e GA-
e f\!~oo.G,4
I
51
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I
ASSESSME~T OF ENVI~ONMENTAL EFFECTS ASSOCIAifED WITH POTENTIAL AQUIFER STORAGE RECOVERY PROJECTS IN COASTAL
GEORGIA
DEPARTMENT OF NATURAL RESOURCES I
ENVIRONMENTAL PROTECTION DIVISION I GEORGIA GEOLOGIC SURVEY I I I
Atlanta
2001
PROJECT REPORT 44
ASSESSMEfjjT. OF ENVIRONMENTAL EFFECTS ASSOCIAifED WITH POTENTIAL AQUIFER
STORAGE RECOVERY PROJECTS IN COASTAL GEORGIA
Performed as parte' the Georgia Environmental Protection Division's . Interim Strategy t0 protect coastal Georgia from salt-water intrusion
DEPARTMENT OF NATURAL RESOURCES I Lonice C. Barrett, Commissioner
. I
.
ENVIRONMENTAL PROTECTION DIVISION
Harold F. Reheis, Director .
f3EORGIA GEOLOGIC SURVEY William H. Mclemore, State Geologist
Atlanta
2001
PROJECT REPORT 44
Reply To: Georgia Geologic Survey Room 400 19 Martin Luther King, Jr. Di. S.W . Atlanta, Georgia 30334 (404) 656-3214
Georgia Department of Natural Resources
205 Butler Street, S.E., East Floyd Tower, Atlanta, Georgia 30334
Lonice C. Barrett , Commissioner
Harold F. Reheis, Director Environmental Protection Division
(404) 656-4713
June 1, 2001 :
To: Coastal Georgia Ground Water Stakeholders
From: William H. MJemoreb<----
State Geologist
Subject: Project Report 44; ASSESSMENT OF ENVIRONMENTAL EFFECTS
I
ASSOCIATED WITH POTENTIAL AQUIFER STORAGE RECOVERY
'
I
PROJECTS IN COASTAL GEORGIA
This Project Report cohrains two separate reports (Appendices 1 and 2) dealing with the
environmental impacts!that might be associated with aquifer storage and recovery (ASR)
projects in coastal Georgia.. In this regard, two separate contractors were given the
following identical mi~sion to assess the published and unpublished technical literature
regarding the following issues, which have been raised by coastal Georgia stakeholders
(i.e., identified as part! of a facilitated meeting sponsored by the Georgia Conservancy
under contract to EPD and included in this Project Report as Appendix 3):
"What happenl during aquifer storage and recovery (ASR)? That is, what
happens to m4vement of stored water, quality of stored water and quality of
natural water under ASR? What are the effects locally? What is the localized I
movement? What are the effects across the full sphere of influence? How far
does the spheri of influence extend? Others include:
--effects bf mixing aerobic and anaerobic waters;
-geochJmical effects on the aquifer itself(on the limestone formations);
-effects lofprior treatment; and
-mixing effects in general.
In addition to the above, EPD requested the two contractors to also consider: .
P~tentibz (1)
for the introduction of regulated or radioactive (i.e., tritium)
chemicals intd the subsurface, and in the event that such chemicals were
introduc~d, thJ viability of successfully removing such chemicals and preventing
them from bein1g introduced into a public drinking water system.
: I
(2) Potential impact upon wells belonging to other persons (i.e., loss of
water) .
(3) Other negative impacts. "
The assessment of the above issues, which did not indude any field studies or
measurements, w~s to bb summarized in a short report that would generally discuss actual
and. perceived adv,erse JInvironmental impacts. Any actual environmental im.pacts would be documented and properly cited .
The above work was lontracted to the firms of CH2MHill. (Appendix 1) and Golder
I
.
Associates (Appendix 2). Both CH2MHill's and Golder's reports were peer reviewed by
LAW Environmental ahd Engineering, Inc. and Camp Dresser and McKee, Inc. LAW
and Camp Dresser ancl McKee were further requested to render a technical opinion
regarding:
Are the~e any inherent adverse environmental impacts associated with
ASR in coastal Georgia that could not be mitigated by competent and reasonable
engineering de~ign and thus would preclude the siting and construction of such a
facility .
Before proceeding further, it is important to remember that ASR is regulated as part of Underground Injection/ Control (UIC), which_ is a federally delegated program from the United States Environmental Protection Agency (EPA). The legal authority under which UIC rules are promulgited is the Georgia Water Quality Control Act (O.C.G.A. 12-5-20). In the spring of2001) Georgia's UIC rules were revised to achieve consistency with changes in EPA regul~tions. The revised rules, which became effective on April 26, 2001 are provided in .Aippendix 4.
Georgia's UIC ll!les p1ovide:
No person shaH operate an ASR in a manner that allows the movement of fluid
containing any/ contaminant into any aquifer, if the presence of the contaminant
may caus~ a vi0lation of drinking water standard.
~SR Injected
later shall be sited so that both the aquifer and nearby wells are not
. contaminated./ [Note: Georgia's Ground-Water Management Plan further
provides that such a siting study shall only be done by a Georgia P.E. or P.O.]
pro~ulgated Injected ASR Later shall not contain. any. contaminate that exceeds.
drinking : watet standard (i.e., the injected water must meet drinking water
standards) .
ASR shall not proceed without the owner first obtaining a permit from EPD; and the permit mal contain provisions for monitoring, testing, and reporting.
Both CH2MHili and <Golder point out several potential impacts (i.e., reducing conditions in the aquifer, mobilization of metals, disinfection by-products, etc.); however, both firms also point out that lsuch impacts can be mitigated by proper siting, testing, and . modifications to design and/or operations.
In their concluding remarks, CH2MHill states:
"Experie~ce dLing the past 17 years with ASR development in other states has I
shown that initial uncertainties, such as the questions posed in this memorandum I
(the CH2MHill Assessment) are relatively normal....... Full confidence in the I
applicability oj ASR technology in Georgia can only come from having at least one full. size ASR well constructed, tested, permitted and placed in operation. Until that timJ arrives, partial confidence can be achieved through literature reviews, studiks, investigations, modeling, and site visits to other nearby operating ASR sites utilizing the upper or lower zones of the Floridan Aquifer as a storage zone. "
Similarly Golder concludes:
"In summary, lsR has the potential to be a useful water resource management
tool in .coastal Georgia. Some concerns have been identified, but no
environmental impacts have been identified that could not potentially be
mitigated. An active permit program administered by GAEPD could insure that
pre-construction investigations, pilot testing, and ASR design, operation, and
monitoring ar~ adequate to achieve the water resource management benefits
while mitigatiAg envimnmental impacts. "
perf~rmin~ Finally, in
their peer reviews,. both LAW and Camp Dresser. and McKee
could not identify any inherent adverse environmental impacts that would be associated
with a properly desigrted and operated ASR system.
-oOo-
With the above in mind, EPD recommends that coastal Georgia stakeholders seriously consider ASR as an ehvironmentally sound approach to enhance the water supply options of region.
APPENDIX 1
CH2MHILL 5 0 Celebrating
Years
April 2; 2001 160843.GG.01
~~ fo)rE @rr:a w(E~
!il APR 05 2001
By
CH2M HILL 3011 S.W. Williston Road Gainesville, FL . 32608-3928 Mailing address: P.O. Box 147009 Gainesville, FL 32614-7009 Tel 352.335.7991 Fax 352.335.2959
Dr. William H. McLemore, State Geologist
King Georgia Geological Sclvey
.
19, Martin Luther Drive, S.W., Room 400
Atlanta, GA 30334
Subject: Aquifer Storage Recovery'in Coastal Georgia
Dear Dr. McLemore:
CH2M HILL is pleasefi to submit our final report entitled "Assessment of Adverse
Environmental Impacts Associated with Potential Aquifer Storage Recovery Projects in
Coastal G.eorgia/' I .
. .
.
We sincerely appreciate the opportunity to work with the Georgia Geological Survey on this
F project and hope that :the report will prove to be helpful in addressing some of the questions
that have been raised recent years_ regarding this technology. If we can assist further in
any way, please' let us know.
. .
We would appreciate/receiving a copy of the broader report that you mentioned in oU:r last telephone conversation, for which this CH2M HILL report would be a part.
Sincerely,
{_/
$?12-Lj
~vid;. Pyn~P~~
Bryan B. McDonald, f.G .
!
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Assessment of Adverse Environmental Impacts Associated with
Po~ential Aquifer Storage Recovery Projects in
Coastal Georg~a
Prepared for Georgia Geological Survey
by R. David G. Pyne, P.E.
and Bryan B. McDonald, P.G.
CH2M HILL, Inc. Gainesville, Florida
April 2, 2001
Assessment of Adverse Environmental Effects Associated with Potential Aquifer Stfrage Recovery Projects in Coastal Georgia
Prepared for the Environmental Protection Division, Georgia Department of Natural Resources
Prepared by R. David G. Pyne, P.E., and Bryan B. McDonald, P.G.
CH2M HILL, Gainesville, Florida
April2001
Background
As of April, 2001, at least 39 ASR projects are known to be operational and fully-
permitted in the Uni~ed States. At least 50 more projects are estimated to be in various stages of dev~lopment, ranging from initial planning to already operational
but not yet fully perdutted. These 39 projects are located in 14 states. Application of
this water managem~nt technology has been fairly rapid; as recently as 1983 there
were only 3 ASR projects nationally. ASR systems are also operational in Canada,
England, Israel and Australia and are under development in several other countries.
st~re Most ASR projects
water in deep, confined aquifers, as has been proposed for
coastal Georgia. Stotage zone depths range from as shallow as 200 feet to as deep as 2600 feet. Geologic cbnditions for the storage zones include sand, sandstone, clayey
sand, limestone, doldmite, basalt and glacial drift deposits. Projects range from single wells with recbvery capacities of under one million gallons per day (MGD), to
more than 30 wells J.ith combined recovery capacity exceeding 100 MGD. Storage
volumes range from ~s small as about 10 million gallons (MG) to about 2.7 billion
.
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gallons (BG). Most storage zones contain fresh water while some contain brackish
,.
wASaRtewr. e11s.
are
d'ff I t 1 er~n
m
both
d estgn
a.nd
oper.ation
fr o~
InJ ection
we11s
or
.
production wells. A?R wells are designed for storage and recovery of high quality
water whereas injecqon wells are designed and operated for either recharge or
disposal of water. ASR wells resolve the inherent operational drawbacks of single-
purpose injection w~lls by equipping each well with a pump and operating it in a
dual-purpose mode for both recharge and recovery. This approach to aquifer
recharge typically o1ercomes the plugging associated with most injection wells, the
hydraulic limitation~ associated with many surface recharge sites, and the large land area requirements o~ these sites. ASR wells are typically backflushed for a few
minutes every few days to few weeks, to remove accumulated particulates from the
well, thereby maint~ning long term recharge and recovery rates. Such particulates
tend to plug injectio~ wells, which are not usually provided with a pump capable of b~ckflushing partic~lates to waste. Accordingly, injection wells require either an
extremely transmissive injection zone, such as occurs in south Florida, or they
require periodic exp~nsive redevelopment, as for the southern California salinity
intrusion barriers in <Drange and Los Angeles counties during the past 40 years.
o~ ASR systems meet a keat variety of needs. Most common is the storage water to
meet seasonal, emergency or long-term needs during drought-flood cycles. Others include water quali~ improvement during storage, reduction or elimination of
withdrawals from SUfface water sources during dry weather periods, salt water
intrusion control, reducing water facility expansion costs, maintaining water
I
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distribution system flows or pressures, and about 20 other applications. Most ASR
systems store treated! drinking water. However in recent years a growing number of
ASR systems are stoting high quality reclaimed water; partially-treated, high quality
surface water; or gro}mdwater from overlying or underlying aquifers, or from the
same aquifer at a different location.
v~lume Typically the same
of water stored in an ASR well can be recovered. In
some situations it mJy be possible to recover a greater volume than the amount
recharged, relying upon mixing between the stored water and the surrounding
native water in the aguifer to provide a blend of acceptable quality. In other
situations, leaving a ~mall percentage of the stored water in the ground may be
desirable to restore depleted groundwater reserves; to address concerns regarding
potential geochemic~l plugging; to form or maintain a buffer zone between stored
water and surroundfug brackish or poor quality native water; or to build up a
reserve for future redovery during droughts, emergencies, or anticipated times of
I higher demand.
.
ASR recovered watef usually requires no retreatment following recovery, other than
disinfection for potaple uses. In a few situations, pH adjustment of the recovered
water ot blending with high quality _water may also be-needed..
Aquife~ The Floridan
underlies Florida and portions of Georgia and South Carolina.
Within this area, nin~ ASR projects are operational and at least 30 more are in
development. Of th~se nine operational projects, four are in locations where the
native groundwater !in the aquifer is fresh while the remainder are in ~ocations
w~ere it is brackish.! The closest ASR site to coastal Georgia is at Beaufort Jasper
Water and Sewer Authority in South Carolina, immediately north of Savannah. This
site has been in oper1ation for over a year and is being expanded to include two
additional wells. I
ASR P.roposed ApplIication in Coastal Georgia
.
During the past few!years, ASR has been proposed for application in coastal
Georgia, to meet public water supply needs and also to help reverse salt water
intrusion. As showt;l in Figure 1, groundwater levels in the upper Floridan aquifer in coastal Georgia h~ve experienced significant declines during the past few
decades, reflecting primarily industrial and urban water supply withdrawals in the
I
2
Savannah area and u~'ban water supply withdrawals in the Brunswick area. Similar
to many other areas a:long the Eastern Seaboard, salt water intrusion is occurring in
the upper Floridan aquifer in coastal Georgia and adjacent portions of South
Carolina. The occurr~nce of a large, regional"bowl" in the potentiometric surface of
the upper Floridan aquifer, as shown on Figure 1, presents a good opportunity for
aquifer recharge with' seasonally available water supplies.from various potential
sources. Any water +charged would be unlikely to leave the region due to the
configuration of the potentiometric surface. 0
p~oposed ASR was originally
for storage in the upper Floridan aquifer in coastal
Georgia, reflecting re~onal water management needs and opportunities, and the
minimal amount of ittformation available regarding hydraulic characteristics and
water quality of the lbwer Floridan aquifer in this area. Subsequently attention has
also focused on the pbtential for ASR storage in the lower Floridan aquifer. Field
investigations are untlerway or planned that would provide further information to
support a careful ass~ssment of which storage zone may be preferable.
Several questions hate been raised regarding these ASR proposals. Following are the key questions, aslsummarized by the Georgia Geological Survey, and answers to each .
(1) What happens during aquifer storage and recove,.Y (ASR)? That is, what
happens to moveme~t of stored water and quality of natural water under ASR?
What are the effects focally? What is the localized movement? What are the effects .
across the full sphere of influence? How far does the sphere ofinfluence extend?
Others include: I
.
eff.ects oI f mixing aerobic and anaerobic waters?
Geoch~mical effects upon the aquifer itself (on the limestone
formations)
.
Effects lof prior treatment, and
M t.xt.ngIIe.JnJ.ects t.n ge. nera l.
Aquifer storage recoyery is defined as the "storage of water in a suitable aquifer through a well durir\g times when it is most available, or when water quality is most suitable, and recovery from the same well when the water is needed, or when water quality from other squrces is unacceptable. During storage of water in an ASR well, a large bubble of stored water is created, displacing water in the aquifer around the well. Typically the bubble of stored water is sufficient in volume to meet a planned recovery duration, such as 90 days, at the rate available from that well, such as 2 million gallons per day (2 MGD) while meeting water quality criteria established for that well during rec<?very. 0 This is called the "stored water volume." It is perhaps
3
helpful to envision thl.s process as shown in Figure 2, which is a somewhat
simplified version of the expected conditions underground during ASR operations. Figure 2 shows a typi~al ASR well in a confined artesian aquifer, as may be expected
in coastal Georgia. ,
Surrounding the storEfd water volume is a buffer zone, which contains a mix of stored water and natiye groundwater. The volume required in the buffer zone depends upon several factors such as aquifer thickness, porosity, permeability, degree of confinement, regional hydraulic gradient, nativewater quality and recovery water qualitY criteria. If there is no real difference between recharge water quality and native gr?undwater quality, there may be no buffer zone volume required. Most ASR sites, however, require a buffer zone volume due to the presence of one or more water quality constituents that would otherwise require treatment of the recoyered water in order to meet drinking water quality standards.
I
The sum of the stored water volume and the buffer zone volume is called the
"Target Storage Voluffie," or TSV. Experience at several operational ASR sites
I
suggests that, once the TSV is reached, subsequent ASR operations usually achieve
full recovery of the W:ater stored after that time. Prior to achieving the TSV, less than
full recovery may occur. The radial distance from the ASR well to the edge of the
TSV depends upon tne thickness and bulk porosity of the aquifer, and the volume of water stored. Howe~er typical radial distances are a few hundred feet around each
ASR well. Within the TSV, water quality will change during recharge and recovery.
Figure 2 shows the stpred water volume, buffer zone volume, and the Target Storage
Volume .
Outside the TSV, na9ve groundwater quality is theoretically unchanged. The water may move slightly iti one direction during recharge and the opposite direction during recovery, however the quality of that water would not be changed as a result of ASR operations. J?uring a typical recharge and recovery cycle, such as one year, the net movement of:the native water surrounding an ASR well would be no different than if the ASR well did not exist, unless the ASR well is operated purposefully to leave water underground, such as for a salinity barrier, or to recover more water than is recharged, such as for a wellfield.
Although water quality changes occur fairly close to an ASR well,pressure changes extend much further, creating a "sphere of influence" for ASR wells. Water level in adjacent wells may rise during recharge and decline during recovery at distances of up to a few thousand feet .from an ASR well. Table 1 indicates approximate changes in water levels in wells at distances of 100, 1000 and 10,000 feet from an ASR well recharging at an assumed rate of 2 MGD in the upper Floridan aquifer near Savannah. Assumed transmissivity is 30,000 ft2/ day, which is perhaps representative of the Savannah area. Actual transmissivities in coastal Georgia vary
over a wide range, from less than 10,000 to more than 200,000 ft2 I day, so the
drawdown estimates shown in Table 1 are approximate. Water level impacts
4
associated with ASR wellfields, instead of single wells, will be proportionately greater.
Table 1 Distance Drawdown Impacts
Radial Distance (ft)
100
Change in Water Level (ft)
2.4
1000 0.1
10,000
During a typical annual cycle of ASR operations, the net change in water level in
adjacent wells will be about zero, unless the ASR well is used for multiple purposes,
including salinity control. With salinity control operation, water levels would
increase during recharge and decline during recovery, however recharge volume
would exceed recovery volume, and therefore annual average change in regional
water level would be positive.
As described above and as shown in Figure 1, ASR operations proposed in coastal Georgia would superimpose any water level changes in adjacent wells upon an aquifer that has already experienced significant historic water level declines. An important criterion for engineering design and operation of ASR systems will be the appropriate selection of the well location and storage zone to be utilized, considering the high gradient occurring historically inthe upper Floridan aquifer and the consequent potentially high rate of lateral movement of stored water around an ASR well between the time of recharge and the time of recovery. Where the water quality difference between the stored water and the native groundwater is insignificant, any lateral movement of the storage bubble should also be insignificant. In the Savannah area, in particular, the configuration of the "bowl" in the potentiometric surface is such that no recharged water will flow out of the .regional system, except by pumping from other wells.
As described above, Figure 2 is a somewhat simplistic version of what actually happens underground around an ASR well. In reality, the boundaries between the storage volume, the buffer zone volume and the surrounding native water in the aquifer are not that well defined, representing a gradation from one quality to the next. In fine-grained aquifers, such as sand or sandstone, this proposed "model" of the TSV is probably fairly accurate, whereas for karst limestone aquifers, the boundaries are more diffuse. For most purposes; however, this model is sufficient since it leads to workable initial estimates of the TSV required for new ASR sites.. These initial estimates are then adjusted during initial operations, as needed to achieve ASR objectives at each site.
5
The general framework described above is applicable for most ASR sites, particularly those storing treated drinking water in limestone aquifers, as proposed for coastal Georgia. It is most appropriate for conservative water quality constituents, such as chloride and total dissolved solids. It is less appropriate for non-conservative constituents, for which concentrations may change during ASR storage due to reaction processes other than simple mixing, dilution, diffusion and dispersion. Such non-conservative processes typically include geochemical and microbiological processes. ASR experience since 1983 in the United States has shown that ASR storage of treated drinking water is successful, such that nonconservative underground reactions are insignificant in most, but not all sites. Drinking water is disinfected so bacterial reactions underground tend to be limited. Furthermore, drinking water tends to be relative stable from a geochemical perspective, so subsurface geochemical reactions are usually minor, transitional and insignificant. When treated drinking water is stored in an ASR well, it usually meets drinking water standards during recovery, although disinfection is provided after recovery before the water is sent to the distribution system in order to meet regulatory public health requirements. At a few sites, pH adjustment of the recharge water or the recovered water is provided, in order to control potential reaction processes.
~ffects of Mixing Aerobic and Anaerobic Waters
Native water in aquifers used for ASR storage is usually, but not always, devoid of oxygen, reflecting bacterial and geochemical processes naturally occurring underground during movement from the location of recharge at an outcrop area to locations of discharge, such as production wells or natural discharge into the Atlantic Ocean. Typical travel times for this movement range from hundreds to thousands of years, or longer, during which oxygen: in the recharge water is consumed and.eventually converted to minerals in the aquifer, such as carbonate.
When this water quality equilibrium is disturbed, such as through recharge in an ASR well, the composition of minerals and clays in the aquifer may tend to change, moving toward a new equilibrium through a variety of natural processes such as ion exchange, adsorption, desorption, solution and precipitation. These various processes have been the subject of extensive geochemical research to define the reaction pathways, reaction times, and end products. Modeis are now available, with varying degrees of complexity, to provide a reasonable basis for estimation of geochemical changes expected underground during ASR storage, the rate at which these changes occur, and the reactions that occur along this pathway. The models usually indicate the tendency of mixed waters, in the presence of certain minerals, to dissolve or precipitate clays or other minerals, depending upon the pH and the Eh of the various waters. Oxidation reduction ("Redox") potential, or ORP, are other
6
terms for Eh that are commonly used, depending upon the equipment used for measurement.
Somewhat less well-defined are the bacterial changes occurring underground. Bacteria are naturally present in ASR storage zones, even at great depths. Addition of water containing oxygen, carbon, nutrients, or with other constituents different than native groundwater, can cause a change in bacterial metabolic activity that can raise or lower pH values in the stored water, thereby potentially triggering geochemical reactions. Similarly, geochemical changes can cause a shift in pH, affecting microbial activity.
Fine-grained ASR storage zones such as sands, sandstones and clayey sands tend to be more reactive than limestone, dolomite or basalt aquifers, which sometimes have greater pore space. ASR experience during the past 17 years in the United States has demonstrated the need for extensive coring and geochemical analysis to support successful development of ASR wells in new areas utilizing such fine-grained aquifers. Redox reactions in such aquifers can cause the precipitation of iron and the dissolution of manganese, if minerals containing these elements are present in the storage zone and if these reactions are allowed to occur in ASR wells. Successful experience has shown that such reactions can be controlled, such as through pH adjustment of the recharge water, so that recovered water does not contain iron or manganese at unacceptable concentrations, even from storage zones where iron and manganese are abundant.
On the other hand, substantial experience in limestone aquifers has shown them to be relatively non-reactive. Other than water quality changes due to mixing and dispersion, recovery water quality has typically been similar to recharge water quality. Accordingly, ASR systems in limestone aquifers have received significantly less attention to changes in water quality associated with storing water from surface and groundwater sources that may or may not contain oxygen, in aquifers that do not contain oxygen.
Recent experience has shown that limestone aquifers can be more reactive than previously understood. During the past two years, detailed investigations at two ASR sites under develop~ent in Florida, utilizing limestone aquifers for storage of treated drinking water, have shown that minerals occurring in the storage zone can release arsenic into the recovered water at elevated concentrations compared to either the recharge water or the native groundwater. Based upon these investigations, the following preliminary conclusions have been drawn:
1. The occurrence of arsenic in therecovered water from ASR wells is a transitional phenomenon, most likely to occur at new ASR sites during cycle testing and initial operations. Through natural attenuation processes occurring in the aquifer, arsenic concentrations diminish with time, approaching background concentrations after four to eight operational cycles.
