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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
Sent: Tuesday, March 25, 2008 11:39 AM
Subject: Re: E-M:/ Wish to unsubscribe - deep-well
injection
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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.
wrote:
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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)
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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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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
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ENVIRO-MICH:
Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen
Action. Archives at
======================
==============================================================
ENVIRO-MICH:
Internet List and Forum for Michigan Environmental
and Conservation Issues and Michigan-based Citizen
Action. Archives at
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