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US EPA's UIC & SDWA 25th Anniversary


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.

Donald Sutherland
Member of the Society of Environmental Journalists
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

The Chemical Manufactures Association (CMA) believes the current EPA Class
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
(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)

"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.

"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