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Re: Underground Injection of Hazardous Waste

More than 200 million pounds of TRI-reported compounds were reported as
injected to Class I wells in 1996.  A very small number of facilities is
responsible for the majority of TRI-reported injection, which clearly shows
that there are many facilities making use of alternatives to injection.
Injection varies by region -- where it's allowed, it's used, because it's

TRI compounds reportedly injected in quantities greater than a million
pounds are (with quantities injected in millions of pounds):
acetamide, 1.2
acetonitrile, 23
acrylamide, 5.7
acrylic acid, 5.2
acrylonitrile, 3.6
ammonia (really weird reporting requirements), 24
n-butyl alcohol, 2.5
tert-butyl alcohol, 1.0
cyanide in cyanide compounds, 3.5
cyclohexanol, 3.6
N,N-dimethylformamide, 1.2
ethylene glycol, 7.7
formaldehyde, 9.4
formic acid, 11
methanol, 24
N-methyl-2-pyrrolidone, 2.9
nitrate compounds, 39
nitric acid, 17
phenol, 2.0

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


(818) 878-0454

-----Original Message-----
From: cooperre@flash.net <cooperre@flash.net>
To: p2tech@great-lakes.net <p2tech@great-lakes.net>
Date: Wednesday, August 04, 1999 8:14 AM
Subject: 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
>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
>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
>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
>>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]
>>BILLING CODE 6560-50-P
>>Juna Z. Snow
>>List Manager
>>Waste Management & Research Center
>Juna Z. Snow
>List Manager
>Waste Management & Research Center