According to the EPA, 89% of hazardous waste, over 9 billion gallons a year, which is disposed on the land is injected into the earth, a process called deep well injection.(http://www.epa.gov/ogwdw/uic/pdfs/uicpocketbook.pdf) These wells, which are intended to segregate waste, are called Class 1 wells and are monitored by the EPA. Class 1 wells dispose of industrial hazardous waste, and non hazardous wastes from industries and municipalities. There are currently 272 facilities that run approximately 529 Class 1 injection wells across the United States. Of the facilities, 51 inject hazardous waste and 221 inject non-hazardous waste. Most of the wells are located along the Gulf coast, the Great Lakes, and Florida. Texas has 78 facilities and Louisiana has 18. The majority of facilities inject waste generated on site, but eleven commercial injectors can accept waste generated off site for disposal. (http://www.epa.gov/ogwdw/uic/classi.html) This map shows the number of Class 1 hazardous waste wells in states. As you can see Texas by far out-numbers the rest of the states.
Injection of liquid into the earth is not a new technology. In the 1930’s, oil companies began injection by products from the production of oil into old wells. Hazardous waste generators adopted this in the 1950’s. Since that time, the government has enacted specific regulations for the construction and operation of the wells to prevent groundwater contamination and environmental damage.
Here are some laws passed to regulate injection wells.
1974 EPA issues
policy Statement the arose form the failure of a few wells. This policy statement
opposed underground injection but did not include
controls due to no evidence of contaminated ground water.
December 1974. Congress inacts Safe Drinking water act (SDWA). Requires
to set requirements
1980 EPA passes underground Injection Control (UIC) regulations to
protect underground sources of drinking water.
1984 Congress enacts Hazardous and Solid Waste Amendments (HSWA) to
1988 EPA amends UIC to address HSWA. Exemptions to Class I operators.
1995 and 1996 estimated risks of Failure of Class I Injection wells
1996 Congress passes Land Disposal Flexibility Ac
Class 1 wells are currently required to treat wastes to acceptable levels of toxicity or prove there is no mitigation of the waste. The wells are designed so that if they happen to fail, the waste would be confined to the injection zone.No mitigation means the waste will not affect an underground water supply for 10,000 years or until the waste is not harmful. To ensure this, the EPA mandates there are no faults or other adverse geological fetures present in the area, that the well injects into layers that do not currently hold water but have the correct features (porosity and permeabilty) to, and that are below a confining layer. Confining layers are generally made of shale, a rock type made of compacted clay. Confining layers are chosen because of their low permeability. Extensive geological research must be done before a well is put into place. http://www.epa.gov/ogwdw/uic/pdfs/uicpocketbook.pdf Class one wells are typically very deep. In the Great Lakes region, tey are 1,700-6,000ft deep while on the Gulf coast they are 2,200-12,000 ft deep. http://www.epa.gov/safewater/uic/classonestudy.pdf
Here are some of the multiple regulations for the construction and mantainence of these wells.
Monitoring and Testing
- follow waste analysis plan
- perform MITs at required intervals
Reporting and Record Keeping
- record injection fluids and all monitoring results
- report on any changes at facility and noncompliances
- flush well with non-reactive fluid
- submit plugging and abandonment report
- monitor ground water until injection zone pressure can no longer influence any USDW
- inform authorities of well location and zone of influence
- AoR testing
- no-migration petition demonstration
- geological studies
- well is cased and cemented
- proper tubing and packer
- UIC program director must approve plan
- monitor injection pressure, flow rate, and volume
- alarms and devices to shut down flow if necessary
- maintain pressures that will not initiate cracking
Zeneca A chemical manufacturing company, Zeneca, agreed to pay millions to clean up an injection well. They have also agreed to cease their injection of hazardous wastes into an aquifer.The company faced the following charges: • Injecting 40 million gallons of contaminated wastewater annually into deep wells. Zeneca's injected wastewater contained contaminants in excess of drinking water standards. The complaint alleges that Zeneca disposed of hazardous waste by deep well injection on several occasions. • Operating a thermal treatment device without the requisite hazardous waste permit. • Failing to undertake an extensive program of detection and repair of benzene leaks, as required by the Clean Air Act. • Discharging leachate into a nearby creek and surrounding area from large amounts of mining and manufacturing wastes generated by the former owners of the facility between 1957 and 1978. Courtesy of the Department of Justice at http://www.usdoj.gov Zeneca agreed to pay these fines along with spending a great deal of money to fix up the pollution problems to prevent further and more severe penalties in the future. http://www.usdoj.gov/opa/pr/1998/August/388enr.html
EDS (Environmental disposal services) received an exemption by the EPA allowing them to dispose of wastes produced at other businesses at their injection well. The EPA determined that the waste that will be disposed at the two Class 1injection sites will stay in the rock formation that it is intended for and does not pose a threat to anyone in the area. The site met the exemption requirements from HSWA of 1988, with proven scientific evidence to show that waste will not move out of the injection zone or reach a underground drinking water source for 10,000 years. This scientific evidence was approved by scientists from the U.S. Geological Survey and the Lawrence Berkeley National Laboratory in California.
Public response: The Public wants a review of spill plans associated with the transportation and storage of toxics before they are injected. The site would dispose of several hundred thousand toxins including chromium, acids, PCBs, and lead. The surrounding communities are worried about the some fifty trucks per day that would be necessary to transport the toxins through their neighborhoods. The state is taking a serious look at the spillage and traffic concerns of the residents.
DuPont was sued by resident in Beaumont, TX claiming that the class 1 injection well was leaking and contaminating the ground underneath their land (unjust pollution), invading their property, and lowering the value of that property. Two wells that dumped waste into a saltwater brine 8,000 feet below the ground, were under review. These two wells contained hydrogen cyanide and some carcinogenic metals. The wells were permitted by the EPA and the necessary Texas agencies. The plaintiffs approached DuPont for royalties and DuPont refused. The Plaintiffs had previously negotiated a deal with another company who agreed to pay royalties of $350,000 to $500,000 since 1979. DuPont was not found liable for the charges that they faced.