6.2. ERMUSR 05-11-2004 - Laserfiche WebLink

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MARCH 17,2004 3. Permitting Support CH2M HILL and HRG met with the Minnesota regulatory agencies to begin establishing the permitting requirements for ASR in Minnesota. On December 9, 2003, the MDH sent a letter to HRG summarizing the possible regulatory requirements for using Well No. 8 as an ASR well. Several agencies will be involved: Minnesota Department of Health is responsible for regulating source water protection, recovered water quality, and a variance from their Well Management Section may be needed for both the pilot test, and operational use. Department of Natural Resources is responsible for water appropriations permits. A modification will be required to amend the current ERMU permit to allow for use of the ASR well. Pollution Control Agency will require a variance to allow for injection of the potable water. US EPA, Region V is responsible for the Underground Injection Control (UIC) program, which regulates all types of injection wells. There is still considerable uncertainty on the degree of regulatory interaction and negotiation that may be involved to acquire the first ASR testing or operational permit in the State of Minnesota. Thus, the scope of this task is limited to 24 hours of engineering time to communicate and correspond with the various agencies to secure their approval to conduct limited ASR testing on Well No. 8. The above limitation includes one meeting with the agencies to discuss the proposed testing plan. The scope does not include developing a 3- dimensional groundwater model of the ASR test site, which may be required by MDH for Source Water Protection purposes. Future Phases Implementation of the approved testing plan is necessary to confirm the technical feasibility of ASR for Elk River Municipal Utilities. Pilot testing will likely involve 3 cycles of recharge and recovery over a 9 to 12 month period. The exact duration, laboratory requirements, and level of effort on the part of CH2M HILL, HRG, or ERMU staff cannot be determined until after the testing plan is accepted by the regulatory agencies. However, the typical cost of Phase I(A and B) pilot testing is typically between $100,000 and $250,000. The cost of Phase II testing is dependent on whether additional construction work is needed to allow for recharge operations, the number of testing cycles, laboratory analyses, and reporting requirements. Upon completion of a successful pilot testing program (Phase IA and B, and Phase II), ERMU 'ill have one full-scale operational ASR well permitted for subsequent operational use. Page 3 of 3