Out of Sight, Out of Mind?
An Analysis of Underground Injection Data
July 1998
National Environmental Trust
1200 18th Street, NW
Fifth Floor
Washington, DC 20036
National Environmental Trust would like to thank the following individuals for their time and expertise in providing information and/or reviewing this report. We apologize to anyone who should be listed but was inadvertently omitted. Not all reviewers agreed with the conclusions reached in the report.
Roger Anzzolin, EPA
Dan Arthur
Joe Ball, Lousiana Department of Environmental Quality
Don Barratt, Oklahoma Department of Environmental Quality
Jerry Delevan, Arkansas Department of Pollution Control and Ecology
Mark Dorfman, INFORM
Melinda Dower, New Jersey Department of Environmental Protection
Karen Florini, Environmental Defense Fund
Peggy Franklin
Phyllis Glazer, Mothers Organized to Stop Environmental Sins
Charles Green, Texas Natural Resource Conservation Commission
Linda Greer, Natural Resources Defense Council
Ben Grunewald, Ground Water Protection Council
Carolyn Hartmann, U.S. PIRG
Katherine Herzog, Texas Natural Resource Conservation Commission
Kurt Hildebrandt, EPA Region VII
Harriet Hubbard, EPA
Dan Jackson
Ben Knape, Texas Natural Resource Conservation Commission
Bruce Kobelski, EPA
Steve Lester, Center for Health, Environment, and Justice
R.P. Lilly
Nancy March, EPA Region IV
Catherine Miller, Hampshire Research
Don Olson, EPA
Gregg Olson, EPA Region IX
Paul Orum, Working Group on Community Right-to-Know
Paul Osborne, EPA Region VIII
Andy Smith, Legal Environmental Assistance Foundation
Bob Smith, EPA
Wilma Subra, Louisiana Environmental Action Network
Beth Teel, Tulane Environmental Law Clinic
Nathan Wiser, EPA Region V
This report was also reviewed and commented upon by members of the Chemical Manufacturers Association’s UIC Task Group.
Written by Rich Puchalsky and Tom Natan
For more information on this report, please contact us at:
National Environmental Trust
1200 18th Street, NW, Fifth Floor
Washington, DC 20036
Phone: 202/887-8800
Fax: 202/887-8877
National Environmental Trust (NET) is a non-profit, non-partisan organization that conducts public education campaigns on environmental issues.
"Underground injection" is a term used to describe the disposal of wastes into deep wells. The most regulated or "Class I" wells inject waste into geologic formations below sources of drinking water. Major industry lobbying groups are advancing the view that the precautions required by regulation make underground injection virtually leakproof, and thus not a release to the environment (as currently defined under one environmental law, the Emergency Planning and Community Right-to-Know Act of 1986). At the same time, citizens’ groups are opposing new and existing wells in their communities, in part because of fears about leaks and emissions, either from the well, or from storage of material before it is injected. This report does not attempt to clarify the debate over releases, but instead analyzes data about wastes sent to Class I wells to inform the public about the kinds of substances injected underground, the locations where these injections occur, and some insight into the operations of facilities that use injection wells for disposal of hazardous waste.
In addition, this report examines how difficult it is for a member of the public to gather basic information about wells. We find that there is no reliable, easily accessible, national source of underground injection well information – unacceptable at a time in which Right-to-Know has been a long-running success story and a high priority for EPA.
Other findings of this report include:
In Willow Springs, LA, citizens complain of accidents, spills, and exposure to air releases associated with a commercial injection well facility. In Romulus, MI, the city has spent more than $700,000 in a successful effort to enforce local zoning laws against a proposed well. And in Winona, TX, community activists organized and litigated against companies operating an underground injection well facility that they blamed for elevated rates of birth defects and other health problems.
At the same time, lobbying groups like the Chemical Manufacturers Association have been advocating the benefits of underground injection versus releases to air or surface water. Once permitted and operational, underground injection can certainly be cheaper than any other large-scale, EPA-approved method of managing waste, and its proponents argue that EPA regulations ensure that waste disposed of in Class I wells will remain isolated from drinking water for 10,000 years.
The opposing views of environmental groups and industry representatives toward underground injection have come into conflict in Congress, in state legislatures, and in regulatory battles at EPA. As an example, consider the Toxics Release Inventory, or TRI, the country’s premier public data resource for information on toxic pollution from manufacturers, and one of two national databases containing underground injection data. Industry groups recently launched a campaign to change the way that underground injection is described within TRI. Although underground injection is currently defined by statute as a release to the environment, industry would like it listed as disposal, claiming EPA has determined that it is safer than air or water releases, and thus should not be placed in the same category. Environmental groups opposed to the change argued that wells leak, and that this change in reporting would make it more publicly acceptable for manufacturers to inject waste into a wall, rather than figuring out ways of not generating it in the first place. Retaining underground injection data in total releases – the data most often used by the public and the media – would ensure that the waste could not be ignored. Finally, EPA affirmed that the statute authorizing TRI specifically stated that underground injection was a release, and so refused the change. Since that time, groups on both sides of the issue have suggested that it should be called an "indirect" release rather than a release. And industry has begun lobbying for a legislative change in the TRI release definition.
What would cause this level of interest not only in the rules governing the underground injection of waste, but even in the public terminology used? NET decided to compile data on underground injection from various EPA sources to find out how much injection was taking place, what facilities and wastes were involved, and where the wastes were going. In the process, we created a national database of Class I wells showing which wastes were going to each. (Class I wells are the most highly regulated type, and the type most often used for underground injection of toxic industrial wastes. For an explanation of underground injection terms, see Appendix I). This report summarizes information from that database with a view to inform the public about the current state of the industry and the major underground injection sites for toxic waste.
This report also has a second purpose: to find out how easy or difficult it is to obtain basic information on underground injection wells. The Toxic Release inventory was one of the first "Right-to-Know" laws. These are intended to give any member of the public information on polluters in their community and judge for themselves what the risks are from these facilities. As a method of encouraging the reduction of pollution, Right-to-Know laws have been hailed as both effective, since no facility wants to be listed as the major polluter in an area, and less restrictive on industry than command-and-control regulation. If this reasoning is accepted, it then becomes important to find out how easy it is for an ordinary member of the public to obtain basic information on wells such as location, regulatory status, wastes handled, and a history of violations.
This report does not attempt to describe the ways that wells can fail or to summarize numbers of accidents and permit violations. Previous reports have focused on methods of well failure,(1) and collecting national information on violations is difficult because the information has not been put into an accessible database (see Part II for a description of these difficulties). If there are concerns about a local well, there are a number of grassroots environmental groups that can assist in finding more information.(2)
To collect information for this report, we went to EPA headquarters, the EPA regions, and some state environmental agencies. We also did extensive searches of on-line databases. Part I summarizes what we found in the form of answers to seven questions:
Part II recounts the difficulties we had in obtaining the information and describes the current state of Class I well information at EPA. The procedures we used in collecting the data are described in Appendices II and III. For a description of specialized underground injection terms and regulations such as RCRA, see Appendix I, which also describes the process of demonstrating "no-migration" under RCRA. Finally, the endnotes contain information on methodologies used in the analyses, as well as additional sources of information on injection.
Mothers Organized to Stop Environmental Sins (M.O.S.E.S.) is a nonprofit grassroots group started in Winona, TX to combat a commercial Class I well facility that was first known as Gibraltar Chemical Resources. Their story, as told by M.O.S.E.S.’s documents, is presented here as an example of one group’s experience with underground injection.(3)
Winona residents complained of releases of air pollutants, noxious odors, and chemical spills, as well as emergency evacuations from accidents at the facility. Residents saw a pattern of health problems and birth defects, especially among people living close by the plant in the Watersbluff section. Many of the people there are descendants of slaves who worked lands in the area.
Chronology of events:
1981
The future operators of Gibraltar Chemical Resources tell residents that the new well would be used to inject salt water from oil field operations (i.e., that it would be a Class II well), and that fruit orchards would be planted on the rest of the site. No fruit orchard was ever planted. Instead, the site would eventually involve two Class I wells, a solvent recovery business, and a hazardous waste fuel blending operation.
1982
Gibraltar starts operation of its first Class I well.
1985
The state of Texas brings civil suit against Gibraltar Chemical Resources for violations under the Texas Solid Waste Disposal Act, including improper operation and monitoring of the well. Gibraltar settles with a consent decree for $80,000.
1989
Following the RCRA "land ban" (which requires treatment of hazardous waste before injection, or a permit demonstrating that the material does not migrate into sources of drinking water), Gibraltar submits a no-migration petition in order to continue injection of untreated waste in its first well, and to commence injection in a second. EPA grants a no-migration petition for both wells. The second well is constructed with an 800 foot-long gap in its concrete sealant – this sealant is supposed to help prevent leakage from the well into drinkable water. The 800 foot-long gap is 363 feet below the drinking water aquifer for parts of Texas, Arkansas, and Louisiana.
At some point during this period, a group of Winona residents called "Concerned Citizens of Winona" files suit against Gibraltar. The settlement is subject to a confidentiality agreement.
1990
A number of environmental groups challenge Gibraltar’s no-migration petition through a lawsuit.
1991
An explosion and release at the plant leads to the involvement of Phyllis Glazer, who lives on a family ranch in the area. She would eventually spend millions of dollars of her own money to hire experts and lawyers, making M.O.S.E.S.’s struggle with Gibraltar one of the few in which a grassroots group was not heavily outspent by industry.
A later analysis of TRI data from this year would reveal that, at this point, the Gibraltar facility received more pounds of TRI chemicals than any other commercial injection well facility in the country (about one-third of all commercial injection in 1991).
1992
M.O.S.E.S. is formed.
1993
An accident at the plant releases a large cloud of corrosive hydrogen bromide and other chemicals. M.O.S.E.S. pickets the plant once a week for seven months, in demonstrations they call "Operation Chemical Storm."
In response to the 1990 lawsuit, EPA denies the no-migration petition for Gibraltar’s second well, due to the 800 foot gap in the concrete casing.
1994
Gibraltar’s permits are up for re-authorization. M.O.S.E.S. contests the permits; also many tort lawsuits have been filed over personal injury. By this time, a non-M.O.S.E.S. class action suit has begun, with 652 plaintiffs suing for $200 million. Gibraltar settles a tort suit with some of the nearest neighbors of the plant. The company also settles Texas’s civil suit for $1.5 million.
Near the end of the year, American Ecology Environmental Services Corporation purchases the Winona site from Gibraltar Chemical Resources for $5.5 million.
1996
EPA re-approves the no-migration petition for the second well. M.O.S.E.S. contends that even though the 800 foot gap has never been fixed (except with drilling mud rather than concrete), EPA grants an exemption because Texas has lowered its standards for well construction. One EPA employee will later claim that EPA worked to help weaken Texas regulation in order to allow the well to be permitted.
Later that year, American Ecology announces suspension of operations and receipt of hazardous waste at the Winona facility. The company blames this surprise decision on adverse impact on the business base caused by public statements of people opposed to the facility, and on demands on managerial resources caused by lawsuits.
Within a couple of months, American Ecology and other corporations sue M.O.S.E.S., Phyllis Glazer, and members of her family for making defamatory public statements, including one in a newspaper article. Ralph Nader dubs this lawsuit a "SLAPP;" a Strategic Lawsuit Against Public Participation intended to scare off opponents who are exercising their rights to make public statements on political issues.
1997
American Ecology formally closes down the Winona site.
At the time this report was published, the class action lawsuit against American Ecology and the suit against M.O.S.E.S. were still ongoing. M.O.S.E.S. has counter-sued American Ecology for a frivolous lawsuit and for harm to the organization.
Data collected for this report are shown in much greater detail on our Web site,
http://www.envirotrust.com. The sections below are divided into questions that summarize the data in various ways.The two primary national sources for data on waste disposal and release quantities are the Biennial Reporting System (BRS) and Toxic Release Inventory (TRI) databases. These databases are described in Appendix III. For comparing underground injection as a waste disposal method to other waste disposal methods, the BRS database is most relevant because it tracks quantities of hazardous waste regulated under the Federal RCRA law.
Within BRS, EPA divides units that treat or dispose of hazardous waste into two types: RCRA regulated and non-RCRA regulated. Non-RCRA regulated units are those that are either regulated under other laws, such as the Clean Water Act, or those that typically handle less hazardous waste. Underground injection wells used for hazardous waste are considered to be RCRA regulated land disposal units.
Underground injection ranks third for volume of toxic chemicals handled among the 17 possible management methods. The 24.6 million tons(4) of hazardous waste sent to deep well injection in 1995 represent 12 percent of the total of 208 million tons managed in RCRA regulated units. More hazardous waste is sent to underground injection than to all incineration, recycling, landfill, and other permitted land disposal methods combined. One major reason why underground injection ranks so far above the non-aqueous waste treatment methods is that injected wastes tend to contain a lot of water, which is included in the RCRA waste quantities.
Table 1.Waste management categories from the 1995 National Biennial RCRA Hazardous Waste Report (RCRA-regulated units only)
|
Waste management type |
Millions of tons managed |
|
Aqueous Organic Treatment Units |
117 |
|
Aqueous Organic and Inorganic Treatment Units |
28 |
|
Deep Well/Underground Injection |
24 |
|
Other Treatment |
18 |
|
Aqueous Inorganic Treatment Units |
8 |
|
Incineration |
4 |
|
Energy Recovery |
2 |
|
Fuel Blending |
2 |
|
Landfill |
1 |
|
Stabilization |
1 |
|
Other Disposal |
0.7 |
|
Metals Recovery |
0.6 |
|
Surface Impoundment |
0.6 |
|
Sludge Treatment |
0.5 |
|
Other Recovery |
0.4 |
|
Solvents Recovery |
0.4 |
|
Land Treatment/Application/Farming |
<0.1 |
TRI provides another view of underground injection as a release of toxic chemicals to the environment. TRI reports contain quantities of specific toxic substances, as opposed to RCRA data which may also contain quantities of non-toxic substances such as water. When compared to other forms of release, on-site underground injection makes up 11 percent of the total – 235 million pounds out of 2.2 billion released in 1995 TRI data. The rest are releases to air, land, and surface water. For off-site transfers, underground injection accounted for only 18 million out of 3.5 billion pounds (three percent of waste transferred off site).
Table 2. 1995 TRI on-site release quantities
|
Release Type |
Millions of pounds |
|
Air |
1,562 |
|
Land |
275 |
|
Underground Injection |
235 |
|
Surface Water |
136 |
With 12 percent of hazardous waste management and 11 percent of on-site toxic releases, underground injection accounted for just over a tenth of both quantities in 1995.
Between 1988 and 1995(5), regulation of underground injection wells changed appreciably, most notably with a series of RCRA regulations banning the land disposal of untreated hazardous waste. Several people that we talked to for this report expressed the belief that, because of these changes, underground injection quantities might have decreased significantly over this period. To examine whether this was the case, we looked at how total TRI(6) and BRS waste quantities changed over these years.
The answer is that waste quantities have decreased only slightly within BRS and TRI. From 1991 to 1995, BRS quantities of injected waste managed on site plus shipped off site decreased by about 260,000 tons, a 1 percent decrease.(7) TRI on-site plus off-site underground injection quantities actually increased from 1991 to 1995 by 2.4 million pounds or 1.6 percent. However, from 1988 to 1991 TRI quantities decreased by 24 million pounds, or 14 percent. This period may have seen the effect of the RCRA "land ban." For the longest period available, for TRI from 1988 to 1995, there was a total decrease of 21 million pounds or 12 percent (among those chemicals reported consistently for those years, the core chemical set).
The number of facilities reporting underground injection has shown a greater decrease. In 1991 BRS, there were 47 on-site and 14 commercial well facilities reported, for a total of 61. This total decreased to 54 by 1995. In TRI, the commercial wells do not report directly, but the number of facilities reporting on-site injection decreased from 124 to 91 between 1988 and 1995. This is a larger percentage decrease than for quantities of waste injected, and may indicate that some wells closed due to more stringent regulations. However, given the smaller change in the waste quantities, closure may have occurred only at smaller and more marginal wells.
The tables below show changes in BRS and TRI numbers from year to year.
Table 3. BRS Management On-site in Underground Injection Wells
|
Year |
Number of facilities |
Number of records |
Tons disposed on-site |
Percent of all on-site management(8) |
|
1991 |
47 |
83 |
24,194,478 |
8.9 % |
|
1993 |
52 |
105 |
24,387,767 |
11 % |
|
1995 |
42 |
108 |
23,988,910 |
12 % |
Table 4. BRS Shipments Off-site to Underground Injection Wells
|
Year |
Number of shippers |
Number of records |
Tons shipped |
Percent of all off-site shipments |
|
1991 |
542 |
1,115 |
652,669 |
5.2 % |
|
1993 |
522 |
1,044 |
655,084 |
3.8 % |
|
1995 |
592 |
1,165 |
601,179 |
5.6 % |
Table 5. BRS Waste Received at Underground Injection Wells (see Endnote 7)
|
Year |
Number of facilities |
Number of records |
Tons received |
Percent of all waste received |
|
1991 |
14 |
4,411 |
268,394 |
3.6 % |
|
1993 |
16 |
1,646 |
701,881 |
8.9 % |
|
1995 |
12 |
1,398 |
622,887 |
7.1 % |
The total amount managed in all types of RCRA permitted units dropped steadily from 279 million tons in 1991, to 234 million in 1993, to 208 million in 1995. At the same time, underground injection quantities have stayed relatively steady. As a result, underground injection accounts for an increasing percentage of the BRS managed waste stream, as can be seen in the last column of Table 3 above.
