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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



------------------------------------------------------------------------- Enviro-Mich message from Larry Nooden <ldnum@umich.edu> -------------------------------------------------------------------------

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/


===================== ENVIRO-MICH: Internet List and Forum for Michigan Environmental and Conservation Issues and Michigan-based Citizen Action. Archives at http://www.great-lakes.net/lists/enviro-mich/

Postings to: enviro-mich@great-lakes.net For info, send email to
majordomo@great-lakes.net with a one-line message body of "info enviro-mich"
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ENVIRO-MICH:  Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen Action.   Archives at
http://www.great-lakes.net/lists/enviro-mich/

Postings to:  enviro-mich@great-lakes.net      For info, send email to
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