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Depending upon your age, you may remember the common, pre-1970s images of industrial waste openly being dumped in American waterways. In Ohio such practices led to the near ruination of Lake Erie, the burning of the Cuyahoga River, and a proliferation of "No Swimming" signs. Fortunately, discharge of wastes into our surface waters is strictly regulated today, and many of our lakes and streams are well on their way to recovery; but this fact doesn't mean those wastes are no longer generated. The disposal of a significant volume of today's liquid industrial-waste products is through deep, subsurface injection wells. Nationwide, deep injection wells dispose of more than eight billion gallons of industrial wastes annually. Such huge volumes of liquid waste, permanently stored beneath our feet, have more and more citizens asking: "Where is it all going?"
Ohio currently has ten industrial-waste disposal wells in operation at three facilities. Eleven additional wells have been plugged during the life of this program. Approximately 260 million gallons of waste are injected annually into the deep subsurface strata of our state through the ten permitted wells. The wastes originate from a variety of industrial processes, including steel processing, fertilizer and fungicide production, and plastics production. Some of the newer components of this waste stream are products of other waste-disposal and clean-up methods, such as incinerator scrubber water, liquids recovered from industrial spill remediation, and leachate from solid-waste disposal sites.
Location of Class I Injection wells.
A quick look at a list of waste generators illustrates how hard it would be for our society to do without the products from these industries. How different our lives would be without steel and metal alloys or the multitude of plastic products! And without modern fertilizers and fungicides, which dramatically increase the yield of our farmlands, the balance of American society as well as international relations would be altered. Add to this list the thousands of jobs and the millions of dollars these industries annually pump into our economy and one can quickly see that we are dependent upon these industries and thus must deal with the wastes they generate. Furthermore, we must always remember that how we deal with these wastes now will affect the well-being of generations to come.
Note: The above location map shows injection well sites. With the exception of the Cargill site, information for wells drilled into the Precambrian and seismic reflection data can be obtained from Map PG-23. Download map and report here. [3 MB PDF]
The U.S. Environmental Protection Agency's (USEPA) Underground Injection Control (UIC) program recognizes five classes of injection wells, which are are defined, in part, by each well's relationship to an Underground Source of Drinking Water (USDW). The Safe Drinking Water Act (SDWA) of 1974 designated as a USDW any aquifer whose water contains a concentration of less than 10,000 mg/L of total dissolved solids. The five injection well classes are:
- Class I wells—Used for injection of industrial or municipal waste fluids beneath the lowermost formation containing a USDW.
- Class II wells—Used for injection of brines produced by oil and gas production or fluids used for enhanced recovery of oil or natural gas.
- Class III wells—Used for injection of fluids for the extraction of soluble minerals, such as salt solution mining in northeastern Ohio.
- Class IV wells—Used for injection of hazardous or radioactive wastes into or above a USDW. As of May 11, 1984, all Class IV wells have been banned in the United States.
- Class V wells—Not covered by Classes I through IV. These wells generally are used for the disposal of nonhazardous fluids and include storm water drainage wells, industrial-drainage wells, heat pump and air-conditioning return wells, cesspools, septic systems, floor drains, and sumps.
Under this system of classification, Ohio's deep industrial-waste disposal wells are all in the Class I category. The USEPA further subdivides this category on the basis of whether the injectate is classified as hazardous or nonhazardous waste. Three of Ohio's Class I facilities inject hazardous waste.
Deep injection of industrial wastes has been practiced since the 1950s. However, no federal regulations governed these wells until passage of the 1974 SDWA. Prior to 1974 individual states self-regulated the drilling and operation of Class I wells. In Ohio the Department of Natural Resources (ODNR) has maintained key involvement in the Class I program. The former Division of Oil and Gas originally had the responsibility of regulating this program. And the Division of Geological Survey has had the longest continuous involvement of any state agency with this program, having worked on it in various capacities since 1968.
In 1980 the USEPA promulgated most of the current UIC regulations. Under these rules, a state may develop a UIC program and apply for primary responsibility ("primacy") for that program. A state must use federal regulations as a baseline and may develop more stringent regulations. After passage of federal regulations, the Ohio Environmental Protection Agency (Ohio EPA) began taking a more pronounced role in the Class I program and in 1985 received primacy from the USEPA. Under current Ohio law, the Ohio EPA is required to review and provide technical assistance on all Class I permit applications from the ODNR divisions of Geological Survey; Soil and Water Resources; and, if the proposed well is in a coal-bearing area, Mineral Resources Management. Review by these divisions provides the Director of the Ohio EPA with information that relates a Class I well permit decision to protection of mineral and oil and gas resources, as well as ground-water availability. Comments generated by ODNR are considered by the Director of the Ohio EPA in establishing permit conditions, if it is decided that a permit to drill or a permit to operate should be issued.
Under Ohio law, all Class I well permits are issued for five years. An operator must update each permit application and submit it for review prior to the expiration date. Permits for the three Class I facilities in Ohio are staggered so they do not all come up for review at the same time. Review of permit renewals, as well as permit modification requests, new well requests, appeals, or other Class I well issues requires the Division of Geological Survey's Energy Resources Group to spend a considerable amount of time on the geology of Class I sites.
In 1984 the U.S. Congress passed the Hazardous and Solid Waste Amendments to the Resource Conservation and Recovery Act. Under this legislation, which has had a large impact on the regulation of some Class I wells, land disposal of all untreated hazardous waste is prohibited after specified dates unless the USEPA has determined that such disposal practices are protective of human health and the environment. These regulations are commonly known as the "Landban Program." Class I well operators have had to submit lengthy documents demonstrating that their sites and practices are safe and that human safety and welfare are protected. Under Landban, a petitioner must demonstrate that, to a reasonable degree of certainty, there will be no migration of hazardous constituents from an injection zone as long as the waste remains hazardous.
In 1987 the USEPA, through the Ohio EPA, contracted with the Division of Geological Survey to assist in the review of the Landban petitions for the hazardous-waste injection sites then operating in Ohio. The federal Landban regulations have strengthened the Ohio program and have allowed detailed analyses of the geology, construction, and operation of these injection wells.
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*This article originally appeared in the Fall 1992/Winter 1993 issue of Ohio Geology.