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NOTICE - General Permit #6 Renewal
The NPDES General Permit for Well Construction and Well Service Discharges (also known as GP6) will expire on February 28, 2020. Iowa DNR proposes to initiate rulemaking to renew the permit for a third 5 year term. The proposed GP6 is nearly identical to the current general permit except for some clarifications.
The permit renewal process includes asking for comments from individual stakeholders, stakeholder groups, and other interested citizens. The department held a stakeholder meeting in May to accept comments about the renewal of the permit, note changes in the permit conditions, and discuss the renewal process.
Additional information can be obtained on the renewal process by contacting Wendy Hieb by phone at 515-725-8405, by email at email@example.com, or by US Postal Service to Wendy Hieb, Iowa Department of Natural Resources, 502 E. 9th Street, Des Moines, IA 50319.
You can view the proposed GP6 at the following web link:
www.iowadnr.gov/Portals/idnr/uploads/water/wells/GP6/Draft GP6 5-8-2018.pdf
General permits are developed and used by the DNR when the type and quality of wastewater generated by an activity is similar, regardless of where in the state the activity takes place. Well construction discharge wastewater meets this criteria. The discharge normally consists of water mixed with coarse and fine geologic materials like clay, silt, sand, and bedrock fragments, and some limited quantities of drilling fluid enhancement products.
General Permit 6 (GP6) is a statewide discharge permit that authorizes the discharge of water well related wastewater into Waters of the United States as long as the wastewater meets the general water quality standards. Discharges under GP6 are temporary and limited only for the time that water well related services are taking place.
If the well related wastewater will not reach a Water of the United States, you do not need to meet the requirements of GP6.
Meeting the general water quality standards is normally acheived by using one or more "best management practices" - also known as BMPs - to slow, retain, and filter the wastewater, and allow the fine material contained within the wastewater to settle-out before the water portion of the waste stream reaches a Water of the United States.
The following resources will provide additional information on the topics related to GP6.
Well contractors approached the State Legislature seeking a uniform and defined rule that authorized discharge of well construction wastewater from well construction sites.
In response to this request, The 82nd State General Assembly passed a statute which required the Department to write new rules and a provide issuance of a General Permit to authorize well construction and well services related wastewater discharge when that discharge reaches a Water of the United States. The Bill History can be found at the following web link:
The department worked with well industy professionals from our state to develop General Permit #6, as well as guidance documents to help inform contractors and engineers on how to meet the conditions of the new requirements.
Beginning on March 17, 2010, all well construction, well related service and GHEX loop borehole drilling related wastewater that reaches a Water of the United States is regulated by National Pollution Discharge Elimination System permit (NPDES) General Permit #6 (GP6).
Many well construction sites are located near ditches, waterways, or subsurface drainage inlets that may allow well construction related wastewater to reach a Water of the United States.
Well construction related wastewater normally consists of a mixture of water, diluted drilling fluids, and groundwater. It also contains small particles of natural minerals like sand, silt, colloids (clay), and bedrock. In some cases, it includes minor amounts of drilling fluid enhancing products to help stabilize the well's borehole.
When allowed to flow untreated, the wastewater may eventually reach a stream, river or a lake. This can result in turbidity that can affect aquatic life and accumulation of sediments that create undesirable changes to the stream or lake bed.
In addition, drilling fluid additives and other products used in drilling and servicing wells may contain substances that are acutely toxic to aquatic life. These products can chemically and physically alter the water body and cause additional problems like killing aquatic life and inhibiting the life processes for all species that depend on the water. Untreated discharges also impact the manner in which the water is used or enjoyed by adjoining property owners and citizens who have access to the water.
Well construction wastewater is the wastewater generated by any well drilling related activity in our state. These activities include new well construction, existing well rehabilitation and renovation, pump installation, test pumping, geothermal borehole drilling, water observation well installation, water well test hole and test well drilling, and potentially other types of drilling that access or utilize the groundwater for a specific purpose.
The wastewater generated during these activities can be made up of drilling fluids, groundwater or a combination of both, can be very turbid to nearly clear and can contain geologic materials and chemicals used to enhance drilling. If the well drilling related discharge leaves the construction site it becomes wastewater discharge.