Table 6. TRI Core Chemical On-site Releases to Underground Injection Wells(9)
|
Year |
Number of facilities |
Number of records |
Pounds Injected |
Percent of all on-site releases |
|
1988 |
124 |
545 |
161,939,132 |
5.5 % |
|
1989 |
113 |
569 |
157,781,635 |
6.0 % |
|
1990 |
305 |
955 |
159,889,409 |
6.4 % |
|
1991 |
111 |
568 |
139,630,811 |
6.2 % |
|
1992 |
106 |
570 |
121,216,674 |
5.7 % |
|
1993 |
96 |
519 |
113,289,640 |
6.0 % |
|
1994 |
98 |
507 |
114,170,231 |
6.7 % |
|
1995 |
91 |
466 |
136,751,624 |
8.5 % |
The total core chemical releases to air, water, land, and underground within TRI have dropped from 3 billion pounds in 1988 to 1.6 billion in 1995.
Table 7. TRI Core Chemical Off-site Transfers to Underground Injection Wells
|
Year |
Number of shippers |
Number of records |
Pounds |
Percent of all off-site transfers to disposal |
|
1988 |
161 |
492 |
8,962,004 |
2.3 % |
|
1989 |
180 |
547 |
11,878,112 |
3.6 % |
|
1990 |
192 |
602 |
10,500,631 |
2.8 % |
|
1991 |
203 |
608 |
7,687,272 |
3.5 % |
|
1992 |
188 |
564 |
8,921,240 |
4.3 % |
|
1993 |
199 |
551 |
9,566,943 |
3.8 % |
|
1994 |
197 |
577 |
10,719,142 |
4.1 % |
|
1995 |
182 |
534 |
12,946,718 |
5.1 % |
Total injection quantities within BRS and TRI have declined relatively slowly, about 12 percent in TRI since 1988 and 1 percent in BRS since 1991. Total waste and release quantities within these databases have declined much faster, by about 44 percent in TRI(10) since 1988 and by 25 percent in BRS(11) since 1991. That means that underground injection is being used for an increasing percentage of the total waste stream, even as the number of underground injection facilities is declining.
BRS and TRI offer some ability to assess what kinds of hazardous and toxic waste are being disposed of in underground injection wells. However, the two databases do not provide results that are directly comparable to each other. One major difference is that TRI reports pounds of toxic chemicals in waste, while BRS reports pounds of waste, including the toxic or hazardous component plus the amount of non-hazardous filler such as water or soil. Within BRS, it is not possible to tell exactly how much of the waste consists of each individual hazardous constituent. (For a full discussion of these differences, see Appendix III).
The TRI chemical list was chosen primarily on the basis of human or ecological toxic effects. The selection of regulated wastes in RCRA BRS is more complex, but basically comes down to properties of toxicity, reactivity, corrosivity, or ignitability. Because deep-well-injected wastes are usually dilute, reactivity and ignitability are generally not common in these wastes. Corrosive wastes, however, can damage well systems and cause leaks.
Within the 1995 TRI, there were 153 different chemicals sent to non-commercial wells and 130 sent to commercial ones. A list of the top 30 in each category is presented in Tables 18 and 19 in Appendix IV. The top five chemicals released to wells on-site were nitrate compounds, acetonitrile, methanol, ammonia, and nitric acid. The top five chemicals sent to off-site wells were nitric acid, sulfuric acid, zinc compounds, methanol, and hydrochloric acid. In both cases the top five chemicals accounted for approximately 60 percent of the total waste sent to wells.
The BRS National Report sums up waste streams according to certain regulatory categories. "Characteristic" waste exhibits one of the hazardous RCRA characteristics under testing. "Listed" waste is waste from specific industrial processes, or certain types of waste that have already been tested and found to be hazardous. A waste can have more than one waste code, and how much of the waste consists of each code is not reported – therefore categories for wastes with multiple codes are necessary. Injected BRS wastes are classified according to this scheme in the table below.(12)
Table 8. BRS wastes injected underground by category
Tons Number Number Tons Number
Managed of Tons of Managed/ of
On-site Records Shipped Records Received Records
Ignitable 168 3 30,691 56 15,360 61
Corrosive 2,000,817 9 35,441 172 188,896 265
Reactive 499,087 1 2,182 3 18 1
Toxic 18,771 1 15,100 58 13,993 110
New Toxic 1,402,412 7 10,907 30 10,068 35
>1 characteristic 8,080,339 24 324,021 413 244,735 567
"F" listed code 217,836 6 72,484 41 24,116 36
"K" listed code 2,043,525 7 12,289 7 2,550 3
"P" listed code 0 1 2,459 2 750 3
"U" listed code 4 5 245 8 1,096 19
>1 listed code 1,099,841 4 19,231 29 38,031 57
Both char. & listed 8,626,111 40 76,128 215 83,273 196
A few major points can immediately be seen from this table. First, a large majority of the waste has more than one code, making real characterization of individual substances impossible. Second, the waste shipped and waste received categories do not exactly agree with each other. This may be due to a number of causes, including waste sent one year that is disposed of on the next, waste sent under RCRA but disposed of in a non-RCRA unit and not reported, and waste records claimed as confidential business information. Finally, there is more characteristic waste than listed waste, although mixed characteristic and listed waste is the largest category.
Tables 20 and 21 in Appendix IV show quantities for the top 30 waste codes injected on site and sent off-site for injection. The top five types of waste managed on site were benzene, corrosive waste, reactive waste, bottom stream from acetonitrile columns in production of acrylonitrile, and bottom stream from wastewater strippers in production of acrylonitrile. The top five types of waste managed off site were corrosive waste, benzene, ignitable waste, leachate from the treatment and disposal of multiple wastes, and reactive waste.(13)
This report also examines two groups of chemicals: persistent or bioaccumulative toxics, and volatile carcinogens. Persistent bioaccumulative toxics (PBTs) are of high concern when released to the environment because they do not degrade. Thus, any leakage, even years after injection, may be cause for concern. The following table presents a list of PBTs(14) injected to wells and reported under TRI or BRS. The list is sorted by chemical name:
Table 9. Underground injection of Persistent Bioaccumulative Toxics (PBTs) reported under TRI and BRS.(i)
Chemical Name
Facility Name State TRI BRS Quantity
(pounds) (tons per code)
CADMIUM
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 0 30,392
CHEMICAL WASTE MANAGEMENT, INC. OH 0 5,285
DISPOSAL SYSTEMS, INC. TX 0 3,416
AMERICAN ECOLOGY CORP. TX 0 2,779
DISPOSAL SYSTEMS OF CORPUS CHRISTI, GNR G TX 0 1,097
Total 0 43,583
CADMIUM COMPOUNDS
Total 109 --
CHLORDANE
Total 0 585
DECABROMODIPHENYL OXIDE
Total 11 0
DI-(2-ETHYLHEXYL) PHTHALATE
Total 0 264
DIELDRIN
Total 0 264
HEXACHLORO-1,3-BUTADIENE
VULCAN CHEMICALS KS 434 78,092
Total 434 78,659
HEXACHLOROBENZENE
VULCAN CHEMICALS KS 480 78,092
Total 480 78,716
HEXACHLOROCYCLOPENTADIENE
Total 250 264
HEXACHLOROETHANE
VULCAN CHEMICALS KS 1,378 78,092
Total 1,378 78,664
LEAD
EMPAK, INC. TX 606,276 757
DUPONT DELISLE PLANT-WHITE PIGMENT & MINE MS 0 303,078
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 0 30,392
CHEMICAL WASTE MANAGEMENT, INC. OH 300 6,826
DISPOSAL SYSTEMS, INC. TX 1,140 5,346
AMERICAN ECOLOGY CORP. TX 1,199 2,985
Total 609,029 349,876
LEAD COMPOUNDS
CHEMICAL WASTE MANAGEMENT, INC. OH 2,300 --
Total 3,249 --
LINDANE
VULCAN CHEMICALS KS 0 78,092
Total 0 78,589
MERCURY
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 0 30,392
CHEMICAL WASTE MANAGEMENT, INC. OH 0 1,675
Total 0 33,558
MERCURY COMPOUNDS
Total 6 --
METHOXYCHLOR
Total 0 460
POLYCYCLIC AROMATIC COMPOUNDS
Total 2 --
TETRACHLOROBENZENE (1,2,3,4 AND 1,2,4,5 [TOXAPHENE])
Total 0 494
Grand Total 614,948 743,978
This table shows that it is impossible to determine the amounts of PBTs injected underground from these sources, especially for individual substances. There are a number of PBTs that appear substantially in BRS but not TRI, such as cadmium, chlordane, lindane, and mercury. The TRI reporting threshold has a "de minimus" provision that allows facilities not to report waste more dilute than a one percent concentration (0.1 percent for carcinogens). This concentration can still trigger BRS reporting of characteristic waste. Likewise, waste reportable to TRI may not exhibit BRS toxicity characteristics. Clearly, both data systems are needed to determine the destinations of these chemicals. EPA is currently reviewing TRI reporting thresholds for PBTs, a process which may resolve the discrepancies with substances reported, although not with reported quantities (since BRS data include amounts other than specific chemicals).
Some residents who live near commercial injection wells have complained about accidents in transit, spills, and air releases from these sites. We examined one chemical group of concern -- volatile organic compounds (VOCs) that are also carcinogens -- to determine whether their injection amounts were significant.(15) Volatile organic compounds are classified as such because they will readily evaporate into the air, making them more dangerous in the event of accidents and spills.
Table 10. VOC Carcinogens reported under TRI and BRS.(ii)
Chemical Name
Facility Name State TRI BRS Quantity
(pounds) (tons per code)
1,1-DIMETHYL HYDRAZINE
Total 0 264
1,2-DIBROMOETHANE
Total 0 264
1,2-DICHLOROETHANE
VULCAN CHEMICALS KS 1,828 78,092
MORTON INTERNATIONAL, INC. MS 12,389 0
THE UPJOHN COMPANY MI 10,000 540
Total 25,094 91,181
1,3-DICHLOROPROPYLENE
Total 0 264
1,4-DICHLOROBENZENE
Total 0 849
1,4-DIOXANE
EMPAK, INC. TX 332,526 5
OXIDE INC. TX 13,298 0
Total 345,824 264
2,4-D 2-ETHYLHEXYL ESTER
Total 3,131 0
2-NITROPROPANE
Total 0 264
3,3'-DICHLOROBENZIDINE
Total 0 264
4,4'-METHYLENEBIS(2-CHLOROANILINE)
Total 0 264
ACETALDEHYDE
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 120,000 0
SOLUTIA (FORMERLY MONSANTO) (OPERATOR F FL 120,000 0
HOECHST CELANESE CHEMICAL COMPANY (BAY CI TX 108,301 0
STERLING CHEMICALS (TEXAS CITY) TX 87,290 0
E.I. DUPONT DENEMOURS AND COMPANY (HOUSTO TX 84,994 0
BP CHEMICALS AMERICA CO. TX 60,000 0
BP CHEMICALS OH 24,000 0
Total 605,885 330
BENZENE
E.I. DUPONT DE NEMOURS AND COMPANY (VICTO TX 8,270 1,625,693
AMOCO OIL COMPANY (TEXAS CITY PLANT) TX 170,000 1,029,741
E.I. DUPONT DE NEMOURS AND COMPANY (SABIN TX 62,386 648,159
ARCO CHEMICAL COMPANY (CHANNELVIEW PLANT) TX 16,756 359,192
MONSANTO COMPANY (CHOCOLATE BAYOU PLANT) TX 58 365,899
BASF CORPORATION (FREEPORT ROAD) TX 7,000 281,555
VULCAN CHEMICALS KS 0 156,184
BETHLEHEM STEEL CORP. (BURNS HARBOR) IN 0 123,293
E.I. DUPONT DE NEMOURS CO. (BEAUMONT PLAN TX 223 106,847
MERICHEM COMPANY TX 4,000 87,548
BP CHEMICALS AMERICA CO. TX 400 63,427
DISPOSAL SYSTEMS, INC. TX 19,684 15,933
HOECHST CELANESE CHEMICAL COMPANY TX 0 21,691
RUBICON, INC. LA 10,400 0
Total 306,742 4,903,289
BENZOIC TRICHLORIDE
Total 250 264
CARBON TETRACHLORIDE
VULCAN CHEMICALS KS 53,964 156,184
Total 56,907 161,125
CHLORDANE
Total 0 585
CHLOROFORM
VULCAN CHEMICALS KS 35,444 156,184
Total 35,726 165,270
CHLOROMETHYL METHYL ETHER
Total 0 264
CREOSOTE
Total 5 281
DICHLOROMETHANE
GREAT LAKES CHEMICAL CORPORATION AR 838,279 0
MONSANTO COMPANY (CHOCOLATE BAYOU PLANT) TX 200,000 9,508
VULCAN CHEMICALS KS 19,056 78,092
THE UPJOHN COMPANY MI 72,000 0
PARKE-DAVIS DIVISION OF WARNER LAMBERT MI 11,000 0
Total 1,145,040 90,715
DIMETHYL SULFATE
Total 0 264
EPICHLOROHYDRIN
Total 0 265
ETHYL ACRYLATE
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 0 30,392
Total 255 30,817
ETHYLENE OXIDE
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 130,000 71,992
Total 130,000 72,318
ETHYLENE THIOUREA
Total 0 230
ETHYLENEIMINE
Total 0 230
FORMALDEHYDE
MONSANTO CO. LA 4,000,000 0
ANGUS CHEMICAL COMPANY LA 2,506,514 0
HOECHST CELANESE CHEMICAL COMPANY TX 530,000 63
MONSANTO COMPANY (CHOCOLATE BAYOU PLANT) TX 160,000 148,723
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 31,000 0
SOLUTIA (FORMERLY MONSANTO) (OPERATOR F FL 28,000 0
BP CHEMICALS OH 26,000 0
AIR PRODUCTS CORPORATION KS 22,000 0
Total 7,327,057 150,531
HEPTACHLOR
Total 0 225
HYDRAZINE
DISPOSAL SYSTEMS, INC. TX 23,499 0
Total 23,499 266
LINDANE
VULCAN CHEMICALS KS 0 78,092
Total 0 78,589
MECOPROP
Total 2,049 --
METHOXONE
Total 1,537 --
N,N-DIMETHYLFORMAMIDE
THE UPJOHN COMPANY MI 1,000,000 --
EMPAK, INC. TX 134,610 --
UOP, INC. LA 99,000 --
Total 1,233,860 --
PENTACHLOROPHENOL
Total 0 304
POLYCYCLIC AROMATIC COMPOUNDS
Total 2 --
PROPYLENE OXIDE
ARCO CHEMICAL COMPANY (CHANNELVIEW PLANT) TX 22,577 --
Total 30,645 --
PROPYLENEIMINE
Total 0 225
SAFROLE
Total 0 230
STYRENE
ARCO CHEMICAL COMPANY (CHANNELVIEW PLANT) TX 209,945 --
Total 219,796 --
TETRACHLOROETHYLENE
VULCAN CHEMICALS KS 20,481 0
Total 20,749 4,878
TRICHLOROETHYLENE
Total 555 836
URETHANE
Total 0 230
VINYL ACETATE
HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE TX 540,000 --
HOECHST CELANESE CHEMICAL COMPANY (BAY CI TX 153,128 --
E.I. DUPONT DENEMOURS AND COMPANY (HOUSTO TX 82,001 --
Total 783,834 --
VINYL CHLORIDE
Total 33 7,498
Grand Total 12,298,475 5,763,939
To put these numbers in the context of TRI releases, total releases of these VOC carcinogens to all environmental media in 1995 were 208 million pounds. Of these, 190 million pounds were air emissions, 1.3 million pounds were discharged to surface water, and 540,000 pounds were released to land. There were 11.7 million pounds injected underground on site and nearly 586,000 pounds sent off site for injection. In total, on-site underground injection represented 5.6 percent of the total on-site releases of VOC carcinogens.
While this percentage is less than the average for all TRI chemicals (11 percent), it is clear that injection occurred at very few facilities. Of 4,659 that reported releases of VOC carcinogens 43 injected wastes containing these chemicals underground, or 0.9 percent of such facilities.
There is some question as to whether these chemicals should be injected at all because of their high rate of evaporation under standard conditions. Apart from possible air emissions at the wellhead, any air emissions from surface handling prior to injection (evaporation at the surface, spills, or transfer losses) will likely not be regulated, since well units generally do not have air permits or air monitoring equipment (their RCRA well permits may have air provisions for surface activities, but this is not always the case). TRI reporting instructions are clear that facilities must report all on-site air emissions of TRI chemicals, including leaks from wells and any emissions from storage or transport prior to on-site injection. In practice, however, if there is no monitoring for air emissions, then it is difficult to dismiss potential exposure a priori. Further investigation of possible air emissions from wells and pre-injection storage and transport is needed.
