US EPA's UIC & SDWA 25th Anniversary

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To: p2tech@great-lakes.net
From: "Donald Sutherland"
<donaldsutherland-iso14000@worldnet.att.net>
Subject: US  EPA's UIC & SDWA 25th Anniversary 


6/30/99

Here's my big picture report on the EPA's hazardous waste injection
wells
and the US Safe Drinking Water Act for your review.

I look forward to your commentary.

Cheers,
Donald Sutherland
Member of the Society of Environmental Journalists
donaldsutherland-iso14000@worldnet.att.net
phone: 508-497-3676

Hazardous Underground Injection Wells Stirs Controversy in Industry
By Donald Sutherland

On the 25th anniversary of the Environmental Protection Agency's
(EPA)
hazardous waste underground injection control (UIC) program and the
Safe
Drinking Water Act industry tensions are mounting on whether the 
two
programs can coincide with each other.

According to the not-for-profit Groundwater Protection Council,
sixty
percent of all liquid hazardous waste that are land disposed in the
United
States are injected underground via deep Class 1 UIC injection wells,
and
most of the companies using hazardous waste injection wells are Fortune
500
companies. DuPont alone injects over 1.5 billion gallons of hazardous
waste
per year.
( http://site.net )

These injection wells are primarily located in EPA Region 4, 5, & 6
with the
majority located in Texas, Florida, and Louisiana.

"The Safe Drinking Water Act (SDWA) amendments in 1986 and 1996
have
generated stricter Right-to-Know Provisions driving stricter
reporting
requirements, and we have a concern for all potential pollution of
source
drinking water supplies," says John H. Sullivan, Deputy Executive
Director
of the American Water Works Association (AWWA) the world's largest
organization of water supply professionals representing 56,000
members,
4,000 utilities, and 200,000 public water systems serving 85% of 
the
populations of Canada and the US.
(http://www.awwa.org
)

"The EPA's UIC program needs alot of looking into, and SDWA
violations from
Class 1 UIC wells contaminating underground sources of drinking water
(USDW)
in Dade County, Florida are not uncommon conditions," says
Sullivan.
(see:
http://www.ficus.usf.edu/exhibit/injection.html

"There is some really toxic stuff going done these Class 1 UIC
wells," he
says.

The Chemical Manufactures Association (CMA) believes the current EPA
Class 1
UIC program is not a threat to underground sources of drinking
water.
( http://www.cma.org
)

"We have 18 companies which own and operate 80 Class 1 UIC wells,
and for
these companies it is their sole source of disposal for hazardous
waste,"
says David Mentall, manager of Environmental Issues and UIC staff
executive
for CMA.

The firms include B.P.Amaco, Monsanto, Solutia, Cytec, and DuPont -which
has
the largest number of Class 1 UIC wells according to Mentall.

"We have no significant concerns from a regulatory stand point, but
there
are a number of civil action suits still pending (one involving DuPont
in
Louisiana, and two other cases in Texas) which we are watching very
closely
because they could set an astronomical monetary effect precedent,"
he says.

Not all CMA members use Class 1 UIC wells.

"Back in the 1970's management did not believe Class 1 UIC wells
for
hazardous waste was right, and they developed a corporate policy
against
them," says Mike Rio, Global Director for Environment, Health &
Safety for
Operations at Dow Chemical.   
(http://www.dow.com
)

"Our last hazardous Class 1 UIC well was closed in the early
eighties, and
we are now reliant on incineration, recycling, and our waste
reduction
program (WRAP)," he says.

For more than eighteen years the not-for-profit Legal Environmental
Assistance Foundation (LEAF) has legally challenged Class 1 UIC wells in
the
United States advocating underground injection of waste doesn't lend
itself
to pollution prevention.

"The EPA's UIC program is too easy a remedy when you have a disposal
method
putting a hazardous waste problem out of sight and out of mind,"
says
Cynthia Valencic, Vice President for Programs at LEAF.

"We believe industry and municipalities should be looking for ways
to reduce
production incorporating close loop systems and recycling as an
alternative
for Class 1 UIC waste disposal," she says.

Regulatory officials and environmentalists admit the EPA's UIC program
is
weakly enforced and poorly monitored.

"In many cases there isn't much monitoring of UIC wells for
violations
except where a problem potential is expected (ie.Florida)," says
Bruce
Kobelski, UIC Team Leader for the EPA Office of Ground Water and
Drinking
Water.
(http://www.epa.gov/OGWDW/uic.html
)

"There are roughly 600 Class 1 hazardous waste wells in the US, but
we at
the EPA can't ban violating facilities because permits are in most cases
a
regional state function," says Kobelski.

Corporations are required to report to the public specific Class 1
injection
releases and inventory under federal Toxic Release Inventory (TRI)
regulations.
http://www.epa.gov/opptintr/tri/whatis.htm

"But, there is nothing in TRI which requires monitoring of the
wells," says
Paul Orum, coordinator of the not-for-profit Working Group on
Community
Right to Know.
http://www.rtk.net

"CMA would like to see status quo for UIC regulations, but when you
have a
Class 1 UIC well its very easy to dump everything down there and create
a
disincentive to pollution prevention," he says.

(c)Donald Sutherland 1999


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Content-Type: text/html;
 charset="windows-1257"
Content-Transfer-Encoding: quoted-printable

<!DOCTYPE HTML PUBLIC "-//W3C//DTD W3 HTML//EN">
 
 
6/30/99
 
Here's my = big picture=20 report on the EPA's hazardous
waste injection wells and the US Safe = Drinking=20 Water Act for your
review.
 