7
,.
Concentrations also appear to diminish with distance from the ASR well and are probably contained within the stored water volume and certainly within the target storage volume surrounding an ASR well. Arsenic is absent in the recovered waters from long-term operating ASR systems at several Florida and South Carolina sites that have been checked to date.
2. ASR systems utilizing groundwater sources are less likely to have a problem with arsenic 'in the recovered water during cycle testing and initial operations. ASR systems utilizing surface water sources are more likely to experience arsenic in the recovered water during cycle testing and initial operations, however such occurrence will attenuate with continuing operations .
3. If arsenic is initially present in the recovered water from an ASR site at unacceptable concentrations, that geochemical process can be controlled .quickly and relatively inexpensively through a chemical feed into the recharge water. The arsenic naturally present in the aquifer will stay in the
aquifer and will not be dissolved out through successive storage and recovery operations so long as the chemical feed continues.
4. It is possible to accelerate the process by which arsenic concentrations decline
in the recovered water from an ASR well, through ini_tial control of pH and oxidation processes. At some sites this approach for managing As concentrations during the transition period may be worthwhile if options are available for blending and/or treatment of the recovered water in early cycles .
5. Arsenic is present naturally in Floridan aquifer limestones and in natural groundwaters in the upper Floridan aquifer. It is one of the most common elements globally present in the environment. It is often associated with the presence of pyrite minerals and the occurrence of iron and manganese in natural groundwaters. For 17 years of ASR operations, and at eight operating sites to date in the Floridan aquifer, arsenic has not been a problem. However until recently it has not been studied intensively during initial cycle testing programs. Typically these programs have demonstrated that natural groundwater, recharge water and recovered water at the end of the cycle testing programs, have complied with drinking water standards. Expensive coring and geochemical analyses in limestone ASR systems has typically not been implemented since there appeared to be no need. In other states with finer-grained aquifer systems, such coring and geochemical analysis is routine. As a result there is little information ori differences in pyrite concentrations, and other minerals that may contain arsenic, at different ASR locati<?ns in the Floridan aquifer. In the absence of such information, the potential for arsenic formation should be assumed to be roughly the same at different locations where the aquifer is present.
B
6. Where it occurs, the generation of 'As appears to be primarily due to an oxidation-reduction reaction, reinforced by natural bacterial activity. underground. Groundwaters and other water sources with low Redox potential are less likely to dissolve arse~ic from aquifer min~rals that may be present. Surface waters tend to have higher dissolved oxygen concentrations and also higher concentrations of natural organics that can drive bacterial reactions underground, potentially altering pH and releasing any arsenic that may be present in the aquifer. As described above, such reactions are believed to be transitional and their rate and duration can be controlled, as needed to meet regulatory constraints.
.Geochemical Effects on the Aquifer Itself (on the limestone formation)
No significant geochemical effects on the aquifer have been noted at operating ASR sites to date.
. At the first ASR site, in Manatee County, Florida, dissolution of the limestone was noted in the immediate vicinity of the well during initial cycle testing conducted prior to 1983. This manifested as a steady rise in the specific capacity of the well during both recharge and recovery of the initial test cycles. Specific capacity is a measure of the rate of water movement into or out of the well (gallons per minute), divided by the increase.or decrease in water level at the well (feet). Once the mechanism was understood and quantified, the source of water for recharge was changed so that the recharge water woul~ be treated drinking water, which is geochemically stable, rather than a more convenient piping location at the original ASR site, which was at the water treatment plant, that yielded water from an intermediate point in the process flow stream that was not.geochemically stable. The ManateeASR site is now expanding for the third.time, which reflects satisfactory ASR performance at that site.
Temporary well plugging has been noted at most ASR sites, however this is a normal part of the operation and is usually resolved by periodic backflushing of the well to remove accumulated particulates in the well bore or the screen and gravel pack. Permanent plugging of the aquifer around the well, such as might occur from precipitation of calcium carbonate or ferric hydroxide, has been a source of concern at a few ASR sites where the potential for this to occur was evident, however to the best of our knowledge no such plugging has been noted. Aquifer performance tests have been conducted at a few sites, to compare aquifer hydraulic data before and after ASR operations. However such comparisons have not noted any significant differences. Plugging pot~ntial in limestone aquifers, such as those present in coastal Georgia, is less likely to be significant. Plugging potential is greater in ASR systems using fine-grained aquifers, which often require more frequent backflushing of ASR wells during normal operation.
9
Effects of Prior Treatment
Water proposed for recharge into coastal Georgia ASR wells would meet state and federal drinking water standards. Treatment prior to recharge would depend upon the water source, however if it is assumed that this is a river such as the Savannah, Ogeechee or Altamaha rivers, then treatment might include a range of processes such as disinfection, chemical coagulation, precipitation and filtration. Other water sources, such as brackish aquifers, might include membrane treatment such as reverse osmosis. Microfiltration or ultrafiltration process_es may also be used to render the water suitable for drinking purposes or for ASR storage.
To enhance the likelihood of ASR success, water treatment process design, ASR system design, and the design of connecting piping should be integrated into a single project so that the quality of water for recharge, and the quality of water produced during recovery, are compatible with water distribution-system needs and opportunities while also being compatible with aquifer mineralogy and native water quality. Where there is inadequate integration or coordination of treatment, transmission and recharge components, a higher risk exists that the ultimate plan may not work properly.
In some situations, the quality of drinking water leaving the water treatment plant is not compatible with the materials of construction for the piping in the transmission or distribution system, creating corrosion problems. Corrosion reaction products . then can plug ASR wells during recharge in addition to arousing customer complaints regarding "red water" conditions. In other situation~, treatment processes may continue in the piping system, creating aluminum hydroxide floes or microbial masses, either of which can cause well plugging. Also, the geochemical and other constraints imposed by the aquifer mineralogy in the ASR storage zone may not be compatible with the quality of water available for recharge. These are not common problems, however they occur sufficiently often that they need to be considered at each ASR site. In such situations, further pretreatment of the recharge water may be required, in addition to, or instead of, more frequent backflushing of the ASR well. This may typically include filtration, sand separation or pH adjustment.
As posed in the question above, "prior treatment" is assumed to include those supplemental processes that may be required in addition to treatment to meet drinking water standards. Prior treatment may therefore include supplemental filtration, sand separation or pH adjustment. Supplemental filtration has never been required for recharge of ASR wells in the Floridan aquifer storing treated drinking water. This reflects the high quality of th~ water source and the high permeability of the storage zone typically utilized for ASR storage.
10
Sand separation is sometimes required in areas utilizing sand and sandstone aquifers for production purposes, or for ASR storage, since sand may accumulate in distribution systems even though it is not present at significant concentrations in the water leaving the water treatment plant. During ASR recharge, flow direction in nearby portions of the water distribution system may reverse direction, flushing . sand deposits into the ASR well and contributing to well plugging. This is also not a problem for ASR systems utilizing the Floridan aquifer.
pH adjustment of the recharge water is uncommon in drinking water ASR systems, occurring where needed to control mobilization of manganese and arsenic, or precipitation of ferric oxyhydroxide during ASR storage. pH adjustment tends to condition a portion of the aquifer in a short radial distance around an ASR well so that undesirable reactions are either controlled or do not occur~ Such reactions include control of iron precipitation as ferric oxyhydroxide, manganese solution, and also solution of arsenic. At the edge of this treatment zone, no change in pH would be anticipated.
In a few states, laws or regulations have been implemented or are under consideration that call this short radial distance a "Zone of Discharge (ZOD)" or an "ASR Management Zone (AMZ)," within which natural subsurface treatment is allowed to occur. In the Netherlands, this practice has been utilized for over 50 years to treat the water supply for the City of Amsterdam. It is also practiced in Australia, to improve the quality of recharge water being stored in aquifers containing brackish water. In the United States such practice is probably consistent with federal law (1974 Safe Drinking Water Act) but may be inconsistent with the current interpretation of EPA regulations promulgated in 1981 pursuant to that law.
Mixing Effects in General
As described above, mixing effects occur within the target storage volume for an ASR well, which is usually within a radius of a few hundred feet. For very thin aqu~fers and large storage volumes, the TSV may extend to perhaps as far as 1000 to 2000ft radius, however that would be unusual.
Mixing effects would include primarilydispersion but also diffusion. Dispersion would be advective, including movement downgradient away from the ASR well due to the slope of the potentiometric surface in the upper Floridan aquifer, as shown in Figure 1. Lateral dispersion would also occur around an ASR well, due to mixing between stored water and native groundwater during recharge and recovery operations. To put these into perspective, the diameter of a typical stored water bubble might be 1000 ft. During a typical si~ month period between the middle of recharge and the middle of recovery, this bubble might move downgradient about 100 ft due to the steep gradient of the potentiometric surface in the Savannah area. If the same volume of water stored is recovered, the quality of the water at the end
11
of recovery would represent a blend of recharge water and native groundwater in the aquifer. Fortunately in the Savannnah area, the two water qualities are probably similar so there would be no practical adverse effects due to mixing. However in other areas where the Floridan aquifer is brackish, this level of mixing may impact ASR operations by creating a situation where some of the stored water is lost every year. Where the value of stored water is high, this could be a substantial annual cost, perhaps necessitating selection of a different site in the same aquifer, or a different aquifer for storage. Fortunately such situations are rare for ASR wells.
Diffusion would also occur, between the solution channels within the limestone, and the adjacent pores within the limestone. However, this "dual porosity" aspect of Floridan aquifer limestones is believed to be a relatively insignificant mechanism affecting quality of the recovered water during initial ASR tes~ng and operations.
(2) Potential for introduction of regulated or radioactive (ie: tritium) chemicals into the subsurface, and in the event that if such chemicals are introduced, the viability of successfully removing such chemicals and preventing them from being introduced into a public drinking water d~stribution system.
Water proposed for recharge into ASR wells .in coastal Georgia would probably be .from a public drinking water distribution system. Monitoring programs are already in place, or would be required, to protect public health and water quality. If any regulated or radioactive chemicals are in the drinking water, t;heir introduction into ASR wells may be considered a much smaller threat to public health than their direct consumption for public supply purposes. Many regulatory procedures are in place to ensure the high quality and reliability of water provided to the public for drinking purposes in Georgia. Since the continued availability of this valuable resource is threatened by salt water intrusion in some areas, ASR is a water management tool under consideration to enhance water supply reliability by helping to control salt water intrusion.
Many barriers are available to protect public health and drinking water quality. In .the event of contamination of any surface water source, such as due to an accidental spill of contaminants, the water treatment plant intake could be shut down until the contaminants have passed by. Monitoring systems are in place on the Savannah River for this purpose, and others could be added if other rivers are developed for water supply purposes. A second barrier to protect public health is the water treatment plant, to the extent that treatment processes are capable of treating the contaminants of concern. A third barrier is that ASR recharge would probably only occur during high flow months of the year, so any source water contamination occurring at other times of the year would not lead to aquifer recharge of those contaminants able to pass through the water treatment plant. A fourth barrier is that contaminants able to pass through the water treatment plant processes would
12
tend to be non-reactive, traveling easily with the water. As a result they should be
removable from an ASR well by pumping to waste a sufficient volume of water from
the well so that concentrations of the contaminant are reduced to acceptable levels.
Typically this might include pumping 1.5 to 2 times the volume of contaminated
water introduced into the well. Assuming that any contaminant spill is detected
within one day, recovery of at least 4 MG of stored water should resolve the
problem. This would require about two days.A fifth barrier is that any portion of
the contaminant remaining underground in the ASR well despite each of the first four barriers, would be subject to natural attenuation due to ~xing, geochemical
and bacterial processes in the aquifer during storage, prior to recovery. The ASR
well could be operated in more of a production well mode for ~ limited time period,
such as recovering 120 percent of the recharge volume each year, thereby controlling
movement of the contaminant toward adjacent wells and ensuring iliat all stored
water is recovered from the ASR well. This water would not be sent into the public
distribution system until testing indicates that it meets applicable water quality
.
I
standards.
The presence of tritium in water from the Savannah River is widely known. The Beaufort Jasper Water and Sewer Authority obtains its water supply from this river, and has maintained records of tritium levels for many years. tritium has a half-life of 13.4 years, so activity levels are declining. Typical tritium activity levels at the water treatment plant intake location on the Savannah River from July 1987 to June . ..1998 ranged from a maximum of 4460 picoCuries/litre (pCi/L) in January 1989 to a minimum of 111 pCi/L in April1993. The drinKing water standard for tritium is 20,000 pCi/L, so at no time did the acti':'ity level exceeded 25 percent of the standard during this monitoring period. Furthermore, a clear declining: trend in tritium concentrations is evident in the data from this period of record.
Recharge water containing any tritium and entering an ASR Well will probably be
recovered for direct potable use within a few months of storage. However any
portion of the water remaining underground will tend to move toward a point of
discharge, such as an adjacent well. Assuming subsurface moYement of between 35
and 350 feet per year in coastal Georgia, due to the gradient of the potentiometric
surface, the distance to an adjacent water supply well that would achieve a further
half-life reduction of tritium activity would be 470 to 4,700 feet. This is provided
only as a point of reference, since all such activity levels are consistent with drinking
water standards.
(3) Potential impact upon wells belonging to other persons (ie: loss of water)
Potential impacts may include changes in water levels or changes in water quality, both of which have been discussed above. Careful siting of any ASR facility will ensure that no adverse effects result from ASR operations.
13
Changes in water levels will depend upon the intended use of an ASR system. Ifit is used only for seasonal water storage, water levels in adjacent wells will be unchanged on an annual average basis, however they will rise during recharge periods and fall during recovery periods. The amount of rise and fall will need to be determined on a site-specific basis, however Table 1 provides a preliminary estimate based upon representative data for the Savannah area. If the ASR system is intended for multiple uses, such asseasonal storage and also salt water intrusion control, then average water levels will tend to rise, offsetting the substantial decline that has occurred during the last few decades of heavy groundwater production. This would tend to reduce pumping costs for adjacent well owners.
Changes in water quality are not expected outside the radius associated with the target storage volume for an ASR well. As described above, for a typical ASR well in the upper Floridan aquifer in the Savannah area, the radius of the TSV is estimated at approximately 2000 feet or less, associated with seasonal water storage operations. Adjacent wells located outside this radius would be unlikely to experience any change in water quality associated with seasonal storage operations. If much greater volumes are stored, or if storage durations are such that considerable advective transport of the stored water occurs, it is possible that adjacent wells located downgradient of the ASR well might experience a slight change in water quality, associated with blending treateq drinking water with the fresh water naturally occurring in the aquifer.
(4) Other negative impacts
We are aware of no other negative impacts upon groundwater quality, public health or the environment, associated with ASR operations at 39 sites around the United States. The principal driver for implementation at these sites has been the relatively low cost of meeting urban and ecosystem water needs with ASR technology, compared to other conventional options. Typically ASR can meet these needs at less than half the capital cost of other options.
A very important secondary driver has been the perceived environmental benefits of ASR compared to other water storage technologies. In particular, ASR has been supported by many water management and regulatory agencies as a desirable approach that provides sustainable water supplies, reducing or eliminating the need for diverting water from rivers and lakes during dry periods, maintaining minimum flows and levels, and reducing or eliminating the need for construction and operation of surface storage reservoirs.
Opposition to ASR has occurred at two locations that we are aware of. The first was in Kerrville, Texas, about five to eight years ago when whitewater kayaking recreational interests intervened legally to block efforts by the Upper Guadalupe River Authority to operate an ASR system that they had already constructed and
14
tested. Their opposition was based upon concern regarding diverting water from
the river at high flow periods. After three court decisions in three years, that legal
challenge was ended and the Kerrville ASR system is now in satisfactory operation,
with expansion underway. The second area of legal opposition has been in coastal
Georgia, which has been the subject of this brief report.
'
Other technical and regulatory issues have arisen on virtually all of the operating ASR sites, and have bee1,1 successfully resolved. Typically the first ASR system in each new state requires a lot of effort to resolve issues and que~tion5 that are raised. Once the first system is constructed and placed into operation, other systems usually follow rapidly to capitalize on the benefits and cost-savings of :ASR.
Some more common water quantity issues have included whether or not water can be stored in wet periods and recovered in dry periods, as intended, or whether recharge and recovery should be constrained to occur within a calendar year or a water year, regardless of whether or not that year is relatively 'wet or dry. Ownership or permitted rights to the stored water is also an issue in some areas, although the direction of legal and regulatory decisions is to sustain permitted rights to recover the stored water from an ASR well, rather than requiring separate permits for recharge and for recovery. Mitigation of any significant adverse effects upon water levels in wells of adjacent well owners has sometimes arisen as a site-specific issue. And the definition of ambient groundwater quality in a proposed storage zone has been the subject of recent discussion in Florida, whether to evaluate this based upon pumping a well for a few hours or days until water quality reaches an equilibrium, or to define it after sampling three casing volumes irrimediately after well construction, regardless of whether water quality equilibrium has been reached .
A high profile, current ASR water quantity issue that is now the subject of much discussion is the planned Comprehensive Everglades Restoration Program in south Florida. That plan includes over 300 ASR wells capable of recharging and recovering water at combined rates up to two billion gallons per day. Concern has been expressed that such high rates may hydrofracture the Hawthorn confining layer over the upper Floridan aquifer, which is proposed as the storage zone. The confining layer is about 600 feet thick and is composed of stiff clays, low permeability limestones and clayey sands. A series of ASR Demonstration Sites are planned to gather the information needed to properly address this issue. Preliminary modeling conducted by CH2M HILL suggests that this should not be a problem. It is significant, perhaps, to the proposed regional ASR applications in coastal Georgia since this Florida project is the first planned large-scale regional application of ASR tedmology.
Some water quality issues of concern at different sites have included the need for control of iron, manganese, fluoride, hydrogen sulfide, chloride, total dissolved solids, sulfate, arsenic, radium (224, 226, 228), radon, gross alpha radioactivity,
15
disinfection byproducts, coliform bacteria, protozoa, viruses, nitrate, nitrite, ammonia, phosphorus, mercury, dissolved gases, and other natural constituents sometimes found in native groundwaters. or in aquifer minerals. For some of these issues, the effort required to achieve resolution has been time consuming, however in each case to date a satisfactory resolution has been found, enabling these projects to move forward.
Conclusion
Experience during the past 17 years with ASR development in other states has
shown that initial uncertainties, such as the questions posed in this memorandum,
are relativelynormal. It is hoped that the responses that have been offered will
prov~ helpful in guiding future ASR development in coastal Georgia and other parts
of the state, providing one more proven water management tool to those charged
with managing regional water resources and providing urban, domestic,
agricultural and industrial water supplies.
Full confidence in the applicability of ASR technology in Georgia can only come from having at least one full size ASR well constructed, tested, permitted and placed into operation. Until that time arrives, partial confidence can be achieved through literature reviews, studies, investigations, modeling, and site visits to other nearby operating ASR sites utilizing the upper or lower zones ofthe Floridan aquifer as a storage zone. In South Carolina, such sites are located at Beaufort Jasper Water and Sewer Authority, Mt Pleasant Waterworks, and Grand Strand Water and Sewer Authority, while an additional site is approaching completion of testing at Kiawah Island. In Florida, the nearest operational ASR sites are at the City of Cocoa, Town of Palm Bay, City of Tampa, Manatee County, Peace River/Manasota Regional . Water Supply Authority and City of Boynton Beach.
To assist in this process, pertinent references regarding ASR are included at the end of this report. Several web sites have also been developed for ASR, including www.asrforum.com, which has links to some of the other web sites.
References
AWRA, "Conjunctive Use of Water Resources: Aquifer Storage Recovery" Conference Proceedings Oct-19-23, 1997 Long Beach, California, 1997.
AWWA Research Foundation. "Aquifer Storage Recovery of Treated Drinking . Water," 1996.
Clarke, et al. Geology and Ground-Water Resources of the Coastal Area of Georgia.
Georgia Geologic Survey Bulletin 113. p. 106, 1990.
16
Gill, H.E., and Mitchell, G.D. Results of Colonels Island Deep Hydrologic Test Well; In Investigations of Alternative Sources of Ground water in the Coastal Area of Georgia: Georgia Department of Natural Resources, Geologic and Water Resources Division Open-File Report 80-3, p. C1-C13, 1979.
Gregg, D.O., and Zimmerman, E.A. Geologic and Hydrologic Control of Chloride Contamination in Aquifers at Brunswick, Glynn County, Georgia: U.S. Geological Survey Water-Supply paper 2029-D, p. 44 1974.
Krause, R.E. and Randolph, R.B., 1989, Hydrology of the Floridan Aquifer in . Southeast Georgia and Adjacent Parts of Florida and South Carolina: U.S. Geological Survey Professional Paper 1403-D. 1989.
McCollum, M.J., and Counts, H.B., 1964, Relation of Salt-Water Encroachment to the
Major Aquifer Zones, Savannah Area, Georgia and South Carolina: U.S. Geological ~urvey Water-Supply Paper 1613-D, p. 26 1964.
Miller, J.A., Hydrogeologic Framework of the Floridan Aquifer System.in Florida and in Parts of Georgia, South Carolina, and Alabama: U.S. Geological Survey Professional Paper 1403-B, p. 91 1986.
McNeal and Craig, "St. Petersburg's REWARD Program: A Step Toward Full Reuse Optimization" FS/AWWA Annual Conference, Nov 29-Dec 2,1999
Pyne, R. D. G., Groundwater Recharge and Wells: A Guide to Aquifer Storage Recovery, Lewis Publishers, CRC Press, ISBN 1-56670-097-3, 376 pp., 1995.
Pyne, McNeal and Glanzman (in prep.) "The Occurrence and Control of Arsenic in
Aquifer Storage (ASR) Wells." CH2M HILL,2001
.
17
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APPENDIX2
,.
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.I
Golder Associates Inc.
3730 Chamblee Tucker Road Atlanta. GA USA 30341 Telephone (770) 496-1893 Fax(770)934-9476
TRANSMITTAL LETTER
TO: Georgia Geologic Survey 19 Martin Luther King Jr. Drive SW Room 400 Atlanta, Georgia 30334
ATTN: Dr. William McLemone
DATE: April27, 2001 Project No.:003-3019.002
State Geologist
Sent by: Jim Renner OMail
D Air Freight D Hand Carried
QUANTITY 3
ITEM Reports
D Under Separate Cover D Enclosed
[8J Federal Express
DESCRIPTION Report on Environmental Review of Aquifer Storage and Recovery in the Floridian Aquifer of Coastal Georgia
1
Remarks: Per:
OFFICES IN AUSTRALIA. CANADA. GERMANY. HUNGARY. ITALY, SWEDEN. UNITED KINGDOM. UNITED STATES
\.
Golder ASsociates Inc.
3730 Chamblee Tucker Road Atlanta. GA USA 30341 Telephone (770) 496-1893 Fax (770) 934-9476
REPORT ON.
ENVIRONJ\.1ENTAL REVIEW OF AQUIFER STORAGE AND RECOVERY
IN THE FLORIDAN AQUIFER OF COASTAL GEORGIA
Submitted to:
Georgia Geologic Survey 19 MartinLuther King Jr. Drive SW
Room 400 Atla1;1ta, Georgia 30334
Prepared by:
Golder Associates Inc. 3730 Chamblee Tucker Road
.Atlanta, GA 30341
Distribution:
3 Copies - Georgia Geologic Survey 9 Copies -Golder Associates Inc.
April2001
003-3019.002
OFFICES IN AUSTRALIA. CANADA. GERMANY. HUNGARY. ITALY. SWEDEN, UNITED KINGDOM, UNITED STATES
,.