Underground injection wells are generally divided for purposes of regulation into five classes (I through V). Class I wells are intended for disposal of waste and have special precautions against leakage, Class II are for disposal of brines from oil extraction, Class III are for solution mining, Class IV are illegal, because they inject toxic waste into or above sources of drinking water,(iii) and Class V are "shallow" wells. One would expect most TRI and BRS waste to be injected into Class I wells. Untreated RCRA hazardous waste is in general supposed to be restricted to Class I wells with hazardous waste permits, though the regulations have many possible loopholes that invalidate this rule. For this report, we categorize wells as Class I if they appeared on our Class I well inventory. Any facilities not listed on the inventory appear in this paper because they were reported in TRI or BRS. These could be wells in other classes (most likely Class V), instances of incorrect reporting, or cases in which a facility with no well accepts waste that it sends to a well elsewhere. Through the rest of this report, facilities that appear in TRI or BRS but not on the Class I inventory will be referred to as "non-Class I."
Wells can also be divided into non-commercial vs. commercial. Non-commercial wells are for disposal of wastes from the company that owns the facility, while commercial ones are for wastes from off-site customers who pay for disposal. In general, non-commercial wells dispose of waste that the facility generates on-site, and commercial wells dispose of waste that other facilities generate. Occasionally, a non-commercial well will dispose of waste that was not generated on site, but instead from other facilities owned by the same parent company. For purposes of this report, we have classified wells as commercial or non-commercial according to whether reported waste comes from on- or off-site.(16) A few wells were explicitly noted in our Class I well inventory as being commercial; we have accepted these designations.
Finally, we have divided wells into hazardous Class I vs. non-hazardous. Non-hazardous Class I wells do not have permits to dispose of untreated RCRA hazardous waste. Hazardous Class I wells do have permits to dispose of untreated RCRA waste, usually because they have obtained approval from EPA of a "no-migration petition" stating that waste injected into the well will remain geologically confined for 10,000 years. Since no information on the regulatory status of non-Class I sites is available, they cannot be categorized in this manner. A facility with more than one well was categorized according to the most regulated well within the facility: i.e. a facility with both a Class I hazardous and a Class I non-hazardous well was listed as Class I hazardous.
A table of facilities by regulatory type is listed below. Within each category, we have broken out subcategories of facilities that are listed within different databases. The percents in the table below are calculated with respect to the full universe of injected waste; i.e., the "percent of TRI pounds" is the amount of TRI waste reported by facilities in the category as a percentage of the amount of TRI waste reported injected into all wells.
Table 11. Facilities by regulatory and reporting type
|
Type of facility |
Number of facilities |
Percent of facilities |
Percent of TRI pounds |
Percent of BRS tons |
|
Class I non-hazardous |
||||
|
Non-commercial- |
||||
|
With no TRI or BRS |
164 |
45.56 |
|
|
|
With TRI only |
35 |
9.72 |
19.67 |
|
|
With BRS only |
2 |
0.56 |
|
3.68 |
|
With both TRI and BRS |
0 |
0 |
|
|
|
Total |
201 |
55.83 |
19.67 |
3.68 |
|
Commercial- |
||||
|
No TRI or BRS |
11 |
3.06 |
|
|
|
TRI only |
1 |
0.28 |
0 |
|
|
BRS only |
0 |
0 |
|
|
|
Both TRI and BRS |
1 |
0.28 |
0.09 |
0.02 |
|
Total |
13 |
3.61 |
0.09 |
0.02 |
|
Class I non hazardous total |
214 |
59.44 |
19.76 |
3.7 |
|
|
||||
|
Class I hazardous |
||||
|
Non-commercial- |
||||
|
No TRI or BRS |
10 |
2.78 |
|
|
|
TRI only |
7 |
1.94 |
0.73 |
|
|
BRS only |
2 |
0.56 |
|
2.05 |
|
Both TRI and BRS |
29 |
8.06 |
72.30 |
91.37 |
|
Total |
48 |
13.33 |
73.02 |
93.42 |
|
Commercial- |
||||
|
No TRI or BRS |
1 |
0.28 |
|
|
|
TRI only |
0 |
0 |
|
|
|
BRS only |
1 |
0.28 |
|
0.64 |
|
Both TRI and BRS |
9 |
2.50 |
6.78 |
2.23 |
|
Total |
11 |
3.06 |
6.78 |
2.86 |
|
Class I hazardous total |
59 |
16.39 |
79.8 |
96.28 |
|
|
||||
|
Non-Class I |
||||
|
Non-commercial- |
||||
|
TRI only |
26 |
7.22 |
0.24 |
|
|
BRS only |
2 |
0.56 |
|
|
|
Both TRI and BRS |
0 |
0 |
|
|
|
Total |
28 |
7.78 |
0.24 |
|
|
Commercial- |
||||
|
TRI only |
9 |
2.50 |
0.13 |
|
|
BRS only |
42 |
11.67 |
|
0.01 |
|
Both TRI and BRS |
8 |
2.22 |
0.07 |
|
|
Total |
59 |
16.39 |
0.20 |
0.01 |
|
Non-Class I total |
88 |
24.17 |
0.44 |
0.01 |
|
|
||||
|
Grand Total |
361 |
100 |
100 |
99.99 |
From the table above, it is apparent that most, but not all, of the RCRA hazardous waste is sent to Class I wells with hazardous waste permits. Just under four percent of this hazardous waste is sent to Class I wells with permits for non-hazardous waste, and 0.01 percent is sent to non-Class I sites. For TRI chemicals, a higher percentage (19.7 percent) is sent to Class I wells with non-hazardous permits.
It is also apparent that the quantity of waste sent to commercial wells is much smaller than that sent to non-commercial wells. Only 7.1 percent of TRI waste and 2.9 percent of the BRS waste is sent to commercial wells.
A large majority of the reported waste goes to 29 non-commercial Class I hazardous facilities that are reported under both TRI and BRS. These facilities account for 72 percent of the total TRI pounds disposed of in wells (both on and off site) and 91 percent of the BRS waste. This result is to some extent expected, as generally the largest facilities have Class I hazardous permits and report to major databases like TRI and BRS. Still, this is a concentration of a sizable amount of waste in a relative handful of facilities. These major facilities are listed in Table 22 in Appendix IV.
For TRI waste, the category of facilities handling the next largest amount of waste is Class I non-hazardous non-commercial wells reporting to TRI only, with 20 percent of the TRI total. This indicates that one-fifth of the total TRI injection is into wells that are not generally permitted to dispose of RCRA hazardous waste. The 26 non-Class I non-commercial facilities that dispose of TRI waste are the best candidates within this database for a group of Class V wells. They are listed in Table 23 in Appendix IV.
For BRS waste, it is more helpful to look first at categories with large numbers of facilities. There are 42 commercial non-Class I facilities reporting BRS waste only that together account for only 0.01 percent of the BRS waste (see Table 24). As a group, these are most likely to be data reporting errors, since these records were generally reported by the shipper and not the receiver of BRS waste, and since there is not confirmation within TRI or the well inventory of the existence of a well at that location. The names of the facilities in this group sometimes appear to be those of landfills, though it is possible that they could have additional well disposal units. After that category, the next highest number of BRS facilities is 9 commercial Class I hazardous wells that are also reported within TRI. This group accounts for 6.8 percent of the TRI waste and 2.2 percent of the BRS waste, and has the lion’s share of waste reported to commercial wells in the database. These wells are listed in Table 24 in Appendix IV.
There are also eight commercial facilities that are listed as accepting waste under both BRS and TRI, but have no Class I well permits. We called these facilities and reached three of them. All three confirmed that they actually have no wells. Instead, they either accept wastewater from other sites and ship it to wells elsewhere, or have only wastewater treatment units. This naturally means that they require no well permits. It is likely that the other facilities in this group may be transfer facilities rather than actual well sites.
Another six percent of the BRS waste is accounted for by only six Class I and non-Class I facilities; all non-commercial and reported under BRS only. They are listed in Appendix IV. Three of these facilities reported large amounts of BRS waste: a Du Pont facility in Pass Christian, MS with 909,000 tons of corrosive waste containing chromium and lead, a Cabot Corp. plant in Tuscola, IL with 420,000 tons of corrosive leachate, and an AK Steel plant in Middletown, OH with 83,000 tons of spent pickle liquor containing chromium. All three of these facilities reported to TRI, but reported zero pounds of releases to underground injection. This was puzzling since chromium and lead are TRI chemicals. In addition, the Du Pont facility in Pass Christian is listed as a non-hazardous Class I well with its no-migration petition under review, so it is unusual that it would be disposing of so much RCRA waste. We called the Du Pont facility and were informed that they didn’t report to TRI because of the "de minimus" exemption, which allows non-reporting if the TRI chemical is less than a certain percentage of the waste and remains so throughout the industrial process (a level of one percent, and 0.1 percent for carcinogens). This means that the amount of chromium injected would not be reported if it were below this 0.1 percent concentration. We also contacted the AK Steel plant in Middletown, OH, but a regulatory specialist there declined to answer questions posed by telephone or by fax.
A numerically large category is those Class I facilities that did not receive any TRI or BRS waste. With 187 facilities, they represent just over half the facilities in the database. Some states such as Florida require many municipal disposal wells to be Class I, and some of the wells are in this category for that reason.
Finally, there is a scattering of 21 facilities in other categories. Nine of these are non-Class I commercial TRI-only facilities. Since these were often only reported within single TRI transfer records, which are reported by the shipper rather than the receiver of waste, they may well be reporting errors. Another seven are Class I hazardous non-commercial TRI-only wells. These are highly regulated and accepted a relatively small amount of TRI waste, 0.7 percent of the total. Of the remaining five wells, only two released more than a thousandth of a percent of the total waste in any category. They are both Class I commercial wells. One, a Chemical Waste Management facility in Port Arthur, TX, reported disposing of 156,000 tons of BRS waste. As a Class I hazardous well facility, it was unusual only in that no TRI transfers to the facility were reported. The other, Perma Fix Treatment Services in Tulsa, OK, received 4,400 tons of BRS waste and 220,000 pounds of TRI chemicals in waste. This facility is unusual in that it has a Class I non-hazardous permit instead of a hazardous one. We contacted this facility and found that in 1995 it was under permit by rule, with its no-migration petition under review – a regulatory status which enabled it to continue disposing of RCRA hazardous waste. The facility currently disposes of treated characteristic waste, which can be done with a non-hazardous Class I permit.
Overall, 72 percent of TRI and 92 percent of BRS waste (both on and off site) is concentrated in only 29 non-commercial Class I hazardous facilities. However, 12 percent of the TRI waste is disposed of in Class I non-hazardous wells and another eight percent in non-Class I wells, indicating that Class V wells may be present within the TRI universe. Commercial disposal constitutes seven percent of the TRI total and three percent of BRS. A few facilities were found that had large quantities of BRS waste and either no Class I hazardous permit or no TRI reports. AK Steel in Middletown, OH was the only such facility that chose not to supply an explanation for these unusual elements.
Not all states have underground geologic formations capable of supporting deep wells, so wells are concentrated in some states and not in others. Table 27, in Appendix IV, shows TRI and BRS totals for each state. Table 28 shows shipments of waste to wells across state lines. Table 29 shows totals of numbers of facilities and wells (there may be more than one well at a facility) in each state, and Table 30 shows the top three TRI chemicals and BRS wastes injected into wells in each state. These four tables provide an outline of state-by-state underground injection activity. For this section, waste is categorized as "on-site" if it was disposed of in the same facility that reported it and "off-site" if a facility reported sending it somewhere else for disposal. Off-site waste is reported as belonging to the state that it ends up in, not the state that sent it.
Texas ranks first in almost every category of injected waste -- for TRI waste both on site and off site, for overall BRS waste, and for off-site BRS waste. The state is second for off-site TRI waste. Texas accepts just under half of the nation's injected TRI waste (126 million pounds) and 65 percent of the BRS waste (16 million tons). Texas is a comparatively large net importer of waste from other states, accepting more than 900 thousand pounds of TRI waste and more than 100 thousand tons of BRS waste. This amount of off-site BRS waste is by far larger than that sent to any other state; Louisiana and Alabama are the sources of most of this waste.
Louisiana ranks second for TRI and BRS waste, both overall and on site. It ranks third for off-site TRI waste and fourth for BRS waste. The state disposes of 22 percent of the nation's injected TRI waste (55 million pounds) and 10 percent of the BRS waste (2.4 million tons).
Florida ranks third for TRI waste overall with 25 million pounds, due to its on-site disposal. However, the state ranks only 10th for BRS waste with 96 thousand tons. No off site waste was reported. Florida has the largest number of facilities with Class I wells of any state (71 facilities), but most of these are municipal disposal wells, which Florida requires to be regulated as Class I.
Kansas ranks third for BRS waste overall with 1.6 million tons or 6.6 percent of the nation's total. The state ranks third for BRS on-site waste and second for BRS off-site waste with 150,000 tons, or 21 percent of the nation's total in that category. Kansas ranks lower for TRI waste with only 0.7 percent of the total. The state has 25 facilities with Class I wells, third after Florida and Texas. However, its high ranking for BRS waste is due to a single facility, Vulcan Materials in Wichita. This facility disposes of almost all of the state's BRS waste, both from its own operations and from shipments of waste from Elf Atochem in Wichita.
Ohio ranks fourth or fifth in most categories, with 9.6 percent of the nation's TRI waste overall and 4.8 percent of the BRS waste. However, the state is ranked first for off-site TRI waste with 9.7 million pounds or 54 percent of the total. It is also third for off-site BRS waste with 15 percent. 6.3 million pounds of the state's off site TRI waste is imported from out of state, including 3.8 million pounds from Maryland. This Maryland waste was sent from two companies in Baltimore to a Chemical Waste Management facility in Vickery.
Mississippi ranks fourth for BRS waste with 1.4 million tons or 5.7 percent of the total. However, the state is ranked only 13th for TRI waste. The BRS waste is all from on site and is from only two facilities: a Du Pont facility in Pass Christian and a Morton International facility in Moss Point.
Other states with significant TRI or BRS waste (ranked higher than 10th in some category) include Alabama, Arkansas, California, Illinois, Indiana, Michigan, Oklahoma, Tennessee, and Wyoming. Alabama, Arizona, and Hawaii all had more than two well facilities but no Class I wells.
Tables 12 and 13 list the top 20 parent companies for underground injection in TRI and BRS. The parent company designations were taken from information submitted by facilities in TRI and BRS.(17)
Table 12. Top Parent Companies for Underground Injection in TRI (both commercial and non-commercial wells)
|
Company |
1995 TRI Underground Injection (pounds) |
Percent of Top 20 |
Percent of TRI Injection |
|
DuPont |
48,918,651 |
21.0 |
20.8 |
|
Cytec Industries |
26,387,958 |
11.3 |
11.2 |
|
BP America |
26,055,630 |
11.2 |
11.1 |
|
Huntsman Specialty Chemicals |
18,255,129 |
7.8 |
7.8 |
|
Monsanto |
16,059,915 |
6.9 |
6.8 |
|
Hoechst Corporation |
15,508,405 |
6.6 |
6.6 |
|
Sterling Chemicals |
14,598,675 |
6.3 |
6.2 |
|
Chemical Waste Management, Inc. |
9,695,097 |
4.2 |
4.1 |
|
Coastal Corporation |
8,168,000 |
3.5 |
3.5 |
|
Rubicon, Inc. |
7,736,350 |
3.3 |
3.3 |
|
Pharmacia & Upjohn, Inc. |
7,074,000 |
3.0 |
3.0 |
|
Maxxam, Inc. |
6,594,743 |
2.8 |
2.8 |
|
Angus Chemical |
5,264,233 |
2.3 |
2.2 |
|
Witco |
4,837,542 |
2.1 |
2.1 |
|
Disposal Systems, Inc. |
3,538,792 |
1.5 |
1.5 |
|
Great Lakes Chemical |
3,127,536 |
1.3 |
1.3 |
|
Merichem |
3,078,300 |
1.3 |
1.3 |
|
International Specialty Products |
3,008,410 |
1.3 |
1.3 |
|
Atlantic Richfield (ARCO) |
2,817,872 |
1.2 |
1.2 |
|
Empak, Inc. |
2,560,757 |
1.1 |
1.1 |
Table 13. Top Parent Companies for Underground Injection in BRS (both commercial and non-commercial wells)
|
Company |
1995 BRS Underground Injection (tons) |
Percent of Top 20 |
Percent of BRS Injection |
|
DuPont |
7,502,019 |
31.1 |
31.0 |
|
Monsanto |
2,512,275 |
10.4 |
10.4 |
|
Amoco Oil |
2,059,482 |
8.5 |
8.5 |
|
BP Chemicals |
1,877,999 |
7.8 |
7.8 |
|
Cytec Industries |
1,742,901 |
7.2 |
7.2 |
|
Vulcan Chemicals |
1,633,383 |
6.8 |
6.8 |
|
Sterling Chemicals |
1,088,370 |
4.5 |
4.5 |
|
ARCO Chemical Company |
1,077,568 |
4.5 |
4.5 |
|
Hoechst Celanese Chemical |
804,460 |
3.3 |
3.3 |
|
Great Lakes Chemical |
743,764 |
3.1 |
3.1 |
|
Morton International |
499,087 |
2.1 |
2.1 |
|
Merichem |
479,163 |
2.0 |
2.0 |
|
Cabot Corporation |
422,249 |
1.7 |
1.7 |
|
Bethlehem Steel Corporation |
391,303 |
1.6 |
1.6 |
|
ASARCO, Inc. |
292,869 |
1.2 |
1.2 |
|
BASF Corporation |
281,555 |
1.2 |
1.2 |
|
Chemical Waste Management, Inc. |
274,875 |
1.1 |
1.1 |
|
Disposal Systems, Inc. |
206,132 |
0.9 |
0.9 |
|
Parke-Davis Division, Warner Lambert |
158,518 |
0.7 |
0.7 |
|
Angus Chemical |
101,681 |
0.4 |
0.4 |
Tables 12 and 13 show that virtually all underground injection in BRS and TRI comes from roughly the same set of parent companies.
