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Re: UIC/Safe Drinking Water Act/TRI



Donald Sutherland wrote about underground injection with some apparent
complaints and at least one misconception.

I taught courses about hazardous waste management for more than ten years.
I have investigated a variety of waste management methods, and have a
significant success rate in pollution prevention and waste minimization with
my clients.

At one time, I was extremely opposed to underground injection as a means of
managing wastes.  I am less so at present under certain limitations.

The misconception in Sutherland's missive is that the point source threat to
unmonitored drinking water wells is always underground injection.  That is
not true.  More likely are leaks from surface and shallow waste disposal
migrating to drinking water, as are leaks from USTs.  Also a threat are
pesticides and fertilizers.

Most recent generation UI wells are deep wells, well below aquifers that
supply drinking water.  They are in the same types of formations that have
trapped oil and natural gas.  They are less likely to leak from the
formation to drinking water than are surface impoundments, waste cells, USTs
and other contaminant sources, which are all point sources!  The principal
risk to drinking water from UI wells is a failure of the casing or the
mishandling of waste at the surface, rather than a failure of the formation
to contain the waste.

UI should only be the method of choice for disposal of dilute wastewaters,
typically those with low levels of organic contamination that is not
amenable to standard waste water treatment technology.  A goal should be to
develop treatment technology which enables the treatment of such waters to a
level that allows reuse or surface discharge, making UI unnecessary.

A big problem:  almost every UI operator that applies for a waiver from the
land disposal restrictions gets one.  It appears that it is very unlikely
that a permittable UI well cannot get a LDR waiver.  This works against the
development of treatment alternatives, since UI disposal is so inexpensive.

Ralph E. Cooper, Ph.D.
J.D. Class of 1999
Case Western Reserve University
School of Law

-----Original Message-----
From: Donald Sutherland <DONALDSUTHERLAND-ISO14000@worldnet.att.net>
To: p2tech@great-lakes.net <p2tech@great-lakes.net>
Date: Monday, June 29, 1998 10:26 AM
Subject: UIC/Safe Drinking Water Act/TRI


>Friday
>June 26, 1998
>
>Dear P2ers,
>I've just started my research into underground injection control permit
>(UIC) research and potential pollution of aquifers serving as a sole source
>of drinking water for communities and here are some of my findings:
>
>1. There is no national data base for sole source aquifers (SSA) and or
>aquifers which serve as the only source of drinking water for a community.
>
>2. There is no national data base for underground injection well permits
>(Class 1 and Class 5) for hazardous waste as identified under the national
>Toxic Release Inventory program.
>
>3.There is no national data base for expired UIC permits.
>
>4.Despite the 1996 admendments to the Safe Drinking Water Act (SDWA)
>directing the USEPA to support the protection of all public drinking water
>sources under the Source Water Assessment & Protection (SWAP) program and
>the Wellhead Protection (WHP) program very few states have an enforced
these
>measures.
>
>5.Officials at the federal Agency for Toxic Substances and Disease Registry
>(ATSDR) state all unmonitored ground water is at risk of contamination from
>toxins coming from point source waste sites (ie.UIC permits).
>
>For a review of toxic waste discharge in the US see:
>
>http://www.epa.gov/oeca/sfi
>
>http://www.edf.org/links/scorecard/traffic.html
>
>What data has your organization gathered on the topic of UIC and drinking
>ground water and are my finding correct?
>
>Best Wishes,
>Donald Sutherland
>Consultant on Environmental Management Systems
>donaldsutherland-iso14000@worldnet.att.net
>
>