vvEPA

United States
Environmental Protectior
Agency

How to Comment

You may comment on the proposed
draft permit in writing. Please refer
to draft permit number:

MI-105-1I-0003

Mail or email your comments to:

Jeffrey Wawczak

U.S. EPA, Water Division
UIC Branch (WU-16J)
77 W. Jackson Blvd.

Chicago, IL 60604-3590
Email: wawczak.jcffrcyVrcpa.gov
Phone:312-886-1988

Comment Period

EPA will accept written comments
until Monday, October 2
(midnight postmark).

Information Repository

You may see the draft permit at:

Ludington Public Library

217 East Ludington Avenue,
Ludington, Michigan;

Or at http://go.usa.gov/3JwFP.

Administrative Record

You may see the full administrative
record, including all data submitted
by Occidental Chemical, at the
EPA' s Chicago regional office
(iaddress above), weekdays from
9am to 4pm. For an appointment to
see the files, contact Jeffrey
Wawczak (see above).

Right to Appeal

You have the right to appeal any
final permit decision if you mate 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 Permit

Occidental Chemical Corporation - Injection Well

Mason County, Michigan	August 2017

U. S. Environmental Protection Agency tentatively approved a request
from Occidental Chemical Company (Occidental Chemical) to re-issue a
Class I nonhazardous injection well permit. Before EPA makes a final
decision, the Agency is providing the public an opportunity to comment on
the draft permit (see left-hand box on how to comment).

Occidental Chemical plans to continue disposal of nonhazardous liquid
waste from their operations into the Class I well in Ludington, Michigan.
The company submitted a reapplication for their Class I injection well.

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 ...

Location of Existing
Oxy (Dow) #25
Well

Ludington, Mason Co.

\ Virnetta Rd

Bryant Rd J

3

0.25

L

0.5
	I	

1 Mile
J

Map shows location of the injection well in the city of Ludington in Mason
County, Michigan.

'Injection wells must meet the regulatory criteria of 40 Code of Federal
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
Jeffrey Wawczak (wawczak.i effrev@epa. gov) during
the public comment period (see front-page box). The
dates of the public comment period are also published
in the Ludington Daily News newspaper for Mason
County. 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
the well concluded it would have no significant
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 Occidental Chemical's existing well,
the base of the lowermost USDW sits at a depth of 585
feet relative to Kelly bushing. This water-bearing
formation is the Glacial Drift.

Site geology: The injection zone is the Traverse Group
and Dundee Limestone from 1,359 to 2,041 feet
relative to Kelly bushing. The immediate overlying
confining zone includes the Antrim formation which is
composed 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 injection well. EPA analyzed the
AOR to identify wells that might allow fluid to move
out of the injection zone. In the AOR for the well, there
are 0 producing, 3 injection, 5 temporarily abandoned,
2 plugged and abandoned, and 1 salt solution mining
well that penetrate the confining zone. These wells
meet construction standards and will not allow fluid to
move out of the injection zone for the well.

Maximum injection pressure: EPA set an injection
pressure limit that will prevent the injection formations
from fracturing. The proposed maximum injection
pressure for the well is limited to 201 pounds per
square inch gauge.

Financial assurance: Occidental Chemical has
demonstrated adequate financial resources to close,
plug and abandon the underground injection well. A
Surety Bond for Well #25 has been established with the
Liberty Mutual Insurance Company.

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