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Re: Underground Injection of Hazardous Waste

Ralph, it must have been a listserv burp that sent this again.  I
definitely was not up 2:55 this AM sending emails!


At 07:18 AM 8/19/1999 -0500, Ralph Cooper wrote:
>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)
>-----Original Message-----
>From: Jeff Cantin <jcantin@tiac.net>
>To: cooperre@flash.net <cooperre@flash.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
>>>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
>> ______ _____   _____
>>|  ____|  __ \ / ____| Jeff Cantin
>>| |__  | |__) | |  __  ERG, Inc.
>>Eastern Research Group www.erg.com
>>| |____| | \ \| |__| | 110 Hartwell Ave.
>>|______|_|  \_\\_____| Lexington, MA 02424-3136
>>                                jcantin@erg.com
>>                                jcantin@tiac.net

 ______ _____   _____
|  ____|  __ \ / ____| 		Jeff Cantin
| |__  | |__) | |  __  		ERG, Inc.
Eastern Research Group 		www.erg.com
| |____| | \ \| |__| | 		110 Hartwell Ave.
|______|_|  \_\\_____| 		Lexington, MA 02424-3136