First, determine if the well construction wastewater will leave the well construction site 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 need to follow GP6 (but you still need to manage your discharge responsibly).
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 to 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:
- The location of the well on the landscape;
- the potential protections or limitations that the landscape may provide for natural wastewater treatment;
- the potential quantities and anticipated qualities of wastewater that may be generated during each phase of the well construction or service work;
- the types, quantities, and locations of best management practices (BMPs) used both on and off of the construction site to hold, filter and treat, and meter the wastewater before it enters Waters of the United States;
- any adjustments or changes made to the BMPs after the initial installation;
- who inspects the BMPs, how often the inspections are performed, and what is found during the inspections;
- determine if you have co-permittees that need to be part of your WWPPP and have them sign-on with your WWPPP as a co-permittee;
- provide a Field Office Notification Form (also known as FON, pronounced "fawn") to the local DNR Field Services Office up to 5 days before the planned discharge, but no later than 24 hours after the discharge starts.
During the times that you discharge, you must:
- inspect your BMPs at least once every six hours to make sure they are adequate for the discharge you generate,
- inspect the receiving body of water and determine if your BMPs are adequate, if not, add additional BMPs to further refine the wastewater treatment, and
- document your inspection on an inspection form as proof that you are monitoring the discharge and that you are taking the necessary steps to meet the conditions of GP6.
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 notify 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"