UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
7 7 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
UNDERGROUND INJECTION CONTROL (UIC) PROGRAM PERMIT
MI-163-II-0001
FACT SHEET Sun Pipe Line Company Class I Non-Hazardous Brine
Disposal Well No. 1A in Wayne County, Michigan
Introduction
Sun Pipe Line Company of Philadelphia,
Pennsylvania has applied to the United
States Environmental Protection
Agency (USEPA) for a permit to
construct and operate a new
Class I injection well located at the
Inkster Terminal facility, Wayne County,
Michigan for the disposal of
non-hazardous liquid waste.
Facility Background
The Class I non-hazardous waste injection
well will be used for the disposal of saturated salt brine from
the development of storage caverns in salt and, after the caverns
are created, for disposal of brine used in operating the caverns.
The construction of the Brine Disposal Well No. 1A meets the
regulatory criteria of 40 CFR 146.12. This requires that all
Class I wells be sited in such a fashion that they inject into a
formation which is beneath the lowermost formation containing an
underground source of drinking water. All Class I wells shall be
cased and cemented to prevent the movement of fluids into or
between underground sources of drinking water.
Site Geology
The injection zone is the Eau Claire and Mt. Simon members of the
Munising Formation and the Precambrian Formation from 3,900 feet
to 4,450 feet below the surface. The immediate overlying
confining zone is the Trempealeau Formation, Glenwood Shale, and
Black River Limestone which are composed of mixed dolomite,
limestone, shale and minor amounts of sandy and silty shales and
carbonates. Adequate confining layers exist between the Eau
Claire, Mt. Simon, and Precambrian Formations and the base of the
lowermost Underground Source of Drinking Water.
Hs
Proposed
!A Well
1 Mi
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Underground Sources of Drinking Water (USDW): A USDW is defined
as any aquifer or portion thereof which 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 USDW has been identified at a depth of 240 feet below
the surface. This water-bearing formation is the upper Detroit
River Limestone.
Operational Parameters
Area of review (APR): The AOR is defined as the area within a
2-mile radius of the injection well. It has been determined that
there are no producing, no injection, no temporarily abandoned,
and no plugged and abandoned wells that penetrate the confining
zone within the AOR. The U.S. EPA has issued permits for two
wells within the AOR which would be used to inject hazardous
industrial wastes into the Mt. Simon if the operator is given an
exemption from the land disposal restrictions on the land
disposal of hazardous wastes.
Maximum Injection Pressure: The proposed permitted maximum
injection pressure shall be limited to 604 pounds per square inch
gauge (psig).
Financial Assurance: Sun Pipe Line Company has demonstrated
adequate financial resources to plug and abandon this well by
means of a State bond, in the amount of $51,000 with Liberty
Mutual Insurance Company.
Intent to Issue a Permit
Review of the permit application indicates that no significant
environmental impact should result from the issuance of this
permit. In accordance with the provisions of the Safe Drinking
Water Act, as amended (42 U.S.C. 300f et. sea., commonly known as
the SDWA) and attendant regulations incorporated by the USEPA
under Title 40 of the Code of Federal Regulations at Parts 124,
144, 146, and 147, the USEPA intends to issue a permit for the
injection well.
Public Comments
Copies of the draft permit and administrative record for this
permit action are available for public review between 9 a.m.
and 4 p.m. at the address listed below. It is recommended that
you telephone Harlan Gerrish at (312) 886-2939 before visiting
the Region 5 office:
U.S. Environmental Protection Agency (WU-16J)
Attn: Lisa P. Perenchio, Chief
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Direct Implementation Section
77 West Jackson Blvd.
Chicago, Illinois 60604-3590
The dates of the public comment period for the draft permit will
be published in the Herald News, Romulus Roman, and the Michigan
Community Newspaper. If significant written comments are
received within thirty (30) days of the date of the newspaper
publication, a public hearing may be scheduled. If a public
hearing is scheduled, a notice of the hearing will be published
at least 30 days in advance.
Part C of the SDWA specifically mandates regulation of the
underground injection of fluids through wells to assure that the
quality of the underground sources of drinking water is
protected. Section 1421 of the SDWA requires the USEPA to
administer underground injection control (UIC) programs in the
states which do not have approved UIC programs. Michigan has not
acquired primacy over the UIC program for Class I injection
wells, therefore USEPA is administering the permit program
pursuant to regulations at 40 CFR Part 147.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
7 7 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
P&ge 1 of 18
U.S. ENVIIOWENTAL PROTECTION AGENCY
UNDERGROUND INJECTION CONTROL PEFMIT: CLASS I NON-HAZARDOUS
Permit Nurrber: MI-163-1I-0001
Facility Name: Brine Disposal Well No. 1A.
Pursuant to the Underground Injection Control regulations of the U.S.
Environmental Protection Agency codified at Title 40 of the Code of Federal
Regulations (40 CER), Parts 124, 144, 146, and 147,
Sun Pipe Line Carpany of Philadelphia, Pennsylvania
is hereby authorized to construct and operate a new Class I non-hazardous waste
injection well located in Michigan, Wayne County, T3S, R9E, Section 12, NE
Quarter Section, injecting into the Eau Claire and Mt. Simon members of the
Munising Formation and the Precambrian Formation at depths between about 3,900
feet and 4,450 feet upon the express condition that the permittee meet the
restrictions set forth herein. The injection of any hazardous fluid, specified
in 40 CER Part 261, is prohibited. Injection shall not commence until the
operator has received authorization in accordance with Part I (J) of this permit
All references to 40 CER are to all regulations that are in effect on the
date that this permit is effective. The following attachments are incorporated
into this permit: A, B, C, D, E, and F.
This permit shall become effective on , and shall
remain in full force and effect during the life of the permit, unless this permit
is revoked, terminated, modified or reissued pursuant to 40 CER §§144.39, 144.40
or 144.41. The permit will expire in one (1) year if the permittee fails to
commence construction, unless a written request for an extension of this one (1)
year period has been approved by the Director. The permittee may request an
expiration date sooner than the one (1) year period, provided no construction on
the well has commenced.
