UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604-3590 

 REPLY TO THE ATTENTION OF:

 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

 UNDERGROUND INJECTION CONTROL PERMIT: CLASS I HAZARDOUS

Permit Number: IN-127-1W-0003

Well Name: Waste Ammonia Liquor #1

Pursuant to the Underground Injection Control regulations of the U.S. Environmental 

Protection Agency codified at Title 40 of the Code of Federal Regulations (40 CFR), Parts 124, 

144, 146, 147, and 148, 

ArcelorMittal Burns Harbor, LLC of Burns Harbor, Indiana

the permittee, is hereby authorized to operate an existing Class I hazardous waste injection well 

located in Indiana, Porter County, T37N, R6W, Section 30, SE Quarter Section subject to the 

conditions of this permit. The injection zone, or zone which will contain the hazardous 

constituents, for this well is the Mt. Simon Sandstone and lower Eau Claire Formation between 

the depths of 2171 and 4287 feet below ground surface. Injection is permitted into the interval 

of the lower Mt. Simon Sandstone between the depths of 2715 and 4287 feet below ground 

surface upon the express condition that the permittee meet the restrictions set forth herein. The 

designated confining zone for this injection well is the upper Eau Claire Formation. 

 

All references to 40 CFR are to all regulations that are in effect on the date that this permit 

becomes effective. The following attachments are incorporated into this permit: A, B, C, D, E, 

F, G and H. 

This permit shall become effective on and shall remain in full force 

and effect during the life of the permit, unless: 1) the statutory provisions of Section 3004(f), (g) 

or (m) of the Resource Conservation and Recovery Act ban or otherwise condition the 

authorization in this permit; 2) the Agency promulgates rules pursuant to these sections which 

withdraw or otherwise condition the authorization in this permit; or 3) this permit is otherwise 

revoked, terminated, modified or reissued pursuant to 40 CFR 144.39, 144.40, or 144.41. This 

permit and the authorization to inject shall expire at midnight, , 

unless terminated. 

Signed and dated: ________________________________________ 

________________________________________ 

Tinka G. Hyde 

Director, Water Division 
TABLE OF CONTENTS 

PART I ................................................................................................................................................. 2

GENERAL PERMIT COMPLIANCE ............................................................................................. 2

A EFFECT OF PERMIT .............................................................................................................. 2 

B PERMIT ACTIONS.................................................................................................................. 2 

1. Modification, Revocation, Reissuance and Termination ..........................................2

2. Transfer of Permits ..................................................................................................3

C SEVERABILITY...................................................................................................................... 3 

D CONFIDENTIALITY............................................................................................................... 3 

E DUTIES AND REQUIREMENTS........................................................................................... 3 

1. Duty to Comply ........................................................................................................3

2. Penalties for Violations of Permit Conditions ...........................................................3

4. Need to Halt or Reduce Activity Not a Defense .......................................................4

5. Duty to Mitigate........................................................................................................4

6. Proper Operation and Maintenance.........................................................................4

7. Duty to Provide Information .....................................................................................5

8. Inspection and Entry ................................................................................................5

9. Records ...................................................................................................................5

10. Monitoring ................................................................................................................6

11. Signatory Requirements ..........................................................................................6

12. Reporting Requirements..........................................................................................6

F CLOSURE ................................................................................................................................ 8 

1. Closure Plan ............................................................................................................8

2. Revision of Closure Plan..........................................................................................8

3. Notice of Intent to Close...........................................................................................8

4. Temporary Disuse....................................................................................................8

5. Closure Report.........................................................................................................8

6. Standards for Well Closure ......................................................................................8

G POST-CLOSURE CARE.......................................................................................................... 9 

1. Post-Closure Plan -.................................................................................................9

2. Duration of Post-Closure Period ..............................................................................9

3. Post-Closure Corrective Action................................................................................9

4. Post-Closure Groundwater Monitoring.....................................................................9

5. Survey Plat ..............................................................................................................9

6. Notification to State and Local Authority ..................................................................9

7. Retention of Records ...............................................................................................9

8. Notice in Deed to Property.......................................................................................9

9. Financial Responsibility for Post-Closure Care......................................................10

H MECHANICAL INTEGRITY................................................................................................ 10 

1. Standards ..............................................................................................................10

2. Periodic Mechanical Integrity Testing ....................................................................10

3. Prior Notice and Reporting.....................................................................................11

4. Gauges ..................................................................................................................11

5. Loss of Mechanical Integrit ....................................................................................11

6. Mechanical Integrity Testing on Request From Director ........................................11

I FINANCIAL RESPONSIBILITY .......................................................................................... 12 

1. Financial Responsibility .........................................................................................12

2. Insolvency..............................................................................................................12

