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Re: Underground Injection of Hazardous Waste

The basic concept of deep well injection is to use geologic formations of
the type that have formerly held oil and gas for thousands of years to
permanently trap wastes underground.  The requirements include that the
waste is to be injected at least 1000 feet below any potential underground
source of drinking water, with at least one confining geologic strata (one
that is impervious to the waste and not likely to be fractured.  Most wells
are more than 5,000 feet deep and many are substantially deeper.

In addition, the siting requirements include a surface distance from any
drinking water well.

Injection wells are triple cased, with the outer casing either cemented or
containing gas pressure for leak detection, the middle ring containing gas
pressure for leak detection (so that leaks go into the inner casing, rather
than out) and the inner casing used for disposal.

>From observation of such operations, my remark is that the risk of other
hazardous materials operations is much greater.  For example, I think there
is a greater risk to drinking water from the transportation of gasoline than
from deep well injection of wastes, given current regulation of the latter,
and the limited regulation and high frequency of the transportation of

Deep well injection is used primarily for dilute wastes which are very
difficult to treat in a cost effective manner, including dilute organics,
and acids and bases that have either metal or organic contamination or both.

Keep in mind that the residues of treatment are still legally hazardous
waste and cannot be discharged to surface unless delisting has taken place.
Delisting is a very expensive process with not the greatest likelihood of
success, and treatment to a level that is likely to result in delisting can
be prohibitively expensive, however, that should be the goal.

Deep well injection is recognized by most users and advocates for it as a
temporary solution until better treatment technology is available and a
regulatory structure that makes it easier to certify a waste as treated to a
level appropriate for discharge.

Much of the deep well injection in this country is for other purposes,
including disposal of brines, such as from oil and gas production, and
enhanced recovery operations in oil and gas fields.
-----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 11:38 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

Juna Z. Snow
List Manager
Waste Management & Research Center