“Class I hazardous wells are safer than virtually any other waste disposal practice.”1
“A 1989 EPA study found that injecting wastes in Class I wells is safer than burying them in landfills, storing them in tanks, or burning the waste in incinerators.”2
“The EPA has no reason but to conclude that existing Class I UIC regulatory controls are strong, adequately protective, and provide an extremely low-risk option in managing the wastewaters of conern.”3
“The USEPA views the underground injection of wastes, when conducted in accordance with all federal and state regulations, to be a safe method of waste disposal.” “Therefore, the USEPA is confident that drinking water supplies will not be affected by the proposed injection operation.”4
Injection Wells are well regulated:
The use of deep well isolation for wastes disposal has been in practice in the United States since the 1930s, with the early wells used by oil companies to dispose of oil field brine and other wastes.
In 1972, the U.S. and Canada signed the Great Lakes Water Quality Agreement (“GLWQA”) to restore and maintain the chemical, physical and biological integrity of the waters of the Great Lakes Basin.
Congress enacted the Safe Drinking Water Act (“SDWA”) in 1974 that required the EPA to develop a program to protect the underground sources of drinking water in the U.S.
EPA issued the baseline Underground Injection Control (“UIC”) program regulations in 1980 to assist in protecting our nation’s drinking water.
In 1988, EPA amended the UIC Program to address the Hazardous and Solid Waste Amendments (“HSWA”) of 1984 that banned the land disposal of hazardous waste unless they are treated to specific standards or would not migrate for 10,000 years.
In 1995, EPA strengthened the GLWQA by passing the Great Lakes Water Quality Guidance for the Great Lakes System. As a result, due to our location near the Great Lakes, we are held to higher standards over other areas of the country with hazardous waste injection wells.
Class I (Hazardous Waste) deep wells operate by injecting waste into a porous and permeable geologic formation located thousands of feet below the ground surface. The permeability and porosity of such “injection zone” formations are sufficient to prevent the buildup of excessive pressure. As the various layers of impermeable rock that is above the “injection zone” are not permeable, the injected waste is effectively prevented from moving vertically and should therefore not go into any source of underground drinking water. Class I deep wells are required by EPA’s regulations to be constructed in geologically stable areas. Deep wells constructed in conformance with EPA’s regulations feature sophisticated, multi-layer construction with many redundant safety features including corrosion-resistant materials, outer and inner casings, and continuous pressure maintained in the annulus area.
Please see http://water.epa.gov/type/groundwater/uic/wells_class1.cfm, especially the “Streaming Flash Video.”
When compared to other treatment & disposal technologies such as (a) landfilling, (b) incineration, and (c) chemical stabilization with traditional waste disposal methods such as sewer discharges, deep well isolation represents the only available technology that does not contribute pollutants to the nation’s surface and drinking waters (i.e. the “hydrologic cycle”). For example:
Landfill leachate can escape from its collection system and then pollute groundwater and/or surface waters
Incineration contributes pollutants to the atmosphere that “wash out” with precipitation and then contribute pollutants to the surface waters, which in turn recharges the groundwater
Chemical &/or Physical Treatment Technologies including “wastewater treatment technologies” that do not utilize deep well isolation generate wastewaters that enter sewer systems with the residual volatile materials vaporizing into the atmosphere and a portion of the wastewaters entering the ground surface and thus the hydrologic cycle through leaks in the sewer systems.
For even more information please see the Ground Water Protection Council website @ gwpc.org.
Properly and effectively isolating (especially) hazardous wastes from surface waters and drinking waters clearly improves our environment by keeping contaminants (aka “pollutants”) out of the hydrologic cycle and the food chain. Additionally, the proper and effective isolation of these wastes within the earth’s mantle will cause them to undergo reactions over time with the naturally occurring materials in the injection zone that will also make the wastes less hazardous.
Additionally, should, in the future, cost-effective recycling approaches be developed, hazardous wastes destined for injection wells can be reused or separated into something useful. When compared to other technologies, deep well isolation provides a disposal option that:
Represents virtually no probability of impact to the drinking waters of our nation
Isolates wastes deep within the earth’s mantle where they will react with naturally occurring materials there, rendering the wastes less hazardous over time, and,
Allows for the subsequent transfer of the wastes to potentially future, new, cost-effective recycling technologies.
According to EPA, there are approximately 500 Class I (hazardous wastes &/or non-hazardous wastes) injection wells in the United States of which 29 (7 hazardous and 22 non-hazardous) are in Michigan. The EGT Romulus facility is the very latest in liquid hazardous waste treatment and disposal technologies.
1 U.S. EPA Office of Solid Waste and Emergency Response, “OSWER Comparative Risk Project: Executive Summary and Overview (OSWER)”, Washington, D.C., EPA/540/1-89/003, Nov. 1989.
2 U.S. EPA, Class I Injection and Your Drinking Water, EPA# 813-F-94-002, July, 1994.
3 U.S. EPA Office of Water, “Class I Underground Injection Control Program: Study of the Risks Associated with Class I Underground Injection Wells,”, Washington, D.C., EPA# 816-=R-01-007, March, 2001.
4 U.S. EPA Region V letter to Honorable John D. Dingell, May 12, 2003.