regional treatment plant which in its
current first phase calls f-a a regional sewage treatment plant with an average
daily c'anitv of 50 MGD aMd a peak 4-hour capacity of 122 MD. Disposal of
effluent; as proposed will be -by eep well injection via eight injection wells
plus one standby well injdcting into the Boulder Zonat an approximate depth
of 3,000 feet
One of the major elements of the discussion which followed the presentation
revolved around tie sequence and timing of construction. BC&E proposed to
drill a "prot~tvn.l" '- ll, performing the necessary testing and conducting
the required exploratory work in stages concurrent with the construction of
the prototype well. This well wil be one of the nine InJiecton wells planed.
When completed, the well will be pumped and test injected at about 1u,O60 GPM
in order to gather additional injection wel performance criteria. After
listening to the presentation our staff went to very substantial lengths to
point out that once again we were being confronted with an emplaced facility
based on exploratory data we' had no opportunity to review as it related to
how the data would impact on the proposed design of the prototype well. We
indicated rather firmly that this ra t au tisf In response,
it was pointed out that ths was onil ne Bi nine suct weI s and that this data
was required by the engineers to gather'design aMd operational criteria for the
remainder of the project. However, we indicated that the exploratory work would
have to be accomplished prior to drilling the first injection well and this data
would form the basis for both the design of the injection well and further evalu-
ation by the regulatory agencies prior to issuance of an injection well construc-
tion permit." .
-e believe that the concerns expressed for the concept of deep well injection
in south Florida as a vialtl option fbr disposal of treated effluent or other
wastes mitigates toward a more positive and substantiated documentation of
site specific exploratory data that will allow the agencies of pertinent juris-
diction to evaluate such proposals and their subsequent impacts with greater
confidence prior to injection well construction approvals.
As a consequence of our analysis of present procedures, we intend to institute
a modification to our existing procedures which will require thai any proposal
involving deep well injection be preceded by an exploratory test hole constructed
explicitlyfor the purpose of gathering site specific geologic and hydrologic
data (which will control all subsequent design and construction) prior to permit
issuance for injection well construction. In summary, the following guidelines
will in the future be used by the District to ensure that certain essential data
will be available to the District and other regulatory agencies prior to the
installation of an injection well facility rather than after such construction
has been completed. '
1) A lithologic ind stratigraphic log prepared by a resident geologist com-
petent and qualified by training and experience to collect and describe
drill cuttings, identify stratigraphic units, and in general make the many
necessary decisions required during the'progress of drilling operations
that will lead successfully to meeting the objectives of the exploratory
work. Appropriate commentary related to unusual hole conditions, hard or
denselayers, extent of solution channels, fractures, etc., must be
2) Geolograph or equal indicating as a minimum, drilling time vs. down time,
bit Weight and trip time.
a~~Y ~ -.-- Y + ~ ~ "
J) Flume (ditch) samples taken every 5 feet, fully labeled and identified
Sand depth correlated for up-hole la%,time, A full set of samples will
1 be retained by the ow.er or his consultant until permit application,
review for pearanent faciliti es is completed. In this inter~Si period,
the District ray .require that a complete suite oi samples as described
,,;above ie,delivered to, the District's geologists for analysis .
4) Cores in. quantity and at depths as coapidered appropriate, and,.necessary
Sby the owner or his consultant, The decision to take copies a a, paartic-
ular depth ,wQuld normally be determined of the basis of conditions found
during drilling, operations. Of specific interest to the, istr.ict are:
'a) impervi guS.zones (o aquiclude) lying above anticipated Injection
horizons, and b) pp ttial monitoring horzons lying apove potential
injecti .6Siorzons. The "apIcanit f d-recogntiZ. that cores may Oe
S specified during subsequent coastruC(jon of Ohe injection wel, I .f
approved,-and will essentially be dependent on data derived from the
S test hole. Cores will serve~tQ confiw .cnfining beds, injection zones
S rethisr,,trfeatures of pertinent hlrogeolIpgic interest. The ippl24ant
should.recognize that l:tbgugh the taking of cores is discretionary, it
can, under certain circumstances, be one of the essential detirminants
in demonstrating the viability of any injection system. It is, therefore,
in,,the applicants' beS : interest to carefully review the planning of the
exploratory program relatjiytp this requirement.
5) Geophysical)logs: Logging shall
covering the entire depth of,the
Continuous bore hole fluid conductivity
Spontgageus potential ,
Combination temperature.and differential
Short,and long normal resistivity .
,,Dual induction ,
In lieu of "i" and "j' above, the owner
(sonic) porosity log. The decision to r
'j',ind "k' rests with the.owner anowil
f hole conditions and other site factor:
Sincl ude the fol owing surveys
Pero .,.,:, 4 r4,
may substi ute ap.accoustic
un surveys relative to "i",
1 be determined enithe basis
6),- Water quality: Water qu4aity phal, be ,determinedduring test, bole drilling
operations in a manner, And using techqques, that will. provide ag.accurate
chemical analyst of water found at-various.depths throughout the bore hole.
Of specific concerns that area at the-bottom of,,or underlying, the Haw-
thorn Formation and extending to the "Boulder Zone" of the Oldsmar and Cedar
Keys limestone. Water quality determinations are required to be taken in
Ythe uppermost part qf tie "Floridan Aquifer" (or bottom of the Hawthprn
Formation), identifying the water quality of.the topmost water 'bearing zone.
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.c 22, 1976
Subsequent samples shall be taken in all significant water bearing zones
extending into the "Boulder Zone", such that a clear and accurate
hydrogeo-chemical gradient can be established. Associated with the water
sampling program, shut in-head pressure shall be taken and integrated into
the sampling program. Such measurements shall be made in all major water
bearing zones, such that an accurate potentiometric head gradient can be
7) All of the above data shall be assembled in report form in which all the
items listed above are fully-described and interpreted in detail as to
their relevance and impact on local and regional geology and hydrology,
and which shall include a section on the impact of these features on the
design and possible impact on the efficacy, maintenance and operation of
any subsequent injection well.
8) The guidelines given above are meant to describe minimum data requirements
that will be necessary at such times as the owner makes application for
permanent injection well facilities. It is not intended to be an exhaust-
ive or inclusive list, but rather, is intended to inform the owner as to
those factors that the District considers essential in reviewing deep well
injection-projects. Additional data derived from prior study or on site
test hole drilling that is considered relevant to evaluating such projects
should be incorporated into the data package.
These minimum requirements are considered to be essential in order for the
District to discharge its responsibilities under existing legislation in pro-
tecting the water resources. They are also consonant with regulations
published in the Federal Register Vol. 39, No. 69, dated April 1974,
concerned with subsurface emplacement of fluids- administrator's statement
#5 & Vol. 41, No. 170, dated August 31, 1976, which addresses certain aspects
of the Safe Drinking Water Act. t
This procedure, detailed at some length herein from the technical standpoint,
has been covered in the proposed Memorandum of Understanding covering "dual
permitting", a draft of which has been forwarded you under separate cover on
In regard to the specific case, mentioned earlier in this letter, concerning
the BC&E proposal on behalf of Miami Dade Water & Sewer Authority, we intend
to formally advise the applicant of these requirements and this procedure. We
will defer this notification, however, for two weeks in order for you to review
and comment on this proposed procedure.
i icerel ,
JON R. MALOY
JRM:WSg (Eecutive Director
cc: Mr. Dan Farley /