Bureau of Water Pollution Control
Underground Injection Control Permit for Renewable Energy Resources

If a facility proposes to construct, alter, repair or abandon any injection well, or owning, using or operating, or proposing to use or operate any injection well on any lands within this State, an Underground Injection Control (UIC) permit is required for a renewable energy resource facility. This does not include injection wells within the limits of any Indian reservation or dependent Indian colony under the jurisdiction of the Federal Government.

The Safe Drinking Water Act of 1977 authorized the U.S. Environmental Protection Agency (US EPA) to establish regulations for underground injection control (UIC). State of Nevada UIC regulations were adopted and became effective in July of 1987.

The Nevada Division of Environmental Protection (NDEP) , within the Department of Conservation and Natural Resources, was designated as the lead agency in administering the State UIC program, and has authority under NRS 445A to regulate all classes of injection wells. Primacy for the federal UIC program was granted to Nevada in October, 1988. Nevada is part of USEPA's Region 9, with headquarters in San Francisco.

Nevada has divided injection wells into five classes pursuant to federal regulations. Under those classifications, Class V wells may apply to renewable energy resource projects.

Specifically, a UIC permit for Class V wells would apply to any injection well not included in Classes I, II, III and IV, and is a geothermal injection wells used in contact and noncontact heating and aquaculture, and in the production of energy. For more program information see the following links.

Streamlining the Process

The most important step an applicant can do to streamline the application process is to arrange a pre-application meeting with Bureau of Water Pollution Control staff to discuss the project and obtain the necessary information for a complete and comprehensive UIC application. Other possible permits can be discussed at this time.

It should be noted an UIC permit for geothermal project usually covers injection wells and surface basin discharges, eliminating the need for a second permit – a ground water discharge permit. This further streamlines the process and cost to the applicant. This is important for the applicant to understand as the application will need to cover injection into wells and discharges to surface basins.

In late 2007, the Nevada Division of Environmental Protection worked with the Nevada Division of Minerals in taking steps to streamline the process of obtaining an UIC construction permit required under UIC regulations. As of March 2008, the drilling permit obtained from NDOM shall satisfy the UIC requirement. An applicant should be aware of UIC injection well requirements via the link below.

The timeline graphic below represents the regulatory time frame, but with a complete and comprehensive application detailing a well designed facility, and provided there are no unforeseen delays, the time to obtain an UIC permit can be reduced to approximately 120 days. This time frame is highly subjective and could be longer depending on response time of and the information provided by the applicant.

Where to apply for a Class V Injection Permit

To obtain an UIC permit, complete permit applications, UIC Form U200: UIC Permit Application [6 Page PDF] and UIC Form U202: Class 5 Geothermal Well Attachments [6 Page PDF], and submit to the NDEP, Bureau of Water Pollution Control, UIC program in Carson City for approval. Link to UIC geothermal permit requirements: Applicant should be aware final injection authorization for each well comes after the following events occur:

  1. UIC permit has been issued
  2. Injection well completion report received and reviewed by NDEP
  3. UIC program issues authorization for each injection well

Applications for discharge permits should be submitted at least 180 days prior to needing final authorization. Once the appropriate fees,[2 Page PDF] UIC Form U200: UIC Permit Application [6 Page PDF], UIC Form U202: Class 5 Geothermal Well Attachments [6 Page PDF], as well as, associated technical information are submitted, a completeness review of the application will be concluded within 30 days and a technical review project concluded with 60 days. All information will be evaluated to determine compliance with applicable statutes and regulations.

Upon completion of the evaluation, and following submission of any necessary supplemental information to NDEP, a notice of intent to issue or deny the permit will be drafted for noticing in the local paper and on the NDEP public notice web page to solicit comments from the public.

The public review and comment period for all injection permits is 30 days. A public hearing may be requested. Within 30 days after the end of the public notice and comment period a UIC permit will be issued or denied. Again, note final injection approval comes with the issuance of the final permit and review and approval of each injection well.

Notes

  • Submission of a complete UIC application, for Geothermal Power Production, consists of a completed Form U200 and the completion of UIC Form U202. Additional information may be required by the Director to ensure the proposed operation will not degrade an underground source of drinking water.
  • Since an UIC Permit may be issued before significant geological and hydrological data is obtained through drilling of production and injection wells, an issued UIC permit may need to be modified based on receipt of new information.
  • An UIC permit can cover injection wells and surface basin discharges in one permit, eliminating the need for two BWPC permits.

UIC Form U200: UIC Permit Application [6 Page PDF]

UIC Form U202: Class 5 Geothermal Well Attachments [6 Page PDF]

It is recommended that an applicant arrange a pre-application meeting with the following entities:

Applicants would use such meeting to present the project and obtain the necessary information for a complete and comprehensive application. At a minimum, the applicant should meet with UIC program to discuss details of application.

Governing Regulations & Statutes

The UIC Program regulates injection wells under the authority of the Nevada Revised Statutes (NRS) 445A.300 - 445A.730 and the Nevada Administrative Code (NAC) 445A.810 - 445A.925, inclusive.

NRS 445A.300 - 445A.730 provides the legislative authority to develop and implement a regulatory program for the UIC program. The State Environmental Commission has the authority to adopt regulations pursuant to these statutes.

NAC 445A.810 - 445A.925 defines regulatory standards for the UIC program and Water Pollution Control. Regulations are enforced and implemented by NDEP and the Bureau of Water Pollution Control.

For additional information concerning UIC permits contact Supervisor Groundwater Protection.

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