Georgia Geologic Survey Dr. William McLemore
- 1-
TABLE OF CONTENTS
April2001 003-3019.002
Table of Contents .............................................................................................................................. i Exe~utive Summary ................................................................. ~................................................... E-1
SECTION
PAGE
J.,Q INTRODUCTION .......................................:........................................................................ 1
Ll Background ........................................................................................................................ 1 !.1 Report Objective and Approach ........................................................................................ 2
2.0 ASR PHYSICAL AND HYDROCHEMICAL PROCESSES ..............................................4
D Physical Processes ............................................................................................................. 4
2.2 Water Quality Processes .................................................................................................... 5 . 3:0 IMPACTS AND IMPACT MITIGATION- LOWER FLORIDAN AQUIFER .................. 7
lJ. Physical Effects ................................................................................................................. 7
3.2 Water Quality Effects ........................................................................................................ 7 3.2.1 Suspended Sediment Fonnation ................................................................................. 7
3.2.2 Disinfection By-products ........................................................................................... 8 3.2.3 Solute Transport Effects ............................................................,................................ 9
4.0 IMPACTS AND IMPACT MITIGATION- UPPER FLORIDAN AQUIFER.................. tO
11. Physical Effects ................................................................................................................ 10
4.2 Water Quality Effects ...................................................................................................... 11
4.2.1 Suspended Sediment and Disinfection By-products ................................................ 11 4.2.2 Uranium Mobilization and Introduction of Tritium ................................................. 11
4.2.3 Pyrite Oxidation .......................................................................:............................... 12 4.2.4 Advective Transport ................................................................................................. 12 4.2.5 Diffusion Exchange ofSolutes..........................................................:...................... 13 5.0 SUMMARY ....:......... ~.; .............................................................................,......................... 14
In Order Following
Page 13
TABLES
TABLE 1 TABLE 2
Potential Impacts Associated with ASR Operations in the Lower Floridian Aquifer Potential Impacts Associated with ASR Operations in the Upper Floridian Aquifer
FIGURES
FIGURE 1 Conceptual ASR Operation
APPENDICES
APPENDIX A Summary of Documented Environmental Impacts of ASR Operation APPENDIX B Floridan Aquifer Hydrogeology APPENDIX C Bibliography
Golder Associates
Georgia Geologic Survey Dr. William McLemore
- E-1 '-
April2001 003-3019.002
EXECUTIVE SUMMARY
The Georgia Environmental Protection Division Geologic Survey Branch (GAEPD) requested that Golder Associates Inc. identify environmental impacts tha.t might arise from construction and operation of an aquifer storage and recovery (ASR) system in the Floridan Aquifer of coastal Georgia. This review .included an examination of the following issues identified by GAEPD as being of significance to coastal Georgia stakeholders:
Movement and distribution of water recharged to the aquifer;
Pressure. effects resulting from injection, including ground stability or water level
impacts on wells adjacent to the ASR well field;
Alteration of the quality of the water recharged to the aquifer (including the likely
effects of chemical reaction between the recharged water and the Floridan Aquifer
limestones);
Alteration of the quality of any in situ groundwater affected by ASR operations
(including general mixing effects and the effect of mixing aerobic and anaerobic
water);
Potential for the introduction of regulated or radioactive substances (e.g. tritium) ~o
the Floridan Aquifer; and
Likelihood that contamination can be successfully remediated.
Golder Associates performed a limited review and assessment of the published and unpublished technical literature on ASR and considered the physical and hydrochemical processes of ASR in light of the characteristics of the Upper and Lower Floridan Aquifers. No instances where aquifers have become polluted as a consequence of ASR have been reported by EPA. In addition, no literature was reviewed that identified physical impacts resulting from an operating ASR. However, physical and hydrochemical processes of ASR could result in environm~ntal impacts depending on the design and operation of a specific ASR system, the characteristics of the storage aquifer and confining or interconnected units, and the utilization of other production wells. Potential impacts of ASR in the Floridan Aquifer of coastal Georgia might include:
Lower Floridan Aquifer
. Generation of suspended iron and manganese oxi-hydroxide sediment due to
dissolved oxygen in the injected water;
~
Generation of Disinfection by Products (DBP's) as a consequence of organic matter
oxidation by disinfection chemicals present in the injected water;
Increased solute concentrations in the Upper Floridan Aquifer as a consequence of
the ASR-induced displacement of poor quality water from the Lower Floridan.
Golder Associates
Georgia Geologic Survey Dr. William McLemore
- E-2-
April2001 003-3019.002
Upper Floridan Aquifer
Uncontrolled discharge from improperly abandoned wells, loss of yield in nearby production wells, and ground destabilization effects linked to water level changes during injection and recovery; .
Suspended sediment and DBP generation similar to that described for the Lower Floridan Aquifer;
Increased concentration of dissolved uranium due to oxidation of uranium-bearing minerals by dissolved oxygen in the injected water;
Increased sulfate and metal concentrations and decreased pH as a consequence of pyrite oxidation in the Upper Confining Unit due to ASR-induced dewatering of the unit;
Lateral migration of poor quality water to other production wells due to flow in large diameter conduits in the southern coastal area and steep hydraulic gradients. in the northern coastal area;
Diffusion of exchange of solutes between the injected water and the aquifer matrix.
In each case, the probability of the impact being realized, the severity of the impact, and the need for and design of impact mitigation measures could be ass.essed by site-specific investigations for a proposed ASR. Such investigations would:
Describe the local geology, hydrogeology, and hydrochemistry; Model the behavior of the aquifer and associated units during alternative injection
and recovery scenarios; Define source-pathway-receptor relationships (e.g. the influence of the proposed
ASR on other production wells or sensitive hydrologic systems).
Following the initial assessment, pilot testing would be an effective means of validating models, making direct observations of physical and hydrochemical pr?cesses, and comparing alternative ASR designs and operating schedules. Finally, monitoring water quality, aquifer characteristics, and ground conditions in potentially sensitive areas during ASR operation would alert operators to possible concerns. Such a monitoring program implies effective facility maintenance, staffing, and operator training as a necessary requirement of ASR operation.
In summary, ASR has the potential to be a useful water resource management tool in coastal Georgia. ~orne concerns have been identified, but no environmental impacts have been identified that could not potentially be mitigated. An active permit program administered by GAEPD could insure that pre-construction investigations, pilot testing, and ASR design, operation, and monitoring are adequate to achieve the water resource management benefits while mitigating environmental impacts.
Golder Associates
Georgia Geologic Survey
Dr. William McLemore
- 1-
April2001 003-3019.002
1.0 INTRODUCTION
1.1 Background
Aquifer storage and recovery (ASR) is a water resources management technique in which treated water is stored by injection into permeable geologic formations. Common ASR applications include:
Meeting demand during periods when the available reserves of raw water are depleted (during droughts, .for example);
Meeting demands which exceed the available treatment capacity (peak demand. management);
Managing groundwater levels for the purpose of maintaining well-field yields or t: controlling salt-water intrusion.
During typical ASR operations, treated water from a surface source or supply aquifer is injected
into an alternate aquifer when surplus water resources are available, demand is low, and surplus
treatment capacity exists (Figure 1). The duration of the subsequent storage period is usually a
I
function of seasonal influences on resource availability and demand. A combination of demand,
. available yield and the total volume of treated water in storage determine the rate and duration of
recovery .
Operational ASR facilities are found in Europe, Africa, Australia and the United States. Systems . in the United States have been in operation or in pilot studies for about thirty years, including approximately 34 facilities in Florida, several of which utilize the Floridan Aquifer. Typically; these facilities utilize either treated surface water or treated ground water as their supply source. However, Florida has recently issued two construction permits, received another construction application and held two pre-application meetings with several utilities interested in using reclaimed wastewater as an ASR source water. Raw ground water injection and raw surface water injection are also proposed (ASRIT, 1999).
In South Carolina, three ASR systems are operating and one system has been under study for 6 . years (Campbell, 2000):
The Beaufort-Jasper Water and Sewer Authority injects treated Savannah River water into the Upper Floridan Aquifer to supply peak demands during summer months, thereby avoiding the need to build an additional treatment plant. The ASR system has operated for one year. Last year 140 million gallons were injected and120 million gallons were
Golder Associates
.)
Georgia Geologic Survey
Dr. William McLemore
-2-
April2001 003-3019.002
withdrawn at a rate of about 2.5 mgd. The withdrawn water is treated lightly (slight disinfection) and mixed with treated surface water. Plans call for increasing capacity to 500 million gallons (Saxon, personal communication). The Mt. Pleasant Waterworks uses reverse osmosis to treat approximately 400 to 500 gaVmin (less than 1 mgd) of water withdrawn from the Cretaceous Middendorf Aquifer. Excess water is injected i11to the Santee Limestone, a Lower Floridan equivalent, allowing the reverse osmosis system to operate at a constant rate. The Grand Strand Water Authority serves the seasonal peak demand of Myrtle Beach by injecting treated surface water into the Cretaceous Black Creek Aquifer. The U.S. Geological Survey has been testing an emergency ASR system for the City. of Charleston to provide water during severe weather when the old distribution system typically experiences problems. This system is somewhat unusual in that it will rely on one time injection of treated surface water into the Santee Limestone.
In Georgia, the state legislature has instituted a moratorium on ASR permitting in order to allow the Georgia Environmental Protection Division (GAEPD) to consider the benefits and consequences of ASR in the coastal area. Additionally, the GAEPD is interested in the utility of ASR in managing salt water intrusion in the vicinity of Savannah and Brunswick.
1.2 Report Objective and Approach
The purpose of this report is to identify environmental impacts that might arise from ASR operations in the Floridan Aquifer of coastal Georgia and to identify possible me.ans by which impacts could be mitigated or managed. For this report, environmental impacts are taken to be any situation or circumstance that has the potential to cause harm or damage to human health or the environment, including:
Physical impacts such as flooding, loss of well yield, and ground destabilization effects (such as ground heave, subsidence, or hydraulic fracturing);
Water quality impacts, such as concentrations of chemicals or micro-biological organisms that are in excess of those currently permitted in drinking water.
To identify potential impacts and mitigation measures, Golder Associates Inc. (Golder) reviewed literature describing the hydrogeology and hydrogeochemistry of the Floridan Aquifer of coastal Georgia and assessed critical features of the ~uifer system relative to ASR. Floridan Aquifer characteristics were then compared to theoretical and actual descriptions of ASR processes, as documented in peer-reviewed journals, conference proceedings, published and unpublished reports and on the internet. Owing to marked differences in Floridan Aquifer hydrogeology, the potential for ASR-related environmental impacts is discussed in terms of the northern (Savannah) and southern (Brunswick) coastal areas .
Golder Associates
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Georgia Geologic Survey
Dr. William McLemore
.; 3 ~
April2001 003-3019.002
In identifying ASR impacts and mitigation measures, Golder made several ,assumptions, as directed by GAEPD:
Any ASR system will require a permit from GAEPD; ASR permit applicants will have to _perform site specific investigations under the
direction of qualified geologists, hydrogeologists, and engineers to address the potential for adverse environmental impacts; Only entities with sufficient capital to invest in appropriate operational facilities, staffing, and operator training will be permitted to develop ASR; Any water injected into the Floridan Aquifer will meet State drinking water standards. Water may be injected into the Upper or Lower Floridan Aquifers, but not the Fernandina Permeable Zone.
For purposes of this report, impacts resulting from operator error (e.g. accidental injection of
i.mproperly treated water) are not emphasized since operator error is possible with any water
treatment or distribution system and is not unique to ASR.
Golder Associates
Georgia Geologic Survey
Dr. William McLemore
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April2001 003-3019.002
-2.0 ASR PHYSICAL AND HYDROCHEMICAL PROCESSES
ASR operations initiate physical and hydrochemical processes in the. storage aquifer. Physical processes include deformation of the aquifer host rock and movement of the injected or native ground water. Ground water pressure changes are often associated with physical processes. Hydrochemical processes include alteration of the chemical characteristics of the recharged water (including changes due to chemical reaction with the aquifer host rock) and alteration of the insitu ground water quality.
2.1 Physical Processes
No literature was reviewed that identified physical impacts directly related to an operating ASR system. Nonetheless, ASR physical processes could provide an opportunity for environmental impacts, depending on the characteristics of the aquifer, the design and operation of the ASR system, and the presence of nearby sensitive receptors (other production wells).
The treated drinking water used for ASR is typically recharged using large-diameter purposefully designed injection wells or modified production wells; These wells allow the water to enter the well via the pump column, sized drop-pipes, drop pipes with flow control valves or direct injection into the annular space between the casing and the pump rising main. Recharge rates are maintained either by gravity flow or pressure in the distribution system; the choice being dependent upon the rest water level in the well and the water level rise or pressure ("head") increase which occurs in response to injection. The head build-up in the well is a function of both the hydraulic properties of the aquifer and the well efficiency; the head build-up in the aquifer is a function of the aquifer properties alone. Similar effects- determine the water level response to . recovery .
Storage of recharged water in confined aquifers occurs principally by elastic deformation of the
aquifer matrix. However, ASR storage processes are evident as both a head level increase
associated with elastic deformation and a displacement of the in situ groundwater by the injected
tl
water. Typically, the pressure effects are transmitted over larger areas than the change in w~ter
quality that is associated with displacement of the in-situ groundwater.
Golder Associates
Georgia Geologic Survey
Dr. William McLemore
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April2001 003-3019.002
The shape and properties of the region of increased pressure or water level rise and the recharged
water mass,is a function of:
Recharge rate and duration (total stored volume); Distribution of aquifer properties (vertically and horizontally); Presence of aquifer boundary conditions; Properties of the in situ groundwater (pressure, temperature, salinity); Pre-existing hydraulic gradients.
For a given aquifer geometry, in situ groundwater quality, and well efficiency, ASR operations in higher transmissivity/lower storativity systems produce smaller head changes and more rapid stabilization of head build~up and draw-down than equivalent operations in lower transmissivity/higher storativity systems. In all cases, transmissivity effects dominate over storativity effects.
Simultaneous ASR operations in closely spaced wells typically produce head build-ups or drawdowns that are greater than would be anticipated on the basis of the performance of each individual well. This effect arises as a consequence of the superposition of the head changes associated with each well (termed "well interference").
2.2 Water Quality Processes
. The U.S. Environmental Protection Agency reported that there have been no instances where aquifers have become polluted as a consequence of ASR (EPA, 1999a). However, ASR-related changes in water quality can be observed within the stored water, in the mixing zone between the stored and in situ water, and at locations removed from the ASR aquifer and the stored water mass. Physical and chemical processes that may be responsible for such changes include:
Within the Stored Water
In
the
Mixing
Zone
Reactions between constituents in the injected water and the aquifer matrix minerals;
On-going reactions between constituents in the injected water; Diffusion of constituents in the injected water into the matrix-held
groundwater and vice-versa (in dual porosity aquifers)
Reaction between dissolved constituents in the injected water and the in situ groundwater;
Hydrodynamic-dispersion of the injected water, including mechanical dispersion and diffusion
Golder Associates
Georgia Geologic Survey
Dr. William McLemore
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April2001 003-3019.002
At Off-site Locations
Pressure displacement of in situ groundwater and migration into adjacent
aquifers or surface waters.
Golder Associates
Georgia Geologic Survey
Dr. William McLemore
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Apri12001 003-3019.002
3.0 IMPACTS AND IMPACT MITIGATION AQUIFER
LOWER FLORIDAN
3.1 Physical Effects
No adverse physical environmental impacts are anticipated from ASR operations in the Lower Floridan Aquifer due to:
Large thickness of overlying strata (750ft to 1500 ft). The postulated high permeability of the Lower Floridan Aquifer in the southern coastal
area. Therefore, the pressure effects arising from injection or recovery are likely to be both small and spread over a large area. The absence of production wells that penetrate the Lower Floridan Aquifer.
Consequently, there is little potential for ASR-related ground destabilization, flooding, reduced yield in other wells, or other physiographic or hydrologic impacts.
3.2 Water Quality Effects
3.2.1 Suspended Sediment Formation No data describing the redox conditions in the Lower Floridan Aquifer were available. However, given the widespread occurrence of reducing conditions in the Upper Floridan Aquifer and the origin of freshwater in the Lower Floridan Aquifer as recharge from the Upper Floridan Aquifer, itis considered likely that reducing conditions prevail in the Lower Floridan Aquifer.
When treated water containing dissolved oxygen is injected into reducing groundwaters that contain iron or manganese, oxidation of these constituents will result in the formation of oxide and oxy-hydroxide precipitates. In the conduit flow systems ofthe southern coastal region, these precipitates may remain suspended in solution under the infl.uence of high groundwater velocities or turbulent flow. Such suspended material may then adversely impact the quality of groundwater thatis withdrawn from affected portions of the aquifer.
~
The affected portion of the aquifer is likely to be restricted to the mixing zone between the injected and in-situ water in areas where (a) the mixing zone is penetrated by wa~er supply wells and (b) the in-situ ground water contains dissolved iron and manganese. Given the limited development of the Lower Floridan Aquifer for water supply purposes and the likely presence of
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April2001 003-3019.002
sulfide in the in-situ groundwater, the potential for adverse impact is small. Additionally, impacts could be effectively managed by a combination of the following measures:
Identification of production wells in the vicinity of the mixing zone between the injected and in~situ water;
Site specific assessment of the redox conditions and dissolved constituents in the in-situ ground water;
Water quality monitoring during ASR pilot testing; Modification of the ASR location, size, and/or operations schedule (injection rate, storage
duration, recovery rate, etc.); Relocation of potentially affected production wells if impacts are observed or predicted; Treatment of withdrawn water to remove suspended sediment.
3.2.2 Disinfection By-products In ASR operation, raw water from a surface source or alternative aquifer is treated to drinking water standards prior to injection into the storage aquifer. Residual disinfectant compounds may be present in the injected water, and oxidation of organic matter in the storage aquifer may J>roduce disinfection by-products (DBPs). Some DBPs are believed to adversely affect human health (e.g. trihalomethanes). Under circumstances in which DBPs are generated and accumulate, stored water quality may be adversely affected. ASR provides an opportunity for generation of DBPs beyond that encountered in traditional water supply operations due to the introduction of treated water after disinfection into a medium (the storage aquifer) that may contain organic matter .
The potential for forming DBPs is a function of the disinfectant (chlorine compounCis are of . particular concern), disinfection method (concentration, contact time, etc.), the types of organic matter present in the storage aquifer, water temperature, pH, and the concentration of bromide in the in-situ ground water. It is likely that impacts. associated with DBP formation can be effectively managed by:
Characterization of the injected and in-situ water quality and the organic matter content of the ASR aquifer matrix material;
Modeling and assessment of the potential for DBP formation; ASR pilot testing and monitoring of injected, in-situ, and extracted water; Modification of the disinfection method of the injected water; Injection into a stratum with lower potential for DBP formation; Managing the ASR injection and extraction schedule to promote natural attenuation of
the DBPs; Additional treatment of water extracted from the storage aquifer prior to distribution.
Golder Associates
Georgia Geologic Survey
Dr. William McLemore
-9 -
April2001 003-3019.002
3.2.3 Solute Transport Effects In localized areas of both the northern and southern coastal regions, the Lower Floridan Aquifer is thought to be in hydraulic continuity with the Upper Floridan Aquifer. In the north this is reflected in the hydraulic response of both aquifers to pumping from the Upper Floridan Aquifer. In the south it is suggested by the pattern of saline upconing in Brunswick.
If injection into the Lower Floridan Aquifer results in an increase in the head gradient across the Middle Confining Unit, upward flow from the Lower to the Upper Floridan Aquifer may be increased. In such cases, the quality of Upper Floridan Aquifer water may be adversely affected if the quality ofwater migrating upward from the Lower Florida~ Aquifer is poor. The potential for adverse impacts to production wells in the Upper Floridan Aquifer will be a function of the insitu .water quality, local permeability distribution, the size of the proposed ASR system, and the proximity of the system to production wells in the Upper Floridan Aquifer. This suggests that the potential for any adverse impacts are likely to be local and so may be effectively managed by:
Characterization of the groundwater quality of the Lower Floridan Aquifer; Assessment of the existing and predicted hydraulic gradients and the permeability of the
Middle Confining Unit; Modeling of ground water migration under different operation conditions; ASR pilot testing and monitoring in the Upper and Lower Floridan Aquifers; Identification of local Upper Floridan Aquifer production wells, and monitoring during
ASR operation; Alteration of the ASR operation schedule to reduce the potential for upward migration
(possibly including relocation to an area where the confining unit is least permeable).
Golder Associates
e
Georgia Geologic Survey Dr. William McLemore
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April2001 003-3019.002
4.0 IMPACTS AND IMPACT MITIGATION- UPPER FLORIDAN AQUIFER
4.1 Physical Effects
It seems unlikely that substantial physical impacts will derive from ASR in the Upper Floridan Aquifer of the southern coastal region, principally due to a combination of the significant thickness of the overlying Upper Confining Unit and extremely high values of aquifer transmissivity. Under such circumstances, ASR-induced head changes are likely to be small and distributed over a large area, so that ground effects or interference with nearby production well yields are likely to be minimal.
By contrast, the lower transmissivity of the Upper Floridan Aquifer in the northern coastal region, combined with the reduced thickness or local absence of the Upper Confining Unit, means that there is a greater potential for ASR-related physical effects. Such effects would arise from the larger head responses that may occur in response to injection or recovery and could include:
Uncontrolled overflow from poorly sealed or capped wells or very localized flooding by upward leakage through the Upper Confining Unit;
Loss of yield in nearby wells; De-stabilization of deep foundations as a consequence of re-saturation of near surface
sediments and an associated loss of mechanical strength; Ground heave or subsidence caused by changing pore-water pressures in near surface
sediments; Hydraulic fracturing of confining strata.
Cooper-Jacob seeping calculations indicate that the risks are only likely to be significant in areas
close to the ASR site, where the resultant potentiometric surface is at or near ground level and
where
exceptionally .
large
volumes
of
water
are
recharged
and
rec.overed
through
.networks
of
closely spaced wells. This suggests that the potential for any associated impact is likely to be
localized and so may be effectively managed by:
, .
Site-specific characterization of the geology and hydrogeology at the test site; Hydrologic modeling to determine the magnitu~e of the head level changes that are likely
to-result from ASR operations;
Reducing the amount of injected or recovered water;
Modifying the ASR well-field layout so as to increase the distance between adjacent
wells .
Monitoring foundation movement and ground elevation in the immediate vicinity of
injection and recovery wells during pilot testing and operation;
Capping and/or properly abandoning unused Floridan Aquifer wells.
Golder Associates
.
\
Georgia Geologic Survey Dr. William McLemore
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April2001 003-3019.002
4.2 Water Quality Effects
4.2.1 Suspended Sediment and Disinfection By-products The potential for formation of suspended iron and manganese oxi-hydroxide sediment and DBPs impacts in the Upper Floridan Aquifer and the opportunity for mitigating these impact is similar to the Lower Floridan Aquifer.
4.2.2 Uranium Mobilization and Introduction of Tritium Eocene and Miocene rocks in Georgia frequently contain strata of clay, organic material, phosphates, or dolomites which contain uranium minerals. In particular, concentrations. of the element are found in the phosphate bearing minerals that are distributed throughout the Upper Confining Unit.
Given the reducing conditions. in the Upper Flor:idan Aquifer, any uranium that is present is likely to be in the form of the low solubility mineral uraninite. Under circumstances in which the uraninite comes into contact with injected water containing dissolved oxygen, however, oxidation may result in dissolution of the mineral and mobilization of the associated uranium. Where _concentrations of the element accumulate, an ad'-:erse impact on the stored water quality may potentially_ occur.
Given that phosphate-bearing minerals are relatively uncommon, except in the Upper Confining Unit, the associated risk is likely to be localized and so may be effectively managed by:
Characterizing the mineral assemblages present in the aquifer host rocks and the .
confining units, with particular emphasis on identification of uranium bearing minerals in
the strata targeted for ASR development;
Examine the accessibility of the uranium-bearing minerals to the injected water
containing dissolved oxygen and predict dissolution and resultant concentrations of
dissolved uranium ions;
If necessary, identify alternate locations for the ASR system where uranium minerals are
not abundant or case off individual uranium-bearing strata;
Operate the ASR system to extend storage time to promote natural reduction of dissolved uranium .