This permit and authorization to inject shall expire at midnight on
, unless terminated prior to the expiration date.
Signed and Dated
DRAFT
Jo Lyn Traub
Director, Water Division
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TABLE OF CONTENTS
Page No.
AUTHORITY 1
PART I. GENERAL PERMIT COMPLIANCE 2
A. EFFECT OF PERMIT 2
B. PERMIT ACTIONS 2
1. Modifications, Revocation, Reissuance and Termination 2
2. Transfer of Permits 2
C. SEVERABILITY 2
D. CONFIDENTIALITY 3
E. DUTIES AND REQUIREMENTS 3
1. Duty to Comply 3
2. Penalties for Violations of Permit Conditions 3
3. Continuation of Expiring Permits 3
4. Need to Halt or Reduce Activity Not a Defense 4
5. Duty to Mitigate 4
6. Proper Operation and Maintenance 4
7. Duty to Provide Information 5
8. Inspection and Entry 5
9. Records 5
10. Monitoring 6
11. Signatory Requirements 7
12. Reporting Requirements 7
F. PLUGGING AND ABANDONMENT 8
1. Notice of Plugging and Abandonment 8
2. Plugging and Abandonment 8
3. Temporary Abandonment 8
4. Revision of Plugging and Abandonment Plan 9
5. Standards for Well Closure 9
G. MECHANICAL INTEGRITY 9
1. Standards 9
2. Periodic Mechanical Integrity Testing 9
3. Prior Notice and Reporting 10
4. Gauges 10
5. Loss of Mechanical Integrity 10
6. Testing on Request from Director 10
H. FINANCIAL RESPONSIBILITY 11
1. Financial Responsibility 11
2. Insolvency 11
3. Notification 11
4. Establishing Other Coverage 12
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I. CORRECTIVE ACTION 12
1. Compliance 12
2. Corrective Action Plan 12
3. Prohibition of Movement of Fluids into USEWs 12
J. COMMENCING INJECTION 12
PART II. WF.T.T, SPECIFIC CONDITIONS 13
A. CONSTRUCTION 13
1. Siting 13
2. Casing and Cementing 13
3. Tubing and Packer Specifications 13
4. Wellhead Specification 13
B. OPERATIONS 13
1. Injection Pressure Limitation 13
2. Additional Injection Limitation 13
3. Annulus Fluid and Pressure 13
4. Annulus/Tubing Pressure Differential 14
5. Automatic Warning and Automatic Shut-off System 14
6. Precautions to Prevent Well Blowouts 14
C. MONITORING 15
1. Sampling Point 15
2. Continuous Monitoring Devices 15
3. Waste Analysis Plan 15
4. Ambient Monitoring 15
D. REPORTING REQUIREMENTS 15
1. Monthly Reports 15
2. Quarterly Reports 16
3. Annual Reports 16
4. Reports on Well Tests and Workovers 17
PART III. ATTACHMENTS 18
A. SUMMARY OF OPERATING, MONITORING AND REPORTING REQUIREMENTS
B. PLUGGING AND ABANDONMENT PIAN
C. FINANCIAL ASSURANCE MECHANISM
D. CONTINGENT CORRECTIVE ACTION
E. CONSTRUCTION DETAILS
F. SOURCE AND ANALYSIS OF WASTE
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PART I
GENERAL PEFMIT CCMPLIANCE
A. EFFECT OF PEFMIT
The permittee is allowed to engage in underground injection in accordance
with the conditions of this permit. Notwithstanding any other provisions
of this permit, the permittee authorized by this permit shall not
construct, operate, maintain, convert, plug, abandon, or conduct any other
injection activity in a manner that allows the movement of injection,
annulus or formation fluids into underground sources of drinking water
(USEWs) . The objective of this permit is to prevent the introduction of
contaminants into USEWs if the presence of that contaminant may cause a
violation of any primary drinking water regulation under 40 CFR Part 141 or
may otherwise adversely affect the health of persons. Any underground
injection activity not specifically authorized in this permit is
prohibited. For purposes of enforcement, compliance with this permit
during its term constitutes compliance, with Part C of the Safe Drinking
Water Act (SEWA) . Such compliance does not constitute a defense to any
action brought under Section 1431 of the SEWA, or any other common or
statutory law other than Part C of the SEWA. Issuance of this permit does
not convey property rights of any sort or any exclusive privilege; nor does
it authorize any injury to persons or property, any invasion of other
private rights, or any infringement of State or local law or regulations.
Nothing in this permit shall be construed to relieve the permittee of any
duties under applicable regulations.
B. PEFMIT ACTIONS
1. Modification, Revocation, Reissuance and Termination - The Director
of the Water Division of the United States Environmental Protection
Agency (USEPA), hereinafter, the Director, may, for cause or upon
request from the permittee, modify, revoke and reissue, or terminate
this permit in accordance with 40 CFR 144.12, 144.39, and 144.40.
Also, the permit is subject to minor modifications for cause as
specified in 40 CFR 144.41. The filing of a request for a permit
modification, revocation and reissuance, or termination, or the
notification of planned changes, or anticipated noncompliance on the
part of the permittee does not stay the applicability or
enforceability of any permit condition.
2. Transfer of Permits - This permit is not transferable to any person
except in accordance with 40 CFR 144.38.
C. SEVERABILITY
The provisions of this permit are severable, and if any provision of this
permit or the application of any provision of this permit to any
circumstance is held invalid, the application of such provision to other
circumstances and the remainder of this permit shall not be affected
thereby.
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D. CONFIDENTIALITY
In accordance with 40 CER Part 2 and Section 144.5, any information
submitted to the USEPA pursuant to this permit may be claimed as
confidential by the submitter. Any such claim must be asserted at the time
of submission by stamping the words "confidential business information" on
each page containing such information. If no claim is made at the time of
submission, the USEPA may make the information available to the public
without further notice. If a claim is asserted, the validity of the claim
will be assessed in accordance with the procedures in 40 CER Part 2 (Public
Information). Claims of confidentiality for the following information will
be denied:
1. The name and address of the permittee; and
2. Information which deals with the existence, absence or level of
contaminants in drinking water.
