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Re: Class 1 UIC vs Class IV UIC



You're right -- a Class I well by definition can't be discharging into drinking water.  If a Class I well fails in certain ways, there can be discharge into drinking water, but this is rare and I don't see how it could be the case with 13 wells in Florida.  Class IV wells inject *hazardous* waste into or above sources of drinking water and are illegal.  I wonder if the 13 wells in Florida are discharging nonhazardous waste into a drinking water source.  (In this case, they would be Class V wells???)  Note that the definition of hazardous and nonhazardous waste for classifying wells is the RCRA definition, and SDWA might restrict discharges that aren't defined as hazardous by RCRA.  COD and BOD come to mind.  Hope this helps.  

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Kirsten Sinclair Rosselot, P.E.
Process Profiles
P.O. Box 8264
Calabasas, CA 91372-8264

818/878-0454

rosselot@ix.netcom.com
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On 06/14/99 10:42:15 you wrote:
>
>Wednesday 
>June 9, 1999
>Dear P2 Tech, 
>I'm looking for clarification on this issue, can you help.
>The EPA's Office of Enforcement Compliance and Assurance (OECA) has informed 
>me the nations largest point source violation of the Safe Drinking Water Act 
>(SDWA) is in Dade County, Florida where 13 Class 1 underground injection 
>control (UIC) wells are daily discharging 208 million gallons of waste into 
>underground sources of drinking water (USDW). 
>(see: http://news.pollutiononline.com/industry-news/19990602-3717.htm)
>Doesn't the fact that Dade, County's Class 1 UIC wells are discharging into 
>USDW technically qualify them as Class IV UIC wells which are banned in the 
>United States? 
>(see: http://www.epa.gov/ogwdw/uic.html and 
>http://www.ficus.usf.edu/library/fcfguide/chap10/chap10-7.htm and 
>http://ww.law.cornell.edu/uscode/42/300h-3.html)
>Thank you for any assistance you can give me on this issue.
>Best Wishes, 
>Donald Sutherland 
>Member of the Society of Environmental Journalists 
>donaldsutherland-iso14000@worldnet.att.net
>
>
>