Top individual facilities could be chosen in many different ways, but in this section we examine the basics – the total TRI and BRS pounds accepted by non-commercial and commercial wells. They are examined separately because commercial well facilities may pose additional risks to surrounding communities caused by the transport of waste to the well. It should be noted that a higher amount of waste does not necessarily imply a higher risk. Some facilities that dispose of a large quantity of relatively less toxic waste may cause less potential hazard or risk than facilities that dispose of a small quantity of very toxic waste. In addition, the geologic conditions at a well site can affect how likely it is that the well will leak and the waste will escape. More extensive details on each of these facilities, including a list of wastes, can be obtained by visiting the web site listed in the Executive Summary of this report.
Table 14. Top 10 Non-Commercial Facilities by TRI pounds
CYTEC INDUSTRIES, INC. Street: 10800 RIVER RD. City : WESTWEGO State: LA Zip: 70094 Class I haz. waste wells: 5 Non-hazardous Class I wells: 0 TRI Pounds: 26,362,503 from on-site: 26,362,503 from off-site: 0 BRS Tons : 1,742,901 from on-site: 1,742,901 from off-site: 0 E.I. DUPONT DE NEMOURS AND COMPANY (VICTORIA) Street: OLD BLOOMINGTON RD. City : VICTORIA State: TX Zip: 77901 Class I haz. waste wells: 11 Non-hazardous Class I wells: 0 TRI Pounds: 24,988,671 from on-site: 24,974,723 from off-site: 13,948 BRS Tons : 4,016,168 from on-site: 4,013,825 from off-site: 2,343 E.I. DUPONT DE NEMOURS CO. (BEAUMONT PLANT) Street: STATE HWY. 347 City : BEAUMONT State: TX Zip: 77704 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 20,447,185 from on-site: 20,447,185 from off-site: 0 BRS Tons : 1,395,384 from on-site: 1,395,384 from off-site: 0 SOLUTIA (FORMERLY MONSANTO) (OPERATOR FOR HUNTSMAN PETRO.) Street: 3000 OLD CHEMSTRAND RD. City : CANTONMENT State: FL Zip: 32533 Class I haz. waste wells: 0 Non-hazardous Class I wells: 3 TRI Pounds: 18,255,129 from on-site: 18,255,129 from off-site: 0 No BRS (RCRA) wastes listed. STERLING CHEMICALS (TEXAS CITY) Street: 201 BAY ST. S. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 14,598,675 from on-site: 14,598,675 from off-site: 0 BRS Tons : 1,088,370 from on-site: 1,088,370 from off-site: 0 BP CHEMICALS Street: 1900 FORT AMANDA RD. City : LIMA State: OH Zip: 45805 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 13,160,730 from on-site: 13,160,730 from off-site: 0 BRS Tons : 991,819 from on-site: 991,819 from off-site: 0 BP CHEMICALS AMERICA CO. Street: TEXAS HWY. 185 City : PORT LAVACA State: TX Zip: 77979 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 12,894,900 from on-site: 12,894,900 from off-site: 0 BRS Tons : 886,180 from on-site: 886,180 from off-site: 0 HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE) Street: 9502 BAYPORT RD. City : PASADENA State: TX Zip: 77507 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 12,602,200 from on-site: 12,602,200 from off-site: 0 BRS Tons : 782,205 from on-site: 782,205 from off-site: 0 MONSANTO COMPANY (CHOCOLATE BAYOU PLANT) Street: FM 2917 City : ALVIN State: TX Zip: 77511 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 10,588,676 from on-site: 10,588,676 from off-site: 0 BRS Tons : 2,512,275 from on-site: 2,512,275 from off-site: 0 COASTAL CHEMICAL Street: 8305 OTTO RD. City : CHEYENNE State: WY Zip: 82007 Class I haz. waste wells: 0 Non-hazardous Class I wells: 4 TRI Pounds: 8,168,000 from on-site: 8,168,000 from off-site: 0 No BRS (RCRA) wastes listed.
Table 15. Top 10 Commercial facilities by TRI pounds
CHEMICAL WASTE MANAGEMENT, INC. Street: 3956 STATE RTE. 412 City : VICKERY State: OH Zip: 43464 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 9,689,391 from on-site: 0 from off-site: 9,689,391 BRS Tons : 117,170 from on-site: 9,166 from off-site: 108,004 DISPOSAL SYSTEMS, INC. Street: 2525 BATTLEGROUND RD. City : DEER PARK State: TX Zip: 77536 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,933,427 from on-site: 0 from off-site: 2,933,427 BRS Tons : 149,864 from on-site: 18,771 from off-site: 131,093 EMPAK, INC. Street: BATTLEGROUND RD. City : DEER PARK State: TX Zip: 77536 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,560,757 from on-site: 0 from off-site: 2,560,757 BRS Tons : 70,270 from on-site: 2,074 from off-site: 68,195 AMERICAN ECOLOGY CORP. Street: P.O. BOX 248 City : WINONA State: TX Zip: 75792 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 852,160 from on-site: 0 from off-site: 852,160 BRS Tons : 58,950 from on-site: 13,197 from off-site: 45,753 DISPOSAL SYSTEMS OF CORPUS CHRISTI, GNR GROUP (FORMERLY CWM) Street: 6901 GREENWOOD DR. City : CORPUS CHRISTI State: TX Zip: 78415 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 605,365 from on-site: 0 from off-site: 605,365 BRS Tons : 56,268 from on-site: 7,256 from off-site: 49,012 ROLLINS ENVIRONMENTAL SERVICES OF LA, INC. Street: City : PLAQUEMINE State: LA Zip: 70764 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 377,519 from on-site: 0 from off-site: 377,519 BRS Tons : 20,897 from on-site: 0 from off-site: 20,897 PERMA FIX TREATMENT SERVICES, INC. Street: 1525 NORTH 105TH EAST AVE. City : TULSA State: OK Zip: 74116 Class I haz. waste wells: 0 Non-hazardous Class I wells: 2 TRI Pounds: 224,212 from on-site: 0 from off-site: 224,212 BRS Tons : 4,426 from on-site: 0 from off-site: 4,426 OXIDE INC. Street: 101 CONCRETE ST. City : HOUSTON State: TX Zip: 77012 No Class I wells listed. TRI Pounds: 156,205 from on-site: 0 from off-site: 156,205 No BRS (RCRA) wastes listed. LOYD'S LANDFILL Street: 1728 BROWNLEE RD. City : BIRMINGHAM State: AL Zip: 35210 No Class I wells listed. TRI Pounds: 148,467 from on-site: 0 from off-site: 148,467 No BRS (RCRA) wastes listed. MALONE SERVICES COMPANY Street: 5200 CAMPBELL BAYOU RD. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 113,699 from on-site: 0 from off-site: 113,699 BRS Tons : 10,295 from on-site: 0 from off-site: 10,295
Table 16. Top 10 Non-commercial facilities by BRS tons
E.I. DUPONT DE NEMOURS AND COMPANY (VICTORIA) Street: OLD BLOOMINGTON RD. City : VICTORIA State: TX Zip: 77901 Class I haz. waste wells: 11 Non-hazardous Class I wells: 0 TRI Pounds: 24,988,671 from on-site: 24,974,723 from off-site: 13,948 BRS Tons : 4,016,168 from on-site: 4,013,825 from off-site: 2,343 MONSANTO COMPANY (CHOCOLATE BAYOU PLANT) Street: FM 2917 City : ALVIN State: TX Zip: 77511 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 10,588,676 from on-site: 10,588,676 from off-site: 0 BRS Tons : 2,512,275 from on-site: 2,512,275 from off-site: 0 AMOCO OIL COMPANY (TEXAS CITY PLANT) Street: 2401 5TH AVE. S. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 1,880,700 from on-site: 1,880,700 from off-site: 0 BRS Tons : 2,059,482 from on-site: 2,059,482 from off-site: 0 CYTEC INDUSTRIES, INC. Street: 10800 RIVER RD. City : WESTWEGO State: LA Zip: 70094 Class I haz. waste wells: 5 Non-hazardous Class I wells: 0 TRI Pounds: 26,362,503 from on-site: 26,362,503 from off-site: 0 BRS Tons : 1,742,901 from on-site: 1,742,901 from off-site: 0 VULCAN CHEMICALS Street: 6200 S. RIDGE RD. City : WICHITA State: KS Zip: 67215 Class I haz. waste wells: 5 Non-hazardous Class I wells: 0 TRI Pounds: 957,064 from on-site: 883,864 from off-site: 73,200 BRS Tons : 1,633,383 from on-site: 1,483,747 from off-site: 149,635 E.I. DUPONT DE NEMOURS CO. (BEAUMONT PLANT) Street: STATE HWY. 347 City : BEAUMONT State: TX Zip: 77704 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 20,447,185 from on-site: 20,447,185 from off-site: 0 BRS Tons : 1,395,384 from on-site: 1,395,384 from off-site: 0 STERLING CHEMICALS (TEXAS CITY) Street: 201 BAY ST. S. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 14,598,675 from on-site: 14,598,675 from off-site: 0 BRS Tons : 1,088,370 from on-site: 1,088,370 from off-site: 0 ARCO CHEMICAL COMPANY (CHANNELVIEW PLANT) Street: 2502 SHELDON RD. City : CHANNELVIEW State: TX Zip: 77530 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 2,817,872 from on-site: 2,802,631 from off-site: 15,241 BRS Tons : 1,077,568 from on-site: 1,027,471 from off-site: 50,097 BP CHEMICALS Street: 1900 FORT AMANDA RD. City : LIMA State: OH Zip: 45805 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 13,160,730 from on-site: 13,160,730 from off-site: 0 BRS Tons : 991,819 from on-site: 991,819 from off-site: 0 DUPONT DELISLE PLANT-WHITE PIGMENT & MINERAL Street: 7658 KILN-DELISLE RD City : PASS CHRISTIAN State: MS Zip: 39571 Class I haz. waste wells: 0 Non-hazardous Class I wells: 0 No TRI chemicals listed. BRS Tons : 909,235 from on-site: 909,235 from off-site: 0
Table 17. Top 10 Commercial facilities by BRS tons
CHEMICAL WASTE MANAGEMENT (PORT ARTHUR) Street: HWY 73 City : PORT ARTHUR State: TX Zip: 77640 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 No TRI chemicals listed. BRS Tons : 156,989 from on-site: 121,279 from off-site: 35,709 DISPOSAL SYSTEMS, INC. Street: 2525 BATTLEGROUND RD. City : DEER PARK State: TX Zip: 77536 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,933,427 from on-site: 0 from off-site: 2,933,427 BRS Tons : 149,864 from on-site: 18,771 from off-site: 131,093 CHEMICAL WASTE MANAGEMENT, INC. Street: 3956 STATE RTE. 412 City : VICKERY State: OH Zip: 43464 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 9,689,391 from on-site: 0 from off-site: 9,689,391 BRS Tons : 117,170 from on-site: 9,166 from off-site: 108,004 EMPAK, INC. Street: BATTLEGROUND RD. City : DEER PARK State: TX Zip: 77536 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,560,757 from on-site: 0 from off-site: 2,560,757 BRS Tons : 70,270 from on-site: 2,074 from off-site: 68,195 AMERICAN ECOLOGY CORP. Street: P.O. BOX 248 City : WINONA State: TX Zip: 75792 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 852,160 from on-site: 0 from off-site: 852,160 BRS Tons : 58,950 from on-site: 13,197 from off-site: 45,753 CECOS INTERNATIONAL (WILLOW SPRINGS) Street: 918 WILLOW SPRINGS City : WESTLAKE State: LA Zip: 70669 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 6,002 from on-site: 0 from off-site: 6,002 BRS Tons : 58,419 from on-site: 49,372 from off-site: 9,048 DISPOSAL SYSTEMS OF CORPUS CHRISTI, GNR GROUP (FORMERLY CWM) Street: 6901 GREENWOOD DR. City : CORPUS CHRISTI State: TX Zip: 78415 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 605,365 from on-site: 0 from off-site: 605,365 BRS Tons : 56,268 from on-site: 7,256 from off-site: 49,012 ROLLINS ENVIRONMENTAL SERVICES OF LA, INC. Street: City : PLAQUEMINE State: LA Zip: 70764 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 377,519 from on-site: 0 from off-site: 377,519 BRS Tons : 20,897 from on-site: 0 from off-site: 20,897 MALONE SERVICES COMPANY Street: 5200 CAMPBELL BAYOU RD. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 113,699 from on-site: 0 from off-site: 113,699 BRS Tons : 10,295 from on-site: 0 from off-site: 10,295 TEXAS ECOLOGIST, INC. Street: 3.5 MILES SOUTH PETRONELA RD. City : ROBSTOWN State: TX Zip: 78380 Class 1 haz. waste wells: 1 Non-hazardous Class 1 wells: 0 This appears to be a commercial site. TRI Pounds: 206 from on-site: 0 from off-site: 206 BRS Tons : 8,231 from on-site: 7,958 from off-site: 273
Since underground injection is the cheapest method of permitted waste disposal once the wells are operational, it might be expected that facilities that rely on underground injection have less economic motivation to practice source reduction. Source reduction or pollution prevention is the implementing of measures to avoid creating waste, as opposed to "end of pipe" measures like underground injection that deal with waste after it has already been created. To test this idea, we compared measures of source reduction within TRI and BRS between facilities that had on-site non-commercial injection wells and facilities that did not.
Facilities are required to report the quantity not generated due to source reduction associated with each BRS waste stream. Traditionally, very little source reduction is reported in BRS, making a comparison between facilities with and without wells impossible. Of a total of 108 records reporting waste generated on site and managed at least partially in an on-site well in 1995, only two records contained any source reduction quantities.
TRI facilities do not report amounts of waste not generated due to source reduction. However, they do report undertaking new source reduction activities during the year by filling in specific codes that describe those activities. It is possible to obtain a measure of source reduction activity by taking the ratio of the number of codes reported to the total number of forms submitted. A higher source reduction activity (SRA) to form ratio indicates that more new source reduction is being attempted than a lower ratio would indicate.(18) It is important when examining these ratios to keep in mind that not all source reduction activities result in the same level of decrease in waste generation, and since no data on amounts reduced are available, this analysis cannot address that issue.
The number of 1995 TRI forms reporting any on-site injection is 593. Of these, 100 forms each reported one source reduction activity. The number of forms with no injection but with non-zero releases to air, water, or land is 53,990; 13,325 of these reported a total of 23,811 source reduction activities. The SRA/form ratio for forms with underground injection was 0.17; for forms without underground injection it was 0.44. Thus, facilities with no on-site well undertook more than twice the number of new source reduction activities per form than facilities with a well.(19)
By these measures, it seems clear that underground injection wells provide a disincentive for examining processes to determine methods of reducing waste generation. On the one hand, facilities could argue that once the wells are permitted and in place, it is more cost-effective to use them than not. On the other hand, the much lower rate of source reduction activities among facilities with wells lends some weight to environmental groups’ arguments that underground injection needs to continue to be included in total releases if any progress is to be made in reducing quantities generated and managed as waste.
Class I wells are the regulated entities that are supposed to accept most of the hazardous and toxic wastes created by manufacturing facilities and disposed of by underground injection. They also constitute a small subset of the much larger universe of Class II, III and V wells. For these reasons, NET thought it was important to have an accurate idea of the names and approximate locations of all Class I wells, so that we could tell whether TRI or BRS wastes were going to Class I wells or not. Most of the claims of safety made for toxic waste disposed of by underground injection presuppose that the waste is going to a Class I well. Class I wells are major regulated entities, so there is an important Right-to-Know component in finding out whether information about them is readily available and reasonably accurate.
To our dismay, we found that there is no reliable national source for Class I well data, and that collecting the limited data that are available is a long and arduous process:
(1) We started by attempting to obtain a national Class I well inventory from EPA Headquarters. Although we quickly received a national Class I inventory document by E-mail, this list turned out to be several years out of date and inaccurate, especially with regard to the classification of wells as hazardous or non-hazardous. The inventory document also included names, states, and identification numbers of wells, but no location information. We were informed that no newer or more accurate data were available from EPA Headquarters, and that the inventory document we received was not required by any regulation and had been discontinued. In response to our comments, we received a corrected version of the inventory -- but only with the corrections that we ourselves had submitted. We were told that if we needed better data, we should go to the EPA Regions.(20)
(2) The 10 EPA Regions are part of the Federal government, but are intended to keep better track of environmental activities by having a greater understanding of their specific local areas. Most permit and enforcement activity within the Federal government occurs in the regions. We called Regions IV through IX to ask them for a list of Class I wells in their area. Region X was left out because of the lack of wells reported in TRI and BRS for their states. Regions I through III were excluded because the EPA experts we contacted generally agreed that there were no Class I wells in those areas. Although responses took up to several weeks, we received data from all of the regions except Region VI. Region VI told us that we would need to contact the individual states in their area (Arkansas, Louisiana, New Mexico, Oklahoma, and Texas). The other Regions sent us data that was generally useful, but in varying formats. A considerable amount of work was required to convert these data into a common database.