E. DUTIES AND REQUIREMENTS
1. Duty to Comply - The permittee shall comply with all applicable
Underground Injection Control (UIC) Program regulations and
conditions of this permit, except to the extent and for the duration
such noncompliance is authorized by an emergency permit issued in
accordance with 40 CER 144.34. Any permit noncompliance constitutes
a violation of the SEWA and is grounds for enforcement action,
permit termination, revocation and reissuance, modification, or for
denial of a permit renewal application.
2. Penalties for Violations of Permit Conditions - Any person who
violates a permit requirement is subject to civil penalties, fines
and other enforcement action under the SEWA. Any person who
willfully violates permit conditions may be subject to criminal
prosecution.
3. Continuation of Expiring Permits
(a) Duty to Reapply - If the permittee wishes to continue an
activity regulated by this permit after the expiration date of
this permit, the permittee must submit a complete application
for a new permit at least 180 calendar days before this permit
expires.
(b) Permit Extensions - The conditions of an expired permit may
continue in force in accordance with 5 U.S.C. 558(c) and 40
CER 144.37.
(c) Effect - Permits continued under 5 U.S.C. 558(c) and 40 CER
144.37 remain fully effective and enforceable.
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(d) Enforcement - When the permittee is not in compliance with the
conditions of the expiring or expired permit, the Director may
choose to do any or all of the following:
(1) Initiate enforcement action based upon the permit which
has been continued;
(2) Issue a notice of intent to deny the new permit in which
case, the owner or operator would then be required to
cease the activities authorized by the continued permit
or be subject to enforcement action for operation
without a permit;
(3) Issue a new permit under 40 CER Part 124 with
appropriate conditions; or
(4) Take other actions authorized by the UIC regulations.
(e) State Continuation - A USEPA-issued permit does not continue
in force beyond its expiration date under Federal law if at
that time a State has primary enforcement responsibility under
the SEWA. A State authorized to administer the UIC program
may continue either USEPA or State-issued permits until the
effective date of the new permits, if State law allows.
Otherwise, the facility or activity is operating without a
permit from the time of expiration of the old permit to the
effective date of the State-issued new permit. Furthermore,
if the State does not continue the USEPA permit upon obtaining
primary enforcement responsibility, the permittee must obtain
a new State permit or be authorized to inject by State rule.
Failure to do so while continuing to operate the well
constitutes unauthorized injection and is a violation subject
to enforcement action.
4. Need to Halt or Reduce Activity Not a Defense - It shall not be a
defense for the permittee in an enforcement action to claim that it
would have been necessary to halt or reduce the permitted activity
in order to maintain compliance with the conditions of this permit.
5. Duty to Mitigate - The permittee shall take all timely and
reasonable steps necessary to minimize or correct any adverse impact
on the environment resulting from noncompliance with this permit.
6. Proper Operation and Maintenance - The permittee shall at all times
properly operate and maintain all facilities and systems of
treatment and control and related appurtenances which are installed
or used by the permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance includes effective
performance, adequate funding, adequate operator staffing and
training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. This provision requires
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the operation of back-up or auxiliary facilities or similar systems
only when necessary to achieve compliance with the conditions of
this permit.
7. Duty to Provide Information - The permittee shall furnish to the
Director, within a time specified, any information which the
Director may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this permit, or to
determine compliance with this permit. The permittee shall also
furnish to the Director, upon request, copies of records required to
be kept by this permit.
8. Inspection and Entry - The permittee shall allow the Director or an
authorized representative, upon the presentation of credentials and
other documents as may be required by law, to:
(a) Enter, at reasonable times, upon the permittee's premises
where a regulated facility or activity is located or
conducted, or where records are kept under the conditions of
this permit;
(b) Have access to and copy, at reasonable times, any records that
are kept under the conditions of this permit;
(c) Inspect, at reasonable times, any facilities, equipment
(including monitoring and control equipment), practices, or
operations regulated or required under this permit; and
(d) Sample or monitor, at reasonable times, for the purposes of
assuring permit compliance or as otherwise authorized by the
SDWA, any substances or parameters at any facilities,
equipment or operations regulated or required under this
permit.
9. Records
(a) The permittee shall retain records and all monitoring
information, including all calibration and maintenance records
and all original chart recordings for continuous monitoring
instrumentation and copies of all reports required by this
permit for a period of at least five (5) years from the date
of the sample, measurement or report, unless these materials
are submitted to the Director as part of reporting
requirements under this permit.
(b) The permittee shall maintain records of all data required to
complete the permit application form for this permit and any
supplemental information submitted under 40 CER 144.27,
144.28, and 144.31 for a period of at least five (5) years
from the date the permit application was signed.
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The permittee shall retain records concerning the nature and
composition of all injected fluids until three (3) years after
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the conpletion of plugging and abandonment of this injection
well.
(d) The retention period specified in Part 1(E) (9) (a) through (c)
of this permit may be extended by request of the Director at
any time. The permittee shall continue to retain records
after the retention period specified in Part 1(E)(9)(a)
through (c) of this permit or any requested extension thereof
expires unless the permittee delivers the records to the
Director or obtains written approval from the Director to
discard the records.
(e) Records of monitoring information shall include:
(1) The date, exact place, and time of sampling or
measurements;
(2) The name(s) of individual (s) who performed the sampling
or measurements;
(3) A precise description of both sampling methodology and
the
handling of samples;
(4)
The
date(s) analyses were performed;
(5)
The
name(s) of individual(s) who performed the analyses;
(6)
The
analytical techniques or methods used; and
(7)
The
results of such analyses.
Monitoring - Samples and measurements taken for the purpose of
monitoring shall be representative of the monitored activity. The
permittee shall use the methods described in "Test Methods for the
Evaluation of Solid Waste, Physical/Chemical Methods" (available
from Solid Waste Information, USEPA, 26 W. St. Claire St.,
Cincinnati, Ohio 45268), or equivalent methods approved by the
Director, to take representative samples. Monitoring results shall
be reported at the intervals contained in Part 11(D)(1) through (3)
and Part III (A) of this permit.