3. Notification .............................................................................................................13

4. Establishing Other Coverage .................................................................................13
J CORRECTIVE ACTION ....................................................................................................... 13 

1. Corrective Action under 40 CFR Section 146.64 ...................................................13

2. Prohibition of Movement of Fluids into USDWs .....................................................13

3. Corrective action under the Resource Conservation and Recovery Act ................13

K INJECTION OF RESTRICTED HAZARDOUS WASTES .................................................. 13 

1. Compliance............................................................................................................14

2. Injection Limitations ...............................................................................................14

3. Petition Update and Amendment ...........................................................................14

4. Petition Termination...............................................................................................14

5. Petition Review (Section 148.23)...........................................................................14

PART II.............................................................................................................................................. 15

WELL SPECIFIC CONDITIONS FOR UIC PERMITS ............................................................. 15

A. CONSTRUCTION.......................................................................................................15

1. Siting......................................................................................................................15

2. Casing and Cementing ..........................................................................................15

3. Tubing and Packer Specifications..........................................................................15

4. Wellhead Specification...........................................................................................15

B. OPERATIONS ............................................................................................................15

1. Injection Pressure Limitation..................................................................................15

2. Additional Injection Limitation ................................................................................16

3. Annulus Fluid and Pressure...................................................................................16

4. Annulus/Tubing Pressure Differential.....................................................................16

5. Warning and Shut-off System ................................................................................16

6. Precautions to Prevent Well Blowouts ...................................................................16

C. MONITORING .......................................................................................................................... 17 

1. Sampling Point.......................................................................................................17

2. Continuous Monitoring Devices .............................................................................17

3. Waste Analysis Plan ..............................................................................................17

4. Ground Water Monitoring.......................................................................................17

5. Ambient Monitoring................................................................................................17

D. REPORTING REQUIREMENTS ............................................................................................. 18 

1. Monthly Reports.....................................................................................................18

2. Quarterly Reports ..................................................................................................19

3. Annual Reports ......................................................................................................19

4. Reports on Well Tests............................................................................................19

PART III............................................................................................................................................ 20

ATTACHMENTS ............................................................................................................................. 20

A. Summary of Operating, Monitoring and Reporting Requirements 

B. Closure Plan 

C. Construction Details 

D. Waste Analysis Plan 

E. Groundwater Monitoring Requirements for the Galesville Sandstone Groundwater Monitoring 

Well 

F. Corrective Action Under the Resource Conservation and Recovery Act 

G. Waste Minimization and Practicability Certifications 
IN-127-1W-0003 

Page 2 of 20 

PART I 

GENERAL PERMIT COMPLIANCE 

A EFFECT OF PERMIT 

1. The permittee is allowed to engage in underground injection in accordance with the 

conditions of this permit. Notwithstanding any other provisions of this permit, the 

permittee authorized by this permit shall not construct, operate, maintain, convert, plug, 

abandon, or conduct any other injection activity in a manner that allows the movement of 

injection, annulus or formation fluids into underground sources of drinking water 

(USDW). The objective of this permit is to prevent the introduction of contaminants into 

a USDW if the presence of that contaminant may cause a violation of any primary 

drinking water regulation under 40 CFR Part 141 or may otherwise adversely affect the 

health of persons. Any underground injection activity not specifically authorized in this 

permit is prohibited. Compliance with this permit during its term constitutes compliance, 

for purposes of enforcement, with Part C of the Safe Drinking Water Act (SDWA). Such 

compliance does not constitute a defense to any action brought under Section 1431 of the 

SDWA, or any other common or statutory law other than Part C of the SDWA. Issuance 

of this permit does not convey property rights of any sort or any exclusive privilege; nor 

does it authorize any injury to persons or property, any invasion of other private rights, or 

any infringement of State or local law or regulations. Nothing in this permit shall be 

construed to relieve the permittee of any duties under applicable regulations. 

2. This permit does not relieve owners and operators of hazardous waste injection wells of 

their obligation to comply with any additional regulations or requirements under the 

Resource Conservation and Recovery Act (RCRA). This permit does not authorize any 

above ground generating, handling, storage, treatment or disposal facilities. Such 

activities must receive authorization under the regulations promulgated pursuant to 

Subtitle C of RCRA, if required. Requirements to follow RCRA corrective action under 

this permit are authorized under 40 CFR Sections 124.1 (General program purpose and 

scope) and 270.60 (RCRA permit-by-rule). 