(3) We were told by Region VI staff that there were no Class I wells in New Mexico. Accordingly we contacted the state environmental regulatory agencies in Arkansas, Louisiana, Oklahoma, and Texas. Responses were received fairly quickly from Arkansas, Louisiana, and Oklahoma, but it took weeks and many phone calls to get data from Texas. Again, significant work was expended in putting the data received into a common format.
(4) After we finished obtaining data from states and regions, we did a more systematic survey of possible data sources in EPA Headquarters to make sure that we had left nothing out. EPA Headquarters does collect two basic types of information from the Regions on a regular basis, the "7520" forms and a yearly count of numbers of wells. The 7520s contain data required by EPA regulation and are intended to report data on enforcement activity; they do not include an inventory of wells. These 7520s are kept on paper and never fully converted into a database. Their main use seems to be to contribute to a yearly summary of enforcement actions, although other ad hoc analyses are done with them on occasion. The yearly count of wells is needed by EPA Headquarters in order to give out Federal grants to state regulatory agencies, but does not contain real inventory information such as well names or locations. EPA’s SDWIS (Safe Drinking Water Information System) database contains information on most entities regulated, as wells are, under the Safe Drinking Water Act. However, underground injection wells are not recorded within that database. Nor are they tracked systematically in RCRIS, which contains information about permits for RCRA regulated facilities.
From a Right-to-Know standpoint, public accessibility to data about Class I wells is inadequate. It is possible that a member of the general public could get detailed information about a single facility in their area, but that would depend on the cooperation and budget of their state regulatory agency or Regional staff. Right-To-Know requires that more than information on single facilities should be obtainable; the current standard is that a member of the public should be able to search an electronically available database. Often a member of the community would like to survey facilities in the area, compare them to facilities in other states, or find out about imports of out-of-state waste. For these purposes, the amount of effort needed to obtain useable data is beyond that which could be reasonably expected of anyone except a professional researcher with time to spare.
Injection of waste underground into wells is governed by regulation under the Safe Drinking Water Act (SDWA), which divides wells into 5 classes. They are:
Class I – wells that inject industrial, municipal, or hazardous waste below the lowermost underground source of drinking water;
Class II – wells that inject brine generated by the oil and gas industry;
Class III – wells used in the solution mining of minerals;
Class IV – (currently illegal except for RCRA or CERCLA groundwater cleanup) wells that inject hazardous waste into or above sources of drinking water;
Class V – wells that inject non-hazardous waste into or above sources of drinking water, and all other wells that do not fit into classes I-IV. Class V wells are often known as shallow wells, as opposed to I-III which are known as deep wells.
Wells in classes I –III have permits under SDWA (Class V wells often have permits by rule). These permits specify how much waste can be injected. To have a Class I well permit, a well must have many devices intended to prevent or detect leakage of waste into the underground source of drinking water (such as well liners and integrity monitoring devices).
Since wells are classed as land disposal systems, they are also regulated under RCRA (the Resource Conservation and Recovery Act) if they dispose of RCRA hazardous waste or non-hazardous municipal waste. RCRA hazardous waste is waste that is listed or shows certain characteristics of toxicity, ignitability, reactivity, or corrosivity. Most wells have RCRA permits by rule if they have a SDWA permit. RCRA generally regulates most hazardous waste treatment, storage, and disposal units.
However, amendments to RCRA created the RCRA Land Ban, which banned land disposal of certain RCRA hazardous wastes if they were untreated. Some injection wells can dispose of a designated RCRA waste despite the ban by treating it (which may consist of merely mixing it with other waste to dilute it). Most facilities apply for a "no migration" petition. This is a petition that uses geological data to show that waste will not migrate from the injection zone under the well for 10,000 years. EPA considers that waste that will not escape for 10,000 years has not really been disposed of to the environment under RCRA, so this condition either satisfies or allows a well to evade the land ban.
It is possible for a well to have a RCRA permit to dispose of particular hazardous waste codes that have not yet been listed under the Land Ban, thus not needing a no-migration petition. However, many EPA regions and other regulatory agencies appear to mean that a well has a valid no-migration petition when they refer to a well that is permitted to dispose of RCRA hazardous waste. Since we received data from different agencies where terminology differed, we use "hazardous well" to mean a well that is permitted to dispose of untreated RCRA hazardous waste whether by RCRA permit or by having a no-migration petition.
EPA review of a no-migration petition requires input from the facility submitting the petition, state agencies, and the public. The petition must include technical information from the requesting facility on the following:
1) Well construction, monitoring, and operation;
2) Types, amounts, and process that generate wastes to be injected;
3) Local and regional geology and hydrogeology;
4) Descriptions of any faults or other penetrations (including manmade or artificial penetrations such as existing or abandoned wells) through which waste might migrate; and
5) Mathematical models showing that waste will not migrate into underground sources of drinking water.
Staff at EPA regional offices coordinate review of petition materials along with input from the states where required. The geological data are reviewed, and facilities must demonstrate that artificial penetrations provide no conduit for waste to enter drinking water supplies. The mathematical model is evaluated for rigor and accuracy, as well as the appropriateness of the assumptions used to model the "worst case" scenarios. The facility is then given time to modify any deficiencies that EPA finds in the petition. If EPA finds that deficiencies cannot be addressed, the Agency gives the facility time to withdraw the petition before officially denying it.
EPA accepts public input at all stages of the review process, but formally notifies the public of its solicitation of input after issuing a draft notice of approval or denial. The Agency also holds a public hearing, usually in the community near the facility submitting the petition. A final decision is typically made 30 to 45 days after the draft notice, and may include certain conditions of operation (such as types and amounts of waste that can be injected). New information submitted after approval can cause the Agency to revoke a petition. Likewise, the facility can request modification or reissuing of a petition if operations change.
The well itself is subject to regulations on well design, construction, and operation to prevent contamination. These include controls to prevent well failure, as well as controls to prevent fluid migration up improperly plugged artificial penetrations, through faults or fractured confining strata, and lateral displacement of fluids.
The Class I well inventory used in this report was based on data collected from EPA Headquarters, EPA regions, and various state environmental agencies (as described in Part II above). It is impossible to cite the data sources used with precision, as most of them were not finished documents or clearly dated versions of databases but rather ad hoc lists that were E-mailed, faxed, or even read to us over the phone. Our basic procedure was to call each regulatory entity that dealt with Class I wells and ask for an inventory list, and if they could not adequately respond then to do the same with the regulatory agencies beneath them. The data sources included files or notes from EPA Headquarters, EPA Regions 4, 5, 7, 8, and 9, and state agencies in Arkansas, Oklahoma, Louisiana, and Texas. Regions 1, 2, 3, and 10 were not called.
The final database created relies to some extent on the initial data set supplied by EPA Headquarters, but has been updated and modified to reflect the data received by EPA Regions and states. Often these data included notations about the hazardous or non-hazardous status of wells, their commercial or non-commercial status, and their city location. ("Hazardous" status was taken to mean that a well was permitted to dispose of untreated RCRA hazardous waste whether by RCRA permit or no-migration petition, as described in Appendix I above). Since the data from regions and states had been collected for permitting and regulatory purposes, it was almost universally recorded with one record for each well rather than one record for each facility. We converted the data into one record per facility and noted the number of wells in each. A facility was labeled "hazardous" if it had at least one well permitted to accept hazardous waste and non-hazardous if it had none. The state and regional data were collected in the last few months of 1997, so it is expected that there will be some differences between the well inventory and the 1995 BRS and TRI data. Old and no longer extant permits were generally listed in the state and regional records; however, we did not include wells with permits that were no longer active in our database.
Wells are divided into "commercial" or "non-commercial" based on whether they accept payment in return for disposal of waste. Commercial sites generally accept waste from other facilities, while non-commercial ones generally dispose waste that is generated on site. However, this is not always true. A non-commercial facility can dispose of waste shipped there from other facilities that are owned by the same parent company. For purposes of this report, we divided the facilities into commercial or non-commercial based on three factors; whether they were explicitly noted as commercial or non-commercial in our Regional or state data, whether they accepted a majority of their waste from on or off site, and in a few cases by the name of the facility. It is possible that some commercial facilities have been incorrectly classified as non-commercial and vice versa, especially for facilities with only one or a few wastes sent from off-site.
The Biennial Reporting System (BRS) is an EPA database that collects biennial reports from facilities about the generation, management, and disposition of hazardous wastes regulated under RCRA (the Resource Conservation and Recovery Act). As such, it is the primary public source of information on Federally regulated hazardous waste streams.
The Toxic Release Inventory (TRI) is a publicly available EPA database that contains toxic chemical release and transfer information from manufacturing facilities. It is the primary public source of information on multi-media (i.e., land, water, and air) releases of toxic chemicals, as well as transfers and disposal destinations for these chemicals.
These two databases comprise the major public sources of national data on wastes going to underground injection wells. As discussed in Part II above, EPA has no national database of underground injection well information, and the data that are collected from EPA Regions are mostly about permits and enforcement rather than wastes.
There are important differences between the TRI and BRS databases. TRI data are collected from facilities that manufacture, use, or process more than a threshold amount of a TRI listed chemical and have more than 10 full-time employees. The TRI chemicals are chosen on the basis of human or ecological toxicity. TRI quantities reported are in pounds, and are reported as pounds of the listed toxic chemical only -- if a facility released 2 hundred pounds of a toxic chemical mixed with 10 tons of water, they would report it as a release of 2 hundred pounds rather than 10 tons. Quantities sent to underground injection are reported in two ways within TRI: as on-site releases to wells at manufacturing facilities, and as off-site transfers to well disposal sites.
BRS data are collected from "Large Quantity Generators" of hazardous waste and "Treatment, Storage, and Disposal Sites" -- basically, the facilities that are major sources and destinations of hazardous waste. Unlike TRI, the database is not limited to manufacturing entities. Hazardous wastes are reported within BRS if they are regulated under RCRA. RCRA classifies waste as hazardous if it meets standards for ignitability, reactivity, corrosivity, or toxicity. Wastes that are tested and found to meet one of these criteria are referred to as "characteristic" wastes; other wastes that are known to be hazardous from their source or composition are "listed" wastes.
BRS quantities are generally converted into tons (2,000 pounds), and are reported as the quantity of waste that contains a hazardous ingredient. Therefore, 200 pounds of a hazardous chemical mixed with 10 tons of water would be reported as 10 tons of hazardous waste within BRS, assuming that the mixture met the RCRA hazardous waste criteria. This difference means that BRS quantities are generally much larger than TRI quantities, since the BRS quantities include water and other inert constituents. Quantities sent to underground injection are reported in three different ways within BRS: as quantities managed on site, as quantities sent off site for disposal, and as quantities received from off site. Because of poorly understood factors within BRS reporting, the quantities sent off site do not match the quantities received.
For this report, we took both the on-site and off-site records of wastes sent to underground injection wells within each database and added them up by destination facility. Although we relied to some extent on common ID numbers to do this, there was also a large element of human judgment. For BRS waste shipments, there was the question of whether to use the reports of waste sent or waste received. We solved this problem by using either the waste sent records or waste received recordss as a group for each facility depending on which group had the higher total for that facility. We decided to leave TRI quantities in pounds and BRS quantities in tons to emphasize the non-comparable nature of totals from the two databases.
The databases used were the final 1995 version of BRS and the "frozen" 1995 reporting year of TRI. Both databases were taken from RTK NET (the Right-To-Know Network), a project of the nonprofit groups OMB Watch and Unison Institute. RTK NET maintains publicly accessible copies of EPA databases.
This section contains data tables that were too lengthy to place in the main body of text.
Table 18. Top 30 TRI chemicals sent to on-site wells, 1995
|
Chemical Name |
Pounds |
# records |
|
NITRATE COMPOUNDS |
46,299,521 |
12 |
|
ACETONITRILE |
27,837,181 |
11 |
|
METHANOL |
24,812,653 |
34 |
|
AMMONIA |
23,205,946 |
40 |
|
NITRIC ACID |
18,755,717 |
7 |
|
ETHYLENE GLYCOL |
12,554,675 |
11 |
|
FORMIC ACID |
11,492,418 |
9 |
|
ACRYLIC ACID |
7,840,000 |
4 |
|
HYDROCHLORIC ACID |
7,382,957 |
7 |
|
FORMALDEHYDE |
7,313,034 |
10 |
|
ACRYLAMIDE |
6,120,154 |
4 |
|
ACRYLONITRILE |
5,193,028 |
9 |
|
CYANIDE COMPOUNDS |
4,399,640 |
9 |
|
PHENOL |
3,723,235 |
13 |
|
CYCLOHEXANOL |
3,623,000 |
3 |
|
N-BUTYL ALCOHOL |
2,263,357 |
8 |
|
ANILINE |
1,222,381 |
7 |
|
DICHLOROMETHANE |
1,140,335 |
5 |
|
N,N-DIMETHYLFORMAMIDE |
1,099,000 |
2 |
|
TERT-BUTYL ALCOHOL |
1,082,071 |
6 |
|
SODIUM NITRITE |
978,500 |
4 |
|
ACETAMIDE |
920,000 |
2 |
|
VINYL ACETATE |
783,829 |
5 |
|
N-METHYL-2-PYRROLIDONE |
769,037 |
3 |
|
HYDROGEN CYANIDE |
683,154 |
5 |
|
M-CRESOL |
680,000 |
1 |
|
CRESOL (MIXED ISOMERS) |
648,882 |
4 |
|
ACETOPHENONE |
629,201 |
2 |
|
ACETALDEHYDE |
605,885 |
8 |
|
O-CRESOL |
590,000 |
1 |
Table 19. Top 30 TRI chemicals sent to off-site wells, 1995
|
Chemical Name |
Pounds |
# records |
|
NITRIC ACID |
3,896,774 |
23 |
|
SULFURIC ACID |
3,123,098 |
5 |
|
ZINC COMPOUNDS |
2,123,044 |
47 |
|
METHANOL |
1,068,160 |
26 |
|
HYDROCHLORIC ACID |
1,015,387 |
17 |
|
HYDROGEN FLUORIDE |
855,401 |
12 |
|
LEAD |
609,029 |
21 |
|
ETHYLENE GLYCOL |
478,217 |
18 |
|
AMMONIA |
471,779 |
20 |
|
DIETHANOLAMINE |
434,846 |
6 |
|
ARSENIC COMPOUNDS |
388,720 |
6 |
|
PHOSPHORIC ACID |
377,673 |
14 |
|
1,4-DIOXANE |
345,824 |
3 |
|
CHROMIUM |
343,420 |
10 |
|
CHROMIUM COMPOUNDS |
326,634 |
21 |
|
PHENOL |
267,048 |
16 |
|
TOLUENE |
226,125 |
28 |
|
N-BUTYL ALCOHOL |
188,001 |
7 |
|
CERTAIN GLYCOL ETHERS |
169,722 |
11 |
|
BARIUM COMPOUNDS |
144,827 |
2 |
|
N,N-DIMETHYLFORMAMIDE |
134,860 |
2 |
|
NICKEL |
120,258 |
7 |
|
COPPER |
105,354 |
8 |
|
NITRATE COMPOUNDS |
99,372 |
1 |
|
N-HEXANE |
79,952 |
5 |
|
XYLENE (MIXED ISOMERS) |
61,238 |
31 |
|
METHYL TERT-BUTYL ETHER |
47,350 |
2 |
|
NICKEL COMPOUNDS |
39,344 |
12 |
|
TITANIUM TETRACHLORIDE |
32,282 |
1 |
|
BENZENE |
31,500 |
20 |
Table 20. Top 30 BRS waste codes for wastes managed on-site --sorted by Quantity 2.
