Land Ban Exemption Granted to BP Chemicals

ENVIRONMENTAL PROTECTION AGENCY

(FRL-4659-9)

Intent To Grant BP Chemicals, Inc., an Exemption From the Land Disposal Restrictions of the Hazardous and Solid Waste Amendments of 1984 (HSWA) Regarding Injection of Hazardous Waste

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice of Intent to Grant an Exemption for the use of Waste Disposal Well No. 4 to BP Chemicals, Inc. of Lima, Ohio, for the Injection of Certain Hazardous Wastes.

SUMMARY: The United States Environmental Protection Agency (USEPA or Agency) today is proposing to grant an exemption from the ban on disposal of hazardous wastes through its waste injection well (WDW) No. 4 to BP Chemicals, Inc. (BPCI) of Lima, Ohio. If the exemption is granted and if WDW No. 4 is permitted by the Ohio Environmental Protection Agency (Ohio EPA), BPCI may use WDW No. 4 to inject Resource Conservation and Recovery Act (RCRA) regulated hazardous wastes, codes K011, K013, K014, F039, and various D, U, and P listed materials listed in the following table:

Ignitability D001

Corrosivity D002

Cyanides D003

Arsenic D004

Barium D005

Cadmium D006

Total chromium D007

Lead D008

Mercury D009

Selenium D010

Silver D011

Acrolein P003

Allyl alcohol P005

Hydrogen cyanide P063

Potassium cyanide P098

Sodium cyanide P106

Acetaldehyde U001

Acetone U002

Acetonitrile U003

Acrylic acid U008

Acrylonitrile U009

Benzene U019

Chloroform U044

Crotonaldehyde U053

Cyclohexane U057

Methylene chloride U080

Ethyl acetate U112

Formaldehyde U122

Formic acid U123

Furan U124

Furfural U125

Lindane U129

Isobutyl alcohol U140

Maleic anhydride U147

Mercury U151

Methacrylonitrile U152

Methanol U154

Methyl ethyl ketone U159

Methyl isobutyl ketone U161

Nitrobenzene U169

Phenol U188

Pyridine U196

Carbon tetrachloride U211

Tetrohydrofuran U213

Toluene U220

Xylene U239

These wastes were banned from land disposal on various dates as set forth at 40 CFR 148.14 et seq. On May 7, 1992, the USEPA granted an exemption for the above named wastes for BPCI's WDW Nos. 1, 2, and 3 based on a finding that BPCI's injected wastes will not migrate out of the injection zone within the next 10,000 years. BPCI has now met all the requirements with respect to WDW No. 4, including a demonstration of mechanical integrity, to enable the USEPA to exempt WDW No. 4 from the restrictions on the land disposal of hazardous wastes.

DATES: The USEPA requests public comments on today's proposed decision. Comments will be accepted until July 6, 1993. Comments post-marked after the close of the comment period will be stamped "Late". A joint public hearing with the Ohio EPA to allow comment on draft permits proposed by Ohio EPA and this proposed action by USEPA will be scheduled and notice of this hearing will be given in a local paper and to all people on mailing lists developed by the USEPA and the Ohio EPA. The participation of the USEPA in the joint public hearing will be canceled if it does not appear to be warranted by public interest. If you wish to be notified of the date and location of the public hearing or to request that USEPA participate, please contact the person listed below.

ADDRESSES: Submit written comments, by mail, to: United States Environmental Protection Agency, Region 5, Underground Injection Control Section (WD-17J), 77 West Jackson Street, Chicago, Illinois 60604, Attn: Richard J. Zdanowicz, Chief.

FOR FURTHER INFORMATION CONTACT: Harlan Gerrish, Lead Petition Reviewer, UIC Section, Water Division, Office Telephone Number: (312) 886-2939, 17th floor, Metcalfe Building, 77 West Jackson Street, Chicago, Illinois 60404.

SUPPLEMENTARY INFORMATION:

I. Background

A. Authority

The Hazardous and Solid Waste Amendments of 1984 (HSWA), enacted on November 8, 1984, impose substantial new responsibilities on those who handle hazardous waste. The amendments prohibit the land disposal of untreated hazardous waste beyond specified dates, unless the Administrator determines that the prohibition is not required in order to protect human health and the environment for as long as the waste remains hazardous (RCRA Section 3004(d)(1), (e)(1), (f)(2), (g)(5)). The requirements for such a determination for injection wells are codified in 40 CFR part 148, Subpart B.