B PERMIT ACTIONS 

1. Modification, Revocation, Reissuance and Termination - The Director of 

the Water Division of United States Environmental Protection Agency (USEPA), Region 

5 (the Director), may modify, revoke and reissue, or terminate this permit in accordance 

with 40 CFR Sections144.39, 144.40, and 144.41 upon request from any interested 

person (including the permittee) or upon the Director’s initiative. The permit is also 

subject to minor modifications for cause as specified in 40 CFR Section 144.41. The 

filing of a request for a permit modification, revocation and reissuance, or termination, or 

the notification of planned changes, or anticipated noncompliance on the part of the 

permittee does not stay the applicability or enforceability of any permit condition. 
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2. Transfer of Permits - This permit is not transferable to any person except in 

accordance with 40 CFR 144.38. 

C SEVERABILITY 

The provisions of this permit are severable, and if any provision of this permit or the 

application of any provision of this permit to any circumstance is held invalid, the 

application of such provision to other circumstances and the remainder of this permit shall 

not be affected. 

D CONFIDENTIALITY 

In accordance with 40 CFR Part 2, Public Information and Section 144.5, any information 

submitted to the USEPA pursuant to this permit may be claimed as confidential by the 

submitter. Any such claim must be asserted at the time of submission by stamping the words 

"confidential business information" on each page containing such information. If no claim is 

made at the time of submission, USEPA may make the information available to the public 

without further notice. If a claim is asserted, the validity of the claim will be assessed in 

accordance with the procedures in 40 CFR Part 2. Claims of confidentiality for the following 

information will be denied: 

1. The name and address of the permittee; and 

2. Information which deals with the existence, absence or level of contaminants in drinking 

water. 

E DUTIES AND REQUIREMENTS 

1. Duty to Comply - The permittee shall comply with all applicable Underground 

Injection Control (UIC) Program regulations and conditions of this permit, except to the 

extent and for the duration such noncompliance is authorized by an emergency permit 

issued in accordance with 40 CFR Section 144.34. Any permit noncompliance 

constitutes a violation of the SDWA and is grounds for enforcement action, permit 

termination, revocation and reissuance, modification, or for denial of a permit renewal 

application. Such noncompliance may also be grounds for enforcement action under 

RCRA. 

2. Penalties for Violations of Permit Conditions - Any person who violates a 

permit requirement is subject to civil penalties, fines and other enforcement action under 

the SDWA and may be subject to such actions pursuant to the RCRA. Any person who 

willfully violates permit conditions may be subject to criminal prosecution. 

3. Continuation of Expiring Permits 
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(a) Duty to Reapply - If the permittee wishes to continue an activity regulated by this 

permit after the expiration date of this permit, the permittee must submit a complete 

application for a new permit at least 180 calendar days before this permit expires. 

(b) Permit Extensions - The conditions of an expired permit may continue in force in 

accordance with 5 U.S.C. 558(c) and 40 CFR Section 144.37. 

(c) Effect - Permits continued under 5 U.S.C. 558(c) and 40 CFR Section 144.37 remain 

fully effective and enforceable. 

(d) Enforcement - When the permittee is not in compliance with the conditions of the 

expiring or expired permit, the Director may choose to do any or all of the following: 

(i) Initiate enforcement action based upon the permit which has been continued; 

(ii) Issue a notice of intent to deny the new permit. If the permit application is 

denied, the owner or operator would then be required to cease the activities 

authorized by the continued permit or be subject to enforcement action for 

operation without a permit; 

(iii) Issue a new permit under 40 CFR Part 124 with appropriate conditions; or 

(iv) Take other actions authorized by the UIC regulations. 

(e) State Continuation - A USEPA-issued permit does not continue in force beyond its 

expiration date under Federal law if at that time a State has primary enforcement 

responsibility under the SDWA. A State authorized to administer the UIC program 

may continue either USEPA- or State-issued permits until the effective date of the 

new permits, if State law allows. Otherwise, the facility or activity is operating 

without a permit from the time of expiration of the old permit to the effective date of 

the State-issued new permit. Furthermore, if the State does not continue the expired 

USEPA permit upon obtaining primary enforcement responsibility, the permittee 

must obtain a new State permit or be authorized to inject by State rule and failure to 

do so will result in unauthorized injection. 

4. Need to Halt or Reduce Activity Not a Defense – It shall not be a defense for 

the permittee in an enforcement action to claim that it would have been necessary to halt 

or reduce the permitted activity in order to maintain compliance with the conditions of 

this permit. 

5. Duty to Mitigate - The permittee shall take all timely and reasonable steps necessary 

to minimize or correct any adverse impact on the environment resulting from 

noncompliance with this permit. 

