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HE24-01(B): Underground Injection Control Systems (UIC)

Details

Type: Bulletin

Topic or Program: Hydraulics  |  Water Resources

Final Number: HE24-01(B)

Effective Date: 02/01/2024

Updated Date: 02/01/2024

Signature on File: Paul R. Wirfs, State Hydraulic Engineer


Purpose

This bulletin provides guidance on the regulatory criteria for the installation of underground injection control systems (UICs) for stormwater management on ODOT projects, and the actions required in order to comply with the conditions of ODOT’s Water Pollution Control Facilities Permit for Class V Stormwater Underground Injection Control Systems (“UIC permit”). The Oregon Department of Environmental Quality (DEQ) issues UIC permits to UIC system operators include ODOT. This bulletin has been updated to include information regarding the documentation requirements for UICs on ODOT right-of-way.


Guidance

This guidance covers the use and definition of UIC systems, the design requirements intended to protect water quality, siting requirements and constraints, and reporting and approval processes. In addition to the procedures described herein for projects with UICs, projects required by law to manage the quality and quantity of post-construction stormwater runoff must also follow procedures described in operational notice PD-05. Not included in this bulletin are engineering design criteria for UIC systems or operation and maintenance requirements. For design guidance refer to the ODOT Hydraulics Design Manual (HDM), Chapter 14. Maintenance requirements are covered in the ODOT Routine Road Maintenance Water Quality and Habitat Guide Best Management Practices in conjunction with operation and maintenance (O&M) manuals.


Definitions

Underground injection control system (UIC)
According to Oregon Administrative Rule 340- 044, a UIC is “a well, improved sinkhole, sewage drain hole, subsurface fluid distribution system or other system or groundwater point source used for the subsurface emplacement or discharge of fluids”; a subsurface fluid distribution system is “an assemblage of perforated pipes, drain tiles or other mechanisms intended to distribute fluids below the surface of the ground.”
Drainage Facility ID (DFI)
A unique “DFI” is assigned to all ODOT stormwater treatment and storage facilities, including UICs. It is used to associate or link the stormwater facility to an O&M manual and asset management systems.
Setback
The distance that must be maintained between a structure or feature (such as a UIC) and water feature (e.g. groundwater table or water well).

Background/Reference

UICs are a stormwater management tools that can be installed and used within the limits prescribed by ODOT’s UIC permit. The permit allows the agency to install UICs without having to request and receive specific authorization for the individual facilities. These are particularly useful for projects where there is no existing stormwater system and inadequate right-of-way, and for projects where stormwater flow and volume control is a priority. Selection and placement of UICs are governed by the permit conditions and the principle that UICs should not be used when other reasonably available treatment or disposal methods provide better protection of public health and water quality.

DEQ considers both dry wells and systems that use perforated pipes to exfiltrate stormwater into the subsurface as UICs. Some bioretention or biofiltration facilities may include design elements that cause these to be classified as UICs. UIC regulations do not apply to swales, French drains, or footing drains. Other common stormwater UICs include, but are not limited to, sumps, infiltration galleries (i.e., infiltration trenches with underdrain pipes), trench drains and drill holes. Subtle differences can separate a design that is a UIC from one that is not. Contact ODOT’s Senior Stormwater Hydraulic Engineer if you are unsure if your design meets a UIC criteria. Additional information can be found on DEQ’s UIC program website and DEQ’s fact sheet on Identifying anUnderground Injection Control.


Explanation

The following highlights the main permit conditions that must be met when considering the use of a UIC. A copy of ODOT’s UIC permit is available on the ODOT stormwater webpage.

Design Elements

Project designs that incorporate UICs require close coordination between the Statewide Project Delivery Branch’s Environmental and Hydraulic Engineering Section, the Maintenance and Operations Branch and individual maintenance districts, and region staff in order for ODOT to fulfill all permit obligations. For UIC design guidance, see Chapter 14 of the HDM.

Location

A UIC may not be installed within the horizontal or vertical setback area (described below) without first obtaining a design deviation endorsed by the region tech center manager and approved by the State Hydraulic Engineer. UICs that discharge directly to groundwater are prohibited. Do not use UICs in geologically unstable areas. Additionally, do not use UICs where there is existing ground or groundwater contamination. Stormwater injection can cause, accelerate, or change the direction of movement of the contamination.

If it is necessary to place a UIC within the horizontal setback, the engineer of record must conduct a groundwater protectiveness demonstration and receive approval by DEQ prior to installation. Additional information about groundwater protectiveness demonstration, including a list of areas where groundwater demonstrations have been conducted, is included in the Groundwater Protectiveness Demonstrations for UIC Permits Fact Sheet from DEQ.

