Underground Injection Control Permitting

We have been involved with the preparation and/or review of permit applications or “No-Migration” petitions for wells in all 10 EPA regions, and were awarded numerous technical assistance contracts from the EPA to review and evaluate Class I, II, III, and V wells. Our professionals have either prepared or performed technical assessments for more than 250 Underground Injection Control (UIC) related permit applications, and have participated in the development of one-third of all Class I hazardous well petition applications.

Our in-house modeling capabilities use both numerical and classical analytical models; this modeling service provides our customers, clients, and others with the services they will continue to need. We can provide pressure history matches, pressure buildup calculations, and fluid dispersion/diffusion calculations for the operational life of a facility and for the extended periods of time required. Well testing and well test analyses are continually upgraded by WSP to provide the appropriate services.

We use state-of-art mapping software to build client databases and produce site location, isopach, and structure maps. Shape files and projects are generated to make future updates quickly and cost-effectively. Industry software is used to make log correlations and build, edit and quickly update geologic cross sections. We maintain industry well data subscriptions with the most up-to-date well data available. We also have CAD capabilities with a full-time, experienced operator dedicated to permitting and petitioning projects.

We have assisted clients with the permitting of injection wells since the late 1970s. Our staff was deeply involved in the Regulatory Negotiation Process that preceded the final regulations as established in 40 CFR 148 and 146. As early as 1987 and 1988, operators of Class I hazardous waste injection wells began addressing the requirements of the “No-Migration” demonstrations that were being discussed and prepared by the EPA. This early movement, which occurred prior to the formulation and passage of the RCRA land ban final rules as they applied to injection wells, was a response to the potential August 8, 1988, land ban date for the disposal of the first third wastes as listed in 40 CFR 261. Of the 102 hazardous waste injection facilities in existence in 1984, when the land disposal ban was promulgated, only 57 filed “No-Migration” petitions; of these 57 petitions, approximately 43 have been approved to date.

We were involved in the development of 21 of the 57 submitted petitions, either as a direct contractor or as an advisor on special issues. We were involved in the development of 14 of the 43 approved petitions, and served as prime contractor for 11 of the documents.

We have been responsible as prime contractor for the development of approximately 25 percent, and involved in the development of approximately 33 percent, of all approved petitions on a national basis. No other consulting company provided this level of effort during this time, nor was any other consulting company more successful in petitioning their clients’ sites to the regulatory agencies.