Are urine drainfields typically considered Underground Injection Control (UIC) wells, and what key compliance considerations or requirements should practitioners be aware of?

We received this question during a recent webinar and thought it would be helpful to discuss here.

Urine drainfields are not considered UICs from my discussions with the EPA. Urine drainfields are long (10-20’) shallow (12-18") and narrow (12-18"). UICs are deeper than they are wide. Urine drainfields are really just simple septic drainfields. Roughly 26M households in the USA manage their urine, feces, and domestic waste water with similar drainfields. The EPA has shut down pit toilets throughout the USA due to their non compliance with the Clean Water Act. The EPA has also approved Toilet Tech systems which have open bottom DCVs which store and process dry solid waste and urine drainfields. These Toilet Tech systems have been approved in the following places where pit toilets were shut down by the EPA: Two Sentinals Camp, CA and USDA Forest Service, Arcadia. A letter from the EPA was sent to Two Sentinals camp and it is attached.

Moreover, there are Federal Guidelines for management of human waste called RM83A (Directors Orders) which specifically identifies use of urine diversion when toilets are considered in remote National Park wilderness and provides design and management recommendations. LINK.