Monitor for dissolved uranium during ASR pilot testing and operation.
Tritium is a constituent of concern in Savannah River water due to the Savannah River Site nuclear facility upstream. Reported levels of radionuclides in Savannah River water are well
Golder Associates
Georgia Geologic Survey Dr. William McLemore
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April2001 003-3019.002
below regulatory guidelines, so the likelihood of introducing tritium into an ASR system that made use of Savannah River water would appear to be low. In addition, the City of Savannah and other entities already use the Sava'nnah River as a raw water supply. Therefore, the risk of utilizing Savannah River water for ASRdoes not seem to be substantially different than the risk now accepted by existing water users, except that the processes of diffusion exchange and advective transport described below could influence the transport of tritium introduced into the aquifer .
4.2.3 Pyrite Oxidation Although not detected during visual inspection of cores and washed samples (USGS, personal communication), pyrite may be locally present in the clays, silts and sandy clays of the Upper Confining Unit. If groundwater withdrawal from the Upper Floridan Aquifer dewaters the Upper Confining Unit, pyrite may be oxidized, possibly causing adverse sulfate, pH, iron or alkali metal impacts on the quality of the recovered water. The magnitude of the impact will be a function of the amount of pyrite. present, the permeability of the Upper Floridan Aquifer and the Upper
I
Confining Unit, and the extent to which withdrawals induce dewatering of the Upper Confining Unit. Special attention should be paid to pyrite oxidation in areas where the Upper Confining Unit has already been dewatered by extensive pumping. Impacts from pyrite oxidation may be effectively managed by:
Quantify the pyrite content of the Upper Confining Unit strata likely to be affected by the proposed ASR operations;
Predict the draw-down likely to be experienced during the extraction of the stored water; If necessary, relocate the ASR system to a more favorable location; Reduce the amount of stored water that is recovered in an individual well; Increase the spacing between extraction wells to minimize exaggerated drawdown caused
by well interference; Monitor water quality during ASR pilot testing and operation;
4.2.4 . Advective Transport
,. Poor quality water generated by any of the mechanisms previously described could laterally
migrate within the Upper Floridan Aquifer due to:
The concentration of flow in large-diameter conduits such as cavities and solution channels in the southern coastal region;
The occurrence of steep hydraulic gradients in areas close to Savannah in the northern coastal region;
Golder Associates
Georgia Geologic Survey Dr. William McLemore
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April2001 003-3019.002
The presence of a large number of public and private water supply wells in both the northern and southern coastal regions.
The potential for extensive lateral migration of poor quality water could be effectively reduced
by: .
Employing previously described measures to limit the opportunity to generate poor quality water;
Controlling the ASR injection and extraction schedule and well locations to avoid substantial steepening of hydraulic gradients;
Monitoring water quality in nearby production wells.
4.2.5 Diffusion Exchange of Solutes Where groundwater flow .in the Upper Floridan Aquifer of the northern coastal region occurs through fractures, the moderate hydraulic conductivity of the unit suggests that these may include a significant number of relatively small-scale features. A group of small-scale fractures has greater surface area relative to the amount of void space versus a large fracture. If the fractured matrix also possesses significant porosity, solute species flux between the fractures and the matrix via the process of diffusion exchange. Under these circumstances, poor quality water that enters the system may partition between the water in the fractures and the matrix-held pore water. Therefore, if ASR introduces or generates poor quality ground water, the poor quality water and/or undesirable constituents may be retained longer than would be predicted for ground water flow in large scale fractures .
The options for mitigating the impact of solute exchange and extended retention of poor quality water are the same as those for managing other water quality concerns. In addition, if an acute water quality problem were identified (e.g. accidental injection of poor quality water) it might be prudent to monitor the recovered water for constituents of concern for an extended period.
While the process of diffusion exchange could also occur in the Upper Floridan Aquifer of the southern coastal region, the associated impact is likely to be mitigated by the concentration of flow in this system in large-diameter conduits.
Golder Associates
Georgia Geologic Survey Dr. William McLemore
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April2001 003-3019.002
5.0 SUMMARY
No instances where aquifers have become polluted as a consequence of ASR have been reported by EPA. In addition, no literature was reviewed that identified physical impacts resulting from an operating ASR. However, physical and hydrochemical processes of ASR can result in . environmental impacts depending on the design and operation of the ASR system, the characteristics of the storage aquifer and confining or interconnected units, and the utilization of other production wells. Potential impacts of ASR in the Floridan Aquifer of coastal Georgia could include:
Lower Floridan Aquifer
Generation of suspended iron and manganese oxi-hydroxide sediment due to dissolved oxygen in the injected water;
Generation of DBP's as a consequence of organic matter oxidation by disinfection chemicals present in the injected water;
Increased solute concentrations in the Upper Floridan Aquifer as a consequence of the ASR-induced displacement of poor quality water from the Lower Floridan.
Upper Floridan Aquifer
Uncontrolled discharge from improperly abandoned wells, loss of yield in nearby
production wells, and ground destabilization effects linked to water level changes during
injection and recovery;
Suspended sediment and DBP generation similar to that described for the Lower Floridan
Aquifer;
Increased concentration of dissolved uranium due to oxidation of uranium-bearing
minerals by dissolved oxygen in the injected water;
Increased sulfate and metal concentrations and decreased pH as a consequence of pyrite
oxidation in the Upper Confining Unit due to ASR-induced dewatering of the unit;
Lateral migration of poor quality water to other production wells due to flow in large
diameter conduits in the southern coastal area and steep hydraulic gradients in the
northern coastal area;
.
Diffusion of exchange of solutes between the injected water and the aquifer matrix.
r!'
In each case, the probability of the impact being realized, the severity of the impact, and the need
for and design of impact mitigation measures may be assessed by site-specific investigations for a proposed ASR (Table 1, Table 2). Such investigations would:
Describe the local geology, hydrogeology, and hydrochemistry;
Golder Associates
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Georgia Geologic Survey Dr. William McLemore
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April2001 003-3019.002
Model the behavior of the aquifer and associated units during alternative injection and recovery scenarios;
Define source-pathway-receptor relationships (e.g. the influence of the proposed ASR on other production wells or sensitive hydrologic sy~tems) .
Following the initial assessment, pilot testing would be an effective means of validating models, making direct observations of physical and hydrochemical processes, and comparing alternative ASR designs and operating schedules. Finally, monit<;>ring water quality, aquifer characteristics, and ground conditions in potentially sensitive areas during ASR operation would alert operators _ to possible concerns. Such a monitoring program implies effective facility maintenance, staffing, and operator training as a necessary requirement of ASR operation.
ln summary, ASR has the potential to be a useful water resource management tool in coastal Georgia. Some concerns have been identified but no environmental impacts have been identified that could not potentially be mitigated. An active permit program administered by GAEPD could insure that pre-construction investigations, pilot testing, and ASR design, operation, and monitoring are adequate to achieve the water resource management benefits while mitigating environmental impacts.
Golder Associates
TABLE 1 ( 1 of2) Potential Impacts Associated with ASR Operations in the Lower Floridian Aquifer
Potential
Responsible
Region Where Impact Most .
Mitigation or Management Strategy
Environmental
Process(es)
Likely to be Experienced
Impact
Increasing solute concentrations
Pressurization ofthe Lower Floridan as a consequence of
Areas where the treated water is
Characterization of the groundwater quality of the Lower Floridan Aquifer;
injected into poor quality in-situ
Assessment of the existing and predicted hydraulic gradients and the
groundwater, where upward vertical
penneability of the Middle Confming Unit;
in the Upper Floridan
injection and upward migration of poor quality groundwater under the influence of increasing vertical head gradients
head gradients are likely to develop as a consequence of injection and where there exists a pathway between the Upper and Lower Floridan
Modeling of ground water migration under different operating conditions; ASR pilot testing and monitoring in the Upper and Lower Floridan
Aquifers;
Identification of local Upper Floridan Aquifer production wells, and monitoring during ASR opei;ation;
Alteration of the ASR operation schedule to reduce the potential for upward
migration (possibly including relocation to an area where the confming unit
is least penneable).
Increasing concentrations of disinfection by-products (DBP's)
Oxidation of organic matter by (disinfection) chemicals present in the injected water
Stored water in areas where the potential for in-situ fonnation of DBP's is high
Characterization of the injected and in-situ water quality and the organic
matter content of the ASR aquifer matrix material;
Modeling and assessment of the potential for DBP fonnation; ASR pilot testing and monitoring of injected, in-situ, and extracted water; Modification the disinfection method of the injected water; Injection into a stratum with lower potential for DBP fonnation; Managing the ASR injection and extraction schedule to promote natural
attenuation of the DBPs;
Additional treatment of water extracted from the storage aquifer prior to
distribution.
-- ----
----
--
Generation of suspended sediment and increasing turbidity
TABLE 1 (continued 2 of2)
Oxidation of any dissolved iron or manganese that is present in the in-situ groundwater
The mixing zone between the stored ~ite s~eci?c assessment of the redox conditions and dissolved constituents
water and in-situ groundwater in
m the m-s1tu ground water;
areas where the in-situ groundwater
Identification of production wells in the vicinity of the mixing zone between
contains dissolved iron or
the injected and in-situ water;
manganese.
Water quality monitoring during ASR pilot testing;
Modification of the ASR location, size, and/or operations schedule (injection
rate, storage duration, recovery rate, etc.);
Relocation of potentially affected production wells if impacts are observed
or predicted;
Treatment of withdrawn water to remove suspended s~diment.
TABLE 2 ( 1 of3) Potential Impacts Associated with ASR Operations in the Upper Floridian Aquifier
Potential Environmental
Impact Flooding, loss of yield and ground destabilization
Responsible Process(es)
Water level changes associated with injection and recovery
Increasing solute concentrations
Lateral migration of any poor quality groundwater that enters the Upper Floridan from the Lower
Region Where Impact Most Likely to be Exp_erienced
Mitigation or Management Strategy
Regions close to the ASR well(s) in Site-specific characterization of the geology and hydrogeology at the test
areas where either the permeability
site;
of the Upper Floridan aquifer is relatively low, large quantities of
Hydraulic modeling to determine the magnitude of the head level changes that are likely to result from ASR operations;
treated water are injected and recovered or where the Upper Confming Unit is thin or absent.
Reducing the amount of injected or recovered water; Modifying the ASR well-field layout so as to increase the distance between
adjacent wells.
Monitoring foundation movement and ground elevation in the immediate
vicinity of injection and recovery wells during pilot testing and operation;
Capping and/or properly abandoning unused Floridan Aquifer wells.
Wells with capture zones that intersect pathways between the Upper and Lower Floridan through which poor quality groundwater could migrate from the underlying Lower Floridan.
Employing measures described in Table I to limit the opportunity to generate poor quality water;
Controlling the ASR injection and extraction schedule and well locations to
avoid substantial steepening of hydraulic gradients;
Monitoring water quality in nearby production wells .
Extended monitoring if diffusion exchange is a concern.
TABLE 2 (continued 2 of 3)
Increasing concentrations of disinfection by-products (DBP's)
Oxidation of organic matter by (disinfection) chemicals present in the injected water
Stored water in areas where the potential for in-situ formation of DBP's is high
Characterization of the injected and in-situ wa_ter quality and the organic
matter content of the ASR aquifer matrix material;
Modeling and assessment of the potential for DBP formation; ASR pilot testing and monitoring of injected, in-situ, and extracted water;
Modification the disinfection method of the injected water; Injection into a stratum with lower potential for DBP formation;
Managing the ASR injection and extraction schedule to promote natural attenuation ofthe DBPs;
Additional treatment of water extracted from the storage aquifer prior to
distribution.
Introduction of tritium and increasing concentrations of uranium
Oxidative dissolution ofuranite
Stored water in regions where dissolved oxygen is likely to come into contact with uranite, including by migration into the base of the Upper Confming Unit.
'
----
-------
Characterizing the mineral assemblages present in the aquifer host rocks and
the confming units, with particular emphasis on identification of uranium
bearing minerals in the strata targeted for ASR development;
Examine the accessibility of the uranium-bearing minerals to the injected water containing dissolved oxygen and predict dissolution and resultant
concentrations of dissolved uranium ions;
If necessary, identify alternate locations for the ASR system where uranium
minerals are not abundant or case off individual uranium-bearing strata;
Operate the ASR system to extend storage time to promote natural reduction
of dissolved uranium.
Monitor for tritium and dissolved uranium during ASR pilot testing and
operation.
TABLE 2 (continued 3 of3)
Increasing sulphate and trace metal concentrations and decreasing pH
Dewatering of Upper Recovered water where recovery
Quantify the pyrite content of the Upper Floridan Aquifer and Upper
Confming Unit strata results in dewatering of the Upper
Confming Unit strata likely to be affected by the proposed ASR operations;
during recovery of Confming Unit or stored water the stored water and where injection raises the water
Predict the draw-down likely to be experienced during the extraction of the
stored water;
oxidation of pyrite or level in the Upper Floridan into
If necessary, relocate the ASR system to a more favorable location;
mobilization of
previously dewatered Upper
Reduce the amount of stored water that is recovered in an individual well;
historical pyrite
Confming Unit strata that originally Increase the spacing between extraction wells to minimize exaggerated
oxidation products contained pyrite.
drawdown caused by well interference;
Monitor water quality during ASR pilot testing and operation;
...
FIGURES
CD RAW WATER WITHDRAWAL FROM RIVER
RAW OR POTABLE WATER WITHDRAWAL FROM ALTERNATIVE SUPPLY AQUIFER
0 WATER TREATMENT PLANT 0 TREATED WATER
TO USERS
TREATED WATER TO RECHARGE WELL
TREATED WATER INJECTED INTO STORAGE AQUIFER
RECHARGE DURING LOW DEMAND PERIOD OR WET SEASON
NO OR REDUCED WITHDRAWAL FROM RIVER
NO OR REDUCED WITHDRAWAL FROM ALTERNATIVE AQUIFER
WATER TREATMENT PLANT
{;\ TREATED WATER TO
\::J USERS (INCLUDING
RECOVERED WATER) RECOVERED WATER ADDED TO DISTRIBUTION SYSTEM WITH MINOR TREATMENT (e.g., DISINFECTION)
STORED TREATED WATER RECOVERED FROM AQUIFER
WITHDRAWAL DURING PEAK DEMAND PERIOD OR DRY SEASON
CUE NT/PROJECT
TITLE
Atlanta, Georgia
DRAWN
GAEPD/ ASR/GA
CONCEPTUAL ASR OPERATION
RJS
DATE SCALE FILE NO.
12/00 . N.T.S. 003-3019
JOB NO. DWG NO.
003-3019
REV. NO.
SUBTITLE
FIGURE NO.
APPENDICES
APPENDIX A
Summary of Documented Environmental Impacts of ASR Operation
(.
ueorgta,ueotogtc :survey Dr. William McLemore
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April2001 003-3019.002
. APPENDIX A
Summary of Documented Environmental Impacts of ASR Operation
A.l Physical Impacts
Physical impacts associated with ASR operations theoretically include flooding, interference with nearby production wells, and ground stability effects. No examples of any such effects could be found in the literature, although routine assessment of the associated risks was apparent.
A.2 Water Quality Impacts
Hydrogeochemical processes that have the potential to impact ASR water quality include reduction-oxidation reactions, dissolution, and ion exchange. These processes may act singly or in combination, with the associated water quality changes being observed in either the stored . water mass or the mixing zone between the stored water and the in situ groundwater. Solute transport processes that may subsequently act to influence the movement and distribution of ASR-related poor quality water include advection, mechanical dispersion, and diffusion.
Examples of ASR facilities where there has been an observable (but not necessarily critical) hydrogeochemical impact on the quality of either the recovered water or in situ groundwater include:
I
Tri;-halomethane (THM) impacts on the quality of water recovered from an ASR scheme in the basin sediments of Las Vegas, NV (Thomas et al, 2000 and Landmeyer et al, 2000);
Nickel and arsenic concentration impacts on the quality ofwater recharged to a series of sandy aquifers in the Netherlands (Stuyfzand, 1998a);
Iron concentration and low pH impacts on the quality.ofwater recharged to the Magothy aquifer of Long Island, NY (Ragone and Vecchioli, 1975);
e Sulfate, magnesium, potassium and total hardness impacts on the quality of water r~covered from an ASR scheme in the London Basin Chalk (Flaviri and Joseph, 1981 );
Sodium, potassium and ammonium concentration impacts on the quality of water injected into marginal quality groundwater in the London Basin Chalk (Moncaster and Cook, 1999);
Recovery of water contaminated with excessive quantities of manganese from an ASR scheme in Chesapeake, Virginia (lbison et al, 1995);
Dissolution driven suspended sediment contamination of water recovered from an ASR scheme in Australia (Rattray et al 1986).
APPENDIXB
Floridian Aquifer Hydrogeology
Georgia: Geologic Survey Dr. William McLemore
APPENDIXB Floridan Aquifer Hydrogeology
April2001 003-3019.002
B.l GENERAL
The Floridan Aquifer comprises a "vertically continuous sequence of carbonate rocks of generally
high permeability that are of Tertiary age, hydraulically connected in varying degrees, and whose
permeability is generally several orders of magnitude greater than that of the rocks that bound the
system above and below" (Miller, 1986).
I
The system underlies all of Florida, southeast Georgia and adjacent parts of Alabama and South Carolina. In Georgia, the Floridan Aquifer strata outcrop parallel to the fall line and dip to the south and southeast. The thickness of the sequence increases from less than I00 ft at outcrop to more than 2,000 ft at the (Atlantic) coast. In the coastal areas, the aquifer is divided into two permeable sub-units, the Upper and Lower Floridan Aquifer. These sub-units are separated by a confini~g unit of variable hydraulic properties.
Groundwater recharge to the coastal Georgia system occurs as a combination of groundwater
inflow from updip or adjacent units of the Floridan Aquifer and natural or induced leakage
through the upper confining unit. The predominant direction of flow is from west to east in the
south aitd from north-west to south-east in the north, in both cases from topographically high
regions .inland towards pumping centers located at the coast. Groundwater discharge occurs both
as withdrawal at the coastal pumping centers and, in areas to the south and east, via upward
leakage into the upper confining layer. All of the withdrawal in coastal Georgia is understood to
be from wells that penetrate the Upper Floridan Aquifer. However, the yield from these wells is
sustained in part by upward leakage from the Lower Floridan Aquifer. This occurs as a
consequence of both natural and induced head gradients and is locally facilitated by the presence
of high permeability flow-paths associated with a series of high-angle faults. Groundwater
development and use in coastal Georgia has resulted in a regional decline in the potentiometric ,
surface and pronounced cones of depression at major pumping centers, notably around Savannah
and Brunswick.
Water quality in the Floridan Aquifer system varies from a calcium bicarbonate type inland to a calcium magnesium bicarbonate or calcium magnesium bicarbonate sulfate at the coast. In addition, high levels of withdrawal in some parts of the region have resulted in saline intrusion to the aquifer. Consequently, concentrations of chloride are locally excessive. The intrusion occurs both laterally and vertically, with poorer quality water entering the Upper Floridan Aquifer from the areas offshore and from deeper sections of the aquifer, respectively.
A brief description of the lithology and hydraulic properties of each of the components of the
Florid~ Aquifer system is given below. This is largely derived from Krause and Randolph
(1989).
.
~
B.2 .UPPER CONFINING UNIT
The Upper Confining Unit comprises an interbedded sequence of sand, silt, clay and sandy clay of low permeability. The unit achieves a maximum thickness of 600 ft in the vicinity of Brunswick and thins northwards to less than I00 ft in the vicinity of Savannah. Locally, in the area of, Savannah and Hilton Head Island, the unit has been breached by the effects of erosion with the result that the underlying Floridan Aquifer is exposed.
ueorg1a fjeologic Survey Dr. Willi.arn McLemore
- B-2-
April2001 003-3019.002
Measured values of the vertical hydraulic conductivity of the Upper Confining Unit vary between SE-07 ft/d and 1.1 ft/d, while values estimated from the results of regional aquifer modeling vary between lE-05 ft/d and IE-03 ft/d. Leakance estimates systematically increase from less than lE-06 ft/d/ft in the south to greater than IE-04 ft/d/ft in the north. This trend reflects the decreasing thickness of the unit towards the north and the relatively narrow range of composite or average vertical hydraulic conductivities.
B.3 UPPER FLORIDAN AQUIFER
In the study area the Upper Floridan Aquifer comprises Oligocene and Late Eocene units including the Suwannee and Ocala Limestone. The former is composed of limestones which vary from soft, chalky and fossiliferous to dense, calcitized, saccharoidal and unfossiliferous. The latter is a white to gray, fossilferous, recrystalized, porous limestone containing large solution cavities ..
Wells in the Brunswick area penetrate two permeable zones in the UpperFloridan Aquifer which are both within the Ocala limestone. The upper zone. is between 75 ft and ISO ft thick and contributes up to 70% of the available yield. The lower zone, which locally includes part of the Middle .Eocene Avon Park Formation, is between 15 ft and 110 ft thick and contributes the remaind~r. In the Savannah area, wells also penetrate two permeable zones in the Upper Floridan Aquifer. The upper of these is less than 50 ft thick and lies within basal Suwannee and Upper Ocala strata; the lower is between 25 ft and 75 ft thick and is entir~ly within middle Ocala strata: These two zones contribute 70% of the available yield.
Estimates of the transmissivity of the Upper Floridan Aquifer derived from aquifer testing vary
between 30,000 ft2/d and 280,000 Wid, while estimates derived from regional aquifer modeling
range between 50,000 ft2/d and 250,000 ft2/d. In both cases values decrease to the south and
north of Camden County, with extremely high values occurring in the vicinity of Brunswick. Associated estimates of the hydraulic conductivity vary between 80 ftld and 670 ftld. Estimates
of the storativity, where these are available, are of the order of 0.0004 to 0.0006.
The extremely high values of aquifer transmissivity reflect flow through cavities, cavernous zones and solution channels in the limestone. The majority of these are orientated in the horizontal plane, enhancing lateral permeabilities, although vertical features associated with highangle fault zones are also present.
B.4 THE LOWER FLORIDAN AQUIFER AND MIDDLE CONFINING UNIT
In the study area the Lower Floridan Aquifer comprises strata of the Lower and Middle Eocene including the Avon Park, Oldsmar, and Cedar Keys formations and the Gosport equivalent. The
hydraulic properties of the unit have not been determined, although transmissivity is thought to vary between 2000 ft2/d and 400,000 W/d and to be less than 100,000 ft2/d in areas outside of extreme southeast Georgia.
'
~
In the vicinity of Brunswick, the lower two-thirds of the Avon Park formation and the upper
portion of the Oldsmar formation comprise an interbedded sequence of limestone and dolomite in
which significant secondary permeability has developed as a consequence of solution activity
along bedding planes. By contrast, upper Avon Park strata is composed of a dense, low-
permeability recrystalized carbonate. This sub-unit acts to confine groundwater in the Lower
Floridan Aquifer, separating it from groundwater in the Upper Floridan Aquifer except in areas where f~ulting allows flow between the two. The vertical hydraulic conductivity of intact Middle
Georgia G' eologic Survey Dr. William McLemore
- B-3-
April2001 003-3019.002
Confining Unit strata is estimated from cores recovered in the Brunswick area to vary between
4E-06 ftld and 5E-05 ftJd. Water level differences across the unit vary between 2 ft and 20 ft but are gene~ally thought to be less than 5 ft.
The bas~ of the Lower Floridan Aquifer in the Brunswick area contains an additional semi-
confining unit and an underlying cavernous limestone known as the Fernandina Permeable Zone.
The hydraulic properties of each of these sub-units are unknown, although the scale of the
caverns ih the limestone are such that the transmissivity of the unit is thought to be of the order of 1E06 ft2/d.
I '
.
In the Savannah area, the Gosport equivalent is composed of a calcareous sand or very sandy
limestone. The unit resp~mds to pumping in the Upper Floridan Aquifer and is thus thought to be
in hydraulic continuity with the Upper Floridan Aquifer. Properties for the Lower Floridan
Aquifer and middle confining. unit in this area are unknown.