(a) Monitoring of the nature of injected fluids shall comply with
applicable analytical methods cited and described in Table I
of 40 CER 136.3 or in certain circumstances by other methods
that have been approved by the Director.
(b) Sampling and analysis shall comply with the specifications of
the Waste Analysis Plan required in Part II(C)(3) of this
permit.
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11. Signatory Requirements - All reports or other information, required
to be submitted by this permit or requested by the Director shall be
signed and certified in accordance with 40 CER 144.32.
12. Reporting Requirements
(a) Planned Changes - The permittee shall give written notice to
the Director, as soon as possible, of any planned physical
alterations or additions to the permitted facility other than
minor repair/replacement maintenance activities.
(b) Anticipated Noncompliance - The permittee shall give advance
notice to the Director of any planned changes in the permitted
facility or activity which may result in noncompliance with
permit requirements.
(c) Compliance Schedules - Reports of compliance or noncompliance
with, or any progress reports on, interim and final
requirements contained in any compliance schedule of this
permit shall be submitted by the permittee no later than
thirty (30) calendar days following each schedule date.
(d) Twenty-four Hour Reporting
(1) The permittee shall report to the Director any permit
noncompliance which may endanger human health or the
environment. See, e.g., Part 1(G)(5) of this permit.
Any information shall be provided orally within twenty-
four (24) hours from the time the permittee becomes
aware of the circumstances. Such reports shall include,
but not be limited to the following information:
(i) Any monitoring or other information which
indicates that any contaminant may cause an
endangerment to a USDW; and
(ii) Any noncompliance with a permit condition, or
malfunction of the injection system, which may
cause fluid migration into or between USDWs; and
(iii) Any failure to maintain mechanical integrity.
(2) A written submission shall also be provided within five
(5) working days of the time the permittee becomes aware
of the circumstances. The written submission shall
contain a description of the noncompliance and its
cause; the period of noncompliance, including exact
dates and times, and, if the noncompliance has not been
corrected, the anticipated time it is expected to
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continue; and steps taken or planned to reduce,
eliminate and prevent recurrence of the noncompliance.
(e) Other Noncompliance - The permittee shall report all other
instances of noncompliance not otherwise reported at the time
monitoring reports are submitted. The reports shall contain
the information listed in Part 1(E)(12)(d)(2) of this permit.
(f) Other Information - When the permittee becomes aware of
failure to submit any relevant facts in the permit application
or that incorrect information was submitted in a permit
application or in any report to the Director, the permittee
shall submit such facts or corrected information within ten
(10) calendar days.
(g) Report on Permit Review - Within thirty (30) calendar days of
receipt of this permit, the permittee shall certify to the
Director that he or she has read and is personally familiar
with all terms and conditions of this permit.
F. PLUGGING AND ABANDONMENT
1. Notice of Plugging and Abandonment - The permittee shall notify the
Director at least sixty (60) calendar days before conversion or
abandonment of the well. At the discretion of the Director, a
shorter notice period may be allowed.
2. Plugging and Abandonment - The permittee must receive the approval
of the Director before plugging the well and shall plug and abandon
the well consistent with 40 CER 144.52(a)(6) and 146.10, as provided
for in the Plugging and Abandonment Plan contained in Part III(B) of
this permit. Within sixty (60) calendar days after plugging a well,
the permittee shall submit a Plugging and Abandonment report to the
Director. The report shall be certified as accurate by the
permittee and by the person who performed the plugging operation (if
other than the permittee), and shall consist of either:
(a) A statement that the well was plugged in accordance with the
Plugging and Abandonment Plan previously approved by the
Director; or
(b) If the actual plugging differed from the approved plan, a
statement defining the actual plugging and explaining why the
Director should approve such deviation. If the Director
determines that a deviation from a previously approved plan
may endanger underground sources of drinking water, the
permittee shall replug the well as required by the Director.
3. Temporary Abandonment - If the permittee ceases injection into the
well for more than twenty-four (24) months, he or she shall plug and
abandon the well in accordance with the approved plan and 40 CER
144.52 (a)(6), unless the permittee has received written
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authorization from the Director to keep the well open. During any
periods of temporary abandonment or disuse, the permittee shall
continue to comply with the conditions of this permit, unless a
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condition is waived by the Director for the period of disuse.
Mechanical integrity testing will not be waived.
4. Revision of Plugging and Abandonment Plan - If the permittee finds
it necessary to change a Plugging and Abandonment Plan, a revised
plan shall be submitted to the Director for approval at the time of
the next monthly report.
5. Standards for Well Closure - Prior to plugging and abandoning the
well:
(a) The permittee shall observe and record the pressure decay for
a time specified by the Director and shall report this
information to the Director.
(b) The permittee shall conduct appropriate mechanical integrity
testing to ensure the integrity of that portion of the long
string casing and cement that will be left in the ground after
closure. Testing methods may include:
(1) Pressure tests with liquid;
(2) Radioactive tracer surveys;
(3) Noise, temperature, pipe evaluation, or cement bond
logs; or
(4) Any other test required by the Director.
(c) Prior to well closure, the well shall be flushed with a buffer
fluid.
G. MECHANICAL INTEGRITY
1. Standards - The injection well must have and maintain mechanical
integrity consistent with 40 CER 146.8(a) (1) and (2) . Mechanical
integrity demonstrations must be witnessed by an authorized
representative of the Director.
2. Periodic Mechanical Integrity Testing [§146.81 - The permittee shall
conduct the mechanical integrity testing as follows:
(a) Long string casing, injection tubing and annular seal shall be
tested by means of an approved pressure test in accordance
with 40 CER 146.8(b)(2). This test shall be performed upon
completion of this well, and at least once every twelfth month
beginning with the date of the last approved demonstration and
whenever there has been a well workover in which tubing is
removed from the well, the packer is reset, or when loss of
mechanical integrity becomes suspected during operation;
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(b) The integrity of the cement at the bottom of the longstring
casing shall be tested by means of an approved radioactive
tracer survey upon completion of this well and at least once
every sixty (60) months beginning with the date of the last
approved demonstration;
(c) An approved temperature, noise, oxygen activation, or other
approved log shall be run upon completion of this well and at
least once every sixty (60) months from the date of the last
approved demonstration to test for movement of fluid along the
bore hole. The Director may require such tests whenever the
well is worked over. The permittee must submit logging
procedures to the Director for approval before running logs
for the purpose of meeting this requirement.
