v>EPA
United States
Environmental Protection
Agency
Public comment
period
EPA would like to receive your
comments about the proposed
permits.
The Agency will accept written
comments during a 45-day comment
period from Wednesday, May 26, to
Monday, July 12. Comments should
be postmarked no later than midnight
July 12 and sent to the EPA office
processing the permit:
EPA Region 5 (WU-16J)
UIC Branch (Attn: Dana Rzeznik)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
or e-mail rzeznik.dana@epa.gov
Public hearing
EPA will also hold a public hearing
about the permits. Oral and written
comments will be accepted at the
meeting:
Tuesday, June 29
7 p.m. to 9 p.m.
Crowne Plaza Hotel
8000 Merriman Road
Romulus, Mich.
Administrative record
The full administrative record,
including all data submitted by
Environmental Disposal Systems Inc.
in support of its permit applications,
is available for public review at the
EPA Region 5 office, 77 W. Jackson
Blvd., Chicago, from 9 a.m. to 4 p.m.
Chicago time Monday through
Friday. If you wish to visit the
Region 5 office, please contact Dana
Rzeznik before you come.
EPA Considering Well
Permits;
Public Hearing Set for
June	
Environmental Disposal Systems Inc.
Romulus, Michigan	
May 2004
U.S. Environmental Protection Agency proposes to issue new permits
for the operation of two hazardous waste injection wells in Romulus,
but the Agency will first hold a public hearing and comment period
before the final decision.
Environmental Disposal Systems Inc., 199 W. Brown St.,
Birmingham, Mich., has applied to EPA for renewal of its permits to
operate two Class I commercial hazardous injection wells located at
28470 Citrin Drive, Romulus. The company intends to accept liquid
waste, some of which is hazardous, from industrial customers and
inject it into two deep wells already built. In March EDS was granted
an exemption to the federal law banning underground injection of
hazardous waste. EPA determined the company was able to
demonstrate the waste will stay confined to a layer of rock more than
3,900 feet underground and will not threaten people or drinking water
supplies.
Permits cover operation issues
EPA will hold a public hearing about the permits June 29
at the Crowne Plaza Hotel in Romulus (see box for details). The
public is also invited to submit written comments by mail or e-mail to
EPA. Written and oral comments receive equal consideration.
This particular hearing and comment period will examine only the
issues surrounding the well permits and will not address the legal,
scientific, feasibility, safety and health issues that arose during
deliberations over the exemption that was granted in March. All
comments will be accepted, but EPA is bound by federal law to
consider only the points that address the two latest permits, such as
construction and testing of the wells, operating procedures and future
monitoring.
New conditions in the draft permits include changes to the waste
analysis plan, the injection rate and pressure, the plugging plan, and
limitations on the injection of several kinds of hazardous waste. These
conditions were added to make the permits consistent with the well
completion reports and the recently approved exemption to the federal
ban on the land disposal of hazardous waste.

-------
Legal references
The Safe Drinking Water Act specifically requires
regulation of the underground injection of fluids
through wells to assure that the quality of
underground sources of drinking water is protected.
This is done in part by issuing permits to owners and
operators of underground injection wells.
Title 40 of the Code of Federal Regulations (40 CFR)
parts 124, 144, 146 and 148 govern permitting for
injection wells.
This EPA fact sheet is intended as a plain-language
summary and public notice of the draft permit
application process for permit numbers MI-163-1W-
C007 (well #1-12) and MI-163-1W-C008 (well #2-
12).
This publication is informational in nature and not
intended as a legal brief for the permit action.
The public hearing will be open to all interested
parties. In order to ensure that all who attend have
the opportunity to comment, time allotted to each
participant may be limited to three minutes. A court
reporter will transcribe the comments, but no
responses will be given until the final decision is
reached.
EPA will consider all comments received, in writing
or orally at the hearing, and then issue a final permit
decision. A document addressing all comments will
be released when the final decision is announced.
Under federal law, anyone who files comments on the
draft permits or participates in the public hearing is
eligible to ask the agency's Environmental Appeals
Board to review the final permit decision. Such a
request must include a statement of the reasons
supporting the review including a showing that the
issues being raised were also raised during the hearing
or comment period. The request should also show
that each condition being appealed is based on a
finding of fact or legal conclusion that is clearly
wrong or include an argument that important policy
considerations should be reviewed by the
Environmental Appeals Board.
Well operation
The disposal company says the average daily volume
of the injected waste will be about 240,000 gallons.
The waste will be in liquid form and will be
hazardous and nonhazardous industrial wastewater
from a variety of sources. The waste will include
diluted acids, spent solvents and landfill drainage as
well as a variety of nonhazardous materials.
Construction of the two wells was completed in 2002.
The original permits from EPA were granted in 1998
and expired Oct. 15, 2003, but remain enforceable
until new permits are either granted or denied. Actual
operation won't start until EDS receives written
permission from Region 5's water division director.
Every 10 years EDS must apply for new permits.
The federal Safe Drinking Water Act requires EPA to
administer Underground Injection Control (UIC)
programs in states that do not have their own
programs. Michigan did not seek the federal UIC
program, so EPA is the primary governing agency in
this case.
History of EDS proposal
To gain an exemption from the land ban for waste
disposal in the federal Resource Conservation and
Recovery Act, EDS had to demonstrate "to a
reasonable degree of certainty" that its waste would
not move above the injection zone or come into
contact with drinking water for at least 10,000 years.
EPA concluded EDS met the demanding requirements
for an exemption.
EDS plans to operate the wells for 20 years.
However, the waste that will be pumped into the
injection zone will move very little (only a few feet
upward and a little more than three miles sideways)
during that time.

