xvEPA
United States
Environmental Protection
Agency
How to Comment
You may comment on the proposed
draft permits in writing. Please refer
to Plains LPG Services draft permit
numbers MI-147-11-0002 and
MI-147-1I-0003.
Mail or email your comments to:
Andrew Greenhagen
U.S. EPA, Water Division
UIC Section (WP-16J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
Email: greenhagen.andrew@epa.gov
Phone:312-353-7648
Comment Period
EPA will accept written comments
until August 20, 2019 (midnight
postmark).
You may see the draft permit at
http://go.usa.gov/3JwFP.
Administrative Record
You may see the full administrative
record, including all data submitted
by Plains LPG Services, L P., at the
EPA's Chicago regional office
|address above), weekdays from
9am to 4pm. For an appointment to
see the files, contact Andrew
Greenhagen (see above).
Right to Appeal
You have the right to appeal any
final permit decision if you make an
official comment during the
comment period or participate in a
public hearing. A public hearing is
not planned at this time. The first
appeal must be made to the
Environmental Appeals Board. The
final decision can be appealed in
federal court only after all agency
review procedures have been
exhausted.
To learn more about EPA's
Underground Injection Control
program, or to join our mailing list
visit http://go.usa.gov/3JwFP
EPA Seeks Comments on
Injection Well Permits
Plains LPG Services, L.P.
St. Clair County, Michigan	July 2019
The U. S. Environmental Protection Agency tentatively approved a request
from Plains LPG Services, L.P. for two Class I nonhazardous injection
well permits. One permit action will be to revoke an existing Class II
injection well permit (MI-147-2D-0010) and reissue a Class I injection
well permit for the existing well (SWD 1-1, MI-147-1I-0003). The second
permit action will be to issue a Class I injection well permit for a proposed
new well (SWD 3-1, MI-147-1I-0002). Before EPA makes a final
decision, the Agency is providing the public an opportunity to comment on
the draft permits (see left-hand box on how to comment).
Plains LPG Services, L.P. plans to dispose of nonhazardous liquid waste
from hydrocarbon storage operations and future storage cavern creation at
their St. Clair, Michigan and Sarnia, Ontario, Canada facilities. The two
injection wells would be located at the Plains LPG Services, L.P. facility at
1575 Fred Moore Highway in St. Clair, Michigan.
Federal law requires all Class I wells be built in a way that protects
drinking water supplies.1 That means waste must be injected into a rock
formation beneath the lowermost formation containing an underground
drinking water source. All Class I wells shall be cased and cemented to
prevent the movement of fluids into or between underground sources of
drinking water.
Text continued on back ...
Map shows location of the proposed injection wells in St. Clair County, Michigan.
'Injection wells must meet the regulatory criteria of 40 Code ofFederal Regulations, or
C.F.R., Sections 124, 144,146, and 147; and the Safe Drinking Water Act, or SDWA. To
view these regulations and laws, see https://www.epa.gov/laws-regulations/regulations.

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Public comments and requests for a
hearing
Send comments and requests for a hearing to EPA's
Andrew Greenhagen (greenhagen.andrew@epa.gov)
during the public comment period (see front-page box).
The public comment period includes 30 days for
comments as required by law, plus an additional three
days for any delay caused by mailing.
Requests for a hearing must be in writing and must
identify issues to be raised. EPA will hold a hearing if
there is significant public interest in the draft permit
decision based on written requests. If a hearing is
scheduled, EPA will publish a notice of the hearing at
least 30 days in advance.
EPA will consider all comments received during the
comment period and the hearing if held and then issue a
final decision along with a document that lists EPA
responses to significant comments.
Permit requirements
Federal regulations for underground injection wells list
standards for construction, geology, location (siting),
operating conditions and record keeping, to protect
supplies of underground drinking water from
contamination caused by injection wells.
EPA's preliminary review of the permit application for
this well concluded it would have no environmental
impact.
Below is an explanation of the some of the factors
involved in permitting injection wells:
Underground Source of Drinking Water (USDW):
An USDW is any aquifer or portion of an aquifer that
contains less than 10,000 milligrams per liter of total
dissolved solids and which can be used as a source of
drinking water.
An aquifer is an underground layer of water-bearing
rock or sand from which water can be extracted by a
well.
In the case of the Plains LPG Services proposed wells,
the base of the lowermost USDW sits at a depth of 330
feet. This formation is the Bedford formation.
Site geology: The injection zone for well SWD 3-1 is
the Franconia, Galesville, Eau Claire, and Mount
Simon Formations from 4,450 feet to 4,715 feet below
the surface. The injection zone for well SWD 1-1 is the
Franconia, Galesville, Eau Claire, Mount Simon, and
Precambrian Formations from 4,450 feet to 4,784 feet
below the surface. The immediate overlying confining
zone is the Burnt Bluff, Cataract, and Richmond
Groups and the Trenton, Black River, Glenwood, and
Trempealeau Formations which contain multiple beds
of shale. Adequate confining layers exist between the
injection zone and the base of the lowermost
Underground Source of Drinking Water.
Area of review (AOR): The AOR is the area within a
two-mile radius of the proposed injection wells. EPA
analyzed the AOR to identify wells that might allow
fluid to move out of the injection zone. In the AOR for
the proposed wells, there are 0 producing, 1 injection
(SWD 1-1), 0 temporarily abandoned, 12 plugged and
abandoned, and 5 other wells that penetrate the
confining zone. None of these wells requires corrective
action to prevent fluid movement out of the injection
zone.
Maximum injection pressure: EPA set an injection
pressure limit that will prevent the injection formations
from fracturing. The proposed maximum injection
pressure for these wells is limited to 1,580 pounds per
square inch gauge.
Financial assurance: Plains LPG Services, L P. has
demonstrated adequate financial resources to close,
plug and abandon these underground injection wells.
Plains has passed the financial test establishing ability
to cover these costs at the amount of $248,500.
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