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Re: E-M:/ Wish to unsubscribe - deep-well injection
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Enviro-Mich message from "Jack Lanigan" <jacklanigan@comcast.net>
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Best wishes in your retirement, Harlan. How refreshing to read the remarks
of a scientist with the opportunity to review countless applications,
geological studies, compliance reports, evaluations, and recommendations on
this subject and to come to a sound supportable conclusion -- free of
emotion.
Deep well injection of selected wastes in a viable, effective, and permanent
solution -- protective of the environment. I cannot agree that the solution
is short-sighted in any way. Properly designed, implemented, and monitored,
there are few superior methods for managing selected low-level toxic wastes.
I use the word "toxic" somewhat loosely, as there are many wastes that are
not necessarily toxic in small quantities or doses, but still require
appropriate management.
It is easy to discourage production of toxic wastes, but discouragement does
not offer a solution. I agree, and generators will agree, that production
of hazardous or toxic waste streams creates management and disposal
responsibilities that are time consuming and expensive. At the end of the
day, if manufacturers did not bear the cost to manage those wastes, the
price to produce commodities that we all want and need would be much
reduced. However, they do produce those wastes, and they pay to dispose of
them.
Even if production of toxic wastes were curtailed, legacy wastes produced
from long-gone manufacturing processes are being produced? These wastes are
being addressed and cleaned today under CERCLA, RCRA, TSCA, and other
regulatory programs that did not exist 50 or 100 years ago. It is hardly
likely that regulators will discourage production of these waste streams;
yet, they need to be addressed and cleaned up. Disposals wells are not a
answer to all these problems, but they can help solve a few of them.
What about better disposal methods and destruction of organic toxins? I
agree, and I continue searching for better methods. What about lead,
cadmium, beryllium wastes -- wastes that are not conducive to organic
destruction? More landfills? A Yucca Mountain-style site? What are better
methods? Wastewater discharge regulations for mercury in the Great Lakes
region is 0.0000013 milligrams per liter (1.3 parts per trillion!). That
concentration could not be measured until recently (and some analytical
chemists will argue that it still cannot be measured reliably). Deep well
disposal of this type of waste certainly falls in the realm of common sense.
If you pump it into the ground, it is sure to float to the surface, pollute
our surface waters, and taint our crops. Hardly. Natural geologic
formations have trapped oil and gas reservoirs underground for millions of
years. Natural brines occur under the entire state of Michigan, and they
have been exploited just as the petroleum deposits. Brines are a source of
many dissolved minerals, and some brines are more "toxic" than the waste
streams considered for injection. The brines are not migrating to the
surface. Why would toxic waste float selectively and natural gas remain
contained?
We are regulating viable waste management options away needlessly. We need
solutions for managing waste streams that are not "hazardous" but are a
concern. (Storm water runoff from CAFO comes to mind.) Treating waste
streams does not necessarily destroy the waste in all cases; it can yields
residuals that still need management. Landfills are not the final answer
either. Selective implementation of a disposal well option is a viable,
effective, and permanent solution to waste management that is protective of
the environment. It is not a one-size-fits-all option, but it is an option
that must remain available.
I will miss a regulator like Mr. Gerrish to help navigate these difficult
options.
Jack
----- Original Message -----
From: "Larry Nooden" <ldnum@umich.edu>
To: <enviro-mich@great-lakes.net>
Sent: Tuesday, March 25, 2008 11:39 AM
Subject: Re: E-M:/ Wish to unsubscribe - deep-well injection
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Enviro-Mich message from Larry Nooden <ldnum@umich.edu>
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I have always been bothered by the short-sightedness of deep-well injection
of toxic wastes. Eventually, this stuff will come back to haunt us, and
that seems likely not to be detected until traceable problems arise.
It seems better to discourage production of the toxic wastes and to
encourage better disposal methods, e.g, destruction for organic toxins.
--On Tuesday, March 25, 2008 7:20 AM -0500 Gerrish.Harlan@epamail.epa.gov
wrote:
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Enviro-Mich message from Gerrish.Harlan@epamail.epa.gov
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I am retiring at the end of the month and this email address will be no
more. You might want to delete it from your distribution list.
BTW, you people should seriously re-evaluate some of your notions. Deep
well injection is a very viable and long-term sustainable means to
dispose of many industrial wastes. Nothing has gone wrong at the EDS
facility in Romulus that routine maintenance in the surface facility
would not have prevented. It is true that the previous management was
untrustworthy.
Harlan Gerrish
Geologist
Underground Injection Control Branch
EPA Region 5, Chicago, Illinois 60604
(312) 886-2939, (312) 886-4235 (fax)
gerrish.harlan@epa.gov
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Larry D. Noodén, Professor Emeritus Ph. 734-764-4436
1270 Natural Sci. Bldg. FAX 734-647-0884
Biology Dept. 734-763-0544
University of Michigan
Ann Arbor, MI 48109-1048 http://www.biology.lsa.umich.edu/~ldnum/
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ENVIRO-MICH: Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen Action. Archives at
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Postings to: enviro-mich@great-lakes.net For info, send email to
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