2002

What are we doing to our drinking water?

It is a common assumption, here in Florida,  that the main threat to our drinking water is consumption coupled with the threat of drought. However, there is another drinking water crisis in Florida that has nothing to do with nature. The hidden crisis of Florida's drinking water is from below, where streams of wastewater, treated by municipalities, are injected underground. The premise of such injection is that their burial, thousands of feet underground, is last we will ever see of it.

It is an easy thing to believe because we wish nothing more than to be far removed from our waste, but it is not true. A toxic stew of ammonia, fecal coliform, and volatile organic chemicals is rising to meet our drinking water through the very underground injection control wells put in place to rid us of the waste.

In South Florida, drinking water is usually drawn from the sole source Biscayne aquifer. But counties and municipalities are increasingly pulling from the Upper Floridan aquifer, and reservoirs in the Upper Floridan created through another injection technology called ASR (Aquifer Storage and Recovery). With ASR,  layers of fresh and brackish water are being used to augment shallow aquifer systems stressed by the burgeoning population growth at Florida's low-lying coastal zones. That is right. We are injecting waste and injecting water to drink later, into the same place.
Disposal of treated waste by deep well injection  has been taken up by county and state officials as the safest and most cost effective strategy for dealing with the inevitable impacts of urban sprawl.  It is certainly more cost effective than flushing the wastewater to tide, which would create a marine wasteland and threaten our tourist-laden beaches.  But it now appears that the waste we are injecting, will not stay away from our drinking water and this could be a crisis of public heath and the environment.

The Sierra Club commissioned a report on Miami Dade's injection control program (see report below). In a study done by McNeill Geological Services, Inc., it is reported that 10 out of 17 of the wells in South Florida were constructed improperly. In short, the waste is not going below what was planned to be an impermeable layer of rock, and, that impermeable layer has been punctured. The effluent, thought to have been made to disappear, is now migrating upward.

Florida is the only state in the nation--to date--permitted by the EPA to operate Class 1 underground injection control wells. They are presumed to be safe. But it seems that no one is looking deep enough. Not to mention that fact that there is almost no effluent quality monitoring, i.e. how `treated' is the waste being injected?

In 1995, the Environmental Protection Agency (EPA) issued Metropolitan Miami Dade County and the Miami-Dade Water and Sewer Department an Administrative and Consent Order (EPA docket No.4-UICC-006-95) for violating the Safe Drinking Water Act. The EPA states: "The Orders include corrective actions required to address violations of Department rules regarding the upward movement of injected fluids into overlying waters of the State and the absence of reasonable assurances of the adequacy of confinement across the site."

So far the only corrective action taken by the FDEP and the county water utilities has been to monitor the migration of the waste into underground sources of drinking water (i.e. the top layer). There is no continuous online testing of wastewater at the point of injection, nor monitoring of the containment of the effluent.

Although utilities claim that the wastewater injected underground does not violate safe drinking water standards, the fact remains that the migration of wastewater upward into the overlying layers from which our drinking water is drawn is a violation of federal law. At the same time we are operating these injection wells, Miami Dade county has been sited as  the nation's largest polluting point source polluter, based on standards of the Safe Drinking Water Act. This federal law is now under assault by municipalities caught between knowledge they are major polluters and the conviction that, for the time being, there is no liability to their illegal actions. What utilities fear most is that the public will begin to learn that the right to clean, safe drinking water is a fiction and that efforts to protect our environment above the ground are being contaminated by what we have put in it.

 Today, Florida's municipalities are racing to change federal law. Under pressure by Florida's utilities, the EPA has initiated a process that could lead to the elimination of the rule prohibiting migration of treated wastewater into overlying aquifers. Currently, the rules governing deep Class 1 underground injection control well permits require adequate confinement of contaminants must be demonstrated and underground sources of drinking water not be contaminated.
Through its 13 municipal Class 1 Underground Injection Control wells, the Miami Dade county disposes, every day, more than 200 million gallons of secondary treated sewage. This summer, FDEP announced its intention to issue permits allowing operational testing of four more municipal Class 1 Underground injection control wells in Miami-Dade County. Once they are online, each well will handle up to 14.9 million gallons of domestic wastewater per day. Both the EPA and FDEP permit Miami Dade to operate these wells, despite the fact the wells are violating the Safe Drinking Water Act.
The wells are becoming the choice method of effluent disposal for municipalities that cannot stand the public pressure of dumping treated wastewater into ground water or outstanding Florida waters. The wells are a cost-effective way to produce economic growth based on construction and development of sprawling suburbs. The alternative, to treat municipal waste to advanced treatment standards, would hike the cost of development.

Through the proliferation of underground injection control wells, state and federal agencies have made a Faustian bargain to accommodate political pressure for more urban sprawl while burying the true costs to the public: the massive violation of the Safe Drinking Water Act.

Today in South Florida, 120 municipal Class 1 Underground injection control wells discharge over 400 million gallons of secondary treated sewage every day. FDEP and EPA monitoring tests indicate these wells are contaminating drinking water supplies in counties on both coasts of the state and contaminating the Upper Floridan Aquifer.
Right now, officials argue that there have been no adverse public health effects documented. But the water is rising.

- Alan Farago
 

Here is the report on the status of these wells.

      Report by McNeill Geological Services, Inc. ( in Adobe Acrobat format)