The Project Team must coordinate with the region senior hydraulic engineer prior to designing a UIC in the setback area, and to provide any exception approval paperwork received from DEQ.

Horizontal Setbacks

The required setback is:

  • Outside the 2-year time-of-travel zone for public water wells (see the DEQ Drinking Water Program Maps and Data website), if one has been determined by the Oregon Health Authority (OHA), or
  • More than 500 feet from known public drinking water, private drinking water or irrigation supply wells, if OHA has not designated the 2-year time-of-travel zone.

Vertical Setbacks

The bottom of the UIC must be at least 5 feet above the seasonal high groundwater table elevation in order to meet the groundwater protectiveness requirements outlined in ODOT’s permit. Sufficient site information demonstrating that the vertical separation requirement is met must be collected prior to installation.

General Considerations

  • Evaluate soils at the site to determine design infiltration rates as outlined in Chapter 14, Section 14.9.6.2 of ODOT’s Hydraulic Design Manual.
  • Avoid placing UICs where they will receive stormwater from non-ODOT drainage.
  • Place UICs and associated BMPs in locations that can be safely accessed by maintenance.
  • Provide adequate right of way for the UIC footprint including the area needed to accommodate all facility components, maintenance access roads, and maintenance operational areas.

Discovery of Existing UICs

If an existing UIC is discovered during construction ODOT must notify DEQ by email at UIC@deq.state.or.us. Contact the Senior Stormwater Hydraulic Engineer to determine if the UIC is already registered. Confirm with the Senior Stormwater Hydraulic Engineer if registration is warranted and register if necessary (see Documentation). Determine if meets setbacks. If doesn’t meet setbacks provide a protectiveness demonstration. Retrofit if necessary. Decommission if necessary.

Pre-Treatment

New UICs must include or be preceded by a structural Best Management Practice (BMP) that effectively removes sediment and oil. Pre-treatment BMPs are described in the Hydraulic Manual. Existing UICs that will be used to manage project stormwater must be retrofitted with a structural BMP when a new project requires work on the UIC or drainage in a highway section that includes a UIC.

Spill Protection

Provision must be made so the UIC can be isolated from spills of hazardous material and other potential pollutants. This can be done by including a shut-off valve between the final inlet to the drainage system prior to the UIC, or by confirming that all inlets to the drainage system can be blocked off. The latter approach is not appropriate where the drainage system serves properties that are not owned or operated by ODOT because ODOT staff may not have access to the affected inlets. Protocols for dealing with spills must be included in the UIC’s operation and maintenance manual.

Retrofit Strategy

The agency target for implementation of a statewide Stormwater Retrofit Program is March 31, 2027. If a statewide Stormwater Retrofit Program has not yet been established, then a region may prepare an interim region-specific retrofit plan that strategically prioritizes structural BMP retrofit projects in the future with approval from the state hydraulic engineer. A design deviation may be requested to postpone a structural BMP retrofit of an existing UIC. Postponement requires the UIC be included under a statewide stormwater retrofit program.

Decommissioning

There are three steps to decommissioning an ODOT stormwater UIC: Step 1 (Notification), Step 2 (Sampling), and Step 3 (Closure). Step 1 involves giving notification to the ODOT Senior Stormwater Hydraulic Engineer and the Clean Water Coordinator to document the closure. ODOT’s UIC Permit allows ODOT self-approval for UIC closures and a Pre-Closure Notification Form submittal to DEQ is not required. For UICs that are high risk (i.e. signs of improper practices, samples show contamination, etc.), ODOT must communicate this information to DEQ immediately by email at UIC@deq.oregon.gov with a copy to the Senior Stormwater Hydraulic Engineer and the Clean Water Coordinator.

Step 2 involves coordinating with ODOT region hazardous material geologist and collecting samples. DEQ requires sampling of sediment in UICs where field screening of sediment inside the UIC indicates the presence of contamination or of a spill, or if the sediment inside the UIC is going to be transported it must be sampled to determine if it must be handled as hazardous waste or non-hazardous waste. Sampling is not required for stormwater UICs that drain runoff solely from roofs or private driveways. The material must be analyzed to determine if the sediment needs to be managed as a hazardous waste. Additional analyses may need to be conducted if evidence of a chemical spill is found during closure. Coordinate this task with the ODOT region hazardous material geologist.

The final step is closure of the UIC. Close the UIC in a manner that prevents vertical fluid movement. If you are closing a vertical UIC, remove the top four feet of the UIC structure and backfill with fill material. At a minimum, the upper four feet of the hole must be backfilled with impermeable material (a fill material of 300 pounds per square inch controlled density fill meets or exceeds Oregon Water Resource Department abandonment requirements) that mushrooms out over the top of the UIC. Horizontal UICs can be closed by installing a permanent plug comprised of controlled density fill. Closure must be overseen by a licensed geologist or engineer, which is necessary to ensure that decommissioning meets the standards of OAR 340-044-0040.