B. Previous Action

On March 1, 1992 USEPA published a notice at 57 FR 8753 proposing to grant an exemption to BPCI WDW Nos. 1, 2, and 3 from the ban on disposal of certain hazardous wastes. This proposal was based on USEPA's review of BPCI's no- migration demonstration which included an analysis of the effects of injection through BPCI's WDW No. 4 in addition to injection through WDW Nos. 1, 2, and 3. USEPA determined that wastes injected through these wells would not leave the injection zone for the next 10,000 years and that the granting of an exemption was proper. It granted the exemption for the BPCI wells on May 7, 1992 (published June 1, 1992 at 57 FR 23094). The USEPA has determined that an exemption for WDW No. 4 must be issued separately because construction of that well was incomplete at the time the original exemption was granted. The wastes for which this exemption is granted are those specified in the Summary portion of this notice.

C. Submission

On November 20, 1992, BPCI submitted a request that an exemption from the land disposal of hazardous wastes be granted for WDW No. 4 at the Lima facility. The request was accompanied by data demonstrating required mechanical integrity testing. BPCI submitted additional data demonstrating satisfactory results of the testing on December 16, 1992.

II. Basis for Determination

The aspects of the no-migration demonstration relevant to BPCI's waste injection operation, including WDW No. 4 among others, were described in the Federal Register notice proposing to grant an exemption to BPCI on March 12, 1992. However, BPCI still needed to submit the Mechanical Integrity Test (MIT) information for WDW No. 4 required by 40 CFR 148.20 (a)(2)(iv). MITs, including a Standard Annulus Pressure Test and a Radioactive Tracer Survey are required to assure that the waste does not leak from the tubing prior to reaching the injection zone nor upward along the well bore after injection. On October 26, 1992, BPCI conducted a pressure test of the annulus system of WDW No. 4 and a series of radioactive tracer surveys, all witnessed by Ohio EPA personnel.

The pressure test consisted of raising the pressure within the annulus system to 1,241 pounds per square inch (psi) which is almost 400 psi above the proposed pressure limit. The pressure in the system, measured using a recently calibrated 0-2,000 psi gauge with an accuracy of 0.25% of full scale, fluctuated by as much as 2 psi, but was 1,241 psig at the end of the 1-hour test period. The greatest fluctuation, therefore, represents only a fraction of the 3% per hour change which is allowable under Ohio and USEPA policies and the stability of the pressure readings indicate that no leak exists. The radioactive tracer surveys were conducted using logging equipment owned and operated by Atlas Wireline Services. The tests included tracking slugs of very short-lived radioactive material through the tubing and open well bore from a depth of 2,865 feet to 3,035 feet. Based on its review of the initial logs of the surveys and additional logs scaled for better resolution, USEPA has determined that the surveys showed that no radioactive material went upward above the casing shoe after its exit from the tubing. Therefore, results of the required tests confirm that the injected wastes are carried into the injection interval via the well and do not return along the well bore upward above the casing shoe.

III. Conditions of the Petition Approval

In addition to general conditions found at 40 CFR part 148, the USEPA imposes the following requirements as a condition of granting this exemption from the ban on injection of certain hazardous wastes for WDW No. 4:

(1) The permitted injection zone must be comprised of the Middle Run, Mt. Simon, and Eau Claire Formations;

(2) Injection shall occur only into the Middle Run and Mt. Simon Sandstones in WDW No. 4;

(3) This exemption is issued in conjunction with the exemption issued for the BPCI Lima, Ohio, site on May 7, 1992; the combined monthly injection volume for all four wells at the BPCI Lima, Ohio, site must not exceed 24 million gallons;

(4) The petitioner shall fully comply with all requirements set forth in the Underground Injection Control Permit-to-Operate for BPCI WDW No. 4 issued by the Ohio EPA; and

(5) The injection pressure at the well head shall be no greater than 844 psi, the pressure at which the no-migration demonstration was made.

Condition 4 of the exemption issued on May 7, 1992, required completion of a final report on seismic surveys carried out near the BPCI facility. The report was submitted on May 8, 1992. On February 8, 1993, USEPA notified BPCI that USEPA is satisfied with the interpretations of the seismic surveys performed in the vicinity of the BPCI facility. These surveys give no evidence of complex structural conditions which might allow movement of injectate from the injection zone. Condition 4 of the original exemption is therefore satisfied.

Dated: May 14, 1993.

Barry C. De Graff, Acting Director, Water Division Region 5, U.S. Environmental Protection Agency.

(FR Doc. 93-12643 Filed 5-26-93; 8:45 am)

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Land Ban Exemption Granted to BP Chemicals

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