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EPA and DEQ seek public comment on reopening Romulus industrial waste injection wells


"If you've heard this story before, don't stop me, because I'd like to hear it again." - Groucho Marx

On March 31, 2011, the United States Environmental Protection Agency (EPA) issued a public notice concerning the issuance of new licenses for the former Environmental Disposal Systems (EDS) hazardous waste injection wells in Romulus, Michigan.  The Michigan Department of Environmental Quality (DEQ) proposes issuing air and water permits and its public hearing and comment period will be conducted concurrently with the EPA public hearing and public comment period.  A Detroit-based company, Environmental Geo-Technologies LLC (EGT), will be operating the two wells in the event EPA and DEQ issue the draft permits.  There will be a public hearing On May 17 from 7:00 PM to 9:00 PM at the Crowne Plaza Hotel in Romulus and EPA and DEQ will accept public coments until June 29. 


These particular wells have a long and storied history, punctuated by public protests and litigation.  EDS first proposed creating the wells to use to dispose hazardous and non-hazardous industrial wastes in 1990.    While EDS obtained approval to construct the wells from both EPA and the then-Department of Natural Resources, local opposition continued to the point where the City of Romulus filed suit to enjoin the construction and use of the wells.  The wells operated for approximately 10 months from 2005 through 2006, until the Department of Environmental Quality closed the facility after finding leaks in aboveground activities associated with the wells' operation.


An underground injection well for industrial wastes is a very rare thing.  The Resource Conservation and Recovery Act (RCRA) imposes a ban on the placement of such wastes on or into land, absent very specific circumstances, known as the "land ban".  One such exception is the disposal of such wastes using injection wells.  EPA regulations require a demonstration that the use of injection wells will ensure that the injected wastes will stay within the injection zone and will not impair drinking water or otherwise harm public health.


If EPA and MDEQ issue the necessary permits, the old EDS wells will be in use again for the disposal of hazardous and non-hazardous industrial wastes.  According to the draft permits, the operator will be able to dispose of the following types of wastes: diluted acid waste waters, such as used in metal cleaning and steel pickling operations, which would have a low pH and possibly an elevated level of heavy metals, such as chromium, cadmium, lead; landfill leachates from either municipal or hazardous waste landfills; and solvent-water mixtures containing less than ten percent solvents (e.g., tetrachloroethylene, trichloroethylene, methylene chloride, xylene, acetone, methanol, and carbon tetrachloride).  Whether this new operator will face the same type of opposition as EDS did remains to be seen.

The author, Saulius Mikalonis, is an environmental attorney with over 25 years of experience in the Bloomfield Hills offices of Plunkett Cooney.  He is also the author of The Green Blawg, in which he writes about environmental law issues for the non-lawyer.  In addition to practicing law, Mr. Mikalonis is an adjunct professor at the Thomas M. Cooley Law School, Auburn Hills Campus, at which he teaches a course entitled "Sustainable Development Law & Policy" and a Board Member of the Detroit Regional Chapter of the United States Green Building Council (USGBC).


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