The Coordination Between State/Local Programs Necessary for a SuccessfulEnforcement Action Involving a Class V UIC Well

摘要

Successfully resolving a Class V Underground Injection Control (UIC) enforcement action often requires effectiverncoordination with numerous state and local government programs. When addressing Class V injection well regulatoryrnrequirements, especially when implementing enforcement against an owner/operator, many complications and crossprogrammaticrnissues can arise. This includes program priorities and requirements established in and for the CleanrnWater Act, Safe Drinking Water Act, Resource Conservation and Recovery Act, U.S. EPA annual work plans, and anyrnstate initiative or strategic plan.rnAs an example, the closure or modification of a Class V UIC well usually involves the installation of a new wasternwater treatment system. In Ohio, permits for the installation and operation of such systems require a permit to installrnissued under the Ohio Clean Water Act and interaction with the program or agency that issues those permits. Therntimely resolution of an enforcement action against the owner/operator of a Class V injection well could involve therncooperation of a local licensing or certification bureau concerning the license of a business or the certification forrnoccupancy of a residence. Class V injection wells used as part of a waste water treatment process at a mobile homernpark could not just be closed as people reside at the facility and condemnation and eviction procedures includingrnrevocation of the occupancy license must be carried out prior to closure of the Class V injection well.rnAll the above complications to a Class V UIC enforcement case necessitate the coordination between UIC staff andrnother state and local officials. The various relevant issues concerning the enforcement process at the facility must bernidentified during the initial stages of enforcement and the various state and local programs that need to be involvedrnmust be contacted and barriers to successful coordination identified and resolved. The permits/licenses that need tornbe issued/revoked and the requirements for acting on the permits/licenses must be identified and the appropriaternentities made aware of their obligations in the process. Funding issues also must be identified and any coordinationrnnecessary involving the clean water act state revolving fund must be explored. Benefits of cross-programmaticrncoordination to the UIC program include quicker resolution of the violations and less commitment of UIC programrnfunds to each enforcement action.