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Re: Underground Injection of Hazardous Waste

My biggest objection to underground injection of hazardous wastes is that if
it does turn out to be the wrong thing to do, by the time we find out it
will be too late.  There will be no way to undo the damage.  This form of
disposal has been going on for about 50 years, which on a geologic time
scale is nothing.  There's no way to prove that the models showing no
migration over a 10,000 year time span (the requirement for haz waste
injection) are adequate.  Remember that at one time, chlorinated
fluorocarbons were the solution to a variety of environmental ills.

Contamination of groundwater from Class I wells has rarely taken place in
the past.  However, besides a failure of the well itself or inadequate
modeling techniques, geologic events can change confining beds and this
isn't modeled.  Also, migration might occur through
unaccounted for (not included in the no-migration model) and abandoned oil
and gas wells.

Companies that are currently relying on underground injection for waste
management should realize that one catastrophic event will result in a
sudden ban on this method of disposal, and alternatives take years to
implement.  Some of the big chemical manufacturers are out of underground
injection, partly because of this.  Also partly because the word on the
street is that underground injection isn't going to be allowed indefinitely.

One of the arguments for approving of underground injection is that it is
preferred over other forms of land disposal.  But that's lame -- we're way
past the stage where disposal to the environment is the only option.

For more info on haz waste injection wells, you might want to see Chapter 9
of the Texas Environmental Almanac Online -- it's sponsored by the Texas
Center for Policy Studies.  I can't find the address but you should be able
to find it with a search.

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


(818) 878-0454

-----Original Message-----
From: Alvin_McGrath@ci.savannah.ga.us <Alvin_McGrath@ci.savannah.ga.us>
To: p2tech@great-lakes.net <p2tech@great-lakes.net>
Date: Tuesday, August 03, 1999 8:42 AM
Subject: Underground Injection of Hazardous Waste

>I am interested in learining more about these types of injection wells as
>noted in the following EPA Federal Register notice.  Can anyone on the list
>help direct me to information on this type of disposal system is supposed
>to work?  Is there no danger of groundwater contamination?  And not one
>comment received by the EPA prior to approving this system.
>Alvin McGrath, Jr.
>---------------------- Forwarded by Alvin McGrath/WaterSewerPlan/SavGa on
>08/02/99 02:25 PM ---------------------------
>envsubset@epamail.epa.gov@valley.rtpnc.epa.gov on 08/02/99 02:17:19 PM
>[Federal Register: August 2, 1999 (Volume 64, Number 147)]
>[Page 41933]
>>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
>Underground Injection Control Program Hazardous Waste Injection
>Restrictions; Petition for Exemption--Class I Hazardous Waste Injection
>Rubicon, Inc.
>AGENCY: Environmental Protection Agency (EPA).
>ACTION: Notice of final decision on no migration petition reissuance.
>SUMMARY: Notice is hereby given that an exemption to the land disposal
>restrictions under the 1984 Hazardous and Solid Waste Amendments to the
>Resource Conservation and Recovery Act has been granted to Rubicon Inc.,
>(Rubicon) for four Class I injection wells located at Geismar, Louisiana.
>As required by 40 CFR part 148, the company has adequately
>demonstrated to the satisfaction of the Environmental Protection Agency by
>the petition and supporting documentation that, to a reasonable degree of
>certainty, there will be no migration of hazardous constituents from the
>injection zone for as long as the waste remains hazardous. This final
>decision allows the underground injection by Rubicon, of the specific
>restricted hazardous wastes identified in the exemption, into four Class I
>hazardous waste injection well nos. 1, 2, 3, and 4 at the Geismar,
>Louisiana facility, until December 31, 2025, unless EPA moves to terminate
>the exemption under provisions of 40 CFR 148.24. As required by 40 CFR
>148.22(b) and 124.10, a public notice was issued May 20, 1999. The public
>comment period closed on July 7, 1999. No comments were received. This
>decision constitutes final Agency
>action and there is no Administrative appeal.
>DATES: This action is effective as of July 26, 1999.
>ADDRESSES: Copies of the petition and all pertinent information relating
>thereto are on file at the following location: Environmental Protection
>Agency, Region 6, Water Quality Protection Division, Source Water
>Protection Branch (6WQ-S), 1445 Ross Avenue, Dallas, Texas 75202-2733.
>FOR FURTHER INFORMATION CONTACT: Philip Dellinger, Chief Ground Water/
>UIC Section, EPA--Region 6, telephone (214) 665-7165.
>Oscar Ramirez, Jr.,
>Acting Director, Water Quality Protection Division (6WQ).
>[FR Doc. 99-19732 Filed 7-30-99; 8:45 am]
>Juna Z. Snow
>List Manager
>Waste Management & Research Center