. I
. ,.
APPENDIXC .
Bibliography
; .
i
Georgi~ Geologic Survey Dr. Wil,liam McLemore
- C-1-
April2001 003-3019.002
APPENDIXC
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The fol)owing references are. pertinent to a description of ASR environmental i!Jlpacts and were reviewed in preparing this report. Included in this list are specific literature citations from this report, as well as references of general use.
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Pyn~. 1 R.D.G 1995. Groundwater Recharge and Wells: A Guide to Aquifer Storage and R~covery. Boca Raton, Florida: CRC Press.
Pyne, R.D.G., P.C. Singer, and C.T. Miller. 1996. Aquifer storage recovery of treated drinking
I
.
Wl;lter.
:
Final
Re.port
to
A WWA
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176p .
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Georgia Geologic Survey I
Dr. William McLemore
:. \ c~1o:.
April2001 003-3019.002
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Inj~ction, Storage and Recovery of Freshwater in the Lower Floridan Aquifer, Okeechobee
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Patk, New York. Ground Water v. 13(1): pp. 17-23 .
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Rattray, K.J., P.J. Dillon, A.L. Herczeg, and P. Pavelic. 1986. Geochemical processes in I I aq':Jifers receiving injected stonnwater. Centre for Groundwater Studies Report No. 65
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Reinh~d, M., W.-H. Ding, and Y. Fujita. 1994. Organic carbon characterization of.advanced
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.
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Robert:S; P.V. 1985. "Field observations of organic contaminant behaviour in the Palo Alto
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I
i Roberti>, P.V., J.O. Leckie, P.L. McCarty, G.A. Parks, R.L. Street, L.Y. Young, M. Reinhard,
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12lP
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'
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I
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I
de Ruiier, H. and P. Stuyzland, 1998. "An experiment on well recharge of oxic water into an
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Georgia Geologic Survey Dr. William McLemore
- C-i i-
April2001 003-3019.002
I
of ~e Third International Symposium on Artificial Recharge of Groundwater - TISAR 98,
I
Amsterdam, Netherlands, 21-25 September 1998, Rotterdam : Balkema.
I
I
Sakharovskii, Y. A., M. B. Rozenkevich, B. M. Andreev, E. P. Magomedbekov. 1999. Removal
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with Water. Atomic energy= Atomnaia energiia. v. 85 (1): pp. 462.
I
Sasaki; T. S-1. S-1 Ishii, and M. Senda. 2000. Tritium in [ISO]water, its identification and
"I
removal. Applied radiation and isotopes v. 52(2000): pp. 175-179.
\
I
Saxon,~ E., 2000. Personal communication to Jim Renner, Golder Associates, regarding operation
I
of the Beaufort-Jasper Water and Sewer Authority ASR system.
I
Sedlack, D.L. 1999. "Pharmaceutically active compounds in the aquatic environment and their
i
rel~tionship to water re-use" in 9th Biennial Symposium on the Artificial Recharge of
Grbundwater, Tempe, Arizona, June 10-12, 1999.
I
Singer,!P.C., R.D. Pyne, A.V.S. Mallikarjun, C.T. Miller, and C. Mojonnier. 1993. Examining the
impact ofaquifer storage and recovery on DBPs. Res. & Tech. 85-94.
South Florida Water Management District. 2000.
SFWMD web page
http://141.232.1.11/org/pld/proj/asr/asrupdate.htm Posted September 22, 1999.
I
Sprinkle, C.L. 1989. Geochemistry of the Floridan Aquifer System in Florida and Parts of
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I
Street)~, M.J. 1998. "Th.e use of modelling to predict the behaviour of ASR systems" in, J.H
Pet~rs et al. (eds.), Artificial Recharge of Groundwater, Proceedings of the Third I
International Symposium on Artificial Recharge of Groundwater - TISAR 98, Amsterdam,
I
Netherlands, 21-25 September 1998, Rotterdam: Balkema.
I
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Streetly, M.J. and S. Kotoub. 1998. Determination of aquifer properties in northern Qatar for
I
application to artificial recharge. Quarterly Journal of Engineering Geology v. 31 : pp. 199-
1
209 .
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Georgia Geologic Survey
I
Dr. WiHiam McLemore
I
April2001 003-3019.002
StumJ, W. and J.J. Morgan. 1981. Aquatic Chemistry: An Introduction Emphasizing Chemical
Eq~ilibria in Natural Waters. New York: John Wiley and Sons Inc.
I !
StuyrzlImd, P.J. 1998a. "Quality changes upon injec.tion into .anoxic aquifers in the. Netherlands:
Ev~luation of 11 experiments" in, J.H PeterS et al (eds.), Artificial Recharge of Groundwater,
I
Pr<?ceedings of the Third International Symposium on Artificial Recharge of Groundwater -
I
TISAR 98, Amsterdam, Netherlands, 21-25 September 1998, Rotterdam : Balkema..
I
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Stuyfumd, P.J. 1998b. "Fate of pollutants during artificial recharge and bank filtration in the
I
Ne~herlands," ill, J.H Peters et al. (eds.), Artificial Recharge of Groundwater, Proceedings of
I
.
th~ Third International Symposium on Artificial Recharge of Groundwater - TISAR 98, i
Amsterdam, Netherlands, 21-25 September 1998, Rotterdam: Balkema., pp. 119-125. I I
I
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Stuyfzand, P.J. 1998c. "Simple models for reactive transport of pollutants and main constituents
I
dufing artificial recha~ge and bank filtration," in, J.H Peters et al. (eds.), Artifici~l Recharge
I
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of Groundwater, Proceedings of the Third International Symposium on Artificial Recharge of
I
Groundwater- TISAR 98, Amsterdam, Netherlands, 21-25 September 1998, Rotterdam : I I
BaJkema, pp. 427-434 .
I
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investigation of tritium in the Gordon and other aquifers in Burke County, Georgia--Final
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.
Report. Georgia Geologic Survey Information Circular 95, 93 p.
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Haloacetic Acids and Trihalomethanes in an Aquifer Storage and Recovery Program, Las
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.
.
Vegas, Nevada. Ground Waterv. 38(4): pp. 605-614.
I
USGS.12000. Personal communication: Fred Falls, Hydrologist (U.S. Geological Survey) to
Chtis Hemingway, Golder: regarding saturation indices in the Lower Floridan/Fednandina, I I
usipg WATEQ speciation routines, emails dated November 2 and 3, 2000..
I
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Wesne~, G.M. 1999. Annual Report. Orange County Water District Wastewater Reclamation,
I
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!
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Georgia Geologic Survey Dr. W~lliam McLemore
- C-13-
April2001 003-3019.002
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O~der No. 91-121.
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.
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Wilson, Timothy E. 1996. The removal of tritium from contaminated water usin'g aeration.
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Zhen~ou, Li. 1998. Removal of tritium. from tritiated water using electrodialysis and
m~tallothermic reduction processes. Thesis (M.S.)--University ofNevada, Reno, 102 p.
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Zullei~Seibert, N. 1998. "Your daily drugs in drinking water ? State of the art for artificial
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grhundwater recharge" in, J.H Peters et al (eds.), Artificial Recharge of Groundwater,
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TISAR 98, Amsterdam, Netherlands, 21-25 September 1998, Rotterdam : Balkema.
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APPENDIX3
'he Georgia :onservaqcy
A. Sibley Ill lenr
10 OF TRUSTEES Izard Jr., Chairman
I. Addrson Jr.. Alpharetta '
Allen. Atlanta
AndP.rson. A rlanta
,
1 C Archer Ill. Suwanee !
M. Bledsoe. Atlanta
C. Boone.. Stone Mounta1'1
yR. Boring. Ph.D. Albany,
E. Bostic Jr.. Atlanta 1
'!I R. Buchanan. Atlanta ,
IBid Carroll. Ph.D.. \VatJ:.msvillt.:
~hace. Ph.D .. Atlanta
:
Champion. Ph.D.. Pine Mofintain'
R Davrs, Atlanta
1e H. Detlels. Atlanta
Di>on. Albany
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mE. Draper. Ph.D .. At/ant~
a Faga. Atlanta
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1 R. Foote. Alpharetta
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Fowler, Athens
:. Goldfrank. Columbus
t Helms. Atlanta
'J. Hill. Roswell'
B. Hudson. M.D.. Augusta
1ghes. Savannah
W. Isley, Ph. D.. Statesboro
zard Jr.. Atlanta'
I
n Kenny. Atlanta
stes Klamon. Atlanta
'pher Klein. Savannah
ty Laird Jr. '
'ontgomery. Rome
Mori. Atlanta
e T. Olmstead. Atlanta
1 Parker. Atlanta
1dat Roark. Atlanta
~. R;::,:~ :~~~;a ~ariettal
i el J. Rumke. Cummmg
A. Rutllerford. Sa,annall ~
>anler. Atlanta
el M. Sizemore. Atlanta
Stoices. Atlanta
i
lS R. Swift. M.D.. Augusta
s H. Tisdale Jr. A 1/anta
1SORY BOARD
rnk Barron. Jr. Rome on Bevington. Atlanta ~n T. Buller. Columbus '. Cowan. Peachtree City y Currey Jr. Atlanta y Hale. Atlanta
1
:l. Hardman. M.D.. Af/antH 1 "d C. Harris. A f/anra Jip Humann. Atlanra tA ur:;. Jasper Lev1lclS. Atlanta : la11g. Atl:.mw uer. AtlwJI,J M. Ratc:lillt:!, Atlanta
o.~., Sn11th. Dulvtll f Tenenbaum. S.Honna/1
/are. AtliWW Q \Villuttns. Atlanta
ted on recyclc<l P~P"'
. . , _-.._.~_: ~~ ! :.:
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.......::
i-"~: JUN 1 tf1 2000
!-J-y ------=--
428 Bull Street Savannah. GA 3140 I
9121447-5910 9121447-0704(fax) www.gaconservancy.org e-mail: tgccoast@bellsouth.net
ME\10RI\NDUM
To: From:
Groundwater Stakeholder Meeting Participants
Patty Mclnt~astal Programs Direct~r .
The Georgia Conservancy
Date:
June 16, 2000
Subject:
Meeting Summaries
Enclosed are summaries of both groundwater stakeholder meetings. The February meeting summary was revised based on corrections and comments received from participants. The May meeting summary contains the stakeholder recommendations that will be forwarded to the Georgia Environmental Protection Division, the US Geological Survey. and the Upper Floridan Aquifer Technical Advisory Committee.
We anticipate hosting additional stakeholder meetings as the Sound Science Initiative proceeds and groundwater management policies are fonnulated. We hope you will continue to participate in these important sessions. Your 'input is invaluable to developing a sound strategy that will ensure a safe, adequate water supply for coastal Georgia. We will notify you of future meetings as they are scheduled.
Please contact me at (912) 447-5910.or.tgccoast@bellsouth.net if you have any C()mments or questions about the enclosed meeting summaries. Thank you.
Groundwater Stakeholder Meeting
Hosted by The Georgia Conservancy Wednesday,. February 23, 2000 1:00-4:00 PM
Midway, Georgia
Meeting One Summary
'urpose:
he meeting was held as one of the tasks outlined in the Georgia Environmental Protection ivision's! (EPD) Sound Science Initiative to address saltwater intrusion into the Upper Floridan .quifer. EPD contracted with The Georgia Conservancy to plan, arrange and host the meeting. takehold7rs representing industry, local government, agriculture, recreation and non-profit rganizati()ns were asked to identify groundwater management questions they would like EPD's roundwater models and technical investigations to answer. Stakeholder input will be used by PD and !the United States Geological Survey (USGS) in developing the next generation of roundwaier models for use in the Sound Science Initiative.
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lttendance
'resenter~:
.
tr. Bill McLemore, Georgia EPD Jhn ClarkeI , USGS
orothy Payne, USGS
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' 'anel Pafticipants:
Facilitator:
Gail Cowie Carl Vinson Institute of Government University of Georgia
1ck Amasbn ea Garde~ Seafood
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:en BrewtIon I
:oastal Environmental )rganizatipn and Bryan
:ounty j
~ichard
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Dpuglas
:oastal Georgia Regional
>evelopm~nt Center
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lilly Edwards :ity of Hi~esville
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\I Elfer !
ekylllslapd Authority
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riary Elfn'er
:oastal G~brgia Land Trust
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3ill Fostet: Jr. tepresent)ng Sea Island
:ompanyj
Wes Harris Bulloch County Extension Service
Dan Hawthorne Mcintosh County Soil Conservation Commission
Glen Hoffman Hercules, Inc.
John Karrh Effingham County
Lamar Keller Savannah Electric
Jack Lantz The Landing Golf Courses
Dave Kyler Coastal Georgia Center for Sustainable Development
Michelle Liotta Fort James Corporation
Dean Moss Beaufort-Jasper Water and Sewer Authority
Milton Peterman Representing Glynn County
Pete Peterson Effingham County Chamber of Commerce
Dave Rutherford City of Port Wentworth
Doug Shaw The Nature Conservancy Altamaha Bioreserve
Deborah Sheppard Mcintosh County Chamber of Commerce
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Otl1ers m. aI!ttendanee:
John
C.
Bai1~d I .
.
Jekylllslani:J Authority
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Jackie Jackson Fort Stewart
Camille Ransom SC DHEC
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Sid Beauchamp
The Landin'gs i
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Michael Dale
Elliott jones USGS
.Harry Jue
.Constance Riggins Mcintosh County Chamber of Commerce
South Caro)ina Department of
City of Savannah
Roy Rountree
Natural Resources I I ~
Robert G. E>eWin R&R Seaf~od Company
Gail Krueger Savannah Morning News
Georgia EPD
Steve Royer Georgia-Pacific Corporation
t:
Kenny Durpas
Christi Lambert The Nature Conservancy
Gary Sharpe
City of Sa~annah
Gilman Paper Company
Tony Foyl~
Tom Matyok Coastal Georgia Center for
Don Smith
Georgia Squthern University
li
Sustainable Development
South Atlantic Utilities
Jeri Gale (;
.
Patty Mcintosh
Jon Sprague
The Georgia Conservancy
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The Georgia Conservancy
TSG Water Resources
Amy Horton
York Phillips
Welby L. Stayton
Brunswick:News
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Coastal Georgia Regional Development Center
USGS
Rick Krause I
USGS, RetI,ired i
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Allan Pulaski The Landings
Katherine Zitsch Camp Dresser & McKee
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Opening:Remarks
Patty Mcl~tosh, Director of Coastal Programs for The Georgia Conservancy, welcomed panel participants
and others/ in attendance, discussed the 'purpose of the meeting, and introduced the presenters and the
facilitator.) Dr. Bill McLemore, State Geologist, discussed the use of models in the Sound Science Initiative, ~fforts and costs to date, and how the stakeholder meeting fits into the Sound Science Initiative
and lnteri,~, Strategy for Addressing Saltwater Intrusion into the Upper Floridan Aquifer. I ~
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USGS Overview of Modeling Effort .
II John Clark~, USGS Project Manager of the Sound Science Initiative, made a presentation explaining what
the ground~ater models can and cannot do. He also gave a historical overview of the movement of
saltwater into the Upper Floridan Aquifer, relating that movement to the drop in artesian pressure due to I,
pumping over the years to support development.
!
USGS mJdeler Dorothy Payne gave a presentation about flow and soiute transport models, modeling II
objectives and modeling limitations. She defined a model as a quantified educated guess and said the models ar~ complex because the hydrologic system is complex. She explained how the groundwater flow system is ~onceptualized, how the models are constructed and calibrated, how management scenarios can
be applied; and how the models can be verified. She also explained the differences in capability between
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he current models and the next generation of models USGS will use in the aquifer study. The next
seneratio~ of models will update the previous models, focusing on confined aquifers.
Based on! input from the Groundwater Stakeholder meeting, USGS will look at how to orient the
models t<;>: address areas of interest and specific boundaries. The problems and issues highlighted in today's meeting will affect the size and location of the model boundaries. This process
encourages stakeholders to think of issues not addressed by the previous models. The new . generati~n of models may or may not be able to answer all of the questions posed.
al~o USGS noted the potential that the proposed Savannah Harbor deepening may cause more
saltwate~ intrusion into the aquifer. The new models could be used to show the vertical flux of the waterI~table system and m.ay provide more information about the potential for downward movement of saltwater over time.
Questionl/concems posed to EPD and USGS by panel participants:
Jack Am*son asked about the Snapper Hole. Con~em ras expressed about th~ lack of k~owledge regar~ing agri~ultural pumpage. Dr. McLemore rephed th~t DNR has contract w1th the Agncultural ExtensiOn Serv1ce to calculate pumpage over a fiveyear peri?d by sampling a subset of irrigation systems. The study began in July I 998 .
Does agricultural use of groundwater require a permit? EPD responded yes. I
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Facilit~ted Discussion I
Gail Co~ie, with the University of Georgia's Carl Vinson Institute of Government, introduced herself as
the facilitator. She stated that her role was to help the group focus on information needs. She also stated
that a se~ond meeting may be needed and that when the information is compiled, results would be sent to
EPD andIshared with the Upper Floridan .Aquifer Technical Advisory Committee.
After an /opening exercise in which panel participants indicated their expectations for the next generation
of models, the facilitator asked each participant to think of questions for the groundwater models in the
following terms:
.
w+ would happen to (object) if(action) takes place in this location (boundary)?
The panel participants were asked to break into small groups and discuss groundwater management
questio~s in the suggested format, keeping in mind what would make significant changes to life in coastal
Georgia[ The group then reconvened and the facilitator recorded the scenarios each group felt should be
addressJd by the EPD's models and technical investigations.
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The following scenarios were posed by participants and recorded by the facilitator:
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1. What would happen to the Miocene aquifer(s) if it/they were developed?
.
Whht would happen to the surficial aquifer and surface water bodies, wetlands, etc., if the Miocene
aqu,fer(s) were developed?
2. Wh~t would happen to river base flow and freshwater inflow to the estuary and freshwater wetlands if the~e were increased development of the Miocene and surficial aquifers? What would happen to river
base flow and freshwater to the estuary and freshwater wetlands for any alternative use scenario? Mo~e generally, what would be the ecological impacts of each scenario?
3. wJIat would be the geological impacts ofpu~ping from the Miocene . aquifer?
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4. What would happen 1f groundwater use were reduced bv 50% and surface water used instead?
Are surface water sources sufficient to provide this am~unt? What would be the ecological effects of
such a;scenario? I
5. What ~vou ld happen to the saltwater interface if specific water conservation actions were
implemented (e.g., retrofits)? How much water (mgd) could be saved? What would be the impact of
speciti;c reductions in use (e.g., 10%, 20%, 30%) on the saltwater interface?
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6. What Vo'ould happen to saltwater intrusion and groundwater quantity if certain wells closest to the
coast Jnd to the cone of depression were abandoned and withdrawals were relocated to the west
where/the aquifer is deeper? Similarly, what would happen to saltwater intrusion and groundwater
quantity ifthese wells were abandoned and use shifted to surface water sources at the coast?
~ould 7. What
be the effect on existing inland wells (water level, particularly) if use were moved
inlandf Scenarios include shifting pumpage from downtown Brunswick to western Glynn County;
from Qlynn County to Camden, Wayne, or Mcintosh County; and Chatham County to Effingham
Count)' .
8. What ~ould happen to saltwater movement into Hilton Head if 5 mgd of freshwater were injected as
a barrier on the north end of Hilton Head Island? .
_
9. How much water can be pumped out of existing wells in Glynn County and still have the Floridan
aquife~ reach a steady state (steady state in terms of groundwater level and salt concentration)? Simil~rly, how much can be pumped from existing wells in Chatham County with the Floridan
reachipg a steady state? Moreover, are the conditions at that steady state acceptable?
I0. What ~ould be the quantity and quality effects in Chatham and the surrounding areas from
unchanged withdrawals in a) Chatham County or b) the study region?
~ould 11. What
be the effects on biological functions of unchanged withdrawals region-wide?
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12. What is the local effect on saltwater movement due to wells in southern Bryan, southern Effingham,
and all counties in the study area? That is, was the cap on withdrawal put in place because of
contributions to localized saltwater impacts or because of contributions to impacts elsewhere?
13. What kre the potential impacts of existing open-bore wells along the Georgia coast?
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14. Whatlhappens during aquifer storage and recovery (ASR)? That is, what happens to
inovefent of stored water, quality of stored water and quality of natural water under ASR?
What; are the effects locally? What is the localized movement? What are the effects across
the fUll sphere of influence? How far does the sphere of influence extend? Other include:
-effects of mixing aerobic and anaerobic waters
.
-geoc~emical effects on the aquifer itself (on the limestone formations);
-effects of prior treatment; and
-mixi~g effects in general.
!
15. What !would he the flow scenarios (short-term and long-term) under major drought conditions?
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16. What ;would happen to groundwater and surface_ water quality and quantity with continued alteration
of wetlands (i.e., drain and fill) across the region?
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17. What ;would happen to the saltwater intrusion due to sea-level rise?
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Other qurstionslcomments posed by participants:
I A few related questions arose during discussion at the meeting and some participants submitted additional
scenarios in writing at the close of the session. These questions and comments are listed below:
.
!
What }vould be the relative cost/benefit of investment in water conservation equipment for major
industrial users versus the development of other water sources?
. !
What happened to the money allocated in 1995 for offshore wells to be drilled? [Dr. McLemore
answered that: money was allocaledfor Tybee and St. Mary's, but not for offshore drilling}
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Concern \vas expressed about the effects of saltwater intrusion in the aquifer on freshwater in the
estuaries and the refusal ofDNR's Coastal Resources Division to see the connection . I I
Does ground water press.ure or absence of same affect the quantity of fresh water in coastal estuaries?
The aryswer to that question should be transferred to the legislature, the Coastal Resource.s Division or
Environmental Protection Division of Georgia DNR, and South Carolina DNR.
'
What can the new models tell us about the potential of downward saltwater leakage caused by harbor
deeperying?
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What is the long-term potential for saltwater intrusion impacting the Skidaway wells based on current
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region11l withdrawal rates?
.
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If the ~hallow aquifer on Skidaway is utilized to reduce demand on the Floridan Aquifer, will the
potential for saltwater intrusion be increased?
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How s~sceptible is the shallow aquifer to saltwater.intrusiol')?
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What would the "head pressure" become for the Floridan Aquifer (knowing what pre-well days I were)?, Would the pressure be reyersed enough to reduce or eliminate the flow of saltwater intrusion
if a policy dictates an MGD reduction? If not, what is the purpose of continuing the model building
process other than for monitoring if in fact we are not solving what seems to be a futuristic problem?
I i Conclus1;on/Adjournment
At the closb of the meeting, participants agreed that it would be useful to meet a second time to review the
scenarios J!sted above and discuss priorities in the face of limited resources. At that meeting, EPD and
USGS willi provide feedback on the scenarios and their suitability for model application. If possible,
informatiot;t from the USGS report on previous modeling efforts, currently being finalized, will be
provided t() the panel before the next meeting, which will be held late spring.
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The meeting was adjourned promptly at 4:00 PM.
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5
Groundwater Stakeholder Meeting
Hosted by The Georgia Conservancy Wednesday, May 17,2000 1:00-4:00 PM
Midway, Georgia
Meeting Two Summary
urpose'
he meetihg was held to conclude the work of stakeholders in identifying groundwater management
uestions Jnd modeling scc:;narios for input into groundwater models and other technical investigations
;:ing COJlducted under EPD's Sound Science Initiative. The initial meeting was held on
ebruarv 2C3, 2000.
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1ttendance
I '
'resenters: I
)hn Clarke, USGS
orothy P~yne, USGS
Facilitator:
Gail Cowie, University of Georgia, Carl Vinson Institute of Government
'ane/ Pa~ticipants:
1ck Amas;on ea Garden. Seafood
Ob Benson I
ilynn Co~nty
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.en Brewt'on :oastal Erivironmental lrganization and .ryan County
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.ichard D9uglas .ong Courtty
,J Elfer I
;:kyll lsla~d Authority
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1ary Elfn~r .