(d) The permittee may request the Director to use any other test
approved by the Director in accordance with the procedures in
146.8(d) .
3. Prior Notice and Reporting - The permittee shall notify the Director
of his or her intent to demonstrate mechanical integrity at least
thirty (30) calendar days prior to such demonstration. At the
discretion of the Director a shorter time period may be allowed.
Reports of mechanical integrity demonstrations which include logs
must include an interpretation of results by a knowledgeable log
analyst. The permittee shall report the results of a mechanical
integrity demonstration within forty-five (45) calendar days after
completion thereof.
4. Gauges - The permittee shall calibrate all gauges used in mechanical
integrity demonstrations to an accuracy of not less than one-half
(0.5) percent of full scale, prior to each required test of
mechanical integrity. A copy of the calibration certificate shall
be submitted to the Director or his or her representative at the
time of demonstration and every time the gauge is calibrated. The
gauge shall be marked in no greater than five (5) psi increments.
5. Loss of Mechanical Integrity - If the permittee or the Director
finds that the well fails to demonstrate mechanical integrity during
a test, or fails to maintain mechanical integrity during operation,
or that a loss of mechanical integrity as defined by 40 CER
146.8(a)(1) and (2) is suspected during operation, the permittee
shall halt the operation immediately and follow the reporting
requirements as directed in Part 1(E)(12) of this permit. The
permittee shall not resume operation until mechanical integrity is
demonstrated and the Director gives approval to recommence
injection.
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6. Mechanical Integrity Testing on Request From Director - The
permittee shall demonstrate mechanical integrity at any time upon
written notice from the Director.
H. FINANCIAL RESPONSIBILITY
1. Financial Responsibility - The permittee shall maintain financial
responsibility and resources to close, plug, and abandon the
underground injection operation in a manner consistent with 40 CFR
144.52(a) (7) . The approved financial assurance mechanism is found
in Part III(C) of this permit.
(a) The permittee must maintain a written cost estimate, in
current dollars, for the Plugging and Abandonment Plan as
specified in 40 CFR 146.10. The plugging and abandonment cost
estimate at any point in the life of the facility operation
must equal the maximum cost of plugging and abandonment at
that time.
(b) The permittee must adjust the cost estimate of plugging and
abandonment for inflation within thirty (30) calendar days
after each anniversary of the first estimate. The inflation
factor is the result of dividing the latest published annual
Oil and Gas Field Equipment Cost Index by the index for the
previous year.
(c) The permittee must revise the plugging and abandonment cost
estimate whenever a change in the Plugging and Abandonment
Plan increases the cost of plugging and abandonment.
(d) If the revised plugging and abandonment estimate exceeds the
current amount of the financial assurance mechanism, the
permittee shall submit a revised mechanism to cover the
increased cost within thirty (30) calendar days after the
revision specified in Part 1(H)(1)(b) and (c) of this permit.
(e) The permittee must keep on file at the facility a copy of the
latest plugging and abandonment cost estimate prepared in
accordance with 40 CFR 144.52(a)(7), during the operating life
of the facility.
2. Insolvency - The permittee must notify the Director within ten (10)
business days of any of the following events:
(a) The bankruptcy of the trustee or issuing institution of the
financial mechanism; or
(b) Suspension or revocation of the authority of the trustee
institution to act as trustee; or
(c) The institution issuing the financial mechanism losing its
authority to issue such an instrument.
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3. Notification - The permittee must notify the Director by certified
mail of the commencement of voluntary or involuntary proceedings
under Title 11 (Bankruptcy), U.S. Code naming the owner or operator
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as debtor, within ten (10) business days after the commencement of
the proceeding. A guarantor of a corporate guarantee must make such
a notification if he or she is named as debtor, as required under
the terms of the guarantee.
4. Establishing Other Coverage - The owner or operator must establish
other financial assurance or liability coverage acceptable to the
Director, within sixty (60) calendar days of the occurrence of the
events in Part 1(H)(2) or (H)(3) of this permit.
I. CORRECTIVE ACTION
1. Compliance - The permittee shall comply with 40 CER 144.55 and
146.7.
2. Corrective Action Plan - The permittee shall file a Corrective
Action Plan for approval by the Director within thirty (30) days of
a written determination by the Director that improperly plugged,
completed, or abandoned wells, or wells for which plugging or
completion information is unavailable, are present in the area of
review and penetrate the confining zone of the permitted well, as
defined in the administrative record for this permit.
3. Prohibition of Movement of Fluids into USEWs [§144.121 Should upward
migration of fluids through the confining zone of this permitted
well be discovered within the two mile area of review due to
injection activities at this facility, and should this migration of
fluids cause the introduction of any contaminant into a USEW
pursuant to 40 CER 144.12, the permittee shall immediately cease
injection into this well until the situation has been corrected and
reauthorization to inject has been given by the Director.
J. COMMENCING INJECTION
The permittee may not commence injection until:
1. Results of the formation testing and logging program as specified in
the administrative record of this permit are submitted to and
approved by the Director; and
2. Mechanical integrity of the well has been demonstrated in accordance
with 40 CER 146.8(a)(1) and (2) and in accordance with Part 1(G)(1)
through (3) of this permit; and
3. Results from ambient monitoring as required in Part 11(C)(4) of this
permit have been submitted and approved by the Director; and
4.
All required corrective action has been taken in accordance with 40
CER 144.55(b)(2) and Part III(D) of this permit; and
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5. Written authorization to conmence injection has been granted by the
Director.
PART II
TaF.LT, SPECIFIC CONDITIONS FDR UIC PERMITS
CONSTRUCTION
1. Siting [§146.12(a)1 - The injection well shall inject only into the
formation at the depths listed on the cover page of this permit. At
no time shall injection occur into a formation which is or is above
the lowermost formation containing, within one quarter mile of the
well bore, an underground source of drinking water.
