PERMITTING OF INTERMITTENT STIMULATION INJECTION

摘要

Experts on the use of deep well injection technologies have concluded that this is the safest and most effective method to use for the disposal of liquid wastes into geologic formations where the wastes will be contained and confined for geologic time. Over the past ten years acceptance of this methodology has expanded to include liquid wastes that contain a significant enough concentration of solids to result in the intermittent fracturing of the injection zone during injection disposal operations. The ability to monitor and control the fracturing that occurs in conjunction with such injection so as to contain the fracturing within the injection zone and to preclude its extension into the confining zone has been documented in a number of different papers previously presented at Ground Water Protection Council Annual Forums. The technical acceptability of grind and inject, and other fracturing technologies has led some to call for revision of EPA’s UIC regulations for Class I injection to authorize the use of the technology. These calls have been based on a presumption that current regulations would constrain use of any injection technology that would result in some fracturing of the injection zone, but not the confining zone. This paper examines whether the technology can be permitted under current regulations and concludes that, where fracturing is controlled and