vvEPA

United States
Environmental Protection
Agency

How to Comment

You may comment on the proposed
draft permit in writing. Please refer
to Cooper Standard Automotive
draft permit number MI-13 7-11-0001

Email your comments to:

Anna Miller

U.S. EPA, Water Division
UIC Section (WP-16J)

Email: miller.anna@epa.gov
Phone: (312) 886-7060

If you do not have access to email,
please contact Anna Miller for
instructions on how to comment.

Comment Period

EPA will accept written comments
until midnight May 31, 2022.

You may see the draft permit at
http: //go .usa. gov/3 JwFP.

Administrative Record

To request review of Administrative
Record files, contact Anna Miller

(see above).

Right to Appeal

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

Cooper Standard Automotive

Otsego County, Michigan	April 2022

The U. S. Environmental Protection Agency has tentatively approved the
reissuance of a Class I nonhazardous injection well permit for Cooper
Standard Automotive. 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).

Cooper Standard Automotive plans to continue to dispose of nonhazardous
liquid waste at its facility in Otsego County at 594 Alpine Hill Road,
Gaylord, Michigan. The injection fluid consists of contaminated
groundwater purged from the Glacial Drift aquifer at the facility and will
be injected into a confined interval approximately 2300 feet below ground
surface.

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 continues on back

Otsego
County

Existing Cooper Standard Automotive well
M1-137-11-0001

M
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GO

2 I

Ol

Aloine Rd

0.125

i

0.25

0.5 Miles

I i i i =l	

Map shows location of the injection well in Otsego 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 Hearing Requests

Send comments and requests for a hearing to EPA's
Anna Miller (miller.anna@epa.gov) during the public
comment period (see front-page box). 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
this well concluded it would have no environmental
impact.

Below is an explanation of the some of the factors
involved in permitting an injection well:

Underground Source of Drinking Water
(USDW): A USDW is defined as any aquifer or
portion thereof 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. In
the case of the Cooper Standard Automotive well, the
base of the lowermost USDW has been identified at a
depth of 825 feet below the ground surface. This water-
bearing formation is the Glacial Drift

Site Geology: The injection zone is the Dundee
Limestone and the Detroit River Group at depths
between 2300 feet and 2648 feet below the surface. The
immediate overlying confining zone is the Bell Shale.
Additional 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 proposed 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 proposed well, there are approximately 5 producing,
4 injection, 0 temporarily abandoned, 30 plugged and
abandoned, and 0 other wells that penetrate the
injection zone. EPA review determined that wells in the
AOR are adequately constructed to prevent injected
fluid migration from the injection zone to the USDW.

Maximum Injection Pressure: EPA set an injection
pressure limit that will prevent the injection formation
from fracturing. The proposed maximum injection
pressure for this well is limited to 700 pounds per
square inch.

Financial Assurance: Cooper Standard Automotive,
has demonstrated adequate financial resources to close,
plug and abandon this underground injection well.
Cooper Standard Automotive, has established surety
bond to cover these costs at the amount of $30,000.


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