2. Casing and Cementing [§146.12 (b) 1 - Notwithstanding any other
provisions of this permit, the permittee shall case and cement the
well in such a manner so as to prevent the movement of fluids into
or between USDWs for the expected life of the well. The casing and
cement used in the construction of this well are shown in Part
III(E) of this permit and in the administrative record for this
permit. Any change shall be submitted for approval by the Director
before installation.
3. Tubing and Packer Specifications [§146.12(c)1 - The permittee shall
inject only through tubing with a packer set within the long string
casing at a point within or below the confining zone. The tubing
and packer used in the well are represented in engineering drawings
contained in Part III (E) of this permit. Any changes shall be
submitted by the permittee for the approval of the Director before
installation.
4. Wellhead Specification [§144.51(i)(4)1 - The permittee shall install
and maintain a female coupling and valve on the wellhead, to be used
for independent injection pressure readings. Further, the permittee
shall install a sampling port for waste sampling consistent with the
permittee's waste sampling procedures, if applicable.
OPERATIONS [§146.13]
1. Injection Pressure Tlimitation - Except during stimulation, the
permittee shall not cause or permit the injection pressure at the
wellhead to exceed the maximum limitation which is specified in Part
III (A) of this permit. In no case shall injection pressure initiate
fractures or propagate existing fractures in the confining zone or
cause the movement of injection or formation fluids into a USDW.
2. Additional Injection Tlimitation - No waste streams other than those
identified in Part III (F) of this permit shall be injected. Every
twelfth month the permittee shall submit a certified statement
attesting to compliance with this requirement.
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3. Annulus Fluid and Pressure - The permittee shall fill the annulus
between the tubing and the long string casing with a fluid approved
by the Director and identified in the administrative record of this
permit. Any change in the annulus fluid, except during workovers or
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times of annulus maintenance, shall be submitted by the permittee
for the approval of the Director before replacement. Except during
workovers, the permittee shall maintain a positive pressure on the
annulus as specified in Part III (A) of this permit.
4. Annulus/Tubing Pressure Differential - Except during workovers or
times of annulus maintenance, the permittee shall maintain, over the
entire length of the tubing, a pressure differential between the
tubing and annulus as specified in Part III (A) of this permit.
5. Automatic Warning and Automatic Shut-off System - The permittee
shall continuously operate and maintain an automatic warning and
automatic shut-off system to stop injection in any of the following
situations:
(a) Pressure changes in the annulus or annulus/tubing differential
signifying or identifying possible deficiencies in mechanical
integrity; or
(b) Injection pressure, annulus pressure, or annulus/tubing
differential pressure reaches the pressure limits as specified
in Part III (A) of this permit.
A trained operator must be on site and within perceptible distance
of the alarm at all times when the well is operating. The permittee
must test the automatic warning and automatic shut-off system at
least every twelfth month. This test must involve subjecting the
system to simulated failure conditions and must be witnessed by the
Director or his or her representative.
6. Precautions to Prevent Well Blowouts [§144.51(e) and §144.52(a)(9)
and (b) (1) 1
(a) The permittee shall maintain on the well at all times a
pressure which will prevent the return of the injection fluid
to the surface. The well bore must be filled with a high
specific gravity fluid during workovers to maintain a positive
(downward) gradient and/or a plug shall be installed which can
resist the pressure differential. A blowout preventer must be
kept in proper operational status during workovers.
(b) In cases where the injected wastes have the potential to react
with the injection formation to generate gases, the permittee
shall follow the procedures below to assure that a backflow or
blowout does not occur:
(1) Limit the temperature, pH or acidity of the injected
waste; and
(2) Develop procedures necessary to assure that pressure
imbalances do not occur.
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C. MONITORING
1. Sampling Point - The injection fluid samples shall be taken at the
sampling location as specified in Part III (A) of this permit.
2. Continuous Monitoring Devices - The permittee shall maintain
continuous monitoring devices and use them to monitor injection
pressure, flow rate, and the pressure on the annulus between the
tubing and the long string of casing. The permittee shall monitor
the sight glass daily. A value correlating changes in sight glass
level with changes in annulus volume must be determined and reported
to the Director within 120 days of the effective date of this
permit. The monitoring results shall be submitted to the Director
as specified in Part 11(D) of this permit. The permittee shall
maintain for USEPA's inspection at the facility an appropriately
scaled, continuous analog record of these monitoring results as well
as original copies of any digitally recorded information pertaining
to these operations.
3. Waste Analysis Plan [§144.52(a)(5)1 - The permittee shall comply
with the written Waste Analysis Plan (Attachment F) which describes
the procedures used to monitor the nature of injected fluids and the
procedures which will be carried out to comply with Part (I)(E)(10)
of permit. A copy of the approved plan shall also be kept at the
facility.
4. Ambient Monitoring [§146.13(d)(1)1 - The permittee shall monitor the
pressure buildup in the injection zone initially upon completion of
the well, and at least once every twelfth month thereafter,
including at a minimum, a shut down of the well for a time
sufficient to conduct a valid observation of the pressure fall-off
curve. From this observation, the permittee shall submit a report
including at least a calculation of pressure build-up in the
injection zone, injection zone transmissivity, and wellbore skin
factor.
D. REPORTING REQUIREMENTS [§146.13(c)]
The permittee shall submit all required reports to the Director at:
United States Environmental Protection Agency
77 West Jackson Boulevard (WU-16J)
Chicago, Illinois 60604-3590
ATTN: UIC Branch, DI Section
1. Monthly Reports - The permittee shall submit monthly reports of the
following information no later than the end of the month following
the reporting period:
(a) Waste analysis results per the approved waste analysis plan as
applicable. Laboratory reports must be submitted with the
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first monthly monitoring report following their receipt by the
operator. This report must include statements showing that
the requirements of Part 1(E)(10) and Part 11(C)(3) have been
met;
(b) A tabulation of maximum injection pressure, maximum and
minimum sight glass levels, and minimum differential between
simultaneous measurements of injection pressure and annulus
pressure for each day of the month;
(c) Appropriately scaled graphs showing injection pressure and
flow rate and sight glass levels. One graph must include, at
a minimum, daily maximum injection pressure and daily average
flow rate, on a single, monthly chart. The same or a second
graph must display the daily maximum and minimum sight glass
levels;
(d) A statement of the total volumes of the fluid injected to
date, in the current calendar year, and the current month;
(e) A tabulation of the dates, amounts and types of liquid added
to or removed from the annulus system during the month, and
the cumulative additions and cumulative subtractions for the
current month and each of the past 12 months;
(f) Any noncompliance with conditions of this permit, including
but not limited to:
(1) Any event that exceeds operating parameters for annulus
pressure or injection pressure or annulus/tubing
differential as specified in the permit; or
(2) Any event which triggers an alarm or shutdown device
required in Part 11(B)(5) of this permit.
