e CDA x/u™„dS,»,eS o EPA Plans to Renew Exemption Environmental Protection ¦ for Hazardous Waste Wells Vickery Environmental Inc. Vickery, Ohio December 2014 Comment period and public hearing scheduled U.S. EPA is taking comments from the public on its plan to reissue an exemption from federal regulations for Vickery Environmental Inc. The public comment period ends Tuesday, January 20. U.S. EPA will hold an open house from 6 to 7 p.m., followed by a formal public hearing from 7 to 8:30 p.m., on Thursday, January 8: Townsend Township Volunteer Fire Department 5076 County Road 247 Vickery How to comment You can comment during the public hearing or send written comments to: Stephen Roy U.S. EPA (WU-16J) 77 W. Jackson Blvd. Chicago, IL 60604-3590 ro> .Stephen a epa.gox FAX: 312-692-2951 For more information To see the draft decision document, visit the Clyde Public Library Reference Desk, 222 W. Buckeye St. The full administrative record, including all data submitted by VEI, is at the EPA's regional office (address above). Contact Stephen Roy at 312-886-6556 for an appointment. To learn about 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. °tTa-o The U.S. Environmental Protection Agency plans to approve a request from Vickery Environmental Inc. 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. VEI has four injection wells at 3856 State Route 412, Vickery. VEI operates the wells under permits from the Ohio EPA. Those permits 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 makes decisions about these exemptions. EPA originally approved the exemption in 1990. If reissued the exemption will be valid until June 2027 based on the modeling done m 2007. 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 for an exemption, 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 underground source of drinking water. This is known as a no-migration demonstration. VEI made an acceptable no-migration demonstration in its request that U.S. EPA reissue the 1990 exemption. Technical information VEI uses hazardous waste wells, which U.S. EPA calls Class I wells, to inject into a geologic interval composed of the Mt. Simon Sandstone. The top and bottom of the injection interval are 2,791 and 2,950 feet below ------- ground level, respectively. The deepest supply of drinking water in the area is approximately 574 feet below ground level, so there is approximately 2,217 feet of separation between the drinking water source and the injected hazardous waste. A containment interval is just above the injection interval. The top and bottom of the containment interval are 2,344 and 2,791 feet below the ground surface, respectively. The containment 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 containment interval together are called the injection zone. A 544-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 five 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. VEI identified six wells within the area of review and showed these wells were properly plugged and abandoned. There are no known faults in the area of review that connect the injection interval with drinking water sources. The VEI wells are permitted by Ohio EPA. Under the permits, the 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 May and June of 2014. 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. VEI 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 VEI facility. 2. Injection of restricted hazardous waste is limited to the part of the Mt. Simon Sandstone at depths between 2,791 and 2,950 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 no less than 1.08 over a three-month period. 6. The cumulative volume of wastes injected into the wells must not exceed 10,368,000 gallons per month. 7. The exemption is approved for the 20-year modeled injection period, which ends on June 30, 2027. VEI 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 Jan. 31, 2027. 8. VEI must submit a quarterly report to U.S. EPA 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. 9. VEI must submit to U.S. EPA an annual report containing the results of a bottom hole pressure survey (fall-off test) performed on one well each year. The survey must be performed according to 40 CFR § 146.68(e)(1). The annual report must demonstrate that the properties of the injection interval have not changed significantly since the exemption was granted. 10. VEI must annually submit to U.S. EPA the results of radioactive tracer surveys and annulus pressure tests for the wells. (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. VEI shall notify U.S. EPA in writing if any well loses mechanical integrity and prior to any workover or plugging. 12. VEI must fully comply with all requirements set forth in underground injection control permits issued by Ohio EPA. 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. ------- |