v>EPA

United States
Environmental Protectior
Agency

How to Comment

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

MI-091 -11-0001 (Well# 1)
MI-091-11-0002 (Well #2)

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: Wawczakjeffrcy'c/,epa.gov
Phone: 312-353-7316

Comment Period

EPA will accept written comments
until Wednesday, Aug. 23
(midnight postmark).

Information Repository

You may see the draft permits at:
Adrian Public Library

143 E. Maumee St.

Adrian, Michigan
Or at http://go.usa.gov/3JwFP.

Administrative Record

You may see the full administrative
record, including all data submitted
by Great Lakes Chemical
Coloration at the EPA's Chicago
regional office (address 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
Draft Injection Well Permits

Great Lakes Chemical Corporation

Lenawee County, Michigan	July 2016

U. S. Environmental Protection Agency tentatively approved a request
from Great Lakes Chemical Corporation for re-issuance of two permits to
operate existing wells for nonhazardous liquid waste. Before EPA gives
final approval to the draft permits, the Agency will review public
comments (see left-hand box on how to comment) and maybe hold a
hearing if enough interest exists.

Currently, the facility that used these injection wells is closed. However,
permits are still required and continuous monitoring of the wells is
mandatory. The wells are located near East Michigan and Gulf Streets in
Adrian, Mich.

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 ...

'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.

Map shows location of the two existing injection wells and the area of
reveiw in central Lenawee County, Mich.

Legend

Area of
" " ¦ Review
2-Mile
Radius


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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 effev@epa. gov) during
the public comment period (see front-page box). The
dates of the public comment period are also published
in the The Daily Telegram newspaper of Adrian,
Michigan. 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
Agency officials determine there is significant public
interest in the draft permit decisions. If a hearing is
scheduled, EPA will publish a notice of the hearing at
least 30 days in advance.

EPA officials 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. Again, the
goal of the regulations and laws is to protect supplies of
underground drinking water from contamination caused
by injection wells.

EPA's preliminary review of the permit applications for
these two wells concluded they 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 Lenawee County, the location of the existing wells,
the base of the lowermost USDW sits at a depth of
924 feet. This water-bearing formation is the Traverse
Limestone.

Site geology: The injection zone for the proposed wells
is the Franconia, Dresbach, Eau Claire, and Mt. Simon
Formations from roughly 3,880 feet to 4,800 feet deep.
The injection zone for well #2 also includes the Pre-
Cambrian Basement Complex, which is slightly deeper.
This is considerably below the lowest point of the
underground drinking water source. The immediate
overlying confining zone of the waste liquid would be
the Trempealeau Formation, which is composed of
dolomite and shale. Adequate confining layers exist
between the Franconia formation 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 each injection well. EPA experts
analyzed the AOR to identify wells that might allow
fluid to move out of the injection zone. In the AOR for
the two existing wells, there are no producing wells, 2
injection, 0 temporarily abandoned, and 4 plugged and
abandoned wells that penetrate the confining zone.
These wells meet construction standards and will not
allow fluid to move out of the injection zone for the
proposed permits.

Maximum injection pressure: EPA staff set an
injection pressure limit that will prevent the injection
formation from fracturing. Since there will be no
injection, the proposed maximum injection pressure for
these wells is limited to 0 pounds per square inch gauge
for each well.

Financial assurance: Great Lakes Chemical
Corporation has demonstrated adequate financial
resources to close, plug and abandon these underground
injection wells. They have set up an irrevocable standby
letter of credit.

2


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