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^ unitedstates EPA Plans to Renew Exemption
Environmental Protectior ¦
for Hazardous Waste Wells
Ineos USA LLC
Lima, Ohio September 2015
Comment period scheduled
U.S. EPA is taking comments from
the public oil its plan to reissue an
exemption from certain federal
regulations for Ineos USA LLC. The
public comment period ends
Tuesday, October 13, 2015.
How to comment
You can send written comments to:
Stephen Roy
U.S. EPA (WU-16J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
roy. stephen@epa.gov
FAX: 312-692-2951
For more information
To see the draft decision document,
visit the Lima Public Library, 650
W. Market St. The full
administrative record, including all
data submitted by Ineos, is at the
U.S. EPA's regional office (address
above). Contact Stephen Roy at
312-886-6556 for an appointment.
To learn about U.S. EPA's
Underground Injection Control
Program, visit
www.epa.gov/r5water/uic.
You may call the EPA toll-free,
800-621-8431, Ext. 66556,
weekdays, 9:30 a.m. to 5:30 p.m.
Ineos USA LLC
Ineos USA LLC
0.5
The U.S. Environmental Protection Agency plans to approve a request
from Ineos USA LLC to continue injecting hazardous waste deep beneath
the earth's surface. The Agency will consider public comments {see box,
left) before making a final decision.
Ineos has four injection wells at 1900 Fort Amanda Road, Lima. Ineos
operates the wells under permits from the Ohio EPA. They allow the
company to dispose of liquid hazardous waste from a variety of sources.
The company also needs an exemption from the federal ban on
underground disposal of hazardous waste. U.S. EPA originally approved
an exemption in 1992. If reissued, the exemption will be valid until
January 2025, based on the modeling done in 2005.
U.S. EPA found the company has shown - based on a reliable prediction -
that injected waste will not move out of the injection zone within 10,000
years. The company has also shown that waste will not come into contact
with any underground source of drinking water.
Background
Federal law prohibits the disposal of untreated hazardous waste on the land
or into an injection well. The law allows U.S. EPA to grant exemptions
To qualify, an owner or operator of an injection well must demonstrate,
with a reasonable degree of certainty, that injected material will stay in the
injection zone for as long as the waste is hazardous. That can be done by
showing conditions at the injection site will prevent any movement of
injected waste out of the injection zone in 10,000 years, and that
conditions will prevent the possibility of waste contaminating any
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underground source of drinking water. This is known
as a no-migration demonstration. Ineos made an
acceptable no-migration demonstration in its request
that U.S. EPA reissue the 1992 exemption.
Technical information
Ineos uses hazardous waste wells, which U.S. EPA
calls Class I wells, to inject into a geologic interval
composed of the lower Eau Clair Formation, the Mt.
Simon Sandstone and the Middle Run Formation. The
top and bottom of the injection interval are 2,631 and
3,241 feet below ground level, respectively. The
deepest supply of drinking water in the area is
approximately 400 feet below ground level, so there is
approximately 2,230 feet of separation between the
drinking water source and the injected hazardous waste.
An arrestment interval is just above the injection
interval. The top and bottom of the arrestment interval
are 1,631 and 2,631 feet below the ground surface,
respectively. The arrestment interval keeps the injected
fluid in the injection zone because it contains low-
permeability rock and does not have faults or fractures
that could allow the fluid to move upward. The
injection interval and the arrestment interval together
are called the injection zone. A 204-foot thick
confining zone lies above the injection zone. Extending
laterally for hundreds of miles, the confining zone
provides additional protection.
All injection wells have an "area of review." In this
case, the area of review extends 10 miles around the
well bore. If there are other wells in the area of review
that are not properly plugged or abandoned, they could
serve as a pathway for waste migration from the
injection zone. Ineos identified five wells within the
area of review and showed these wells were properly
constructed or outside the area in which pressure could
cause fluids to contaminate underground sources of
drinking water. There are no known faults in the area
of review that connect the injection interval with
drinking water sources.
Under Ohio EPA permits, the Ineos wells must pass an
annual pressure test and a radioactive tracer survey to
confirm the injected fluids are entering the injection
interval and not moving up the well bore out of the
injection zone. These tests demonstrate the mechanical
integrity of a well's key components. The wells passed
the annual pressure test and radioactive tracer survey
performed between June 2014 and March 2015.
Conditions of petition approval
The proposed reissuance of the exemption is subject to
conditions. Failure to comply with the conditions is
grounds for termination of the exemption. Ineos must
submit a petition for reissuance if it wants to modify
any of the following conditions:
1. The exemption applies to the four existing
hazardous waste injection wells at the Ineos facility.
2. Injection of restricted hazardous waste is limited to
the part of the Mt. Simon Sandstone and Middle Run
Formations at depths between 2,631 and 3,241 feet
below the surface.
3. Only restricted wastes designated by the codes in
Table 1 in the draft decision may be injected.
4. Maximum concentrations of chemicals allowed to
be injected are listed in Table 2 in the draft decision.
5. The average specific gravity of the injected waste
stream must be between 1.00 and 1.05 over a three-
month period.
6. Ineos may inject up to 175 gallons per minute into
each of its four wells, based on a monthly average.
7. The exemption is approved for the 20-year modeled
injection period, which ends on Jan. 31, 2025. Ineos
may petition for a reissuance of the exemption
beyond that date, provided the company gives U.S.
EPA a new and complete petition and no-migration
demonstration by June 30, 2024.
8. Ineos must submit a quarterly report containing an
analysis of the injected waste and indicating the
chemical and physical properties, including the
concentrations, of all the injected chemicals listed in
Table 2 in the draft decision to U.S. EPA.
9. Ineos must submit an annual report containing the
results of a bottom hole pressure survey (fall-off
test) performed on one well each year to U.S. EPA.
The annual report must demonstrate that the
properties of the injection interval have not changed
significantly since the exemption was granted.
10. Ineos must submit the results of radioactive tracer
surveys and annulus pressure tests for the wells to
U.S. EPA annually. (The annulus is the area of the
well that separates the inner tubing through which
fluids are injected and the outer portion of the well.)
These tests demonstrate whether the wells are
working properly.
11. Ineos shall notify U.S. EPA in writing if any well
loses mechanical integrity, and prior to any
workover or plugging.
12. Ineos must fully comply with all requirements set
forth in underground injection control permits issued
by Ohio EPA for the four Ineos wells.
13. The exemption is subject to review upon the
expiration, cancellation, reissuance or modification
of the Ohio EPA well permits.
14. Whenever U.S. EPA determines that the basis for
approval of a petition under 40 CFR §§ 148.23 and
148.24 may no longer be valid, the Agency may
terminate this exemption and require a new
demonstration.
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