|
Waste Description |
Code |
Waste quantity 1 |
Waste Quantity 2 |
Waste quantity 3 |
|
Benzene |
D018 |
1,402,412.17 |
4,626,292.19 |
13,016,107.28 |
|
Corrosive waste |
D002 |
2,000,816.91 |
4,250,095.52 |
12,420,048.19 |
|
Reactive waste |
D003 |
499,087.31 |
2,175,858.92 |
5,772,691.74 |
|
Bottom stream from acetonitrile column in prod. of acrylonitrile |
K013 |
794,170.00 |
1,476,253.34 |
6,045,873.05 |
|
Bottom stream from wastewater stripper in prod. of acrylonitrile |
K011 |
440,605.00 |
1,383,853.17 |
6,210,321.05 |
|
Pyridine |
D038 |
0 |
1,158,503.85 |
5,557,297.56 |
|
Leachate from treatment/disposal of wastes classed under >1 code |
F039 |
51,615.50 |
744,348.66 |
4,323,291.79 |
|
Spent absorbent & solids from prod. of methyl bromide |
K132 |
743,764.00 |
743,989.24 |
858,559.27 |
|
Chromium |
D007 |
18,770.89 |
682,831.18 |
5,951,768.38 |
|
Bottoms from acetonitrile pure. column in prod. of acrylonitrile |
K014 |
8,579.00 |
551,447.14 |
3,172,054.05 |
|
Ignitable waste |
D001 |
167.8 |
416,830.72 |
1,940,381.67 |
|
Lead |
D008 |
0 |
334,276.21 |
1,740,506.82 |
|
2-Propenenitrile or Acrylonitrile |
U009 |
0.07 |
332,265.71 |
4,397,972.51 |
|
Hydrocyanic acid or Hydrogen cyanide |
P063 |
0 |
332,260.71 |
4,395,898.27 |
|
Methanol (I) or Methyl alcohol (I) |
U154 |
0.34 |
232,286.54 |
3,781,325.66 |
|
Benzene (I,T) |
U019 |
0 |
227,142.30 |
3,917,120.65 |
|
Spent non-halogenated solvents (see 1991 Form) |
F005 |
166,220.91 |
201,578.26 |
1,047,605.52 |
|
Selenium |
D010 |
0 |
197,315.92 |
795,012.07 |
|
Acetonitrile (I,T) |
U003 |
0 |
194,129.61 |
2,316,219.44 |
|
Cresol |
D026 |
0 |
156,743.66 |
742,792.16 |
|
Formaldehyde |
U122 |
0 |
150,437.11 |
2,456,835.27 |
|
Phenol |
U188 |
0 |
148,987.71 |
2,432,684.44 |
|
2-Propenal or Acrolein |
P003 |
0 |
148,953.63 |
2,423,787.44 |
|
Benzo[a]pyrene |
U022 |
0 |
139,479.45 |
2,213,994.44 |
|
Sodium cyanide Na(CN) |
P106 |
0 |
133,462.03 |
1,472,228.87 |
|
Arsenic |
D004 |
0 |
113,954.47 |
1,342,955.12 |
|
Nitrobenzene |
D036 |
0 |
107,111.54 |
446,309.16 |
|
Combined wastewater streams from nitrobenzene/anilene prod. |
K104 |
0 |
107,077.44 |
437,411.24 |
|
2-Propanone (I) or Acerone (1) |
U002 |
0 |
102,540.51 |
1,912,171.39 |
|
Methane, dichloro- or Methylene chloride |
U080 |
0 |
90,663.05 |
1,878,578.18 |
Table 21. Top 30 BRS waste codes for wastes received from off-site -- sorted by Quantity 2.
|
Waste Description |
Code |
Waste quantity 1 |
Waste quantity 2 |
Waste quantity 3 |
|
Corrosive waste |
D002 |
188,768.88 |
284,204.62 |
451,516.68 |
|
Benzene |
D018 |
7,460.41 |
49,569.33 |
120,480.54 |
|
Ignitable waste |
D001 |
15,359.99 |
38,665.15 |
85,370.63 |
|
Leachate from treatment/disposal of wastes classed under >1 code |
F039 |
24,868.59 |
34,907.81 |
57,482.53 |
|
Reactive waste |
D003 |
18.28 |
30,371.46 |
85,756.97 |
|
Arsenic |
D004 |
9,864.62 |
27,323.41 |
75,462.32 |
|
Chromium |
D007 |
2,856.44 |
25,832.48 |
82,409.06 |
|
Spent pickle liquor from steel finishing operations, with except. |
K062 |
0 |
18,902.46 |
43,939.00 |
|
Lead |
D008 |
1,129.33 |
15,599.86 |
59,464.03 |
|
Cadmium |
D006 |
1.73 |
12,384.65 |
50,372.02 |
|
Spent halogenated solvents used in degreasing (see 1991 Form) |
F001 |
0.68 |
7,955.44 |
33,733.28 |
|
Barium |
D005 |
0 |
7,733.81 |
33,333.42 |
|
Spent solvents: cresols, cresylic acid, and nitrobenzene |
F004 |
0 |
6,366.03 |
26,398.30 |
|
Spent non-halogenated solvents (see 1991 Form) |
F005 |
112.4 |
5,749.99 |
24,408.29 |
|
Spent halogenated solvents (see 1991 Form) |
F002 |
87.34 |
5,573.95 |
20,580.91 |
|
l,2-Dichloroethane |
D028 |
2,411.39 |
5,441.30 |
13,954.97 |
|
Spent non-halogenated solvents (see 1991 Form) |
F003 |
0.56 |
4,885.33 |
20,254.24 |
|
Carbon tetrachloride |
D019 |
0 |
4,093.90 |
14,273.56 |
|
Methyl ethyl ketone |
D035 |
1,046.68 |
3,192.99 |
11,484.02 |
|
Tetrachloroethylene |
D039 |
1,185.13 |
3,139.49 |
7,326.46 |
|
Emission control dust/sludge from primary prod. of steel |
K061 |
2,420.63 |
2,448.50 |
2,504.23 |
|
By-product salts from prod. of MSMA and cacodylic acid |
K031 |
0 |
2,308.10 |
4,616.19 |
|
Cresol |
D026 |
0 |
2,266.59 |
10,224.41 |
|
Mercury |
D009 |
192.1 |
2,111.98 |
10,379.76 |
|
Selenium |
D010 |
82 |
2,091.44 |
9,220.64 |
|
Chloroform |
D022 |
0.2 |
1,948.26 |
9,723.75 |
|
l,l-Dichloroethylene |
D029 |
2.25 |
1,627.28 |
8,347.01 |
|
2-Propen-l-01 (Allyl alcohol) |
P005 |
709.05 |
1,273.60 |
2,402.68 |
|
Nitrobenzene |
D036 |
606.2 |
930.84 |
3,786.08 |
|
Petroleum refinery primary separation sludge, with exceptions |
F037 |
91.81 |
925.14 |
3,425.14 |
Table 22. Twenty-nine non-commercial Class I hazardous well facilities reported under both TRI and BRS
AMOCO OIL COMPANY (TEXAS CITY PLANT) Street: 2401 5TH AVE. S. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 1,880,700 from on-site: 1,880,700 from off-site: 0 BRS Tons : 2,059,482 from on-site: 2,059,482 from off-site: 0 ANGUS CHEMICAL COMPANY Street: LOUISIANA HWY. 2 City : STERLINGTON State: LA Zip: 71280 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 5,264,233 from on-site: 5,264,233 from off-site: 0 BRS Tons : 101,681 from on-site: 101,681 from off-site: 0 ARCO CHEMICAL COMPANY (CHANNELVIEW PLANT) Street: 2502 SHELDON RD. City : CHANNELVIEW State: TX Zip: 77530 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 2,817,872 from on-site: 2,802,631 from off-site: 15,241 BRS Tons : 1,077,568 from on-site: 1,027,471 from off-site: 50,097 ASARCO, INC. (AMARILLO COPPER REFINERY) Street: HWY. 136 8 MILES N. W. OF AMARILLO City : AMARILLO State: TX Zip: 79108 Class I haz. waste wells: 2 Non-hazardous Class I wells: 1 TRI Pounds: 175,855 from on-site: 175,855 from off-site: 0 BRS Tons : 292,869 from on-site: 292,869 from off-site: 0 BASF CORPORATION (FREEPORT ROAD) Street: 602 COPPER RD. City : FREEPORT State: TX Zip: 77541 Class I haz. waste wells: 3 Non-hazardous Class I wells: 1 TRI Pounds: 1,926,800 from on-site: 1,926,800 from off-site: 0 BRS Tons : 281,555 from on-site: 281,555 from off-site: 0 BETHLEHEM STEEL CORP. (BURNS HARBOR) Street: U.S. RTE. 12 & S.R. 249 City : BURNS HARBOR State: IN Zip: 46304 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 3,000 from on-site: 3,000 from off-site: 0 BRS Tons : 391,303 from on-site: 391,303 from off-site: 0 BP CHEMICALS Street: 1900 FORT AMANDA RD. City : LIMA State: OH Zip: 45805 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 13,160,730 from on-site: 13,160,730 from off-site: 0 BRS Tons : 991,819 from on-site: 991,819 from off-site: 0 BP CHEMICALS AMERICA CO. Street: TEXAS HWY. 185 City : PORT LAVACA State: TX Zip: 77979 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 12,894,900 from on-site: 12,894,900 from off-site: 0 BRS Tons : 886,180 from on-site: 886,180 from off-site: 0 CYTEC INDUSTRIES, INC. Street: 10800 RIVER RD. City : WESTWEGO State: LA Zip: 70094 Class I haz. waste wells: 5 Non-hazardous Class I wells: 0 TRI Pounds: 26,362,503 from on-site: 26,362,503 from off-site: 0 BRS Tons : 1,742,901 from on-site: 1,742,901 from off-site: 0 E.I. DUPONT (PONTCHARTRAIN WORKS) Street: 586 HWY. 44 City : LA PLACE State: LA Zip: 70068 Class I haz. waste wells: 3 Non-hazardous Class I wells: 2 TRI Pounds: 701,622 from on-site: 701,622 from off-site: 0 BRS Tons : 494,219 from on-site: 494,219 from off-site: 0 E.I. DUPONT DE NEMOURS AND COMPANY (SABINE) Street: FARM RD. 1006 City : ORANGE State: TX Zip: 77631 Class I haz. waste wells: 7 Non-hazardous Class I wells: 0 TRI Pounds: 710,259 from on-site: 710,259 from off-site: 0 BRS Tons : 686,441 from on-site: 686,441 from off-site: 0 E.I. DUPONT DE NEMOURS AND COMPANY (VICTORIA) Street: OLD BLOOMINGTON RD. City : VICTORIA State: TX Zip: 77901 Class I haz. waste wells: 11 Non-hazardous Class I wells: 0 TRI Pounds: 24,988,671 from on-site: 24,974,723 from off-site: 13,948 BRS Tons : 4,016,168 from on-site: 4,013,825 from off-site: 2,343 E.I. DUPONT DE NEMOURS CO. (BEAUMONT PLANT) Street: STATE HWY. 347 City : BEAUMONT State: TX Zip: 77704 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 20,447,185 from on-site: 20,447,185 from off-site: 0 BRS Tons : 1,395,384 from on-site: 1,395,384 from off-site: 0 GREAT LAKES CHEMICAL CORPORATION Street: 2426 HAYNESVILLE HWY. City : EL DORADO State: AR Zip: 71730 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 2,628,199 from on-site: 2,628,199 from off-site: 0 BRS Tons : 743,764 from on-site: 743,764 from off-site: 0 HOECHST CELANESE CHEMICAL CO. (CLEAR LAKE) Street: 9502 BAYPORT RD. City : PASADENA State: TX Zip: 77507 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 12,602,200 from on-site: 12,602,200 from off-site: 0 BRS Tons : 782,205 from on-site: 782,205 from off-site: 0 HOECHST CELANESE CHEMICAL COMPANY Street: 1 MILE S. OF BISHOP TEXAS HWY. 77 BUSINESS City : BISHOP State: TX Zip: 78343 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,066,300 from on-site: 2,066,300 from off-site: 0 BRS Tons : 22,255 from on-site: 22,255 from off-site: 0 ISP TECHNOLOGIES, INC. (TEXAS CITY) Street: HWY. 146 & INDL. RD. City : TEXAS CITY State: TX Zip: 77592 Class I haz. waste wells: 3 Non-hazardous Class I wells: 1 TRI Pounds: 3,008,410 from on-site: 3,008,410 from off-site: 0 BRS Tons : 779 from on-site: 779 from off-site: 0 KAISER ALUMINUM & CHEMICAL COMPANY Street: 2420 OLD HWY. 60 City : MULBERRY State: FL Zip: 33860 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 6,594,743 from on-site: 6,594,743 from off-site: 0 BRS Tons : 96,492 from on-site: 96,492 from off-site: 0 LTV STEEL COMPANY (HENNEPIN WORKS) Street: RTS. 180 & 71 City : HENNEPIN State: IL Zip: 61327 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 250 from on-site: 250 from off-site: 0 BRS Tons : 34,983 from on-site: 34,983 from off-site: 0 MERICHEM COMPANY Street: 1914 HADEN RD. City : HOUSTON State: TX Zip: 77015 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 3,078,300 from on-site: 3,078,300 from off-site: 0 BRS Tons : 479,163 from on-site: 479,163 from off-site: 0 MONSANTO COMPANY (CHOCOLATE BAYOU PLANT) Street: FM 2917 City : ALVIN State: TX Zip: 77511 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 10,588,676 from on-site: 10,588,676 from off-site: 0 BRS Tons : 2,512,275 from on-site: 2,512,275 from off-site: 0 MORTON INTERNATIONAL, INC. Street: 5724 ELDER FERRY RD. City : MOSS POINT State: MS Zip: 39563 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 82,228 from on-site: 82,228 from off-site: 0 BRS Tons : 499,087 from on-site: 499,087 from off-site: 0 OCCIDENTAL PETROLEUM CORP. Street: 1501 MCKINZIE RD. City : CORPUS CHRISTI State: TX Zip: 78410 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 1,500 from on-site: 1,500 from off-site: 0 BRS Tons : 18,757 from on-site: 0 from off-site: 18,757 PARKE-DAVIS DIVISION OF WARNER LAMBERT Street: 188 HOWARD AVE. City : HOLLAND State: MI Zip: 49424 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 364,370 from on-site: 364,370 from off-site: 0 BRS Tons : 158,518 from on-site: 158,518 from off-site: 0 RUBICON, INC. Street: 9156 HWY. 75 City : GEISMAR State: LA Zip: 70734 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 7,736,350 from on-site: 7,736,350 from off-site: 0 BRS Tons : 19,599 from on-site: 19,599 from off-site: 0 STERLING CHEMICALS (TEXAS CITY) Street: 201 BAY ST. S. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 3 Non-hazardous Class I wells: 0 TRI Pounds: 14,598,675 from on-site: 14,598,675 from off-site: 0 BRS Tons : 1,088,370 from on-site: 1,088,370 from off-site: 0 THE UPJOHN COMPANY Street: 7171 PORTAGE RD. City : PORTAGE State: MI Zip: 49001 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 7,074,000 from on-site: 7,074,000 from off-site: 0 BRS Tons : 2,701 from on-site: 2,701 from off-site: 0 VULCAN CHEMICALS Street: 6200 S. RIDGE RD. City : WICHITA State: KS Zip: 67215 Class I haz. waste wells: 5 Non-hazardous Class I wells: 0 TRI Pounds: 957,064 from on-site: 883,864 from off-site: 73,200 BRS Tons : 1,633,383 from on-site: 1,483,747 from off-site: 149,635 WITCO CHEMICAL COMPANY (MARSHALL PLANT) Street: HWY. 59N & BUSSEY RD. City : MARSHALL State: TX Zip: 75670 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 184,550 from on-site: 184,550 from off-site: 0 BRS Tons : 55,503 from on-site: 55,503 from off-site: 0
Table 23. Non-Class I non-commercial wells reporting to TRI only (with more than 100 lbs)
U.S. DOE NAVAL PETROLEUM Street: 28590 HWY. 119 City : TUPMAN State: CA Zip: 93276 No Class I wells listed. TRI Pounds: 325,385 from on-site: 325,385 from off-site: 0 NORTH AMERICAN CHEMICAL CO. Street: 13200 MAIN ST. City : TRONA State: CA Zip: 93562 No Class I wells listed. TRI Pounds: 110,000 from on-site: 110,000 from off-site: 0 MARTIN MARIETTA MAGNESIA Street: 1800 EASTLAKE RD. City : MANISTEE State: MI Zip: 49660 No Class I wells listed. TRI Pounds: 102,063 from on-site: 102,063 from off-site: 0 TEXACO REFINING & MARKETING Street: 6451 ROSEDALE HWY. City : BAKERSFIELD State: CA Zip: 93308 No Class I wells listed. TRI Pounds: 43,589 from on-site: 43,589 from off-site: 0 MAUI PINEAPPLE CO. LTD. Street: 120 KANE ST. City : KAHULUI State: HI Zip: 96732 No Class I wells listed. TRI Pounds: 23,000 from on-site: 23,000 from off-site: 0 BHP PETROLEUM AMERICAS Street: 91-325 KOMOHANA ST. City : KAPOLEI State: HI Zip: 96707 No Class I wells listed. TRI Pounds: 1,047 from on-site: 1,047 from off-site: 0 PLASMA PROCESSING CORP. Street: JACKSON COUNTY INDL. PARK ST. RTE. 2 City : MILLWOOD State: WV Zip: 25262 No Class I wells listed. TRI Pounds: 1,000 from on-site: 1,000 from off-site: 0 U.S. DOE NAVAL PETROLEUM Street: 907 N. POPLAR SUITE 150 City : CASPER State: WY Zip: 82601 No Class I wells listed. TRI Pounds: 366 from on-site: 366 from off-site: 0 BOLIDEN INTERTRADE INC. Street: HWY. 68 City : COPPERHILL State: TN Zip: 37317 No Class I wells listed. TRI Pounds: 250 from on-site: 250 from off-site: 0 JORGENSEN STEEL & ALUMINUM Street: 91-104 KALAELOA BLVD. City : KAPOLEI State: HI Zip: 96707 No Class I wells listed. TRI Pounds: 250 from on-site: 250 from off-site: 0 FRASER PAPER INC. Street: 51 SOUTH ELM ST. City : WEST CARROLLTON State: OH Zip: 45449 No Class I wells listed. TRI Pounds: 220 from on-site: 220 from off-site: 0 UNOCAL AGRICULTURAL PRODS. Street: MILE 21 SPUR HWY. City : KENAI State: AK Zip: 99611 No Class I wells listed. TRI Pounds: 188 from on-site: 188 from off-site: 0
Table 24. Nine commercial Class I hazardous wells reported under both TRI and BRS
AMERICAN ECOLOGY CORP. Street: P.O. BOX 248 City : WINONA State: TX Zip: 75792 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 852,160 from on-site: 0 from off-site: 852,160 BRS Tons : 58,950 from on-site: 13,197 from off-site: 45,753 CECOS INTERNATIONAL (WILLOW SPRINGS) Street: 918 WILLOW SPRINGS City : WESTLAKE State: LA Zip: 70669 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 6,002 from on-site: 0 from off-site: 6,002 BRS Tons : 58,419 from on-site: 49,372 from off-site: 9,048 CHEMICAL WASTE MANAGEMENT, INC. Street: 3956 STATE RTE. 412 City : VICKERY State: OH Zip: 43464 Class I haz. waste wells: 4 Non-hazardous Class I wells: 0 TRI Pounds: 9,689,391 from on-site: 0 from off-site: 9,689,391 BRS Tons : 117,170 from on-site: 9,166 from off-site: 108,004 DISPOSAL SYSTEMS OF CORPUS CHRISTI, GNR GROUP Street: 6901 GREENWOOD DR. City : CORPUS CHRISTI State: TX Zip: 78415 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 605,365 from on-site: 0 from off-site: 605,365 BRS Tons : 56,268 from on-site: 7,256 from off-site: 49.012 DISPOSAL SYSTEMS, INC. Street: 2525 BATTLEGROUND RD. City : DEER PARK State: TX Zip: 77536 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,933,427 from on-site: 0 from off-site: 2,933,427 BRS Tons : 149,864 from on-site: 18,771 from off-site: 131,093 EMPAK, INC. Street: BATTLEGROUND RD. City : DEER PARK State: TX Zip: 77536 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 2,560,757 from on-site: 0 from off-site: 2,560,757 BRS Tons : 70,270 from on-site: 2,074 from off-site: 68,195 MALONE SERVICES COMPANY Street: 5200 CAMPBELL BAYOU RD. City : TEXAS CITY State: TX Zip: 77590 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 TRI Pounds: 113,699 from on-site: 0 from off-site: 113,699 BRS Tons : 10,295 from on-site: 0 from off-site: 10,295 ROLLINS ENVIRONMENTAL SERVICES OF LA, INC. Street: City : PLAQUEMINE State: LA Zip: 70764 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 377,519 from on-site: 0 from off-site: 377,519 BRS Tons : 20,897 from on-site: 0 from off-site: 20,897 TEXAS ECOLOGIST, INC. Street: 3.5 MILES SOUTH PETRONELA RD. City : ROBSTOWN State: TX Zip: 78380 Class I haz. waste wells: 1 Non-hazardous Class I wells: 0 TRI Pounds: 206 from on-site: 0 from off-site: 206 BRS Tons : 8,231 from on-site: 7,958 from off-site: 273
Table 25. Eight commercial non-Class I wells reported under both TRI and BRS.
