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Re: Underground Injection of Hazardous Waste



I thought this was resolved earlier.  I missed putting a sig on the item.
My apologies.

Professor until 1977.  AAAS Congressional Science Fellow, 1977-78.
Battelle, 1978-1983, doing EISs on energy and waste related projects, and
related projects.  PCB transformer decontamination industry, Corp. Dir. Govt
Affairs, Env., Safety, etc. 1984-85.  Environmental management consultant
and seminar instructor, 1985-1996, major focus on reducing environmental and
resource impact of industry and major govt facilities, inc. pollution
prevention.  Chaired hazardous materials conference, 1988-1993.  Law
student, 1996-99.  Just completed the Texas Bar Exam.

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

-----Original Message-----
From: Jeff Cantin <jcantin@tiac.net>
To: cooperre@flash.net <cooperre@flash.net>; p2tech@great-lakes.net
<p2tech@great-lakes.net>
Date: Thursday, August 19, 1999 2:55 AM
Subject: Re: Underground Injection of Hazardous Waste


>Please, everyone, provide your affiliation if you want your postings to be
>taken seriously.  This was a helpful response but we can't infer much about
>who cooperre@flash.net is or from what experience s/he is speaking.
>
>-Jeff Cantin
>
>
>At 11:14 AM 8/4/99 -0400, cooperre@flash.net wrote:
>
>>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
>>gasoline.
>>
>>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)]
>>>[Notices]
>>>[Page 41933]
>>>>From the Federal Register Online via GPO Access [wais.access.gpo.gov]
>>>[DOCID:fr02au99-100]
>>>
>>>-----------------------------------------------------------------------
>>>
>>>ENVIRONMENTAL PROTECTION AGENCY
>>>
>>>[FRL-6411-1]
>>>
>>>
>>>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
>>>listman@wmrc.hazard.uiuc.edu
>>>217.333.8945
>>>
>>
>>
>>----------
>>Juna Z. Snow
>>List Manager
>>Waste Management & Research Center
>>listman@wmrc.hazard.uiuc.edu
>>217.333.8945
>>
>>
>
> ______ _____   _____
>|  ____|  __ \ / ____| Jeff Cantin
>| |__  | |__) | |  __  ERG, Inc.
>Eastern Research Group www.erg.com
>| |____| | \ \| |__| | 110 Hartwell Ave.
>|______|_|  \_\\_____| Lexington, MA 02424-3136
>                                jcantin@erg.com
>                                jcantin@tiac.net
>
>