Anytime the wastewater generated by well related construction and services discharges off the well construction site and reaches a Water of the United States, the wastewater falls under the requirements of GP6. GP6 requires the wastewater to comply with the treatment standards and discharge requirements stated in GP6. If the well construction or well services related wastewater does not reach Waters of the United States, the discharge is not subject to GP6.
The following well services are covered by GP6:
The following services are not covered under GP6:
To start, first determine if the well construction wastewater will leave the drill site and reach and reach a Water of the United States. If the answer is yes, then you are legally obligated to follow the requirements of GP6. If the answer is no - your water will not reach a Water of the United States - then you do not have to follow GP6.
For all discharges that require GP6, you are required to create a well water pollution prevention plan (also known as a WWPPP, pronounced "wip") for the site before any discharge that reaches Waters of the United States takes place. The WWPPP that you create will be the water treatment model you assemble and use to control and treat the wastewater that is generated during your well services.
The WWPPP shall take into account items that will influence how the wastewater is managed, such as:
During the times that you discharge, you must:
If you find that any of the BMPs are inadequate and that the discharge is in violation of Iowa's "general water quality" parameters, you must take corrective action immediately. This includes stopping the discharge until you can increase the BMPs and improve water treatment, and notifying the Iowa DNR.
All issues and comments about your discharge, WWPPP, co-permittees, or inspections, should be recorded on your inspection form. You are also required to update your WWPPP to reflect the additional BMPs. After addressing the water quality issue(s), you can resume the discharge, monitor the BMPs and discharge water quality, and follow-up with additional inspections.
For more details on the requirements, please review our guidance document titled "A brief Guide to Developing a Well Water Pollution Prevention Plan and Using Best Management Practices"
Not all Waters of the United States can be used as a discharge point by following the conditions of GP6. Iowa has a class of waters called "Outstanding Iowa Waters" or "OIWs" that require the discharger to apply for and obtain an individual National Pollutant Discharge Elimination System (NPDES) Discharge Permit through Iowa DNR before any discharge can take place.
Outstanding Iowa Waters are streams/stream segments or lakes, that have been designated as high quality waters that constitute an outstanding resource to our state and its citizens. These waters are such an exceptional recreational or ecological significance, that the water quality of these features shall be strictly maintained and protected.
Iowa DNR has a map of Iowa's Outstanding Iowa Waters that will help you see what areas of the state may have more stringent permitting and discharge requirements.
For more information on Outstanding Iowa Waters, please visit the follwing web page: http://www.iowadnr.gov/Environmental-Protection/Water-Quality/Water-Quality-Standards/Antidegradation.
If your discharge will reach an OIW, or you have questions about applying for an Individual NPDES Discharge Permit, please contact Wendy Hieb for more information. Wendy can be reached by phone at 515-725-8405, or by email at firstname.lastname@example.org.
You should contact your local IDNR Field Services office if you suspect a body of water is being impacted by well construction or well service related discharges. The map below will help you determine which field office is located in the area of your concern. The phone number for each field office is available below the map.
Field Office 1 - NE
909 W. Main Street, #4
Manchester, Iowa 52057
Field Office 2 - NC Iowa
2300 15th St. SW
Mason City, Iowa 50401
Field Office 3 - NW Iowa
1900 N. Grand Ave., Ste. E17
Spencer, Iowa 51301
Field Office 4 - SW Iowa
1401 Sunnyside Ln.
Atlantic, Iowa 50022
Field Office 5 - SC Iowa
7900 Hickman Rd., Ste. 200
Windsor Heights, Iowa 50324
Field Office 6 - SE Iowa
1023 W. Madison
Washington, Iowa 52353
For more information about GP6 and how you can comply, please contact:
Russ Tell - phone: 515-725-0462, email@example.com
Iowa DNR Water Supply Engineering, 502 E 9th Street, Des Moines, IA 50319
Wendy Hieb - phone: 515-725-8405, firstname.lastname@example.org
Iowa DNR NPDES Wastewater Permits, 502 E 9th Street, Des Moines, IA 50319, or by Fax: 515-725-8202