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The Ground Water Protection Council (GWPC) has had initial discussions with the American Petroleum Institute staff and several major oil companies concerning a project that would address several technical and regulatory issues related to the use of injection wells at refineries. All parties believe that this project has significant potential to save millions of dollars in operational costs by streamlining and improving both state and federal regulations which are now overly redundant and not risk-based. As currently regulated by the United States Environmental Protection Agency (USEPA), injection wells used for refinery related disposal are typically classified as either Class I hazardous or non-hazardous, depending on RCRA classification. The expense of acquiring an operating permit for these types of wells is very high and they have substantially more operational expenses than a typical Class II injection well. The combination of permitting requirements (including a {open_quotes}no-migration{close_quotes} petition), stringent construction requirements, and intensive monitoring and reporting requirements often make these wells uneconomical for otherwise legitimate waste disposal purposes

Use of injection wells for refinery waste disposal. Quarterly technical report, January 1, 1997--March 31, 1997