Deep Well Injections

APP@FloridaDEP.gov. 
richard.lobinske@floridadep.gov

ManaSota-88 strongly recommends the FDEP deny any permit for the construction of a Class V, Group 9 exploratory well at the Mosaic Central Polk in Polk County. There are many reasons why phosphate wastewater should not be injected into Florida’s groundwater, here are just a few:

• All wells are subject to failure. There are too many unknowns to safely inject treated or partially treated effluent. The operation of a deep well relies very heavily on predictions and good faith.
• Liquid wastes that cannot be discharged into surface waters are injected into deep wells thus the worst wastes end up in these wells.
• Existing FDEP regulations are inadequate to protect against groundwater pollution.
• There is inadequate knowledge re: how to adequately monitor a well. If a failure occurs, very little can be done to correct it. If an aquifer is contaminated, it’s too late.
• Deep well injection results in acceptance of lower levels of protection for some underground sources of drinking water directly contradicting the spirit of the Safe Drinking Water Act.
• Failure to require monitoring of the drinking water sources through which or near where the well bore passes; the injection zone; and the confining layers to determine whether contaminants have migrated.
• Inaccurate assumptions about the migration of waste and changes in pressure resulting from injection and the critical components in the determination of the potential zone of endangering influence.
• Failure to prevent adverse chemical and biological reactions between injected effluent and the well materials, the injection zone and the confining layers.
• Failure to require mechanical integrity testing at an adequate frequency to detect damage of the well bore before significant leakage occurs.
• Failure to require post-closure care or the showing of financial assurance for post-closure by a third-party liability or cleaning-up contaminated groundwater.
• The composition of underground aquifer formations is not always as uniform as scientific models would have us believe. Nevertheless, most studies of deep-well injected wastes are based upon such models.
• While the models upon which decisions to inject wastes are based look good on paper, changing conditions in the aquifers can allow wastewater to seep into the groundwater supply, and it would be too late then, to correct the problem.