Geothermal well/heat pump systems are becoming a popular choice for facility heating and cooling.  The Massachusetts Department of Environmental Protection (DEP) has recently ruled that geothermal wells are considered “Class V injection wells”.  As such, geothermal wells are subject to registration and/or permitting in accordance with their Underground Injection Control and Groundwater Discharge Permit Program regulations (310 CMR 27.00 and 314 CMR 5.00, respectively).  These permit requirements are summarized below:

• UIC Registration: If the aggregate discharge from the well(s) is less than 15,000 gallon per day (gpd), then the geothermal well(s) are subject to registration under DEP’s Underground Injection Control (UIC) program.  Registration requires completing a DEP UIC registration form and payment of a fee ($100-500).
• Groundwater Discharge Permit: If the return flow to the ground from the well(s) is in excess of 15,000 gpd, then a Groundwater Discharge Permit must be obtained from DEP (geothermal well discharge has been determined by DEP to fall into their “Other” category).  Obtaining this permit requires groundwater sampling data, well operational information, publishing of a public notice, completing DEP’s permit application, and a permit fee ($2300 transmittal fee, $175 annual operations fee).  In addition, permit maintenance requires on-going sampling and reporting requirements.

In addition, many designs for geothermal well result in the generation of bleed water.  If reuse of this water on site is not feasible, then on-going, intermittent discharge of this water will require permitting through the local sewer authority (i.e., Massachusetts Water Resources Authority) or EPA’s National Pollutant Discharge Elimination System (NPDES).

If geothermal well(s) are being installed as part of a construction project, then the Architect will be working with a geothermal well engineer to design the appropriate system for the heating/cooling needs of a project.  In addition, an environmental compliance professional should be retained by the University to consider the critical environmental permitting issues with regard to geothermal well installation and use. 

In order to ensure that Geothermal Well Permitting consultants working at the University understand Harvard-specific issues around permitting, the EH&S Department has compiled the attached list of Geothermal Well Permitting Consultants [PDF] who have done satisfactory work for the University.

The Geothermal Well Permitting consultant will complete all regulatory sampling and coordinate with the Project Manager, Architect and geothermal well designer to complete and submit all permit/registration applications on behalf of the Owner.  In addition, the Geothermal Well Permitting consultant will prepare a specification that details the permitting, monitoring, and treatment/discharge requirements for incorporation into the Architect’s design documents.