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Re: Underground Injection of Hazardous Waste

Some of the injection solutions are less than one percent, many less than
1/10 of a percent.  Most of the injecting companies are aware of the value
of the material and have PP programs in place to try to reduce the losses.
But under current EPA rules, one molecule of a U listed wastes makes a
million gallons of water a hazardous waste.

Ralph E. Cooper, Ph.D., J.D.
14139 Woodstream
San Antonio, TX 78231
210-479-5490 (4)

-----Original Message-----
From: Jack Annis <jack.annis@ces.uwex.edu>
To: Kirsten Sinclair Rosselot <rosselot@ix.netcom.com>; cooperre@flash.net
<cooperre@flash.net>; p2tech@great-lakes.net <p2tech@great-lakes.net>
Date: Thursday, August 05, 1999 9:25 AM
Subject: RE: Underground Injection of Hazardous Waste

>I usually don't comment on issues like this.  I don't  know enough about
>safeness or lack of safeness involved with injecting hazardous waste
>underground. Not a geologist.
>However I don't understand the business or economic sense of it. Even if it
>is cheap to dispose of this way, you would assume the waste chemical will
>replaced by new chemical for whatever process it is used in. That's pretty
>I'm not a chemist either but at least 3 or 4 of the less complex chemical
>compounds Ethylene glycol, NMP, Methanol, n-butyl alcohol are highly
>recyclable either in new product or through energy recovery ,even in dilute
>concentrations. There are probably others on the list.
>Or conversely you can concentrate solutions to make them valuable.
>Even the acids are valuable. Several technologies that could recover the
>Even if the "injecting" companies are incapable, sorry, don't want to deal
>with the wastes, there are other companies that specialize in
>treating used chemical solutions.
>Maybe this is a good Common Sense Initiative area the regulators can work
>with the "injectors".  Would be nice to know the stuff is not going in to
>the ground and might eliminate the need for those pesky regulations.
>Good luck.
>Phillip (Jack) Annis
>Waste Reduction and Recycling Specialist
>161 West Wisconsin Avenue, Suite 6000
>Milwaukee, WI 53203
>Telephone 414-227-3371
>Fax 414-227-3165
>Email pannis@facstaff.wisc.edu
>-----Original Message-----
>From: owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On
>Behalf Of Kirsten Sinclair Rosselot
>Sent: Wednesday, August 04, 1999 2:14 PM
>To: cooperre@flash.net; p2tech@great-lakes.net
>Subject: 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
>>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,
>>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
>>is a greater risk to drinking water from the transportation of gasoline
>>from deep well injection of wastes, given current regulation of the
>>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
>>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
>>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
>>>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
>>>hazardous waste injection well nos. 1, 2, 3, and 4 at the Geismar,
>>>Louisiana facility, until December 31, 2025, unless EPA moves to
>>>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