2. Quarterly Reports - The permittee shall report the results of the
injection fluid analyses specified in the approved Waste Analysis
Plan, as recorded in the administrative record for this permit at
least quarterly. In reporting fluid analyses, the permittee shall
identify the waste components of the waste stream by their common
name, chemical name, structure and concentration, or as approved by
the Director.
3. Annual Reports - The permittee shall report the following at least
every twelve months:
(a) Results of the injection fluid analyses specified in the
approved waste analysis plan as recorded in the administrative
record for this permit as applicable. This report must
include statements showing that the requirements of Part
1(E) (10), Part 11(B) (2) and Part 11(C) (3) have been met; and
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(b) Results of ambient monitoring required by 40 CER 146.13(d) (1)
and Part 11(C)(4) of this permit.
(c) A certified statement attesting that no waste streams other
than those identified in Part III (F) of this permit were
injected into the well.
4. Reports on Well Tests and Workovers - Within forty-five (45)
calendar days after the activity, the permittee shall report to the
Director the results of demonstrations of mechanical integrity, any
well workover, and/or results of other tests required by this
permit.
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PART III
ATTACHMENTS
These attachments include, but are not limited to, permit conditions and plans
concerning operating procedures, monitoring and reporting, as required by 40 CER
Parts 144 and 146. The permittee shall comply with these conditions and adhere
to these plans as approved by the Director, as follows:
A. SUMMARY OF OPERATING, MONITORING AND REPORTING REQUIREMENTS (ATTACHED)
B. PLUGGING AND ABANDONMENT PIAN (ATTACHED)
C. FINANCIAL ASSURANCE MECHANISM (ATTACHED)
D. CONTINGENT CORRECTIVE ACTION (ATTACHED)
E. CONSTRUCTION DETAILS (ATTACHED)
F.
SOURCE AND ANALYSIS OF WASTE (ATTACHED)
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ATTACHMENT A
SUXMARY OF OPERATING, MONITORING AND REPORTING REQUIREMENTS
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ATTACHMENT A
SUMMARY OF OPERATING, MONITORING AND REPORTING REQUIREMENTS
CHARACTERISTIC LIMITATION
MINIMUM
MONITORING
FREQUENCY
Injection Pressure
Annulus Pressure
Annulus/Tubing
Differential
604 psig maximum continuous
100 psig minimum continuous
100 psig minimum continuous
above operating
injection pressure
Flow Rate
Sight Glass Level
Cumulative Volume
Annulus Fluid Loss
Chemical Composition of
Injected Fluids**
Physical Characteristics of
Injected Fluids**
continuous
daily
continuous
monthly
quarterly
quarterly
MINIMUM
REPORTING
FREQUENCY
monthly
monthly
monthly
monthly
monthly
monthly
monthly
quarterly
quarterly
Sampling Location: Samples will be collected from a tap at the well head.
*This limitation was calculated using the following formula:
[{0.70 psi/ft - (0.433 psi/ft x specific gravity)} x depth ] - 14.7 psi.
The maximum injection pressure is dependent upon depth, specific gravity of the
injection fluid, and fracture gradient of the injection zone. The Eau Claire
Member of the Munising formation at 3,900 feet was used as the depth and a
specific gravity of 1.25 was used for the injection fluid. The fracture
gradient of 0.70 psi/ft is used as a default value, unless a site-specific
value is determined pursuant to Part III(D)(B) of this permit, in which case
the maximum injection pressure will be modified to reflect the specific value
of the fracture gradient in this well. Such modification shall be considered a
minor modification as allowed for at 40 CFR §144.41(f). The limitation on
injection pressure will serve to prevent injection-formation fracturing.
**As specified in the Sampling and Analysis Plan, found in the administrative
record for this permit. At a minimum, this analysis shall include, but not be
limited to, the following: Temperature, Specific Conductance, pH and Specific
Gravity.
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ATTACHMENT B
PLUGGING AND ABANDONMENT ELAN
Attachment B, the Plugging and Abandonment Plan, is not viewable over the
Internet. Please visit the public library listed in the public
notice above or contact the permit writer listed in the public notice.
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ATTACHMENT C
FINANCIAL ASSURANCE MECHANISM
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Page C-l of 4
FINANCIAL ASSURANCE MECHTWISM
The Sun Pipeline Company has established financial assurance for the plugging of
the brine disposal well Number 1A through maintenance of State Bond #17004459 in
the amount of $25,000 plus a rider which increases the amount to $51,000 with the
Liberty Mutual Insurance Company of Boston, Massachusetts. Copies of the State
Bond and most recent cost estimates are attached.
These documents are not viewable over the Internet. Please visit the public
library listed in the public notice above or contact the permit writer listed in
the public notice.
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ATTACHMENT D
CONTINGENT OCRRECTIVE ACTICN ELAN
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CONTINGENT CORRECTIVE ACTION AND
ESTABLISHMENT OF MSXIMUM INJECTION PRESSURE
MI-163-1I-0001
Page D-l of 3
A. Contingent Corrective Action Plan
At present a corrective action plan is not required because no problems were
encountered which might pose either a constraint on injection well operations or
a threat to ground water systems.
