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What is Underground Injection?
Underground injection is the technology of placing fluids underground, in porous formations of rocks, through wells or other similar conveyance systems. While rocks such as sandstone, shale, limestone appear to be solid, they can contain significant voids or pores that allow water and other fluids to fill and move through them. Man-made or produced fluids (liquids, gases or slurries) can move into the pores of rocks by the use of pumps or by gravity. The fluids may be water, wastewater or water mixed with chemicals. Injection well technology can predict the capacity of rocks to contain fluids and the technical details to do so safely.
Why Do We Need a Program to Regulate the Placement of Fluids Underground? Facilities across the United States and in Indian Country discharge a variety of hazardous and nonhazardous fluids into more than 400,000 injection wells. While treatment technologies exist, it would be very costly to treat and release to surface waters the billions and trillions of gallons of wastes that industries produce each year. Agribusiness and the chemical and petroleum industries all make use of underground injection for waste disposal. When wells are properly sited, constructed, and operated, underground injection is an effective and environmentally safe method to dispose of wastes.
The Safe Drinking Water Act established the Underground Injection Control (UIC) Program to provide these safeguards so that injection wells do not endanger current and future underground sources of drinking water (USDW). The most accessible fresh water is stored in shallow geological formations called aquifers and is the most vulnerable to contamination. These aquifers feed our lakes; provide recharge to our streams and rivers, particularly during dry periods; and serve as resources for 92 percent of public water systems in the United States. What Is an Injection Well?
The UIC Program defines an injection well as any bored, drilled or a driven shaft or a dug hole, where the depth is greater than the largest surface dimension that is used to discharge fluids underground. This definition covers a wide variety of injection practices that range from more than 100,000 technically sophisticated and highly monitored wells which pump fluids into isolated formations up to two miles below the Earth's surface, to the far more numerous on-site drainage systems, such as septic systems, cesspools, and storm water wells, that discharge fluids a few feet underground.
What does a deep technically sophisticated injection well look like?
How Does the UIC Program Regulate the Very Different Types of Underground Injection?
The EPA groups underground injection into five classes for regulatory control purposes. Each class includes wells with similar functions, and construction and operating features so that technical requirements can be applied consistently to the class. Class I includes the emplacement of hazardous and nonhazardous fluids (industrial and municipal wastes) into isolated formations beneath the lowermost USDW. Because they may inject hazardous waste, Class I wells are the most strictly regulated and are further regulated under the Resource, Conservation and Recovery Act. Class II includes injection of brines and other fluids associated with oil and gas production; Class III encompasses injection of fluids associated with solution mining of minerals; Class IV addresses injection of hazardous or radioactive wastes into or above a USDW and is banned unless authorized under other Statutes for ground water remediation. Class V includes all underground injection not included in Classes I-IV. Class V wells inject nonhazardous fluids into or above a USDW and are typically shallow, on-site disposal systems, such as floor and sink drains which discharge directly or indirectly to ground water, dry wells, leach fields, and similar types of drainage wells. Injection practices or wells which are not covered by the UIC Program include other individual residential waste disposal systems that inject ONLY sanitary waste and commercial waste disposal systems that serve fewer than 20 persons that inject ONLY sanitary waste.
Are All Injection Wells Waste Disposal Wells?
All injection wells are not waste disposal wells. Some Class V wells, for example, inject surface water to replenish depleted aquifers or to prevent salt water intrusion. Some Class II wells inject fluids for enhanced recovery of oil and natural gas, and others inject liquid hydrocarbons that constitute our Nation's strategic fuel reserves in times of crisis.
How Does the UIC Program Prevent Contamination of Our Water Supply? Injection wells have the potential to inject contaminants that may cause our underground sources of drinking water to become contaminated. The UIC Program prevents this contamination by setting minimum requirements. The goals of the EPA's UIC Program are to prevent contamination by keeping injected fluids within the well and the intended injection zone, or in the case of injection of fluids directly or indirectly into a USDW, to require that injected fluids not cause a public water system to violate drinking water standards or otherwise adversely affect public health. These minimum requirements affect the siting of an injection well, and the construction, operation, maintenance, monitoring, testing, and finally, the closure of the well. All injection wells require authorization under general rules or specific permits. Finally, States may apply to have primary enforcement responsibility for the UIC Program. To date, 33 States, Guam, the Commonwealth of the Mariana Islands, and Puerto Rico have obtained primacy for all classes of injection wells. Seven States share primacy with the EPA. The EPA administers UIC programs for the remaining States, the Virgin Islands, American Samoa and Indian Country.
