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Re: E-M:/ Jack Lanigan + Deep Well Injection



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Enviro-Mich message from "Alexander J. Sagady" <ajs@sagady.com>
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This may surprise some of my colleagues in the environmental 
movement, but I have to agree in large measure with Jack Lanigan 
that a properly designed and operated deep well is an appropriate method of waste disposal 
for certain kinds of wastewater.

Siting of wellhead operations and the installation and design of
the wells themselves are important technical issues requiring attention to 
detail.   

Let's give as example.....petroleum refineries receive crude oil in 
pipelines, but the incoming crude can sometimes contain up to 5% by 
volume of brine.   Well, what do you do with the brine?   At the 
BP refinery in Whiting IN, they mix it with cooling water and dump it 
in Lake Michigan.   To the best of my knowledge, Marathon Petroleum 
dumps their brine wastes into Detroit WW treatment plant sewers and it is
then discharged to the Detroit River with no treatment for the 
dissolved solids in the brine (except for oil/grease removal).   Would it 
be better to put that brine down a properly sited, installed, designed and 
operated deep well?   I think I would answer yes.

I am also a strong supporter of the land ban provisions of the Resource 
Conservation and Recovery Act and, from a policy standpoint, I would
oppose the use of deepwells to dispose of untreated hydrocarbon-bearing
wastewater under various waivers of RCRA land-ban requirements.

Do we always know enough to make decisions about the underground to 
properly site a deep well.  Probably not....and on that ground I would 
question siting of  deepwells directly adjacent to large bodies of water 
like the Great Lakes connecting waterways.  

Deepwell disposal of brine is already common in the oil and gas industry, and
is a better environmental practice than any other management of brine 
wastewaters (i.e. spraying on gravel roads).

Will there be future conflicts on the use of the underground that might 
mitigate against deep well disposal?   I think the answer on that might be 
yes if carbon dioxide sequestration ever gets going in a serious way.


At 05:51 AM 03/26/2008, Christopher Bedford wrote:
>Jack and the list,
>
>This email from Jack Lanigan represents the kind of thinking that has created many of the problems we face in Michigan today.
>Aside from the technical questions of deep well injection that center around "we really don't know where the waste goes" and "if we make a mistake it can't be fixed"
>is the question of sustainability.
>
>In Nature, the concept of waste does not exist. Everything that might be categorized as waste in Nature is actually food for another organism in natural systems.
>We must design our economy to work the same way. 
>Recycling as an after thought at the end of a product's life is not enough.
>We need to design processes and products around the concept of total recycling.
>Ultimately, these closed loop systems will guarantee Michigan's economic future. For they are the future of manufacturing in an increasingly stressed natural world.
>It's just a question of intention and design.
>
>So Jack's line, "Properly designed, implemented, and monitored, there are few superior methods for managing selected low-level toxic wastes." is such old thinking as to be dangerous. We should be striving to eliminate waste altogether.
>
>My thoughts over first coffee.
>
>Chris Bedford
>Chris Bedford
>Center for Economic Security
>#6543 Hancock Road
>Montague, MI 49437
>231-893-3937
>231-670-4817 (cell)
><mailto:chrisbedford@charter.net>chrisbedford@charter.net
>www.center4economicsecurity.org
>www.chrisbedfordfilms.com
>
>The Center for Economic Security produces programs, media, and campaigns to build ecological understanding among consumers and to promote ecological intelligence in private and public decisionmaking. 
>
>"Let us teach ourselves and others that politics can be not only the art of the possible but also the art of the impossible, namely, the art of improving ourselves and the world." -- Vaclav Havel
>
>
>
>On Mar 25, 2008, at 9:29 PM, Jack Lanigan wrote:
>
>>-------------------------------------------------------------------------
>>Enviro-Mich message from "Jack Lanigan" <<mailto:jacklanigan@comcast.net>jacklanigan@comcast.net>
>>-------------------------------------------------------------------------
>>
>>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" <<mailto:ldnum@umich.edu>ldnum@umich.edu>
>>To: <<mailto:enviro-mich@great-lakes.net>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 <<mailto:ldnum@umich.edu>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 <mailto:Gerrish.Harlan@epamail.epa.gov>Gerrish.Harlan@epamail.epa.gov
>>wrote:
>>
>>>-------------------------------------------------------------------------
>>>Enviro-Mich message from <mailto:Gerrish.Harlan@epamail.epa.gov>Gerrish.Harlan@epamail.epa.gov
>>>-------------------------------------------------------------------------
>>>
>>>
>>>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)
>>><mailto:gerrish.harlan@epa.gov>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/>http://www.biology.lsa.umich.edu/~ldnum/
>>
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