For additional information on UIC closure, refer to DEQ’s UIC Frequently Asked Questions webpage.

Documentation

The permit requires that all new, newly discovered, retrofitted and decommissioned UICs be documented and reported in the annual report to DEQ. To support the annual report requirement, the project team must fill out the UIC Registration Form and submit the form to the Senior Stormwater Hydraulic Engineer for entry into ODOT’s UIC inventory, unless the UIC is determined not to need registration. In addition to the registration form, each UIC requires a drainage facility identification (DFI) number assignment for tracking in ODOT’s asset management system. DFI numbers are assigned by contacting ODOT’s Senior Stormwater Hydraulic Engineer to obtain a unique “DFI”. The project hydraulic designer requests drainage facility IDs during the project’s PE phase as discussed in Chapter 17 of ODOT’s Hydraulic Design Manual. The DFI for a UIC refers to both the UIC BMP itself and the associated pretreatment BMP(s). The UIC Registration and DFI Request Forms are available on the ODOT hydraulics webpage in the Design Resources, Project Design Process Forms section.

Both the registration form and the DFI number are to be requested concurrently during a project’s preliminary engineering phase, and prior to completion of the Stormwater Design Report. A copy of the DEQ approval for installation or decommissioning of a UIC must be provided to the Senior Stormwater Hydraulic Engineer.

The information necessary for registration is detailed in the UIC Registration Form. Refer to the ODOT Hydraulics Design Manual, Chapter 17 for DFI registration requirements.

Operation and Maintenance (O&M) Manuals

The purpose of O&M manuals are to support maintenance, protect water quality and ensure compliance with permit commitments. An O&M Manual describes the type of facility and how it operates, outlines an inspection schedule, and summarizes maintenance actions. Guidance on preparing O&M Manuals is outlined in Hydraulics Design Manual, Chapter 4 and technical bulletin GE16-02(B).


Responsibilities

Region Manager
  • Sponsor region-specific retrofit plan, if needed.
Tech Center Manager
  • Acknowledge/endorse design deviation requests related to horizontal or vertical setback locations.
State Hydraulic Engineer
  • Develop a statewide retrofit program in conjunction with all impacted business lines.
  • Approve/deny design deviations.
  • Ensure the design, asset management, and setback permit requirements are met.
  • Approve/deny region specific retrofit plan.
  • Manage Agency Stormwater Retrofit Program funds.
Senior Stormwater Hydraulic Engineer
  • Provide general UIC registration information.
  • Provide technical support regarding UIC design and stormwater treatment facility questions.
  • Provide technical support regarding groundwater protection demonstrations.
  • Evaluate UIC registration submittals for design, asset management, and setback elements.
  • Review/concur/deny design deviations.
  • Assign DFI #’s.
  • Develop and administer agency’s UIC asset management system.
  • Administer Agency Stormwater Retrofit Program.
  • Provide information on new, newly discovered, retrofitted, and decommissioned UIC systems to the Maintenance and Operations Branch.
Clean Water Coordinator
  • Document all new, newly discovered, retrofitted and decommissioned UICs in the annual report to DEQ.
Region Hazardous Materials Technical Resource
  • Provide technical support and guidance regarding UIC spills, on-site cleanup, and UIC decommissioning (including material sampling support).
  • Provide technical support regarding groundwater protection demonstrations.
  • Inform senior stormwater hydraulic engineer of decommissioned UIC’s.
Region Hydraulic Engineering Technical Resource
  • Provide technical support regarding UIC design and stormwater treatment facility questions.
  • Provide technical support regarding groundwater protection demonstrations.
  • Review/concur/deny design deviations.
Project Team
  • Obtain site investigation information including but not limited to groundwater depth, subsurface characterization, infiltration rates, and geological hazards as required for groundwater protection evaluations, engineering design, and regulatory reporting.
  • Request DFI # for new or recently discovered UICs.
  • Complete registration form and submit the form to the Senior Stormwater Hydraulic Engineer.
  • Conduct a groundwater protectiveness demonstration, if required. Provide copy of DEQ approval to the senior stormwater hydraulic engineer.
  • Prepare design deviations.
  • Prepare a stormwater design report.
  • Coordinate with the region hazardous materials geologists for assistance when decommissioning a UIC.
  • Prepare UIC Operation and Maintenance Manual in consultation with the appropriate maintenance District.



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