I look forward to your=20 commentary.
 
Cheers,
Donald=20 Sutherland
Member of the Society of = Environmental=20 Journalists
donaldsutherla= nd-iso14000@worldnet.att.net
phone: = 508-497-3676
 
Hazardous = Underground=20 Injection Wells Stirs
Controversy in Industry
By Donald=20 Sutherland
 
On the 25th = anniversary=20 of the Environmental
Protection Agency's (EPA) hazardous waste = underground=20 injection
control (UIC) program and the Safe Drinking Water Act industry = tensions
are mounting on whether the two programs can coincide with each =
other.
 
According to the = not-for-profit=20 Groundwater
Protection Council, sixty percent of all liquid hazardous = waste that=20
are land disposed in the United States are injected underground via deep
= Class 1=20 UIC injection wells, and most of the companies using
hazardous waste = injection=20 wells are Fortune 500 companies. DuPont=20
alone injects over 1.5 billion gallons of hazardous waste per=20
year.
http://site.net )
 
These injection wells are primarily located in EPA Region 4, 5, = &
6=20 with the majority located in Texas, Florida, and = Louisiana.
 
"The Safe Drinking = Water Act=20 (SDWA) amendments in 1986 and 1996
have generated stricter Right-to-Know = Provisions driving stricter
reporting requirements, and we have a = concern for=20 all potential
pollution of source drinking water supplies," says = John H.=20
Sullivan, Deputy Executive Director of the American Water Works =
Association=20 (AWWA) the world's largest organization of water supply
professionals=20 representing 56,000 members, 4,000 utilities, and
200,000 public water = systems=20 serving 85% of the populations of
Canada and the US.
(http://www.awwa.org )
 
"The EPA's UIC program = needs alot=20 of looking into, and SDWA
violations from Class 1 UIC wells = contaminating=20 underground sources
of drinking water (USDW) in Dade County, Florida are = not=20 uncommon
conditions," says Sullivan. 
(see: http://www.ficus.usf.edu/ex=
hibit/injection.html
 
"There is some really = toxic stuff=20 going done these Class 1 UIC
wells," he says.
 
The Chemical Manufactures = Association=20 (CMA) believes the current EPA
Class 1 UIC program is not a threat to=20 underground sources of drinking
water.
( http://www.cma.org )
 
"We have 18 companies = which own=20 and operate 80 Class 1 UIC
wells, and for these companies it is their = sole=20 source of disposal
for hazardous waste," says David Mentall, = manager of Environmental
Issues and = UIC staff=20 executive for CMA.
 
The firms = include B.P.Amaco, Monsanto, Solutia, Cytec, = and DuPont=20
-which has the largest number of Class 1 UIC wells according to=20
Mentall.
 
"We have no = significant concerns=20 from a regulatory stand point,
but there are a number of civil action = suits=20 still pending (one
involving DuPont in Louisiana, and two other cases in = Texas)=20 which
we are watching very closely because they could set an = astronomical=20
monetary effect precedent," he says.
 
Not all CMA members use = Class 1 UIC=20 wells.
 
"Back in the 1970's management did not believe Class 1 UIC = wells
for=20 hazardous waste was right, and they developed a corporate policy
against = them," says Mike Rio, = Global Director=20 for
Environment, Health & Safety for Operations at Dow=20 Chemical.   
(
 
"Our last hazardous Class 1 UIC well was = closed in the=20 early
eighties, and we are now reliant on incineration, recycling, and = our
waste=20 reduction program (WRAP)," he says.
 
For more than eighteen = years the=20 not-for-profit Legal Environmental
Assistance Foundation (LEAF) has = legally=20 challenged Class 1 UIC
wells in the United States advocating underground = injection of waste
doesn't lend itself to pollution = prevention.
 
"The EPA's UIC program = is too easy=20 a remedy when you have a
disposal method putting a hazardous waste = problem out=20 of sight and
out of mind," says Cynthia Valencic, Vice President = for=20
Programs at LEAF.
 
"We believe industry = and=20 municipalities should be looking for
ways to reduce production = incorporating=20 close loop systems and
recycling as an alternative for Class 1 UIC waste = disposal," she
says.
 
Regulatory officials and=20 environmentalists admit the EPA's UIC program
is weakly enforced and = poorly=20 monitored.
 
"In many cases there = isn't much=20 monitoring of UIC wells for
violations except where a problem potential = is=20 expected
(ie.Florida)," says Bruce Kobelski, UIC Team Leader for = the EPA=20
Office of Ground Water and Drinking Water.
(http://www.epa.gov/OGWDW/uic.h= tml=20 )
 
"There are roughly 600 = Class 1=20 hazardous waste wells in the US,
but we at the EPA can't ban violating=20 facilities because permits are
in most cases a regional state = function,"=20 says Kobelski.
 
Corporations are required = to report to=20 the public specific Class 1
injection releases and inventory under = federal Toxic=20 Release
Inventory (TRI)  regulations.
http://www.epa.gov/op= ptintr/tri/whatis.htm
 
"But, there is nothing = in TRI=20 which requires monitoring of the
wells," says Paul Orum, = coordinator of the=20 not-for-profit
Working Group on Community Right to Know.
http://www.rtk.net
 
"CMA would like to see = status quo=20 for UIC regulations, but when
you have a Class 1 UIC well its very easy = to dump=20 everything down
there and create a disincentive to pollution = prevention,"=20 he
says.
 
(c)Donald = Sutherland 1999=20 
 
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