For More Information about the EPA's UIC Program Contact: The Safe Drinking Water Hotline (800) 426-4791 or the Office of Ground Water and Drinking Water (202) 260-7077. Write to: The UIC Program, Mail Code 4606, U.S. EPA, 401 M Street S.W., Washington, D.C. 20460. Please visit the web site at www.epa.gov/safewater. www.riskworld.com/NEWS/03q2/nw03a102.htm
EPA to Permit Florida to Pollute Drinking Water Supplies
By Donald Sutherland
Before EPA Administrator Christine Todd Whitman resigned from her office she had decided to sign off on a rule-making decision drawn up by EPA water administrators declaring Florida exempt from certain provisions of the Safe Drinking Water Act.
Published in the Federal Register on May 5, 2003, the exemption will permit Florida to legally pollute drinking water aquifers with inadequately treated waste through municipal underground injection control (UIC) wells. (this is the actual problem - Insufficient confinement is evident at some facilities and locations. At nine facilities, there is either confirmed or suspected contamination of USDWs as a result of the movement of fluid from designated injection zones. This is a violation of Federal and State Class I UIC requirements, which prohibit any contaminants from entering USDWs. At nine other facilities, there is evidence of movement outside of the injection zone, though not yet into USDWs.
Monitoring reports from some facilities suggest that fluid movement has resulted in fluctuations in total dissolved solids (TDS) concentrations and less pronounced changes in the concentrations of other potential stressors (e.g., fecal coliform, nitrate, ammonia, and total Kjeldahl nitrogen). Such fluid may have the potential to contaminate future sources of drinking water and place existing public and private water supplies at risk.)
The problem the EPA administrators were and are still reviewing arose when the federal agency advised the Florida Department of Environmental Protection (FDEP) in the late seventies to initiate a program of disposal of municipal sewage and industrial waste by injection underground via deep injection wells.
A Fortune 500 engineering consulting firm, CH2M Hill, had assured all parties the deeply injected underground waste effluent would be contained by a geological barrier and not commingle with drinking water aquifers. The injected sewage and industrial waste would also harmlessly be disposed of in deep saline aquifers and then migrate into coastal waters. Since the time the EPA gave the OK for the underground injection of sewage and industrial waste over one hundred and twenty Class 1 UIC wells have been built to service the bulging unfettered growth in south Florida. FDEP officials estimate the flow of injected waste at over 400 million gallons daily (mgd) but environmental groups contend it is closer to 1 billion MGD.
However, there is a big containment problem.
EPA and FDEP monitoring tests in the nineties and this year have shown the UIC waste is migrating upward into aquifers the region relies on for drinking water.
U.S. Geological Society (USGS) tracer studies of injection wells in the Florida Keys have also shown bacteria, viruses, and nutrient loading from migrating UIC sewage waste are contaminating tourist beaches and destroying the nutrient sensitive fragile coastal reef ecosystem in the Florida Keys National Marine Sanctuary. Coral choking algae, fish and marine mammal killing harmful algal blooms (HABs), and dying sea grass beds are all associated with nutrient loading from sewage waste.
Government officials admit these events are occurring where sewage waste injected into Florida's underground sources of drinking water (USDW) is migrating into coastal waters.
Federal and state governments have secured no funding to study the health implications of the nation's largest violation of the Safe Drinking Water Act and the environmental impact of municipal UIC waste migration into coastal waters.
The tourist, recreational, and resort industries have not expressed a concern with the economic impact of UIC pollution even though beach closings due to bacteria contamination and HABs have increased since the inception of municipal UICs.
Florida's building, housing, and construction industries endorse the continuation of a sewage disposal process that is less expensive than building advanced wastewater treatment plants with treated effluent reuse facilities.
Communities and residents of most of south Florida's counties have not repealed the expansion of municipal injection wells and have not expressed a health concern with the practice.
Only Pinellas County has decided to plug failed UIC wells and replace them with an extensive wastewater reuse program.