-------
Injecting hazardous waste deep underground is a
proven way of safe disposal. Since Underground
Injection Control regulations have been in place, there
have been no failures of wells resulting in
contamination of underground sources of drinking
water.
The integrity of the well construction is a part of the
permit deliberations. EDS performed several tests on
the wells, including injecting a radioactive tracer to
test for leaks. The wells are also set up with alarms
and will be continuously monitored for leaks or
breaks. The well casings will undergo a thorough test
once a year during the 20-year operation.
Additional technical information
Site geology: The injection zone for Class I
hazardous wells is subdivided into an injection zone
or interval into which the fluid is directly injected and
a safety valve layer, which has the technical name of
"arrestment interval." The fluid could spread out
through this safety layer but won't be able to leave it.
In these wells, injection is permitted into the rocks in
the interval between the depths of 3,937 and 4,550
feet below the surface. Geologists have names for
these rock layers (the Mt. Simon, Eau Claire, and
Contact EPA
For more information and questions, or if you need
special accommodations to attend the public hearing,
Dana Rzeznik will be available to help you. You can
contact her at:
EPA Region 5
Underground Injection Control Branch
(mail code WU-16J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
(312)886-1492
toll-free (800) 621-8431,
weekdays 10 a.m.-5:30 p.m. EDT
rzeznik. dana@epa.gov
Information at local libraries
Public documents concerning the EDS injection wells
are available at three local libraries:
Romulus Public Library Taylor Community Library
11121 Wayne Road 12303 Pardee Road
Mon.-Thr. 10 a.m.-8 p.m. Mon.-Thr. 10 a.m.-8 p.m.
Sat. noon-5 p.m.	Fri.-Sat. 10 a.m.-5 p.m.
Eshleman Library, Henry Ford Community College
5101 Evergreen Road, Dearborn
Mon.-Thurs. 7:30 a.m.-9:30 p.m.
Web page
For more information about EPA's Underground
Injection Control program:
www.epa.gov/r5water/uic/uic.htm
Franconia-Dresbach formations). The safety layer lies
at depths between 3,369 and 3,937 feet underground
(Trempealeau, Glenwood, and lower Black River
formations). Above the safety valve layer, additional
rock layers called the confining zone give added
insurance that injected fluids will never reach
underground sources of drinking water. The confining
zone is composed of dense limestone and shale that
doesn't hold water and serves as a lid over the
injection zone (the upper Black River, Trenton, and
Utica formations).
Underground sources of drinking water: This is
defined by federal law as any aquifer (underground
formation containing water) or part of an aquifer that
contains less than 10,000 milligrams per liter of total
dissolved solids and which is being or can be used as
a source of drinking water. The base of the
lowermost underground source of drinking water at
this site has been identified at a depth of 136 feet.
This water-bearing formation is the Dundee
Limestone.
Area of review: Under 40 CFR 146.63, the area of
review for these EDS wells is a circle with a radius of
6.1 miles extending from the center of an imaginary
line connecting the two wells. Within the area of
review, inspectors found no producing or injection

-------
wells, one temporarily abandoned well, and one
plugged and abandoned well that penetrates the
confining zone. The determination of the area of
review is in the "Permit Renewal Application for
Class I Hazardous EDS #1-12 and EDS #2-12" and in
another document titled "UIC Class I Petition
Revision Following Construction of EDS #1-12 and
#2-12." These documents are part of the
administrative record.
Maximum injection pressure: The proposed
permitted maximum injection pressure shall be
limited to 765 pounds per square inch gauge.
Maximum injection pressure is discussed in the draft
permit, Attachment A, and in the administrative
record.
Injection fluid: Wastewater allowed for disposal may
consist of hazardous and nonhazardous ingredients.
The RCRA hazardous waste codes that are allowed
are listed in the "Notice of Issuance of Exemption
from Land Disposal Restrictions" and in the draft
permit, Attachment D, which are part of the
administrative record.
Financial assurance: EDS has demonstrated adequate
financial resources to plug and abandon these wells
and for post-closure care by means of an irrevocable
letter of credit and standby trust agreement and state
bond. These statements are in the draft permit,
Attachment B. The plugging cost estimate for each
well must be updated on an annual basis.
&EPA
United States
Environmental Protection
Agency
Region 5
Office of Public Affairs (P-19J)
77 West Jackson Boulevard
Chicago, Illinois 60604
EDS ROMULUS, MICH. - Well Permits Considered

-------