:oastal G~orgia Land Trust
I
Kelly Ferda South Island Utilities HHI, SC
Wes Harris Bulloch County Extension Service
j
Richard Johnston Glynn County
Lamar Keller Savannah Electric
David Kyler Coastal Georgia Center for Sustainable Development
Jack Lantz The Landing Golf Courses
Michelle Liotta Fort James Corporation
Dean Moss Beaufort-Jasper Water and Sewer Authority
Pete Peterson Effingham County Chamber of Commerce
David Rutherford City of Port Wentworth
Deborah Sheppard Mcintosh County Chamber of Commerce
)thers in: attendance:
.aurie K. Abbott :oastal WaI ter & Sewerage
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'ony Abbptt :onsolidated Utilities
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~am Arora lydrovisibn
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John C. Baird Jekyll Island Authority Deatre Denion Chatham-Savannah MPC Kenny Dumas City of Savannah
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Fred Falls US Geological Survey, Columbia, SC
Dieter Franz Camp, Dresser & McKee
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Jeri Gale j:
The Georgi~ Conservancy
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Christine Griffiths I
The Nature, Conservancy
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Phyllis Isley Georgia so:uthern University
Jean McDowell Chatham-Savannah MPC
Patty Mcintosh The Georgia Conservancy
Andy Ninnemann Landings Club
SteveRoyer Georgia-Pacific Corporation
Gary Sharpe Gilman Paper Company
Cardwell Smith Army Corps of Engineers
Alice Miller Keyes The Georg~a Conservancy
Rick Krau~e Hydrovision
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Gail K.rueger Savannah rytorning News
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Judy JenniDgs Sierra Club
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Openinfir Remarks
Jimmy Otto Mcintosh County Development Authority
Camille Ransom SC DHEC
Roy Rountree Georgia EPD
Jon Sprague TSG Water Resources
Steve Walker Georgia Geological Survey
James White SC DHEC
USGS staff discussed their model scenario report and provided feedback on the 17 scenarios posed by stakeholders at the February 23rd meeting (see list of scenarios and USGS responses attached to this
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summary).! Bill McLemore (GAEPD) and Dieter Fr:anz (Camp, Dresser, & McKee) reviewed the surface water assessments underway as part of the Sound Science Initiative. Under contract with GAEPD, a consultant '(Camp, Dresser & McKee) is looking at surface water supplies and storage needs. Their
studies wifl address reclaimed water, off-mainstream impoundments, conjunctive surface-groundwater
use, and Wfiter conservation opportunities.
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Meeting p~rticipants stressed the importance of protecting minimum flows in the large rivers. The
consultant.is evaluating ways to provide water supply during minimum flow periods (e.g., conjunctive
surface-gn;mndwater use). Participants suggested that GAEPD and their consultants look at water supply
in an envir'onmentally s~lUnd manner, including protection of riverine habitat with provision of water
supply (a doncern for the Ogeechee River, in particular).
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Facilitated Discussion
Participants broke into five small groups to review the modeling scenarios developed at the February 23rd
meeting. Each group was asked to select up to five scenarios they felt would provide information critical
to the future of the region. The following items were selected:
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Selected b'y four groups
a) What ~ould happen to river base flow and freshwater inflow to the estuary and freshwater wetlands if
there ~ere increased development of the Miocene and surficial aquifers? What would happen to river
base flow and freshwater to the estuary and freshwater wetlands for any alternative use scenario? I
More generally, what would be the ecological impacts of each scenario?
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Sugge~ted revision: Ecological concepts should be defined and considered up-frpnt in developing
scenafios to be studied. For example, what minimum in-streamflow and seasonal.fluctuations are
necessary to maintain ecological junctions ofsubject streams?
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Facilitator's note: This item is closely related to item g, which was selected by two ofthe groups.
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b) What would happen to saltwater intrusion and groundwater quantity if certain wells closest to the coast a~d to the cone of depression were abandoned and withdrawals were relocated to the west where the aquifer is deeper? Similarly, what would happen to saltwater intrusion and groundwater quantity if these wells were abandoned and use shifted to surface water sources at the coast?
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Facilitawr s note: Item) includes a related question.
Selected by: three groups . c) What ~'ould happen if groundwater use were reduced by various amounts (e.g., 50%) and surface.
water u'sed instead? Are surface water sources sufficient to provide this amount? What would be the ecologi,cal effects of such a scenario?
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d) What ~ould happen to the saltwater interface if specific water conservation actions were implemented (e.g., retrofits)? How much water (mgd) could be saved? What would be the impact of specifi4 reductions in use (e.g., I 0%, 20%, 30%) on the saltwater interface?
e) How m:uch water can be pumped out of existing wells in Glynn County and s~ill have the Floridan aquifer:reach a steady state (steady state in terms of groundwater level and salt. concentration)? Similarly, how much can be pumped from existing wells in Chatham County with the Floridan
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reach in~ a steady state? Moreover, are the conditions at that steady state acceptable? I
Selected by; two groups
f) What would happen to the Miocene and Lower Floridan aquifer(s) if developed as an alternative to the Upper Floridan Aquifer? What would happen to the surficial aquifer and surface water bodies, wetlanqs, etc. if the Miocene aquifer were developed?
g) What Jould be the biologial and ecological effects of all scenarios evaluated? EPD must accept that there isla relationship between groundwater and surface water and a compound effect o.n the coastal ecology and estuaries. All water decisions need to be considered as they affect the coastal ecology .
h) What i~ the local effect on saltwater movement due to wells in southern Bryan, southern Effingham, and all counties in the study area? That is, was the cap on withdrawal put in place because of contributions to localized saltwater impacts or because of contributions to :impacts elsewhere?
i) What h~ppens during aquifer storage and recovery (ASR)? That is, what happens to movement of stored ~ater, quality of stored water, and quality of natural water under ASR? What are the effects locally? What is the localized movement? What are the effects across the full sphere of influence? How far does the sphere of influence extend?
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Related issues: effects of mixing aerobic and anaerobic waters; geochemical effects on the aquifer itself (o.n the limestone formations); effects of prior treatment; and mixing effects in general.
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Selected by!one group
j) What Would be the effect on existing inland wells (water level, particularly) if use were moved inland?! Scenarios include shifting pumpage from downtown Brunswick to western Glynn County or from Glynn and Chatham counties to Bryan and Effingham counties, respectively.
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Facilit~tor 's note: Related questions are listed on item b above. k) What ~o' uld be the quantity and quality effects in Chatham and the surr~>Unding areas from
unchanged withdrawals in a) Chatham County or b) the study region?
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n summary, participants recommended the following:
Asses~ the ecological effects of all use scenarios, particularly effects on river base flow, on wetlands.
and on freshwater inflow to estuaries (see items a, c and g above) .
1 Model specific use scenarios listed above (see items b, c, d, f, i and j).
I. Asses~ conditions at steady state groundwater levels and chloride concentrations (see item e) .
L Specify impacts of current and unchanged withdrawals (see items h and k) .
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. ';onclu~}on/Adjournment
rhe facilitator reiterated that the purpose of the two stakeholder meetings was to solicit input specifically or the grdundwater ~odels and technical investigations. Some questions can be answered through these nechanis~s, but others are beyond the scope and will have to be addressed by EPD in another manner.
rhe result!ofthe facilitated sessions will be forwarded to EPD, the Upper Floridan Aquifer Technical
\dvisory ~ommittee, and meeting participants.
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Jpon an offer from EPD, stakeholders expressed interest in participating in additional meetings to
>rovide input as the Sound Science Initiative studies progress and management policies are formulated.
rhe Georgia Conservancy agreed to host the meetings and will notify interested parties as they are
;cheduled:
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rhe meeting was adjourned at 4:00PM. I I '
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USGS Feedback on Stakeholder Modeling Scenarios
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The foiiO\\:ing scenarios were posed by stakeholders at the February 23'd meeting. USGS reviewed the
scenarios to determine their suitability for model application. Their responses appear in italics .
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I. What would happen to the Miocene aquifer(s) if it/they were developed?
What ~ould happen to the surficial aquifer and surface water bodies, wetlands, etc., if the Miocene
aquif~~(s) were developed?
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This question may be addressed by scenario testing with the models, and is within the scope of the
propo~ed modeling.
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.., What ~ould happen to river base flow and freshwater inflow to the estuary and freshwater wetlands if
there \yere increased development of the Miocene and surficial aquifers? What would happen to river
base fl,bw and freshwater to the estuary and freshwater wetlands for any alternative use scenario?
More ~enerally, what would be theecological impacts of ea~h scenario?
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This question may be partially addressed by the models. Differences in groundwater discharge to the surfac~-water body resulting from changes in pumpage can be simulated. Ecological impacts that
result }rom these changes cannot be addressed directly by the model. To simulate the particular
proceises occurring in the es/Uaries, a more specific model ofthe surficial aquifer would be required.
The tifne scale and the length scale are much shorter in the surficial aquifer than in the confined
aquifer system, and the unsaturated zone behaves differently than the saturated zone. These
conditions should be considered and incorporated into a more detailed surficial aquifer model. HowevIer, this is not compatible with the proposed modeling scope. The modeling results may
subsequently highlight or provide a framework from which to build a proper, more accurate surficial
mode(
3. What Would be the geological impacts of pumping from the Miocene aquifer?
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Subsidence and aquifer compaction are not addressable by the type ofmodeling proposed, nor are they u~derstood to be part ofthe scope.
4. What ~ould happen if groundwater use were reduced by 50% and surface water used instead?
Are surface water sources sufficient to provide this amount? What would be the ecological effects of
such aI scenario? I
A det4iled surface water model is not proposed, but impacts on surface water can be addressed in a
general manner as described in point #2 above. Ecological effects may be inferredfrom the
modeling, but are not directly addressed. Impacts ofpumpage reductions on ground water conditions
can bf?I simulated by the models.
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5. What ~would happen to the saltwater interface if specific water conservation actions were imple!llented (e.g., retrofits)? How much water (mgd) could be saved? What would be the impact of
specific reductions in use (e.g., 10%,20%, 30%) on the saltwater interface?
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Scendrio testing using the saltwater transport model will address questions such as these, for specific
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locations. Similar scenarios have been tested using existing ground water models in coastal Georgia
(see s~enarios A-2, A-3 in USGS report).
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6. W~at would happen to saltwater intrusion and groundwater quantity if certain wells closest to
thd coast and to the cone of depression were abandoned and withdrawals were relocated to
th~ west where the aquifer is deeper? Similarly, what would happen to saltwater intrusion an~ ground"vater quantity if these wells were abandoned and use shifted to surface water
sources at the coast? I
Scbnario testing using the saltwater transport model will address questions such as these, for spJcijic locations; the model will address surface water effects in a general way. Similar scJnarios have been tested using existing ground water models in coastal Georgia.
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7. What would be the effect on existing inland wells (water level, particularly) if use were
mdved inland? Scenarios include shifting pumpage from downtown Brunswick to western GlyI nn County; from Glynn County to Camden; Wayne, or Mcintosh County; and Chatham Cdunty to Effingham County.
Th~ regional flow model will address these questions through scenario testing. Similar
sc~narios have been tested using existing ground water models in coastal Georgia. I
8. What would happen to salt"vater movement into Hilton Head if 5 mgd of freshwater were injected as a barrier on the north end of Hilton Head Island?
Thle saltwater transport model could address this.through scenario testing.
HJw 9.
much water can be pumped out of existing wells in Glynn County and still have the
FJbridan aquifer reach a steady state (steady state in terms of groundwater level and salt
cobcentration)? Similarly, how much can be pumped from existing wells in Chatham County
wifh the Floridan reaching a steady state? Moreover, are the conditions at that steady state .
acceptable?
T~ese questions can be addressed using transient simulations ofground water flow and I
solute transport. Whether these conditions are acceptable or not can then be evaluated by waIter managers.
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I0. What would be the quantity and quality effects inChatham and the surrounding areas from u~changed withdrawals in a) Chatham County or b) the study region?
TAese will be addressed by the scenario testing ofthe models.
11. w'hat would be the effects on biological functions of unchanged withdrawals region-wide?
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The models will not be able to address this directly, but the results may be usefulfor other
stfdies regarding this question.
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12. W;hat is the local effect on saltwater movement due to wells in southern Bryan, southern
Effingham, and all counties in the study area? That is, was the cap on withdrawal put in
pl~ce because of contributions to localized saltwater impacts or because of contributions to
irrtpacts elsewhere?
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This question can b.e addressed by ground water flow and solute transport modeling.
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13. ~hat are the potential impacts ~f existing open-bore wells along the Georgia coast?
This is a site-specific problem that could be addressed with very high resolution modeling, I
but is probably beyond the scope ofthe planned models.
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14. ~hat happens during aquifer storage and recovery (ASR)? That is, what happens to
mpvement of stored water, quality of stored water and quality of natural water under
ASR? What are the effects locally? What is the localized movement? What are the I
e~fects across the full sphere of influence? How far does the sphere of influence
e~tend? Other include:
-effects of mixing aerobic and anaerobic waters
-g~ochemical effects onthe aquifer itself(on th~ limestone formations);
-effects of prior treatment; and
-mIix.ing effects in general.
Although the models are capable ofevaluating the impact ofaquifer storage and recovery on gr~und water levels and sal/Water intrusion, they are not capable ofemluciting ~ater-quality
in!pacls of injected waters. Such questions can be addressed using geochemical speciation a~d reaction-transport modeling, which are not part ofthe planned models.
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.JS. W,hat would be the flow scenanos (short-term and long-term) under maJor drought
conditions?
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T~is can be addressed through scenario testing of both the flow and solute transport models
by: varying the amounts ofsurficial recharge.
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16. What would happen to groundwater and surface water quality and quantity with continued
alt1eration of wetlands (i.e., drain and fill) across the region?
TJis is a specific question that is probably better addressed by smaller scale modeling of su~ficial aquifers that can account for changes that occur in engineered situations: changes
in ~urface topography, sediment compaction, etc.
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17. WhI at would ha.ppen to the-saltwater intrusion due to sea-level ri.se?
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It is possible to address the effect ofsea level change on the movement ofthe saltwater.fr~shwater interface, but the time scale ofa sea level change ofsufficient magnitude to affect
thJ interface (thousands ofyears) is likely to be many times greater than the time scale of
interest to management problems (one hundred years);
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USGS response to summary of stakeholder recommendations
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July 2000 .
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The s~mmary of stakeholder recommendations is concise and specific and provides
reconhnendations that are generally achievable by, and are appropriate to the scope of the
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modelIing study. Our response to the f.our recommendations follows:
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( 1) ~ssess the ecological effects of all use scenarios, particularly effects on river base
flow, jon wetlands and on freshwater inflow to estuaries: The models cannot address
ecolo~ical effects directly, but they can be made to address at least in a general way the
.niteracitJ.On between the surface water and ground water. The regw" nal flow model and.
subre~ional solute-transport models will each simulate flow in the surficial aquifer, and
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can thus simulate interactions with between the ground water and s4rface-water systems,
r~:e~:::::~~OW h 1
Wit o
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model will include major rivers and streams as part Of the upper
I model boundary. The surficial aquifer will be actively modeled and will be
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' allowed to interact with the surface water and the underlying confined and semi-
confined aquifers. Data used to characterize this part of the model will be taken,
in part, from a stream-baseflow analysis, yet to be performed. The results of this
model will not be able to simulate, in detail, individual wetland or estuarine
systems because the time and areal scale of the model will be of too coarse a
resolution. Despite these limitations, simulations may indicate specific areas
appropriate for more-detailed modeling ofsurface water/groundwater interactions.
For the Savannah-Hilton Head Island solute-transport model, it is particularly
important to characterize the surficial aquifer and interactions between surface
water bodies and the confined aquifers. A leading hypothesis for saltwater
contamin<~:tion of the Upper Floridan aquifer in this area is thinning or breaching
.of the surfical aquifer, both off-shore, and landward of the barrier islands (intra-
coastal areas). The areal scale of this model will also be more conducive to
characterizing the local estuarine systems.
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For the Brunswick solute-transport model, the primary area of concern is upward
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migration of hypersaline water at depth (Fernandina permeable ~one) .
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1 Interactions between the surface water bodies and the confined aquifers are not
I likely to be very important, as the aquifers are deeply buried and the overlying
confining unit is extremely thick. Nonetheless, the surficial aquifer can be
modeled actively, and interaction between the surface water and confined aquifers
will be considered.
(2) jodel specific use scenarios: The scenarios discussed at the meetings included
unchahged (or increased) withdrawals, conservation actions, use of surface water in place
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of gro,und water, redistribution of pumping locations, and redistribution of pumping to
other hsable aquifers. Interest was expressed in the resulting effects of these scenarios on
of surfaJe-water bodies (as discussed above), on ground-water levels the various aquifers,
o~ and saltwater movement. The calibrated models will be capable of evaluating each of
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these jmpacts to varying degrees. It should be noted that these ground-water flow and
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solutd-transport models will not be able to specifically address the surficial water I
resoutces, but, as indicated previously, the effect of changing surface-water flow on the
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surficial and underlying aquifer flow systems can be examined.
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(3) Aissess ground-water levels and chloride concentrations under steady-state
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conditions: Transient model simulations will be used to evaluate the maximum quantity
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of ground water that can be removed before the system can no longer sustain a steady-
~ondition. state
For the ground-water flow model, the flow system will be stressed to the
I point iof assumed unrecoverable loss of aquifer head (incomplete saturation of the
confihI ed aquifers). For the solute-transport models, ste.ady state is ach.ieved when the
saltwIater front (transition zone) is stationary; which.may occur under entirely different
condiItions than steady state. for the ground-water flo.w model. These models may be used
to assess the time it takes for a steady state flow system to achieve steady state chloride
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distribution, and the geometry of that distribution. Each of these scenarios will help
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assesk the water-supply potential of the various aquifers .
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(4) S)pecify impacts ofcurrent and unchanged withdrawals: This is essentially a specific
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use sdenario as described under "Model-specific use scenarios". This will be addressed
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as patIt of model calibrat.ion to current conditions.
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Modelj Boundaries
To facilitate development of specific model scenarios, we offer the following
maps
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that
show
the
anticipated
boundaries
for
the
flow
and
solute-tr~msport
models.
~re Th. ese I subject to change with additional information, directives, or preiiminar.y
modeling results. All model boundaries are shown in red.
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Regional Flow Model Boundary I
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Georgia..
~: ,
A/Janlic
..---. -
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Brunrick Solute Transport Model
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Savannah-Hilton Head Island Solute Transport Model
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...._.
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Beaufort County
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c ' . Jasper .
<-,----I~-
ounty ._
/
\~.
,
Hilton Head Island
_.. -.
.. _ .
Chatham
-
County
Savannah .:.: .
Atlantic
.............,_
.. ..
-~~-.}
,:
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Georgia beparhnent of Natural Resources
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205 Butler Street, S.E., E~st Floyd Tower, Atlanta, Georgia 30334
Lonice Barrett, Commissioner
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Harold F. Reheis, Director
Environmental Protection Division
October !13, 1999
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John Sibley Prest"denIt
The Geo~gia Conservancy
1776 Pe<I;ichtree Street, NW ..
Ste. 400 !South
Atlanta, ,GA 30309
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Dear Mr!. Sibley: I i
This letter follows up on discussions between Dr. William McLemore, the State Geologist, and Mrs .
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. Patricia Mcintosh of the Conservancy's Savannah Office. This letter also is an Agreement between
the Envitonmental Protection Division (EPD) and the Georgia Conservancy, Inc. for the purposes of the C~nservancy facilitating a meeting on "Ground-Water Modeling Needs for Coastal Georgia"
sometirtie in the Winter/Spring of 1999-2000. This meeting represents Task# 1 of Project Three-
Scenarid Development (a photocopy of the narrative description of this task taken from the
Recomn\endations of the Upper Floridan Technical Advisory Committee is attached and is made
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part ofthis Agreement.) A copy of the Recommendations report has been provided separately to
Mrs. Mdintosh.
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pri~ary The
objective ofthe facilitated meeting would be for the convened stakeholders to identify
those gtound-water management questions that they expect EPD's tecluiical investigations and
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ground-}vater modeling to answer. For illustrative purposes, examples of the questions might
include: I
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i C1) What would happen if Upper Floridan pumpage in Chatham County is reduced by
*- million gallons per day?
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~2) What would happen if x million gallons of pumpage in Brunswick, Glynn County
were moved westward to the vicinity of Mt. Pleasant in Wayne County?
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In this tegard, it does need to be remembered that modeling is useful in making predictions of
changes in .chloride concentrations over time. Thus the answer to Question #i might be that the
chlorid~ front would take an additional y years to reach Savannah, or the upward plume at
Brunswick would shrink in areal extent by z percent. Modeling will not tell whether the scenario
is good rr bad; it will only give estimates of changes in salt-water intrusion.
With th~I above in mind, the Co.nservancy shall:
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(A) Secure a meeting site in either Savannah or Brunswick for the purposes of the
ineeting. The meeting shall last between Y2-l days; and the Conservancy shall provide boffee, tea, and other refreshments to meetingparticipants.
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(8) Provide a meeting facilitator to Recp the meeting focus~d on th~ specific goal of
modeling needs. The Consernncy shall further provid<: a court r~port<:r. who'' illtran~~.:ri11L meeting notes and pand comm~nts ..
(C) Invite and secure confinnations ofapproximately two dozen panel p~micipants. The Conservancy shall further invit~ the members of the Technical Alh isory Committ~<.: and the USGS. whom will not be panel participants. The Conservancy shall also penn it a maximum of six of EPD"s contractors or employees to attend, strictly for educational purposes.
(D) Insure that the panel is approximately equally divided between industry (large and small). local governments (large and small), agriculture and recreation, and non-profit organizations (chambers of commerce, environmental advocacy organizations. political advocacy organizations. etc.). The Conservancy. shall attempt to insure that the panel generally reflects the water users of coastal Georgia.
(E) Summarize meeting results/recommendations in a short report (six copies, \vhich
EPD will reproduce, as needed). The Conservancy shall also provide one copy of the court
. reporter's transcript. The report and transcript shall be provided to EPD within 90 day.s of
the meeting.
(F) All work shallb~ completed by September 30, 2000.
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The Gonservancy's fee for the above services shall be for a fixed fee of$7,000, which be paid upon
receipt of an invoice upon completion of activities (A through E, above). If the above tenns and
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conditions are acceptable, please sign in the space below and. return four originals to myself. I
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Sincerely:
~.OM\N
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Harold F. Reheis
Director i
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Accepted: The Georgia Conservancy, Inc.
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):~4$z
Title:
Date:!
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cc: Bertha Turner I WilIliam M. cLemore Carolyn Cardin
USGS I I I
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Engineering and Environmental &rvices, different models based on differer.t computer codes may be needed a~ Savannah-Hilton Head and at Brunswick. Law
recommends and EPD supPc>i'ts thai tfie 5olute-ttansport codes selected be chosen after a comprehensive analysis of the major prog:rams and available case studies.
In this regard, it is recogn.iz.ed that national experts, including the USGS and private companies, be convened, utilizing a facilitator, to analyze the technicaJ issues and make a recommendation regarding the model or models to be used. The expens should attempt to define the expected capability of the model and the expected c:alibration/validation/documentation. The only limitation on the model recommendation would be that thecode is documented and it is aceeptable to the USGS, which is the agency that provides modeling expertise to the States of Georgia,. Florida, and South Carolina as well as local governmental agencies through a variety of joint funding agreemt'nt The general minutes of the
convened experts as well as their recommendations should be described in a report .
