EPA seeks comments on injection well permits

Public announcement posted by The Huron Hub | Oct. 25, 2021

The U. S. Environmental Protection Agency has tentatively approved the issuance of two Class I nonhazardous injection well permits for Republic Services of Michigan I, LLC. Before EPA makes a final decision, the Agency is providing the public an opportunity to comment on the draft permits.

Republic Services of Michigan I, LLC plans to dispose of nonhazardous liquid waste from its related landfill, located at 28800 Clark Road, Wayne County, Michigan. The injection fluid, which consists of waste fluid from the landfill, will be injected into a confined interval approximately 3,171 for MI-163-1I-0009 and 3,141 for MI-163-1I-0010 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.

1Injection wells must meet the regulatory criteria of 40 Code of Federal Regulations, or C.F.R., parts 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

Public Comments and Hearing Requests
Send comments and requests for a hearing to EPA’s Felicia Chase (chase.felicia@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 decisions 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 applications for these wells 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 Republic Services of Michigan I, LLC well, the base of the lowermost USDW has been identified at a depth of 400 feet below the ground surface.

This water-bearing formation is the Bois Blanc Formation.

Site Geology: The injection zone is comprised of the Mt. Simon Sandstone from 3,171 for MI-163-1I-0009 and 3,141 for MI-163-1I-0010 feet to 3,500 feet below the surface. The immediate overlying confining zone is the Black River Formation. 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 wells, there are approximately 0 producing, 0 injection, 1 temporarily abandoned, 5 plugged and abandoned, and 0 other wells that penetrate the injection zone.

Maximum Injection Pressure: EPA set an injection pressure limit that will prevent the injection formation from fracturing. The proposed maximum injection pressure for these wells are limited to 808 and 800 MI- 163-1I-0010 pounds per square inch.
Financial Assurance: Republic Services of Michigan I, LLC has demonstrated adequate financial resources to close, plug and abandon these underground injection wells. Republic Services of Michigan I, LLC has established a Surety Bond to cover the costs in the amount of $121,000.

How to Comment
You may comment on the proposed draft permits in writing. Please refer to Republic Services of Michigan I, LLC draft permit numbers MI-163- 1I-0009 and MI-163-1I-0010.
Email your comments to:
Felicia Chase
U.S. EPA, Water Division UIC Section
Email: chase.felicia@epa.gov Phone: (312) 886-0240
If you do not have access to email, please contact Felicia Chase for instructions on how to comment.
Comment Period
EPA will accept written comments until midnight November 10, 2021.
You may see the draft permits at http://go.usa.gov/3JwFP.
Administrative Record
To request review of Administrative Record files, contact Felicia Chase (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