Local agencies often require this type of well. Statewide bans of these wells is not good. It eliminates flexibility and is a competition issue. The best solution is to connect these facilities to municipal sewers, but there is no need to close a well down if there is no impact. General permitting is a good idea because there are thousands of small facilities and the permitting must be simple.
Clear guidance is needed on closure requirements and what is clean and alternatives.
An EPA web site is needed with the pertinent information for compliance with the new rule. Steve Card, Albemarle, Inc., gave a presentation on a unique type of Class V well. Brine is pumped to the surface from a deepwell and the bromine then removed. The spent brine is then returned to the same formation. The return well is designed very similar to a Class I injection well.