Task #4
Develop three~imensionaL density dependent, transient solute-transport models .
for both the Savannah-Hilton Head area and the Glynn County area. The models
should be based on the computer codes recommended in Project Two-Task *4.
above. Both models also should be integrated and compatible with the
recalibrated flow model including the revised estimates of agricultural pumpage
and n:configured potentiometric surface at Savannah reflecting the three offshore
monitoring wells, The Savannah-Hilton Head model should be capable of
estimating travel times for an encroaching salt water wedge (i.e., 2SO ppm, SOO
ppm, and 1000 ppm) to reach certain water supply wells on Hihon Head and at
SavaDDab from known or suspec:ted entra.Dce points. The Brunswick model should
be capable of estimating the salt water flux frcm the Femafina Permeable Zcme
to the Lower Floridan and from the Lower Floridan to the Upper Floridan IS well
as the chan&e in size of curtail T shaped plume. Sea models should be
capable of considering diffusion, ldvecticm. md. mediiDicaJihydroclyuamic
dispelsiOD. The results of the modeling and. the ISSitmptions upon which the
modeling is based should be deScribed in two reports (one for Savannah-Hilton
Head and one for Brunswick). The model also should be made available to
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ssctaekneahno.olsd.ers in digital format so that dley may independently perform their own
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Project ~euario DeveJopmeut:
Scenario Cievelopment involves modeling actual and hypothetical changes in recharge and
withdrawals to assess the impact of salt water intrusion. Basically the scenario development
attempts tb answer a variety of -what would happen if" questions.
Task *1 i
Obtain a general consensus on the needed modeling scenarios. The effectiveness of scenario development is dependent on a general consensus that the scenarios being modeled are reasonable and appropriate; therefore. it is recommended that
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appropriate stalceholders be convened and querried, utilizing a facilitator, regarding ne-eded ~narios. The general minutes of the convened stakeholders and their recommendations should be described in a repon.
Task ~2
Model varying pumping and ground-water management scenarios. Depending on the recommendations of the aforementioned convened stakeholders, scenarios would be modeled and the results would be presented in map and Damtive format. Information that should be provided for each scenario should include: a potentiometric map, salt watrz travel times to key wells for tbe Savannah-Hilton Head area, changes in flux and changes in size of the plume in the Brunswick area, and narrative describing modeling assumptions and impacts {i.e., the Hilton Head wedge would reach a certain well in approximately a certain number of years or the ..,... shaped plume at Brunswick would increase in. size by a certain
percentage). While the exact number of modeling scenarios is not predictable at this time, for estimating purposes it is anticipated that the total number will be on the order of 200. It is further recommended that upon completion of aD modeling scenarios, that the results be SUIIlii'Wiz.ed in a repon or a series of repons.s
Projed FbIur-Impact Analysis:.
i. Task 4'1
Validate hydrogeologic rationale for separating the Northern and Central Subareas.
i Ground-water flow modeling by the USGS {Professional Paper 1403-D) indicates
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1 that Upper Aoridan withdrawals north of the Gulf Trough6 have little impact on
water levels south of the Gulf Trough. While the Gulf Trough is reasonably well-
defined southwest of Statesboro, its e.xi~eDU ~ of Statesboro is DOt well
doalmented ExteDskm of the Gulf Trouah from Statesboro to the SaVIDDih
Riwr would be JeUOMble jlsdficatiaa b maintwininl tbe JDtesrity of the
Nanhem Subela ad Jess Jestrictiw water 111eleplaticDL OD the other bm1.
if the Troup does DOt atald Daltheast rl Statesbcro, tbeD it may be appopriate
to include portions of Bulloch IDd Saeven counties in the Ceubal Subarea.
Validation of the northeast eXtension of the Gulf Trough should be 1ssessod by
performing two seismic-reflection profiles, generally perpendicular to the axis of
the Trough, and coring three deep borings, w1izing EPD's wire-tiDe coring
equipment, along one or near ODe of the seismic profiles, through the confining
units and into the carbonate portion of the aquifrz fOr about 100a200 feet. The
seismic pronles would define the exmence or Dallelh1ence of any DOrtheastward
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' t1uch d lbe PiDaJ Sn~egy Will be depeMem Cllllbe modelioa ICmlrios dill~ de~oped. Many d
these may be analyZed betweeo July I, 2005 when EPD iDitiates ~ d lbe PIDII S~r~~qy IDd December
31, 200S wbieo EPD 8 scheduled 10 fmaJize 1be PiDal Snaqy. In aD Jikibocd,lbe ~qat desc:ribiD& lbe
sceaarios wCi:Wd DOC be iDitiated UDiil &her JaDuary 1, 2006.
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6 ~Gulf Troueb is a subsUrface poJocic feaue tbat sepuates !be Ncnbem.Subuea from lbe CeDiraJ
Subarea. 1
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APPENDIX4
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Water Quality Control
Chapter 391-3-6
I RULES
OF
GEORGIA DEPARTMENT OF NATURAL RESOURCES
ENVIRONMENTAL PROTECTION DIVISION
CHAPTER 391-3-6
TABLE OF CONTENTS
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391-3-6-.13 Underground Injection Control
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391-3-6-.13 Underground Injection Control
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(1) PuQ>ose. The purpose of this rule, 391-3-6-.13 is to establish classes of injection wells,
pro~ibitions, criteria and standards applicable to injection wells.
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(2) Definitions. Amended. All terms used in this rule shall be interpreted in accordance with
the aefinitions as set forth in the Act, unless otherwise defined in this Paragraph or in any oth~r Paragraph of this Chapter. All federal regulations adopted by reference are those in
effe:ct as of January 1, 2000.
(a) "ABandoned well" means a well whose use has been permanently discontinued or which is in
a stkte of disrepair such that it cannot be used for its intended purpose or for observation
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purposes.
(b) "Aquifer" means a geological formation, group of formations, or part of a formation that is cap~ble of yielding water to a well or spring.
(c) "Ar~a of review" means the area surrounding.an injection well or field where migration of
the injection and/or formation fluid into an underground source ofdrinking water may occur.
(d) "Casing" means a pipe or tubing of appropriate material of varying diameter and weight,
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lowered into a borehole during or after drilling in order to support the sides of the hole and
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thus prevent the walls from caving, to prevent loss of drilling mud into porous ground or to
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prevent water, gas or other fluid from entering or leaving the hole.
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(e) "Catastrophic collapse" means the sudden and utter failure of overlying strata caused by the
renioval of underlying materials.
(f) "CJmenting" means the operation whereby a cement slurry is pumped into a drilled hole I and/or forced behind the casing.
(g) "CJsspool" meaps a "drywell" that receives untreated sanitary waste containing human
exc~eta, and which sometimes has an open bottom and/or perforated sides. I
(h) "Cl~ss V septic system" means a "septic system" that handles sanitary and/or other wastes
anci has the capacity to serve 20 or more persons a day. I
(i) "C<?nfining bed" means a body of impermeable or distinctly less permeable material
str~tigraphically adjacent to one or more aquifers.
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fo~ations, (j) "Cdnfining zone" means a geological formation, group of
or part ofa formation
tha~ is capable of limiting fluid movement above or below an injection zone.
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(k) "Cqntaminant" means any physical, chemical, biological or radiological substance or matter
in water.
(l) "Cbnventional mine" means an open pit or underground excavation for the production of
minerals .
(m)"Di:sposal well" means a well used for the disposal of waste into a subsurface stratum. (n) "D~ainage well" means a well used to drain surface water into a shallow aquifer. An induced
rec~arge well which drains ground water from a shallow aquifer into a deeper aquifer is not a
drainage well.
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(o) "Dr\ywell" means a well, other than an improved sinkhole or subsurface fluid distribution
sysiem, completed above the water table so that its bottom and sides are typically dry except
whtm receiving fluids .
(p) "E~empted aquifer" means an aquifer or its portion that meets the criteria in the definition of
unqerground source of drinking water but which has been exempted according to the
pro~edures in Rule 391-3-6-.13(4) ofthis Chapter.
(q) "Facility, operation or activity" means any injection well or system.
(r) "Flhid" means any material or substance which flows or moves whether in a semisolid, liq~d, sludge, gas, or any other form or state.
(s) "Fdrmation" means a body ofconsolidated or unconsolidated rock characterized by a degree
oflithologic homogeneity which is prevailingly, but not necessarily, tabular and is mappable
on the earth's surface or traceable in the subsurface.
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(t) "Formation fluid" means fluid present in a formation under natural conditions as opposed to
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introduced fluids, such as drilling mud.
(u) "G~nerator" means any person, by site location, whose actor process produces hazardous
w~te identified or listed in Federal Regulations, 40 C.F.R. Part 261.
(v) "Groundwater" means water below the land surface in the zone of saturation.
(w)"Gtout" means a mixture of not more than six gallons of clear water to one 95 pound bag of
portland cement or a mixture of clear water and bentonite adequate to create an impervious I
sea,. The mixture may contain additives in proper amounts as necessary to reduce shrinkage
and increase compatibility of the grout to injection and formation fluids. I
(x) "Hazardous waste" means a hazardous waste as defined by the Georgia Hazardous Waste
Management Act, Georgia Laws 1979, p. 1127, et seq., and the rules adopted pursuant to the
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Act
(y) "Hkardous waste management facility" means all contiguous land and structures, other
appurtenances and improvements on the land used for treating, storing, or disposing of I
h~dous waste. A facility may consist of several treatment, storage, or disposal opera~ional
units.
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(z) "!~proved sinkhole" means a naturally occurring karst depression or other natural crevice
fo~nd in other geologic settings which has been modified by man for the purpose ofdirecting
and emplacing fluids into the subsurface.
(aa) ! "Injection" means the subsurface emplacement of fluids.
(bb) I "Injection well" means a well into which fluids are being, or intended to be, injected.
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( cc)
"Injection zone" means a geological formation, group of formations, or part of a
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formation receiving fluids through a well.
(dd) "Packer" means a device lowered into a well to produce a fluid-tight seal.
( ee)
"Person" means any individual, corporation, association, partnership, county,
mmPcipality, State agency, Federal agency or facility or other entity.
(ff) "Plugging" means the act or process ofstopping the flow ofall fluids, including water, oil or
gas ;into or out of a formation through a borehole or wep penetrating that formation.
(gg) 1 "Point of injection" means the last accessible sampling point prior to waste fluids beiqg released into the subsurface environment through an injection well. For example, the
point of injection of a Class V septic system might be the distribution box -- the last acc~ssible sampling point before the waste fluids drain into the underlying soils. For a
d~ell, it is likely to be the weil bore itself.
(hh) i "Radioactive waste" means any waste which contains radioactive material.
(ii) "S~itary waste" means liquid or solid wastes originating solely from humans and human
activities, such as wastes collected from toilets, showers, wash basins, sinks used for I
cleaping domestic areas, sinks used for food preparation, clothes washing operations, and
sinks or washing machines where food and beverage serving dishes, glasses, and utensils are
cleahed. Sources of these wastes may include single or multiple residences, hotels and
motels, restaurants, bunkhouses, schools, ranger stations, crew quarters, guard stations, c~pgrounds, picnic grounds, day-use recreation areas, other commercial facilities, and
industrial facilities provided the waste is not mixed with industrial waste.
GD "Septic system" means a "well" that is used to emplace sanitary waste below the surface and
is tYpically comprised of a septic tank and subsurface fluid distribution system or disposal
systFm.
(kk) 1 "Site" means the land or water area where any facility, operation or activity is phy~ically located or conducted, including adjacent land used in connection with the facility,
operation or activity.
(ll) "Stratum (plural strata)" means a single sedimentary bed or layer, regardless of thickness,
thatIconsists of generally the same kind of rock material.
(mm) i "Subsidence" means the lowering of the natural land surface in response to: earth
mo~ements; lowering offluid pressure; removal ofunderlying supporting material by mining
or solution of solids, either artificially or from natural causes; compaction due to wetting I
(hydrocompaction); oxidation of organic matter in soils; or added load on the land surface.
(nn) i "Subsurface fluid distribution system" means an assemblage of perforated pipes,
draih tiles, or similar mechanisms intended to distribute fluids below the surface of the
ground .
(oo) i "Underground source of drinking water" means all aquifers or portions of aquifers
which are not exempted aquifers.
(pp) i "Waters or Waters ofthe State" includes any and all rivers, streams, creeks, branches,
reservoirs, ponds, drainage systems, springs, wells, and all other bodies of surface or
sub$urface water, natural or artificial, lying within or forminga part ofthe boundaries ofthe
State which are not entirely confined and retained completely upon the property of a single
individual, partnership, or corporation.
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(qq) I "Well" means an open bored, drilled or driven shaft, whose depth is greater than the
lar~est surface dimension; or an open dug hole whose depth is greater than the largest surface di~ension; or, an iniproved sinkhole; or a subsurface fluid distribution system. Ditches and
drains, open or filled, are not wells.
(rr) "Well head protection area" means that land area delineated in accordance with Rule 391-3-
5-.40 (ss)"Well injection" means the subsurface emplacement of fluids through a well.
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(tt) All! other technical terms shall be defined in accordance to the definitions provided in
Dri'scoll, F.G., 1996, Groundwater and wells, Johnson Division, St. Paul, MN 55112.
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(3) Classification oflnjection Wells. Amended. I (a) Cl~ss I Wells. This class consists ofindustrial and municipal disposal wells that inject fluids
otM:r than hazardous waste or radioactive waste below the lowermost formation containing,
within two (2) miles of the well bore (or greater distance if determined by the Director), an
underground source of drinking water. (b) Cl~ss II Wells.
1. ~is class consists of wells which inject fluids:
(i) :which are brought to the surface in connection with conventional oil or natural gas I ;production and which may be commingled with waste waters from gas plants which are
ian integral part of production operations, unless those waters are classified as a
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hazardous waste at the time of injection;
(ii)i for enhanced recovery of oil or natural gas; and
(iii) for storage of hydrocarbons which are liquid at standard temperature and pressure.
(c) Cl&ss III Wells.
1. This class consists of wells which inject fluids for the extraction of minerals including:
(i) tuining of sulfur by the Frasch method;
(ii)! in situ production of uranium or other metals; this category includes only in situ
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1! production from ore bodies which have not been conventionally mined. Solution mining
.of conventional mines such as stops leaching is included in Class V; and
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(iii} solution mining of minerals, such as salt or potash.
(d) Class IV Wells.
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1. T}\is class consists of injection wells used by generators ofhazardous waste or ofradioactive
w~te, by owners or operators of hazardous waste management facilities, or by owners or
operators of radioactive waste disposal sites to dispose of hazardous waste or radioactive I
w~te into the subsurface or gro\.md water.
2. Any septic tank, well or cesspool used by generators of hazardous or radioactive waste, or
b~ owners or operators ofhazardous or radioactive waste management facilities, to dispose
of fluids containing hazardous or radioactive wastes into the subsurface or ground water.
3. The subsurface emplacement ofhazardous waste or radioactive waste by well injection into
th~ subsurface or waters of the State is hereby prohibited. No permit authorizing or
e~tablishing an effluent limitation inconsistent with the foregoing shall be issued.
(e) Clc\.ss V wells consists of all injection wells not included in Classes I, II, III or IV. Typically,
Cl~ss V wells are shallow wells used to place a variety of fluids directly below the land
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surface. However, if the fluids placed in the ground qualify as a hazardous waste under the
Re~ource Conservation and Recovery Act (RCRA), the well is a Class IV well, not a Class V
well. Class V wells include, but are not limited to:
1. Ai:r conditioning return flow wells or any other open-loop system used to return to the
supply aquifer or any aquifer the water used for heating or cooling in a heat pump;
2. Large-capacity cesspools including multiple dwelling, community or regional cesspools, or
other devices that receive sanitary wastes, containing human excreta, which have an open
bdttom and sometimes have perforated sides. These requirements do not apply to single
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family residential cesspools nor to non-residential cesspools which receive solely sanitary
wkte and have the capacity to serve fewer than 20 persons a day;
3. Cooling water return flow wells used to inject water previously used for cooling; .
4. Dtainage wells used to drain surface fluid, primarily storm runoff, into a subsurface
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formation;,
5. Dtywells used for the injection of wastes into a subsurface formation; 6. R~charge wells used to replenish or store water in an aquifer; 7. R~mediation wells used to inject water, air, oxygen, nutrients, or partly clean water to
retnediate sites contaminated with hydrocarbons or chemicals;
8. Sa,lt water intrusion barrier wells used to inject water into a fresh water aquifer to prevent the
intrusion of salt water into the fresh water; . I
9. Sand backfill and other backfill wells used to inject a mixture of water and sand, mill I tailings or other solids into mined out-portions ofsubsurface mines whether what is injected
is Ia radioactive waste or not;
10. Septic system wells used to inject the waste or effluent from a multiple dwelling business I e1stablishment, community or regional business establishment septic system. These rules do I
riot apply to single family residential septic system wells, nor to non-residential septic I
system wells that are used solely for the disposal ofsanitary waste and have. the capacity to
sfrve fewer than 20 persons a day;
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(4) Idimtification of Underground Sources of Drinking Water and Exempted Aquifers.
Arbended. I
(a) The Director may identify by narrative description, illustrations, maps, or other means, and
sh~ll protect, except where exempted under subparagraph (b) of this paragraph, as an
un~erground source of drinking water, all aquifers or parts of aquifers whichmeet the
: deftnition of an Ounderground source of drinking waterO for the purposes of these rules.
Uqless specifically exempted by the Director under subparagraph (b) ofthis paragraph, all
aquifers shall be considered, for the purposes of these rules, as underground sources of
drihl:ing water.
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(b) Tile Director may identify by narrative description, illustrations, maps, or other means, all
aqhifers or parts of aquifers which the Director proposes to designate as an exempted aquifer, fo~ the purposes of these rules, if it meets the following criteria:
1. It 'does not currently serve as a source of drinking water;
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2. The total dissolved solids (TDS) is greater than 3,000 milligrams per liter;
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3. Injection into the aquifer will not cause salt-water to move into and contaminate ~derground sources of drinking water; and
4. It ~annot now and will not in the future serve as a source of drinking water because:
(i) it is mineral, hydrocarbon or geothermal energy producing or can be demonstrated by a I ;permit applicant for a Class II or III operation to contain minerals or hydrocarbons, that
;considering their quantity and location, are expected to be coinrnercially producible
1based on available information; or
(ii) iit is situated at a depth or location which makes recovery of water for drinking water
!purposes economically or technologically impractical; or
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(iii) it is so contaminated that it would be economically or technologically impractical to
[render the water fit for human consumption; or
(iv) .it is located over a Class III mining area subject to subsidence or catastrophic collapse.
(c) Fot Class III wells,.the pirector shall require an applicant for a permit which necessitates an
aqJifer exemption to furnish the data necessary to demonstrate that the aquifer is expected to
be bineral or hydrocarbon producing. Information contained in the mining plan for the
probosed project, such as a map and general description of the mining zone, general
inf6rmation on the mineralogy and geochemistry of the mining zone, analysis of the
ambnability of the mining zone to the proposed mining method and a timetable of planned
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development of the mining zone shall be considered by the Director in addition to the
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information required by Rule 391-3-6-.13(6). Approval ofthe aquifer exemption shall be
treJted as a program revision under this paragraph.
(d). Fot Class II wells, a demonstration of commercial productibility shall be made as follows:
1. Fdr a Class II well to be used for enhanced oil recovery processes in a field or project c~ntaining aquifers from which hydrocarbons were previously produced, commercial
prpductibility shall be presumed by the Director upon a demonstration by the applicant of
hi~torical production having occurred in the project area or field.
2. F9r Class II wells not located in a field or project containing aquifers from which
hxdrocarbons were previously produced, information such .as logs, core data, formation
d~scription, .formation depth, formation thickness and formation parameters such as
p~rmeability and porosity shall be considered by the Director, to the extent such information
is ;available.
(e) No, designation ofan exempted aquifer, for the purposes ofthese rules, shall be final until the
Di*ector has provided public notice and opportunity for a public hearing on the proposed
deSignation and the designation has been approved by the Administrator.
. II
(5) Prhhibition of Movement of Fluid into Underground Sources of Drinking Water.
Ariiended . I
(a) Nd owner or operator shall construct, operate, maintain, convert, plug, abandon, or conduct
ant other injection activity in a manner that allows the movement of fluid containing any
cob.taminant into underground sources ofdrinking water, ifthe presence ofthat contaminant
may cause a violation of any primary drinking water regulation under Georgia's Rules for
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Safe Drinking Water, Chapter 391-3-5-.18, or may otherwise adversely affect the health of
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I per~ons. The applicant for a pennit shall have the burden of showing that the requirements
of t.pis paragraph are met.
(b) Ex~ept for remediation wells, injection of fluids shall be prohibited in the inner management
zone of any well head protection area defined by Rule 391-3-5-AO. l I I
(6) Pe~mit Application for Class I, II and III Wells. Amended.
(a) No person shall, in accordance with Section 10 ofthe Act, construct or operate a Class I, II, or 1~1 injection well without first having applied for, and obtained, an injection well pennit
from the Director. The requirements for Class II wells do not include permits for
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exp,loration, drilling and well construction for oil and/or gas production.
(b) Th~ subsurface emplacement ofhazardous waste or radioactive waste by well injection into
the J subsurface or waters of the State is hereby prohibited. No permit authorizing or
establishing an effluent limitation inconsistent with the foregoing shall be issued.
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(c) Applications for injection well permits for Class I, II or III injection wells shall be in
accbrdance with Federal Regulations, 40 C.F.R. 144.11, 144.21, and 144.31. Applications I
shall be on fonns as may be prescribed and furnished from time to time by the Division and . I
sha~l be accompanied by all pertinent infonnation as the Division may request including, but
not: limited to, the infonnation the Director must consider for authorizing Class I, II or III weVs as set forth in the ~ederal Regulations, 40 C.F.R. 146.14, 146.24 and 146.34.
(d) Alllpennit applications and reports for Class I, II, or Ill injection wells shall be signed in
accbrdance with the Federal Regulations, 40 C.F.R. 144.32, 146.12 and 146,22. I
(e) WHen a facility or activity is owned by one person but is operated by another person, it is the
op~rator's duty to obtain a pennit.
No~ice (7)
and Public Participation for Class I, II and Ill Wells. Amended.
(a) Wl'ien the Division is satisfied that the application is complete, a tentative determination will
be ~ade to issue or deny the pennit. If the tentative detennination is to issue the pennit, a
draft permit will be prepared in accordance with Federal Regulations, 40 C.F.R. 124.6 and
ap~licable State laws prior to the issuance of a public notice.
(b) Public notice of the draft pennit will be prepared and circulated in a manner designated to I inf?rm interested and potentially interested persons of the proposed injection and of the
proposed detennination to issue or deny a pennit for the proposed injection. Procedures for
cirdulation of the public notice shall include the following: I
1. Within the geographical area of the proposed injection the public notice shall be circulated
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bYr at least one ofthe following: posting in the post office or other public buildings near the
prbmises of the applicant in which the injection is located or posting at the entrance of the
ap~licant's premises or nearby; .and publication in one (1) or more newspapers of general
circulation in the area affected by the injection;
2. Pdsting of the public notice in the Office of the Secretary of State;
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3. A popy of the public notice shall be mailed to the applicant;
4. M*iling of the public notice to any person or group upon written request including persons
so'licited from area lists from past pennit proceedings. The Division shall maintain a
m~iling list for distribution of public notices and fact sheets. Any person or group may
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request that their names be added to the mailing list. The request should be in writing to the
Division and shall be renewed in December ofeach year. Failure to renew the request shall
result in the removal of such name from the mailing list;
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5. The Division shall provide a period ofnot less than thirty (30) days following the date ofthe
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public notice in which interested persons may submit their written views on the tentative
determination with respect to the draft Injection Well Permit. All written comments
submitted during the thirty (30) day comment period will be retained by the Division and
cohsidered in the final determination with respect to the permit application and shall be I
responded to in accordance with Federal Regulations, 40 C.F.R. 124.17. The comment
period may be extended at the discretion of the Director;
6. The contents ofthe public notice will be in accordance with Federal Regulations, 40 C.F.R.
12~' .10;
7. The Division will prepare and distribute a fact sheet in accordance with Federal Regulations,
40JC.F.R. 124.8 and applicable State laws. A copy ofthe fact sheet will be available for
public inspection at the Division office in Atlanta. Any person may request in writing a
copy of the fact sheet and it will be provided. The Division shall add the name of any
petson or group upon request to the mailing list to receive copies of fact sheets; I
8. The Division will prepare and distribute a statement of basis in accordance with Federal
R~gulations, 40 C.F.R. 124.7;
9. Copies ofthe draft permit shall be transmitted to the Regional Administrator for review and
cohunents in such manner as the Director and Regional Administrator shall agree.