CHEMICAL WASTE MANAGEMENT INC. Street: RT. 2 JOHN BRANNON RD. City : CARLYSS State: LA Zip: 70663 No Class I wells listed. TRI Pounds: 5,666 from on-site: 0 from off-site: 5,666 BRS Tons : 1 from on-site: 0 from off-site: 1 CLEAN HARBORS OF CHICAGO INC. Street: 11800 S. STONEY ISLAND AVE. City : CHICAGO State: IL Zip: 60617 No Class I wells listed. TRI Pounds: 68,000 from on-site: 0 from off-site: 68,000 BRS Tons : 24 from on-site: 0 from off-site: 24 DUPONT Street: RTE. 130 SPOT 746 TECHLAB City : DEEPWATER State: NJ Zip: 08023 No Class I wells listed. TRI Pounds: 70,738 from on-site: 0 from off-site: 70,738 BRS Tons : 572 from on-site: 0 from off-site: 572 ENVOTECH Street: 49350 N. SERVICE DR. City : BELLEVILLE State: MI Zip: 48111 No Class I wells listed. TRI Pounds: 5,960 from on-site: 0 from off-site: 5,960 BRS Tons : 0 from on-site: 0 from off-site: 0 ELTEX Street: 4050 HOMESTEAD RD. City : HOUSTON State: TX Zip: 77028 No Class I wells listed. TRI Pounds: 750 from on-site: 0 from off-site: 750 BRS Tons : 178 from on-site: 0 from off-site: 178 HYDROCARBON RECYCLERS INC. Street: 5354 W. 46TH ST. S. City : TULSA State: OK Zip: 74107 No Class I wells listed. TRI Pounds: 11,000 from on-site: 0 from off-site: 11,000 BRS Tons : 211 from on-site: 0 from off-site: 211 HYDROCARBON RECYCLERS INC.-TX Street: 4303 PROFIT DR. City : SAN ANTONIO State: TX Zip: 78219 No Class I wells listed. TRI Pounds: 5,496 from on-site: 0 from off-site: 5,496 BRS Tons : 96 from on-site: 0 from off-site: 96 USPCI/SSI FACILITY Street: 1021 BERRYESSA RD. City : SAN JOSE State: CA Zip: 94133 No Class I wells listed. TRI Pounds: 4,200 from on-site: 0 from off-site: 4,200 BRS Tons : 29 from on-site: 0 from off-site: 29
Table 26. Six non-commercial facilities reported under BRS but not TRI
AK STEEL CO. Street: 1801 CRAWFORD ST. City : MIDDLETOWN State: OH Zip: 45043 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 BRS Tons : 83,645 from on-site: 83,645 from off-site: 0 BLACK HAWK COUNTY LANKFILL Street: 1509 E. WASHINGTON City : WATERLOO State: IA Zip: 50701 No Class I wells listed. BRS Tons : 23 from on-site: 23 from off-site: 0 CABOT CORPORATION Street: 700 E US HWY 36 City : TUSCOLA State: IL Zip: 61953 Class I haz. waste wells: 2 Non-hazardous Class I wells: 0 BRS Tons : 422,249 from on-site: 422,249 from off-site: 0 DUPONT DELISLE PLANT-WHITE PIGMENT & MINERAL Street: 7658 KILN-DELISLE RD City : PASS CHRISTIAN State: MS Zip: 39571 Class I haz. waste wells: 0 Non-hazardous Class I wells: 0 BRS Tons : 909,235 from on-site: 909,235 from off-site: 0 PERMA-FIX ENVIRONMENTAL SERVICES, INC. Street: 901 E BODLEY City : MEMPHIS State: TN Zip: 38106 No Class I wells listed. BRS Tons : 113 from on-site: 113 from off-site: 0 TEXACO REFINING AND MARKETING (AMARILLO) Street: City : AMARILLO State: TX Zip: Class I haz. waste wells: 0 Non-hazardous Class I wells: 2 BRS Tons : 2 from on-site: 0 from off-site: 2
Table 27. State BRS and TRI totals
|
State |
TRI Pounds |
TRI Percent |
TRI Rank |
BRS Tons |
BRS Percent |
BRS Rank |
|
AK |
193 |
0 |
22 |
0 |
0 |
24 |
|
AL |
148,483 |
0.1 |
12 |
546 |
0 |
13 |
|
AR |
2,637,068 |
1 |
7 |
743,799 |
3 |
6 |
|
AZ |
14 |
0 |
23 |
10 |
0 |
20 |
|
CA |
483,174 |
0.2 |
10 |
205 |
0 |
14 |
|
CO |
0 |
0 |
25 |
5 |
0 |
21 |
|
FL |
25,343,332 |
10 |
3 |
96,492 |
0.4 |
10 |
|
HI |
24,306 |
0 |
16 |
0 |
0 |
24 |
|
IA |
0 |
0 |
25 |
23 |
0 |
18 |
|
IL |
68,365 |
0 |
15 |
457,256 |
1.9 |
7 |
|
IN |
3,398 |
0 |
17 |
391,324 |
1.6 |
8 |
|
KS |
1,747,329 |
0.7 |
8 |
1,633,384 |
6.6 |
3 |
|
KY |
0 |
0 |
25 |
2 |
0 |
22 |
|
LA |
54,883,720 |
21.7 |
2 |
2,437,877 |
9.9 |
2 |
|
MI |
7,578,268 |
3 |
6 |
161,220 |
0.7 |
9 |
|
MO |
2,000 |
0 |
19 |
0 |
0 |
23 |
|
MS |
82,251 |
0 |
13 |
1,408,322 |
5.7 |
4 |
|
NC |
0 |
0 |
25 |
46 |
0 |
17 |
|
ND |
691 |
0 |
21 |
0 |
0 |
24 |
|
NJ |
70,743 |
0 |
14 |
572 |
0 |
12 |
|
NM |
0 |
0 |
25 |
0 |
0 |
24 |
|
NV |
0 |
0 |
25 |
14 |
0 |
19 |
|
NY |
5 |
0 |
24 |
0 |
0 |
24 |
|
OH |
24,159,454 |
9.6 |
4 |
1,193,210 |
4.8 |
5 |
|
OK |
245,450 |
0.1 |
11 |
4,765 |
0 |
11 |
|
PA |
3,336 |
0 |
18 |
0 |
0 |
24 |
|
SC |
0 |
0 |
25 |
71 |
0 |
16 |
|
TN |
1,174,570 |
0.5 |
9 |
167 |
0 |
15 |
|
TX |
126,115,597 |
49.9 |
1 |
16,166,772 |
65.5 |
1 |
|
WI |
5 |
0 |
24 |
0 |
0 |
24 |
|
WV |
1,000 |
0 |
20 |
0 |
0 |
24 |
|
WY |
8,168,366 |
3.2 |
5 |
0 |
0 |
24 |
Table 28. State Imports and Exports (TRI data in pounds, BRS data in tons)
|
State |
TRI Imports |
TRI Exports |
TRI Net |
BRS Imports |
BRS Exports |
BRS Net |
|
AL |
305,982 |
0 |
305,982 |
31,811 |
546 |
31,265 |
|
AR |
251,575 |
0 |
251,575 |
4,845 |
35 |
4,810 |
|
AZ |
0 |
0 |
0 |
387 |
7 |
380 |
|
CA |
134,689 |
0 |
134,689 |
7,639 |
0 |
7,639 |
|
CO |
28,760 |
0 |
28,760 |
778 |
5 |
773 |
|
CT |
0 |
0 |
0 |
79 |
0 |
79 |
|
DE |
0 |
0 |
0 |
1,146 |
0 |
1,146 |
|
FL |
262,579 |
0 |
262,579 |
1,017 |
0 |
1,017 |
|
GA |
329,650 |
0 |
329,650 |
708 |
0 |
708 |
|
IA |
156,352 |
0 |
156,352 |
555 |
0 |
555 |
|
IL |
347,220 |
0 |
347,220 |
9,255 |
24 |
9,231 |
|
IN |
733,440 |
0 |
733,440 |
12,460 |
22 |
12,438 |
|
KS |
0 |
0 |
0 |
785 |
0 |
785 |
|
KY |
243,315 |
0 |
243,315 |
3,176 |
2 |
3,174 |
|
LA |
137,922 |
267,127 |
-129,205 |
48,173 |
10,322 |
37,851 |
|
MA |
70,738 |
0 |
70,738 |
354 |
0 |
354 |
|
MD |
3,790,687 |
0 |
3,790,687 |
0 |
0 |
0 |
|
MI |
61,512 |
5,960 |
55,552 |
16,256 |
1 |
16,256 |
|
MO |
12,728 |
0 |
12,728 |
4,203 |
0 |
4,203 |
|
MS |
256,942 |
0 |
256,942 |
3,140 |
0 |
3,140 |
|
MT |
13,281 |
0 |
13,281 |
854 |
0 |
854 |
|
NC |
109,396 |
0 |
109,396 |
208 |
46 |
162 |
|
ND |
6 |
691 |
-685 |
46 |
0 |
46 |
|
NE |
0 |
0 |
0 |
180 |
0 |
180 |
|
NJ |
0 |
71,324 |
-71,324 |
0 |
562 |
-562 |
|
NM |
0 |
0 |
0 |
27 |
0 |
27 |
|
NV |
0 |
0 |
0 |
713 |
14 |
699 |
|
NY |
228,511 |
0 |
228,511 |
359 |
0 |
359 |
|
OH |
21,929 |
6,270,390 |
-6,248,461 |
211 |
39,980 |
-39,769 |
|
OK |
7,969 |
147,811 |
-139,842 |
6,652 |
2,442 |
4,209 |
|
OR |
0 |
0 |
0 |
63 |
0 |
63 |
|
PA |
73,882 |
0 |
73,882 |
2,439 |
0 |
2,439 |
|
SC |
46,809 |
0 |
46,809 |
0 |
71 |
-71 |
|
TN |
80,203 |
0 |
80,203 |
791 |
54 |
736 |
|
TX |
12,273 |
954,447 |
-942,174 |
745 |
111,086 |
-110,341 |
|
UT |
0 |
0 |
0 |
4,998 |
0 |
4,998 |
|
VA |
0 |
0 |
0 |
66 |
0 |
66 |
|
WA |
0 |
0 |
0 |
166 |
0 |
166 |
|
WV |
0 |
0 |
0 |
613 |
0 |
613 |
Table 29. Numbers of wells by state
|
State |
Total Facilities with Wells |
Class I Facilities |
TRI Facilities |
BRS Facilities |
Commercial Facilities |
Class I Hazardous Wells |
Class I Non-hazardous Wells |
|
AK |
3 |
1 |
2 |
0 |
0 |
0 |
3 |
|
AL |
6 |
0 |
4 |
2 |
3 |
0 |
0 |
|
AR |
8 |
6 |
3 |
3 |
2 |
3 |
10 |
|
AZ |
4 |
0 |
1 |
3 |
3 |
0 |
0 |
|
CA |
13 |
5 |
4 |
5 |
5 |
0 |
5 |
|
CO |
7 |
6 |
0 |
1 |
2 |
0 |
6 |
|
FL |
72 |
71 |
5 |
1 |
0 |
1 |
130 |
|
HI |
4 |
0 |
4 |
0 |
0 |
0 |
0 |
|
IA |
1 |
0 |
0 |
1 |
0 |
0 |
0 |
|
IL |
5 |
4 |
4 |
3 |
1 |
4 |
1 |
|
IN |
9 |
8 |
3 |
2 |
1 |
6 |
7 |
|
KS |
26 |
25 |
5 |
2 |
1 |
5 |
40 |
|
KY |
3 |
2 |
0 |
1 |
1 |
2 |
1 |
|
LA |
22 |
18 |
18 |
8 |
5 |
17 |
25 |
|
MI |
21 |
16 |
8 |
4 |
3 |
10 |
14 |
|
MO |
2 |
0 |
1 |
1 |
2 |
0 |
0 |
|
MS |
4 |
3 |
2 |
2 |
0 |
1 |
1 |
|
NC |
2 |
0 |
0 |
2 |
2 |
0 |
0 |
|
ND |
3 |
2 |
1 |
0 |
1 |
0 |
3 |
|
NJ |
2 |
0 |
2 |
1 |
1 |
0 |
0 |
|
NM |
1 |
1 |
0 |
0 |
0 |
0 |
1 |
|
NV |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
|
NY |
1 |
0 |
1 |
0 |
0 |
0 |
0 |
|
OH |
13 |
7 |
6 |
7 |
6 |
10 |
7 |
|
OK |
12 |
9 |
5 |
4 |
4 |
0 |
13 |
|
PA |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
|
SC |
2 |
0 |
0 |
2 |
2 |
0 |
0 |
|
TN |
6 |
1 |
2 |
4 |
3 |
0 |
3 |
|
TX |
84 |
69 |
39 |
36 |
24 |
81 |
61 |
|
WI |
1 |
0 |
1 |
0 |
0 |
0 |
0 |
|
WV |
1 |
0 |
1 |
0 |
0 |
0 |
0 |
|
WY |
18 |
17 |
2 |
0 |
9 |
0 |
30 |
Table 30. Top three TRI chemicals and BRS waste codes injected in each state (Quantities in pounds for TRI, tons for BRS)
|
State |
TRI or BRS |
Chemical or waste name |
Quantity |
|
AK |
|||
|
TRI |
AMMONIA |
150 |
|
|
TRI |
METHANOL |
38 |
|
|
TRI |
SULFURIC ACID |
5 |
|
|
AL |
|||
|
TRI |
BARIUM COMPOUNDS |
138,867 |
|
|
TRI |
CHROMIUM COMPOUNDS |
6,600 |
|
|
TRI |
NICKEL COMPOUNDS |
3,000 |
|
|
AR |
|||
|
TRI |
METHANOL |
1,501,400 |
|
|
TRI |
DICHLOROMETHANE |
838,279 |
|
|
TRI |
TRIETHYLAMINE |
276,142 |
|
|
BRS |
Spent absorbent & solids from production of methyl bromide (K132) |
743,764.00 |
|
|
AZ |
|||
|
TRI |
COPPER |
10 |
|
|
TRI |
MANGANESE |
3 |
|
|
TRI |
CHROMIUM |
1 |
|
|
CA |
|||
|
TRI |
METHANOL |
315,242 |
|
|
TRI |
AMMONIA |
139,204 |
|
|
TRI |
CRESOL (MIXED ISOMERS) |
13,736 |
|
|
FL |
|||
|
TRI |
NITRATE COMPOUNDS |
11,000,000 |
|
|
TRI |
HYDROCHLORIC ACID |
6,594,743 |
|
|
TRI |
FORMIC ACID |
3,400,000 |
|
|
BRS |
Corrosive waste (D002) |
96,492.15 |
|
|
GA |
|||
|
TRI |
DAZOMET |
2,300 |
|
|
HI |
|||
|
TRI |
AMMONIA |
24,047 |
|
|
TRI |
HYDROCHLORIC ACID |
250 |
|
|
TRI |
MANGANESE |
9 |
|
|
IA |
|||
|
BRS |
Wastewater treatment sludges from electroplating, with exceptions (F006) |
4.67 |
|
|
BRS |
Spent cyanide plating bath solutions from electroplating (F007) |
4.67 |
|
|
BRS |
Plating bath residues from electroplating bottoms, with cyanide (F008) |
4.67 |
|
|
IL |
|||
|
TRI |
AMMONIA |
68,000 |
|
|
TRI |
ZINC COMPOUNDS |
250 |
|
|
TRI |
1,1-DICHLORO-1-FLUOROETHANE |
26 |
|
|
BRS |
Corrosive waste (D002) |
211,124.60 |
|
|
BRS |
Leachate from treatment/disposal of wastes classed under more than 1 code (F039) |
211,124.60 |
|
|
BRS |
Spent pickle liquor from steel finishing operations, with exceptions (K062) |
34,983.00 |
|
|
IN |
|||
|
TRI |
MANGANESE COMPOUNDS |
3,000 |
|
|
TRI |
CHLORINE |
190 |
|
|
TRI |
NICKEL |
181 |
|
|
BRS |
Selenium (D010) |
123,293.00 |
|
|
BRS |
Benzene (D018) |
123,293.00 |
|
|
BRS |
Pyridine (D038) |
123,293.00 |
|
|
KS |
|||
|
TRI |
METHANOL |
816,180 |
|
|
TRI |
HYDROCHLORIC ACID |
458,880 |
|
|
TRI |
CHLORINE |
73,861 |
|
|
BRS |
Corrosive waste (D002) |
227,727.34 |
|
|
BRS |
Chromium (D007) |
78,091.96 |
|
|
BRS |
Lindane (l,2,3,4,5,6-hexachlorocyclohexane, gamma isomer) (D013) |
78,091.96 |
|
|
LA |
|||
|
TRI |
ACETONITRILE |
11,003,500 |
|
|
TRI |
NITRATE COMPOUNDS |
6,857,372 |
|
|
TRI |
ACRYLIC ACID |
6,600,000 |
|
|
BRS |
Pyridine (D038) |
715,817.98 |
|
|
BRS |
Reactive waste (D003) |
453,474.60 |
|
|
BRS |
Corrosive waste (D002) |
438,256.30 |
|
|
MI |
|||
|
TRI |
METHANOL |
5,820,000 |
|
|
TRI |
N,N-DIMETHYLFORMAMIDE |
1,000,000 |
|
|
TRI |
ACETONITRILE |
219,000 |
|
|
BRS |
Corrosive waste (D002) |
158,517.69 |
|
|
BRS |
Chromium (D007) |
540.26 |
|
|
BRS |
l,2-Dichloroethane (D028) |
540.26 |
|
|
MO |
|||
|
TRI |
NICKEL COMPOUNDS |
2,000 |
|
|
MS |
|||
|
TRI |
METHYL ETHYL KETONE |
43,708 |
|
|
TRI |
CERTAIN GLYCOL ETHERS |
22,000 |
|
|
TRI |
1,2-DICHLOROETHANE |
12,389 |
|
|
BRS |
Reactive waste (D003) |
499,087.31 |
|
|
BRS |
Corrosive waste (D002) |
303,078.33 |
|
|
BRS |
Chromium (D007) |
303,078.33 |
|
|
ND |
|||
|
TRI |
NICKEL COMPOUNDS |
691 |
|
|
NJ |
|||
|
TRI |
ZINC COMPOUNDS |
70,738 |
|
|
TRI |
STYRENE |
353 |
|
|
TRI |
TOLUENE |
233 |
|
|
NY |
|||
|
TRI |
PHOSPHORIC ACID |
5 |
|
|
OH |
|||
|
TRI |
ACETONITRILE |
4,300,000 |
|
|
TRI |
NITRIC ACID |
3,346,904 |
|
|
TRI |
SULFURIC ACID |
3,115,122 |
|
|
BRS |
Bottom stream from acetonitrile column in production of acrylonitrile (K013) |
538,826.00 |
|
|
BRS |
Bottom stream from wastewater stripper in production of acrylonitrile (K011) |
440,605.00 |
|
|
BRS |
Corrosive waste (D002) |
74,822.50 |
|
|
OK |
|||
|
TRI |
ZINC COMPOUNDS |
96,119 |
|
|
TRI |
CERTAIN GLYCOL ETHERS |
61,256 |
|
|
TRI |
HYDROCHLORIC ACID |
50,920 |
|
|
BRS |
Tetrachloroethylene (D039) |
2,002.09 |
|
|
BRS |
Corrosive waste (D002) |
1,590.49 |
|
|
BRS |
Benzene (D018) |
521.91 |
|
|
PA |
|||
|
TRI |
MANGANESE COMPOUNDS |
3,336 |
|
|
TN |
|||
|
TRI |
AMMONIA |
658,258 |
|
|
TRI |
METHANOL |
464,179 |
|
|
TRI |
DIMETHYL CHLOROTHIOPHOSPHATE |
51,677 |
|
|
BRS |
Ignitable waste (D001) |
56.54 |
|
|
BRS |
Benzene (D018) |
56.54 |
|
|
TX |
|||
|
TRI |
NITRATE COMPOUNDS |
20,200,021 |
|
|
TRI |
NITRIC ACID |
16,345,815 |
|
|
TRI |
AMMONIA |
14,574,334 |
|
|
BRS |
Benzene (D018) |
4,466,377.03 |
|
|
BRS |
Corrosive waste (D002) |
3,022,690.74 |
|
|
BRS |
Reactive waste (D003) |
1,252,679.14 |
|
|
WI |
|||
|
TRI |
PHOSPHORIC ACID |
5 |
|
|
WV |
|||
|
TRI |
AMMONIA |
750 |
|
|
TRI |
ALUMINUM (FUME OR DUST) |
250 |
|
|
WY |
|||
|
TRI |
NITRATE COMPOUNDS |
7,700,000 |
|
|
TRI |
AMMONIA |
448,000 |
|
|
TRI |
ETHYLENE GLYCOL |
17,000 |
(1) A partial bibliography includes the following:
A Class I Injection Well Survey: Phase I Report, Survey of Selected Sites. Underground Injection Practices Council (prepared by CH2M Hill), Oklahoma City, OK, April 1986.
Analysis of the Effects of EPA Restrictions on the Deep Injection of Hazardous Waste, U.S. EPA 570/9-91-031, October 1991.
Thornton, Joe. A Shot in the Dark: Underground Injection of Hazardous Waste, Greenpeace USA, July 1990.