All of Florida's government representatives, officials, and agencies have endorsed south Florida's loosely permitted UIC disposal.
Although two Democratic state legislators this year proposed legislation to have a stricter accounting of UIC permitting, the proposal failed to be considered.
All this, even though Florida's UIC municipal waste disposal program is banned in other states because it is viewed as a health and environmental threat.
"There is no short term solution to the municipal Class 1 UIC fluid migration into underground sources of drinking water (USDW) in Florida," says Nancy H. Marsh, program manager for EPA Region 4 Ground Water UIC section.
"Municipalities are reliant on these injection wells and they can't be shut down," she says.
Only two environmental organizations, the Florida Sierra Club and Legal Environmental Assistance Foundation (LEAF), have mounted a campaign to oppose the nation's largest violation of the Safe Drinking Water Act and the UIC destruction of Florida's marine ecosystems.
"The Sierra Club's Florida Chapter has been rebuffed by the state in a call for transparency of the state's underground injection control program that would enhance the public right to know," says Alan Farago, the organization's Miami Conservation Chair.
"Governor Bush and FDEP Secretary Struhs failed to support a proposal which sought simply to account for the massive pollution of underground aquifers in Florida," he says.
So far there are no lawsuits being brought against the EPA, FDEP, or any local utility authority.
A regional EPA official who walked out of the DC headquarters rule reversal sessions on Florida's UIC program says, "The big question is, is the EPA violating the federal law National Environmental Policy Act (NEPA) with this action?"
NEPA requires all federal agencies to integrate environmental values in their rule-making processes which consider environmental impacts of their proposed actions and give reasonable alternatives to those actions. The act also mandates a detailed Environmental Impact Statement (EIS) for these rule-making processes.
A bigger question according to the same EPA regional official is what is the legal precedent set by this EPA rule change of the Safe Drinking Water Act to accommodate a state's noncompliance with a national law to safeguard the public and the environment.
-Donald Sutherland 2003
References
"Underground Injection Control Program--Revision of Underground Injection Control Requirements for Class I Municipal Wells in Florida; Notice of Data Availability" [Federal Register: May 5, 2003 (Volume 68, Number 86)]
WEBSITE
"Underground Injection Control Regulations for Class V Injection Wells, Revision; Final Rule" [Federal Register: December 7, 1999 (Vol. 64, Number 234)
WEBSITE
"Revision to the Federal Underground Injection Control (UIC) Requirements for Class I-Municipal Wells in Florida; Extension of Comment Period" [Federal Register: September 1, 2000 (Volume 65, Number 171)]
WEBSITE
"Notice of Stakeholder Meeting on the Revision to Federal Underground Injection Control (UIC) Requirements for Class I--Municipal Wells in Florida" [Federal Register: June 7, 1999 (Volume 64, Number 108)]
WEBSITE
EPA News Release: "EPA Proposes Revision to Federal Requirements for Wastewater Disposal in Florida," July 7, 2000.
WEBSITE
National Environmental Policy Act (NEPA)
WEBSITE
Good link ** Florida Department of Environmental Protection's "Water Resources"
WEBSITE
"Underground Injection Control" of Florida Department of Environmental Protection's "Water Resources"
WEBSITE
"Wastewater" section of Florida Department of Environmental Protection's Underground Injection Control Program
WEBSITE
"Vulnerability of Biscayne Aquifer to Contamination," U.S. Geological Survey
WEBSITE
"Determination of Groundwater-Flow Direction and Rate Beneath Florida Bay, the Florida Keys, and Reef Tract," U.S. Geological Survey
WEBSITE
Pinellas County Utilities Update
WEBSITE
"Harmful Algal Blooms," National Centers for Coastal Ocean Science website
WEBSITE
"Issues: Safe Drinking Water," Florida Chapter, Sierra Club
WEBSITE
"What are we doing to our drinking water?" - Miami Group, Sierra Club
WEBSITE
Legal Environmental Assistance Foundation, Inc.
WEBSITE
"Testing the Waters: A Guide to Water Quality at Vacation Beaches," July 2002, Natural Resources Defense Council
WEBSITE
"Underground Injection Control," Environmental and Land Use Law Section of The Florida Bar
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