(c) Th~ Director shall provide an opportunity for an applicant, any affected state or interstate
agency, the Regional Administrator or any other interested agency, person or group of
per~ons to request a public hearing with respect to an Injection Well Permit. Any such
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req~est for public hearing shall be filed within the 30 day comment period prescribed in
su~paragraph 391-3-6.13(7)(b) 5. and shall indicate the interest of the party filing such a
req'uest, the reasons why a hearing is requested, and those specific portions ofthe application
or Information to be considered at the public hearing. The Director shall hold a hearing ifhe
determines that there is sufficient public interest in holding such a hearing or ifthe Director
de~ires to clarify a permitting decision:
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1. .Arty public hearing held pursuant to this subparagraph shall be held in the geographical area
of: the proposed injection or other appropriate location at the discretion of the Director;
2. 3.
Th'e Director may hold one public hearing on Public notice of any hearing held .pursuant to
groups of related permit applications; this su. bparagraph shall be provided at
least
thlrty (30) days in advance of the hearing date and shall be circulated in accordance with
F~deral Regulations, 40 C.F.R. 124.10(c) where applicable to State-issued permits.
(d) A bopy of the administrative record for the final permit (40 C.F.R.124.18(b)(1)), including
bui not limited to the Injection Well Permit Application, public notice, fact sheet, statement I
.of pasis, draft permit and other well forms related thereto, written public comments of all
governmental agencies thereon and other reports, files and information not involving
m~thods or processes entitled to protection as trade secrets, and not including written public
comments by any person, shall be available for public inspection and copying during normal
bukiness hours at the Division office in Atlanta and in addition shall be distributed in
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accbrdance with Federal Regulations, 40 C.F.R. 124.10(e). Public access to such
infdrmation shall be in accordance With Federal Regulations, 40 C.F.R. 14.5.
(e) AnyI information submitted in an Injection Well Permit Application form together with
repbrts, records or plans that are considered confidential by the applicant should be clearly
labeled 0 Confidential 0 and be supported by a statement as to the reasons that such
infdrmation should be considered confidential. If the Director, with the concurrence ofthe
Regional Administrator, determines that such information is entitled to confidential
protection, he shall label and handle same accordingly:
1. when the information being considered for confidential treatment is contained in the ap~lication, the Director shall forward such information to the Regional Administrator for
his concurrence in any determination of confidentiality.
2. Ariy information accorded confidential status, whether or not contained in the application, sh~ll be made available, upon written request, to the Regional Administrator or his
authorized representative who shall maintain the information as confidential.
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(f) Claims for confidentiality for the following will be denied:
1. Thb name and address of any permit applicant or permittee; or
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2. InfIormati.on which deals with the existence, absence, or level of contaminants in drinking water.
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(8) Te~ms. and Conditions of Permits for Class I, II, or III Wells. Amended.
(a) Terms and conditions under which an Injection Well will be permitted will be specified on
. the/permit issued and shall be in accordance with Federal Regulations, 40 C.F.R. 144.4, 40 C.~.R. 144.51 and 40 C.F.R. 144.52, Rule 391-3-6-.13(9) of this Chapter and as may be
adcVtionally required by the Director. (b) Nojlnje~tion ,Well Permit.shall be issued au~o~izing the ~ovement of fluid containin~ any
coiltammant mto.underground sources of dnnkmg water 1fthe presence ofthat contammant
maY cause a violation of any primary drinking water regulation set forth in Georgia Rules for
Safe Drinking Water, Chapter 391-3-5, or may otherwise adversely affect the health of I
persons. The applicant for a permit shall have the burden ofshowing that the requirement of
thi~ paragraph is met.
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(c) ~en the corrective action plan as required in Paragraph 391-3-6-.13(9) is adequate, the
Dirbctor shall incorporate it into the permit as a condition. Where the Director's review ofan
apP,lication indicates that the permittee's plan is inadequate (based on the factors in Federal
Re~ulations 40, C.F.R. 146.07), the Director shall require the applicant to revise the plan,
pre~cribe a plan for corrective action as a condition of the permit under paragraph (b) ofthis
section, or deny the application.
1. N9 ovmer or operator of a ne": injection well may begin injection until all required
.corrective action has been taken.
2. Tne Director may require as a permit condition that injection pressure be so limited that
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pressure in the injection zone does not exceed hydrostatic pressure at the site of any
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improperly completed or abandoned well within the area ofreview. This pressure limitation
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shall satisfy the corrective action requirement. Alternatively, such injection pressure
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liihitation can be part of a compliance schedule and last until all other required corrective
action has been taken.
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3. When setting corrective action requirements for Class III wells the Djrector shall consider
th~ overall effect ofthe project on the hydraulic gradient in potentially affected underground
so'urces of drinking water, and the corresponding changes in potentiometric surface(s) and
flow direction(s) rather than the discrete effect of each well. If a decision is made that c~rrective action is not necessary based on the determinations above, the monitoring
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prpgram required in Federal Regulations, 40 C.F.R. 146.33(b) shallbe designed to verify
the validity of sucli determination. (d) Th~ permittee shall report any monitoring or other information which indicates any
corit~inant that may cause an endangerinent of an underground source of drinking water,
any noncompliance that may endanger health or the environment, or any noncompliance with
a p~rmit condition or malfunction of the injection system which may cause fluid migration
intp or between fresh water zones or underground sources of drinking water. Any
nob.compliance with a permit condition or a malfunction ofthe injection information shall be
reported by telephone to the Director within twenty four (24) hours from the time the
.Per;mittee becomes aware ofthe noncompliance and a written submission within five (5) days
of: the oral notification. The written submission shall contain a description of the
no~compliance and its cause, the period of noncompliance including exact dates and times,
the corrective action taken to reduce or eliminate the noncompliance, and the steps planned
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to prevent a recurrence of the noncompliance.
(e). Th~ permittee is required to maintain financial responsibility and resources to close, plug and
abandon the underground injection operation in a manner prescribed by the Director~ The
petrnittee must show evidence offinancial responsibility to the Director by the submission of s~ety bond, or other adequate assurance, such as financial statements or other materials
acceptable to the Director.
(f) The permittee shall operate the well so as not to exceed maximum injection volumes and
pressures as necessary to assure that fractures are not initiated in the confining zone; that
injbcted fluids do not migrate into fresh water zones or underground sources of drinking
w~ter; or that formation fluids are not displaced into underground sources ofdrinking water.
Th;e Director shall establish such volumes and pressure limits as permit conditions.
(g) lnj:ection may not commence until construction is complete and written approval to
commence has been given by the Director. The permittee shall submit notice ofcompletion
of;construction to the Director including:
1. Ail available logging and testing program data on the well;
2. A! demonstration ofthe mechanical integrity ofthe well;
3. The anticipated maximum pressure and flow rate at which the permittee will operate;
4. T~e results of the formation testing program;
5.The actual injection procedure; I
6.The compatibility of injected waste with the fluids in the injection zone; and I
7.The status of corrective action on defective wells in the area of review to prevent fluid
rJovement into underground sources of drinking water. I
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(h) The fpermittee shall notify the' Director in writing of any proposal to abandon an injection
well! and that the plugging and abandonment plan approved as part of the permit will be
followed .
(i) A pJrmit shall be issued for a period not to exceed five (5) years fro~ the date of issuance.
On ~xpiration of the permit the permit shall become invalid and the injection prohibited I
unle1ss application is made at least ninety (90) days prior to the expiration date for a
reis~uance ofthe permit. When a permittee has submitted a timely and sufficient application
a for new Injection Well P~rmit and the Director is unable, through no fault ofthe permittee,
to issue the new permit before the expiration date of the existing permit, then the Director
shali extend the existing permit until a new permit is issued.
G) A pbrmit may be transferred to any person provided the permittee notifies the Director in I writ~ng at least 30 days in advance ofthe proposed transfer date and the transfer is approved
by t~e Director.
(k) The:permit does not convey any property rights of any sort or any exclusive privilege.
(1) Thei permit may be modified, revoked and reissued, or terminated for cause, or minor
modifications may be made in accordance with Federal Regulations, 40 C.F.R. 124.5, 144.39
and i144.41. The permittee shall furnish the Director any information which the Director may
request to determine whether cause exists for modifying, revoking and reissuing or
temhnating a permit or to determine compliance with the permit.
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(m)The; Director may terminate a permit during its term or deny a permit renewal for the
fo110wing causes: 1. No~compliance by the permittee with any conditions of the permit;
2. Th~ permittee's failure in the application or during the permit issuance process to disclose
fully all relevant facts, or the permittee's misrepresentation ofany relevant facts at any time;
3. A d~termination that the permitted activity endangers human health or the environment and
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cari only be regulated to acceptable levels by permit modification of termination; or
4. A f~ilure by the permittee to demonstrate that continuation ofthe operation under the permit
wi~l not result in degradation of the water quality.
(n) For:Class I, II and III Wells, if any water quality monitoring of an underground source of
drinking water indicates the movement of any contaminant into the. underground source of I
drinking water, the Director shall prescribe such additional requirements for construction, I .
corrective action, operation, monitoring or reporting (including closure ofthe injection well)
as Je necessary to prevent ~uch movement. I
(oYNot,withstanding any other provisions ofthis rule the Director may issue a temporary permit
for a specific injection in accordance with the Federal Regulations, 40 C.F.R. 144.34.
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(9) Coirective Action.
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(a) Applicants for Class I, II, or III injection well permits shall identify the location ofall known
wells within the injection well's area of review which penetrate the injection zone, or in the I
case of Class II wells operating over the fracture pressure of the injection formation, all kno:WU wells within the area of review penetrating forma~ions affected by the increase in
preSsure. For such wells which are improperly sealed, completed, or abandoned, the I
applicant shall also submit a plan consisting of such steps or modifications as are necessary
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to prevent movement offluid into underground sources ofdrinking water (corrective action).
where the plan is adequate, the Director shall incorporate it into the permit as a condition.
where the Director's review of an application indicates that the permittee's plan is inadequate
(b~ed on the factors in subparagraph 391-3-6-.13(8)(c)), the Director shall require the
appl_icant to revise the plan, prescribe a plan for corrective action as a condition ofthe permit
under subparagraph (b) of this paragraph or deny the application.
(b) In ;determining the adequacy of corrective action proposed by the applicant under this
paragraph and in determining the additional steps needed to prevent fluid movement into
un~erground sources ofdrinking water, the following criteria and factors shall be considered
by !the Director: 1. N~ture and volume of injected fluid; 2. N~ture of native fluids or by-products of injection;
3. Pdtentially affected population; 4. G~ology;
5. Hydrology;
6. History of the injection operation;
7. cbmpletion and plugging records; I
8. Abandonment procedures in effect at the time the well was' abandoned; and
9. H~draulic connections with underground sources of drinking water. .
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(10) C~iteria and Standards Applicable to Class I, II, and III Injection Wells.
(a) Each permittee shall comply with the criteria and standards for underground injection control
fot Class I, II and III injection wells as set forth in the Federal Regulations, 40 C.F.R.
14~.12, 146.22 and 146.32 and as may be additionally prescribed by the Director.
(b) AI~ Class I wells shall be sited in such a fashion that they inject into a formation which is
beheath the lowermost formation containing, within a two (2) mile radius ofthe well bore or
gr~ater if determined by the Director, an underground source of drinking water.
(c) All Class II wells shall be sited in such a fashion that they inject into a formation which is I separated from an underground source of drinking water by a confining zone that is free of
knpwn open faults or fractures within the area of review.
(d) Operating, monitoring and reporting requirements shall be in accordance with Federal
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R~gulations, 40 C.F.R. 146.13, 40 C.F.R. 146.23 and 40 C.F.R. 146.33 and as may be
adpitionally prescribed by the Director. !
(11) Pe1rmit Application for Class V Wells. Amended. . (a) E~cept as identified in subparagraph 1. below, no person shall, after the effective date ofthis
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ru~e, construct or operate a Class V injection well for the injection of contaminants or fluids
unless authorized by a permit issued by the Director.
1. Irt accordance with O.C.G.A. 12-5-30 (f.), the use of a Class V septic system that handles
o~ly sanitary wastes shall be permitted under a General Permit issued by the Director.
c:overage under this permit shall be automatic upon notification by the Georgia Department I
ofHuman Resources that such a system meets requirements of290-5-26 and 391-3-16-.02.
shch notification shall be in the form of an annual inventory of new and existing systems.
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~eptic TJe Genefat Permit and a list ofall Class V systems shall be maintained in the offices
oft the Division.
(b) A~er the effective date of this rule, use of a new or existing Class V septic system that
hartdles sanitary and/or other wastes shall be permitted by the Director provided that a
written hydrogeologic determination has been made by a professional geologist or
prqfessional engineer registered in the State of Georgia in accordance with Chapter 19 or Ch~pter 15, respectively, of Title 43 that such a system does not endanger an underground
source of drinking water nor is such a system within the inner management zone of any exi~ting well head protection area.
(c) Th~ use of a Class V remediation well that is used as part of a Division - approved plan to
reniediate a site having contaminated soil and /or ground water shall be permitted by the
Ditector provided that such an approved plan has been prepared and signed and sealed by a pro1fessional geologist or professional engineer registered in the State of Georgia in
acdordance with Chapter 19 or Chapter 15, respectively, of Title 43.
(d) Cl~ss V wells apply to all injection wells not included in Classes I, II, III or IV. Class V
wells are defined in subparagraph 391-3-6-.13(3)(e).
(e) Ex6lusive ofthe authorizations indicated in subparagraphs (a) 1. above ofthis paragraph, any I person desiring to construct a Class V well shall apply in writing to the Director for an inj~ction well permit. Any persons owning or operating any unpermitted well meeting the
definitions ofa Class V well, exclusive ofthe authorizations described in subparagraph (a) 1.
abqve ofthis paragraph, prior to the effective date ofthis rule shall submit an application and
infbrmation to the Director no later than July 1, 2001. The. application shall include, but
nedd not be limited to, the following information:
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1. Na:me, mailing address telephone number, latitUde and longitude and location ofthe facility;
2. Na;me and address ofthe owner and operator, telephone number, ifdifferent than the facility;
3. A fllap showing the location of each existing or proposed injection well at the facility;
4. A\ diagram showing the details of the construction existing injection well(s) and the
proposed construction of any proposed injection well(s).
5. Prbposed or existing injection rate and injection pressure or gravity flow;
6. Thb chemical, physical and radioactive characteristics ofthe fluid injected or to be injected; an~
7. Si~nature ofthe applicant.
(d) Upbn receipt of the application, the Director shall:
1. D~termine if the facility is a Class V well.
.
2. D~termine if additional information is required to evaluate the facility.
3. As~ess the pcitenti.al adverse affect upon the underground source of drinking water.
4. Determine any construction and operating requirements to protect the underground drinking
water source.
(e) Aftr an evaluation of the application, the Director shall: 1. Is~ue a permit in the form of a letter containing any special permit conditions as may be ne~essary such as well construction, operation, monitoritig and reporting. The permit shall
beifor a period not to exceed ten (10) years.
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2. If!the Director determines that the facility is not a Class V well, he shall require. the
applicant to submit a permit application in accordance with Rule 391-3-6-.13(6) of this
Chapter. The application processing and permit issuance shall be. in accordance with Ru1es
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3Q1-3-6-.13(6) and 391-3-6-.13(7).
3. Ddny the issuance of a permit.
(f) Nofperson shall be issued a permit to operate a Class V well where the movement offluid, in the~udgment ofthe Director, may cause a violation of any primary drinking water ru1e under
the:Georgia Rules for Safe Drinking Water, Chapter 391..:3-5, or which may adversely affect
the!health of persons. 1. If ~t any time the Director learns that a permitted Class V well may cause a violation under
this paragraph, the Director shall:
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(i) order the injector to take such actions as may be necessary to prevent the violation,
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including where required closure of the injection well; or
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(ii):take enforcement action.
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2. Ndtwithstanding any other provisions of this paragraph, the Director may take emergency
achon upon receipt of information that a contaminant which is present in, or is likely to e~ter a pubic water system, may present an imminent and substantial endangerment to the
he~lth of persons.
.
(g) Any persons operating an existing unpermitted Class V well and injecting fluids after the effective date of this rule shall be authorized to continue the.operation under condition~ of
pe~its or other authorization in effect prior to the effective date of this rule, provided an
apP,lication is submitted within twelve months after the effective date of this rule. An
ex~eption to this rule is that any person injecting fluids that may endanger an underground
soJrce of drinking water shall notify the Director within thirty (30) days ofthe effective date
of this rule.
(12) Stjndards and Criteria Applicable to Class V Wells. Amended.
(a) Except as identified in subparagraph 391-3-6-.13(11)(a)1: above, no person shall construct a . Cl~ss V well without first having applied for and obtained a permit from the Director.
(b) Cl~ss V wells shall be sited so that the injection fluid does not contaminate an underground
>ource of drinking water.
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(c) Ex~ept for remediation wells, the injected fluid, upon reaching any underground source of
dri~ng water, shall not contain any chemical constituents that exceed any Maximum
Co~taminant Levels (MCL) identified in Rule 391-3-5-.18. For Class V septic systems, the
flui,d leaving the subsurface distribution system may exceed any maximum contaminant
levrls (MCLs) identified in Rule 391-3-5-.18 provided that the MCL is not exceeded upon
the!fluld reaching any underground source of drinking water.
(d) With the exception of remediation wells, no Class V well shall be located within the inner
mattagement zone of any well head protection area after the effective date of this rule.
(e) Class V well construction.
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Subsections 1., 2. and 3. below shall not apply to Class V septic systems as identified in I
suBparagraphs 39f-3-6-.13(11)(a)l. and (b.) above:
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1. T~e person constructing the well shall be a licensed water well contractor in the State of G~orgia in accordance with the provisions of Chapter 5 of Title 12.
2. cdsing shall extend at least five (5) feet into the injection zone unless otherwise specified by
the Director.
3. The annular space around the entire length of the casing shall be grouted and sealed to
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pf.event pollution by surface waters, other formation fluids or pollutants into the formation
above the injection zone.
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4. Special construction requirements may be specified by the Director or the permit to prevent
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cqntamination of an underground source of drinking water.
5. Sptic systems shall be constructed in accordance with the Georgia Department of Human
R~sources requirements in 290-5-26.
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(f) An; injection permit may be transferred to any person provided the permittee notifies the
Di~ector in writing at least 30 days in advance of the proposed transfer date and the transfer
is ~pproved by the Director.
(g) A permit issued by the Director may include permit conditions for the monitoring, testing
an~ reporting of the injection facility.
(h) Plugging and Abandonment. Ex~ept for septic systems identified in subparagraphs 391-3-6-.13(11)(a)l. and 2. above, the
following shall apply:
1. T~e Director may order a Class V well plugged and abandoned by the owner when it no
longer performs its intended purpose, or when it is determined to endanger underground
s~urces of drinking water.
2. It ~hall be the owner's responsibility to have any injection well plugged and abandoned by
th~ water well contractor before removing the drilling equipment from the site ifthe well is
nqt completed for its intended purpose.
3. It shall be the owner's responsibility to have any exploratory and/or test well(s) constructed f~r the purpose of obtaining information on an injection well site, plugged and abandoned
by the water well contractor.
4. Tile entire depth of the well shall be completely filled with cement grout, which shall be
in~roduced into the well by a pipe which extends to the bottom of the well and is raised as
w~ll is filled, unless otherwise approved by the Director.
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(13) M~chanical Integrity. Amended. Ex~ept for septic systems as identified in subparagraphs 391-3-6-.13(11)(a)l. and 2. above,
the following shall apply:
(a} An injection well has mechanical integrity if:
1. There is no deteCtable leak in the casing, tubing or packer; and
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2. There is no detectable fluid movement into an underground source ofdrinking water through
v~rtical channels adjacent to the injection well bore.
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(b) 0Qe ofthe following methods must be used to evaluate the absence ofdetectable leaks under
subparagraph 391-3-6-.13(13)(a)l:
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1. Monitoring of annulus pressure; or I .
2. Pr~ssure test with liquid or gas.
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(c) Th~ methods used to determine the absence of detectable fluid movement into an un~erground source of drinking water shall be the results of a temperature or sonic log.
(d)
In
onducting
'
and
evaluating
the tests
for
mechanical
integ.rity,
the owner or operator and
the
Director shall apply methods and standards generally accepted in the industry. When the
owper or operator reports the results of mechanical integrity tests to the Director, the report
shall include a description of the test(s) and method(s) used. The Director, in making an
evcil.uation shall review monitoring and other test data submitted since the previous
eva,luation. (e) The Director may waive mechanical integrity testing of remediation wells in shallow
unsonfined aquifers.
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(14) PIJgging and Abandoning Class I, II and III Wells. Amended. I (a) The permittee shall inform the Director in writing of the permittee's intent to abandon an I injection well at least forty-five (45) working days prior to the abandonment. (b) Th~ permittee shall be responsible for the plugging of any injection well that is abandoned.
Such plugging shall be in accordance with the criteria identified in Chapter 5 (120-138) of I
Title 12. (c) W~Us shall be plugged with cement in a manner which will not allow the movement offluids
eitller into or between underground sources of drinking water. I
(d) The placement of the cement shall be accomplished under pressure from bottom to top.
(e) The well to be cemented shall be in a state of static equilibrium with the mud weight I equalized top to bottom, either by circulating the mud in the well at least once or by a
cor#parable method prescribed by the Director, such as the use of a packer, prior to the
placement of the cement plugs. I
(f) The Director may require ground water monitoring after well abandonment ifcontamination
Jn of underground source of drinking water is suspected.
(g) The permittee shall certify to the Director within thirty (30) days of plugging that the
injcliction well was plugged. according to permitted procedures.
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(15) E~ergency Action. If at any time the Director learns that an injection well may cause or
has;caused the movements of any fluids containing contaminants into an underground source
of drinking water or otherwise adversely affect the water quality or adversely affect the
pu~lic health, the Director shall:
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(a) Order the injector to cease the operation and take such actions as may be necessary to prevent
the 1violation;
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(b) Order the injector to take such actions as may be necessary to correct the violation;
(c) Tak~ enforcement action; or
.
(d) Take emergency action upon receipt of information that a contaminant is likely to enter a
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pub,lic water system and present an imminent and substantial endangerment to the health of
the public.
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(16) Pr.)bibited Wells. Amended. The following types of wells are specifically prohibited
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Statewide.
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(a) All! Class IV wells that are used to emplace hazardous waste or radioactive waste into the
suosurface .
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(b) New drainage wells, except where such wells have been permitted and designed by a
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professional geologist or professional engineer registered in the State of Georgia in
accbrdance with Chapter 19 or Chapter 15, respectively, of Title 43 ancl the injected fluid
do~s not contain any chemical constituent that exceeds any Maximum Contaminant Level I
(MCL) identified in Rule 391-3-5-.18.
(c) Ne~ large~capacity cesspools are prohibited. A large-capacity cesspool receives sanitary
wruhe from multiple dwellings and community or regional establishments serving more than I
20 persons a day. Existing large-capacity cesspools shall be closed by April 5, 2005. Such
closure shall include a 30 day notification prior to closure. Well closure shall include
rerrioval ofcontaminated materials, disinfection, and plugging with an impervious bentonite-
ce~ent mixture. Closure shall be in accordance with criteria identified in the Chapter 5 I
(120-138) ofTitle 12.
(d). Op6n loop heat pump systems where return water is discharged into a well.
(e) Motor vehicle waste disposal wells.
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Authonty p.C.G.A. Sec. 12-5-23 (Ga. L. 1957) p. 629, Sec. 4; Ga. L. 1964, p. 416, Sees. 5, 24;
Ga. L. 196~, p. 316, Sec1; Ga. L. 1972, p. 1015, Sees. 1517, 1534; Ga. L. 1972 p. 1266, Sec. 1;
Ga. L. 1.974, p. 599, Sees. 6, ~; G.a. L. 1977,,p. 368, Sec. 2. Administrative History: Original
. Rule entitle1d "Underground InJection Control was filed on Dec. 9, 1983, eff. Dec. 29, 1983.
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