1. Should upward fluid migration occur through the well bore of any
previously unknown, improperly plugged or unplugged well due to
injection of permitted fluid and/or should any problems develop with
the casing of the injection well the permittee will:
A. Notify the United States Environmental Protection Agency
(USEPA) and the Michigan Department of Environmental Quality
(MDEQ) by telephone within twenty-four (24) hours of the
discovery of the problem; and
B. Provide written confirmation transmitted by letter within five
(5) days;
C. Immediately plug the improperly plugged well.
2. Should failure of Well Number 1A occur the permittee will:
A. Immediately shut the well in;
B. Divert the brine that normally would be injected into the
disposal well into the two 500,000 gallon holding pits and
10,000 gallon brine tank until the cause of the well failure
is remedied; and
C. End or reduce the circulation of fresh water to ensure that
the volume of water produced could be managed.
3. In the case of well failure the permittee will:
A. Conduct an investigation of the indicated well failure
problem;
B. Develop a plan of action to eliminate the problem; and
C. Inform the UIC Branch of the results and give the UIC Branch
the opportunity to comment before the remedial work is
performed.
D. Perform any needed remedial work.
B. bfeximum Injection Pressure (146.13)
1. During construction of this well, the permittee shall determine if
the maximum injection pressure as specified at Part III (A) of this
permit allows sufficient operational flexibility. If sufficient
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flexibility is allowed for in the maximum injection pressure, the
permittee may opt not to proceed with additional testing and the
requirements of Part III(D)(B) of this permit shall be met. If the
maximum injection pressure calculated prior to direct testing proves
insufficient, or another need is identified that requires modifying
the maximum injection pressure, the permittee shall conduct one or
more of the following tests to ensure that the maximum injection
pressure exerted during operation will not propagate existing or
open new fractures in any part of the injection zone. In all cases,
the permittee shall submit a plan, for the Director's approval,
describing the detailed procedures to be followed during any test
designed to determine maximum injection pressure. Modification of
the maximum permitted injection pressure following a test conducted
under Part III(D)(B) of this permit shall follow the procedures set
forth for minor permit modifications, as specified at 40 CER
§144.41(f) .
(a) In-Situ Stress Tests
The permittee shall isolate zones for testing the fracturing
pressure by means of a straddle packer assembly, or other comparable
means. The zones chosen for testing shall be those predicted to
have the lowest fracturing value. The permittee shall use either
fresh water to conduct this test or a fluid that is permissible for
injection into this well as allowed for in this permit. At a
minimum, the permittee shall measure the test fluid for its specific
gravity and viscosity during the In-Situ Stress test. The results
of this test shall be submitted to the USEPA as specified at Part
III(D)(B)(2) of this permit. Failure to report test results shall
be considered grounds to deny a requested permit modification.
(b) Step Rate Test
The permittee shall isolate the entire injection zone by means of a
packer assembly, or other comparable means. The permittee shall
inject either fresh water for this test or a fluid that is
permissible for injection into this well as allowed for in this
permit. At a minimum, the permittee shall measure the test fluid
for its specific gravity and viscosity during the Step Rate Test.
The permittee shall inject into the well at increasing rates,
holding each rate step constant. Each rate step shall span the same
amount of time (at least 30 minutes per rate step is recommended).
The permittee shall attempt to inject at three (3) rates which
result in a pressure higher than the injection zone fracture
pressure during this test. A Cartesian plot of rate against the
final stabilized pressure at each step shall be included as part of
the data package submitted to the USEPA. The results of this test
shall be submitted to the USEPA as specified at Part III(D)(B)(2) of
this permit. Failure to report test results shall be considered
grounds to deny a requested permit modification.
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(c) Other Test(s) Approvable by the Director
The permittee may choose to conduct test(s) other than the two
described in Parts III(D)(B)(1)(a) and (b) of this permit. If so,
the permittee shall submit a plan to conduct alternative test(s) to
the Director for approval prior to conducting the test(s).
2. Reporting Maximum Injection Pressure Determination
The permittee shall report the results of the measurements, tests and
determinations conducted in Parts III(D)(B)(1) of this permit within 30
days of their completion.
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ATTACHMENT E
CONSTRUCTION DETAILS
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CONSTRUCTION DETAILS
Attached are diagrams of the well construction, wellhead schematic, and a diagram
of the annulus monitoring system.
These documents are not viewable over the Internet. Please visit the public
library listed in the public notice above or contact the permit writer listed in
the public notice.
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ATTACHMENT F
SOURCE AND ANALYSIS OF WASTE
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SOURCE AND ANALYSIS OF WASTE
MI-163-1I-0001
Page F-l of 4
Source of Waste - The waste stream to be injected into the Sun Pipeline Company
well will consist of brine produced through the circulation of fresh water
through caverns already leached out of formations of salt found at depths between
1,150 and 1,750 feet below the surface. The water will cause the dissolution of
additional salt, thus enlarging the caverns. It is also possible that additional
caverns may be created. The Sun Pipeline Company has used these caverns to store
liquid petroleum gases since about 1950.
T.imi t-a-Hm - Only brine coming from storage caverns at the Inkster Terminal
facility operated by the Sun Pipeline Company of Philadelphia, Pennsylvania, and
those fluids approved by the Director for the purpose of well testing,
stimulation, workovers, or as buffer fluids, may be injected through this well.
Sampling Range and Frequency - Quarterly grab samples will be taken at the well
by the operator. The permittee shall submit the results of any monitoring well
sampling from the facility to the USEPA UIC Branch within 45 days of the sampling
event.
Attached is a copy of the waste analysis plan submitted by the operator. The
following table lists the species to be sampled. The permittee shall follow the
procedures outlined in the Waste Analysis Plan for this permit.
Parameter
pH
Specific Gravity
Temperature
Specific Conductance
Total Dissolved Solids
Sodium (Na+)
Potassium (K1")
Calcium (Ca++)
Magnesium (Mg++)
Barium (Ba++)
Total Iron (Fe++,Fe+++)
Chloride (CI")
Carbonates (C03~)
Bicarbonates (HC03~)
Sulfates (S04~")
Total Organic Carbon
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The Monitoring Program and Waste Analysis Plan are not viewable over the
Internet. Please visit the public library listed in the public notice above or
contact the permit writer listed in the public notice.
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