Assessing the Geochemical Fate of Deep-Well-Injected Hazardous Waste: A Reference Guide. U.S. EPA 625/6-89-025a, June 1990.
Gordon, Wendy, and Bloom, Jane. Deeper Problems: Limits to Underground Injection as a Hazardous Waste Disposal Method, Natural Resources Defense Council, New York, 1985.
Lester, Stephen, and Sullivan, Barbara. Deep-Well Injection: An Explosive Issue. Citizens’ Clearinghouse for Hazardous Waste, Falls Church, VA, August 1995.
Environmental Protection: Information on EPA’s Underground Injection Control Program. U.S. General Accounting Office, GAO/RCED-95-21, December 1994.
Hazardous Waste: Controls over Injection Well Disposal Operations Protect Drinking Water. U.S. General Accounting Office, GAO/RCED-87-170, August 1987.
(2) Some groups that may be able to help are:
Center for Health, Environment, and Justice (formerly CCHW)
PO Box 6806
Falls Church, VA 22040
CCHW@essential.orgLegal Environmental Assistance Foundation, Inc. (LEAF)
1115 North Gadsden Street
Tallahassee, FL 32303-6327
(904) 681-2591
leaf@igc.apc.orgMothers Organized to Stop Environmental Sins (M.O.S.E.S.)
13231 Wittmore Circle
Dallas, TX 75240
(972) 960-1421
(3) Representatives of both industry and regulatory agencies who reviewed this report have disagreed with M.O.S.E.S.’s assessment of failure of the well, and questioned whether spills resulting in air emissions, surface water discharges, and groundwater contamination were instead responsible for local health problems.
(4) Tons is the traditional unit of measurement in BRS. Our total of 24.6 million tons sent to underground injection does not exactly match the 24 million tons listed in the 1995 EPA National Biennial RCRA Hazardous Waste Report used as the source of data in Table 1. In addition to rounding issues, this is probably because RCRA waste is calculated for the National Report using a complicated procedure that can treat some waste going to RCRA units as non-RCRA.
(5) The copy of BRS available to us actually extends from 1989 to 1995, but 1989 was deemed unsuitable because the data may not be comparable with later years. The toxicity characteristics rule promulgated in 1990 added new characteristic waste codes to BRS and captured a larger universe of waste. Since each waste may have more than one code, it is not possible to separate out the new type of waste from the old. Therefore, to avoid invalidating the year-to-year comparison by including waste not existing in the data for all years, we left out 1989 data.
The TRI database actually extends back to 1987, but that data was considered to be of suspect quality since it was the first reporting year. EPA uses 1988 as the base year for year-to-year TRI release comparisons and we follow that practice here.
(6) The TRI data presented for multi-year comparison includes the "core chemical set" only, a set of chemicals that were reported during all the years under consideration. Thus, chemicals that were either dropped after being reported in early years or added in later years are not included. In addition, certain chemicals whose reporting guidance changed in such a way as to drastically change the number of pounds reported are not included.
(7) Looking at the BRS tables, the reader will notice that the BRS quantities reported by generators as being shipped off site do not match the quantities reported as being received by wells. There are a few possible reasons for this: classification of shipment data as confidential business information by receiving but not by shipping facilities, shipment of waste that is injected in the following year, waste received from foreign countries, and simple reporting error. Since the 1991 received waste quantity is unusually low, we used the shipped waste quantities for the comparative BRS waste totals.
(8) EPA prefers to consider only waste that is managed in a RCRA permitted unit in its totals. In practice, a varying percentage of "exempt" waste (waste that does not go to RCRA units) will be captured in the database each year, making the numbers fluctuate unpredictably. Therefore, for these BRS tables, the percentages are taken in comparison to the total waste going to RCRA regulated units. Non RCRA-regulated units are left out.
(9) These TRI tables use the "core chemical" data set for year-to-year comparisons – only chemicals that were not added or dropped within TRI over the years. Consequently, the totals and percentages are different for the 1995 year in these tables and in the preceding section.
(10) This percentage decline is for the TRI core chemicals and for the total of releases and transfers excluding transfers to recycling and energy recovery. Transfers to recycling and energy recovery were not collected in 1988, making comparison with 1995 impossible.
(11) This percentage decline is for all waste managed in RCRA regulated units.
(12) The classification scheme is set out below:
|
Category |
Waste Codes |
|
Ignitable |
(D001) |
|
Corrosive |
(D002) |
|
Reactive |
(D003) |
|
Toxic |
(D004 - D017) |
|
Toxic (under newer regs) |
(D018 - D043) |
|
More than one characteristic (D) code |
|
|
"F" listed code |
any starting with "F" |
|
"K" listed code |
any starting with "K" |
|
"P" listed code |
any starting with "P" |
|
"U" listed code |
any starting with "U" |
|
More than one listed (F,K,P,U) code |
|
|
Both characteristic and listed codes |
(13) Because of the many wastes with multiple codes, breaking out the amount of waste for each code can be difficult. We have provided three columns representing a range of possible values. The first column has the amount of waste listed with only one code. This is the amount of waste that can be absolutely associated with the particular code. The second column has the amount of waste listed with more than one code, divided by the number of codes reported, essentially the amount of waste that would be associated with each code if a waste with multiple codes were evenly divided among its codes. (This will not be generally true for actual wastes, but it provides a way of presenting quantities by code in a table that avoids double counting of waste.) The third column contains the total amount of waste listed with one or many codes. This represents the maximum amount of waste that might be associated with each code.
(14) This list of persistent bioaccumulative toxics was combined from two sources: bioaccumulative chemicals of concern from the Federal Register, Vol. 60, No. 56, p. 15393, and endocrine disrupting chemicals from the Wingspread consensus statement of scientists (Chemically-Induced Alterations in Sexual Development: The Wildlife/Human Connection, July 1991).
(15) This list of VOC carcinogens was derived from EPA’s list of TRI carcinogens (1995 Toxics Release Inventory Public Data Release, EPA 745-R-97-005, April 1997), modified to include only chemicals with measurable vapor pressure at standard temperature and pressure.
(16) Some facilities had waste reported from both on- and off-site. There were only three TRI facilities in this category; they reported a small amount of off-site waste compared to on-site. These were classed as non-commercial facilities and the waste from off-site was not included in their waste totals. In BRS, it is relatively common for commercial waste treatment facilities to report on-site disposal of waste. This may be waste generated from other waste disposal or treatment units, waste from last year, or other specialized reporting categories. For these reasons we included both on- and off-site waste as part of the waste total for each BRS facility.
(17)TRI facilities designate parent companies on their reporting forms, and these were used to aggregate parent company totals in TRI. BRS facilities do not report parent companies. In this report, a combination of TRI parent companies and facility name aggregation was used to determine BRS parent company totals. The parent companies named on TRI forms may not be the ultimate parent companies, so some parent companies listed in this report may in fact be subsidiaries of other companies.
(18) TRI provides data to calculate quantity of waste output each year since 1991, and a production index which is intended to allow calculation of the amount of waste prevented by source reduction each year. However, we found these data to be too poor in quality to use, mainly because many facilities appear to provide production indexes that are too high.
(19) We checked to see whether this number was sensitive to changes in the presumed size of facilities by imposing a cutoff on the release total for forms under consideration. When we considered only forms with 1,000 pounds or more, the SRA/form ratio for forms without underground injection was 0.51 and for forms with injection it was 0.18. With a cutoff of 10,000 pounds the ratios were 0.53 and 0.20 respectively. So the difference between forms with injection and those without is not due to facility size, at least as indicated by proxy. We also tried taking the SRA/form ratio for all facilities with an on-site well as opposed to all facilities without: the SRA/form ratios were 0.44 and 0.18, about the same as the ratio obtained when forms were considered separately. We tried obtaining a separate SRA/form ratio for all forms for the top ten chemicals sent to underground injection in case there was some chemical-specific factor that lowered source reduction activity for these chemicals. The SRA/form ratio for those chemicals was 0.35, close to the ratio for all TRI chemicals. Lastly, we checked the SRA/form ratios using the 1991 TRI data (the first year SRAs were reported). The resulting ratios for forms without and with underground injection were 0.51 and 0.31. These were somewhat higher than the 1995 numbers, but there still is a considerable difference between the two ratios. The correlation of SRA/form ratios and the presence of underground injection does not seem to be strongly affected by any of the factors we tested for.
We also checked to see if the SRA ratio difference might be due to differences between types of businesses that use injection wells and other facilities reporting to TRI. To do this, we compared SRA ratios for forms from facilities with and without wells within the top ten four-digit SIC codes (industry designations) reported by facilities with injection wells. These SIC codes were mainly within the chemical industry, SIC 28, with one in the petroleum industry, SIC 29. In this group of industries, the SRA to forms ratio was 0.34 for forms with injection and 0.19 for forms without injection. This is not quite the two-to-one difference for TRI as a whole, but is nonetheless sizable.
Keep in mind that source reduction activities are likely underreported in TRI in general (see, for example, INFORM’s Toxics Watch 1995). However, there is no reason to expect that this underreporting affects some forms or facilities disproportionately.
(20) At one time, EPA began working on a national database of wells called WATERS. After spending more than a million dollars on this effort, it was abandoned a few years ago as a national database, although it is still used by some EPA regions. We were given reasons for its abandonment that included poor design and lack of assessment of user needs, but a commonly cited reason was that a state regulatory group, the Ground Water Protection Council or GWPC, was developing its own database for tracking Class II wells under a grant from DOE. This GWPC database is not designed for national use, but for use by individual state regulatory agencies or businesses. Although we were told that it was intended to help foster public access among other uses, there appears to be no particular method of public access to data held in any one of its copies other than by calling the agency involved
(i) BRS quantities are the BRS tons for each waste divided by the number of codes for that waste. This avoids double counting the tons if the waste has more than one toxic constituent. Quantities marked “—“ are wastes not listed within BRS. Records for individual facilities with less than 10,000 in both quantity columns have been deleted to save space, but not deleted from totals.
(ii) BRS quantities are the BRS tons for each waste divided by the number of codes for that waste. This avoids double counting the tons if the waste has more than one toxic constituent. Quantities marked “—“ are wastes not listed within BRS. Records for individual facilities with less than 1,000 in both quantity columns have been deleted to save space, but not deleted from totals.
(iii)Under most circumstances, Class IV wells are illegal. There can be an exception when the wells are used in groundwater cleanup for RCRA or Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) projects.