An Interpretation of the Safe Drinking Water Act's “Non-Endangerment” Standard for the Underground Injection Control (UIC) Program

Abstract

This chapter describes the methodology for varying approaches and considerations for the non-endangerment standard of the Safe Drinking Water Act (SDWA) for the underground injection control (UIC) program. To determine the most appropriate course of action for preventing endangerment of underground sources of drinking water (USDWs) from the threats posed by all injection practices, the Environmental Protection Agency (EPA) evaluated key considerations within the framework of the SDWA. Besides being inconsistent with the SDWA, the practices are exceedingly difficult to assure compliance, and there is a high degree of uncertainty over whether public health protection is being achieved. It is believed that injection well approaches to preventing endangerment of USDWs generally fall within five different categories. All of these approaches take into account specific factors and considerations in how the appropriate course of action is taken by the UIC program. Some of these approaches have a low assurance of preventing endangerment of USDWs and the public health.