6. Proper Operation and Maintenance - The permittee shall at all times properly 

operate and maintain all facilities and systems of treatment and control and related 

appurtenances which are installed or used by the permittee to achieve compliance with 
IN-127-1W-0003 

Page 5 of 20 

the conditions of this permit. Proper operation and maintenance includes effective 

performance, adequate funding, adequate operator staffing and training, and adequate 

laboratory and process controls, including appropriate quality assurance procedures. 

This provision requires the operation of back-up or auxiliary facilities or similar systems 

only when necessary to achieve compliance with the conditions of this permit. 

7. Duty to Provide Information - The permittee shall furnish to the Director, within a 

time specified, any information which the Director may request to determine whether 

cause exists for modifying, revoking and reissuing, or terminating this permit, or to 

determine compliance with this permit. The permittee shall also furnish to the Director, 

upon request within a time specified, copies of records required to be kept by this permit. 

8. Inspection and Entry - The permittee shall allow the Director or an authorized 

representative, upon the presentation of credentials and other documents as may be 

required by law to: 

(a) Enter, at reasonable times, upon the permittee's premises where a regulated facility or 

activity is located or conducted, or where records are kept under the conditions of this 

permit; 

(b) Have access to and copy, at reasonable times, any records that are kept under the 

conditions of this permit; 

(c) Inspect, at reasonable times, any facilities, equipment (including monitoring and 

control equipment), practices, or operations regulated or required under this permit; 

and 

(d) Sample or monitor, at reasonable times, for the purposes of assuring permit 

compliance or as otherwise authorized by the SDWA, any substances or parameters at 

any facilities, equipment or operations regulated or required under this permit. 

9. Records 

(a) The permittee shall retain records of all monitoring information, including all 

calibration and maintenance records and all original chart recordings or electronic 

data for continuous monitoring instrumentation and copies of all reports required by 

this permit for a period of at least three (3) years from the date of the sample, 

measurement or report, unless these materials are submitted to the Director as part of 

reporting requirements under this permit. This period may be extended by the request 

of the Director at any time. For purposes of this section, an "original" chart recording 

shall be deemed to include an exact electronic version (such as one made through 

Adobe Acrobat) of a paper recording. 

(b) As required by 40 CFR 144.31(f), the permittee shall maintain records of all data 

required to complete the permit application form for this permit and any supplemental 

information submitted under 40 CFR Section 144.31 for a period of at least three (3) 
IN-127-1W-0003 

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years from the date the application was signed. This period may be extended by the 

request of the Director at any time. 

(c) The permittee shall retain records concerning the nature and composition of all 

injected fluids until three (3) years after the completion of plugging and 

abandonment. This retention period may be extended by request of the Director at 

any time. The permittee shall continue to retain records after the three-year retention 

period or any requested extension thereof expires unless the permittee delivers the 

records to the Director or obtains written approval from the Director to discard the 

records. 

(d) Records of monitoring information shall include: 

(i) The date, exact place, and time of sampling or measurements; 

(ii) The name(s) of the individual(s) who performed the sampling or measurements; 

(iii) The date(s) analyses were performed; 

(iv)The name(s) of individual(s) who performed the analyses; 

(v) The analytical techniques or methods used; and 

(vi)The results of such analyses. 

10. Monitoring - Samples and measurements taken for the purpose of monitoring shall be 

representative of the monitored activity. The permittee shall use the methods identified 

in the approved Waste Analysis Plan found in Part III(D) of this permit. Monitoring 

results shall be reported at the intervals contained in Part II(D)(1) through (4) and Parts 

III(A) and (E) of this permit. 

(a) Monitoring of the nature of injected fluids shall comply with applicable analytical 

methods cited and described in Table I of 40 CFR Section 136.3 or in Appendix III of 

Part 261 or in certain circumstances by other methods that have been approved by the 

Director. 

(b) Sampling and analysis shall comply with the specifications of the Waste Analysis 

Plan required in Part II(C)(3) of this permit. 

11. Signatory Requirements - All reports required by the permit and other information 

when so requested by the Director shall be signed and certified in accordance with 40 

CFR Section 144.32. 

12. Reporting Requirements - In accordance with 5 CFR Section 1320.5(b)(2)(i), the 

permittee is not required to comply with the reporting requirements of a collection of 

information unless a valid OMB Control Number is printed on the collection of 

information. A valid OMB Control Number appears on the cover page of this permit. 
IN-127-1W-0003 

Page 7 of 20 

(a) Planned Changes - The permittee shall give written notice to the Director, as soon as 

possible, of any planned physical alterations or additions to the permitted facility 

other than minor repair/replacement maintenance activities. 

(b) Anticipated Noncompliance - The permittee shall give advance notice to the Director 

of any planned changes in the permitted facility or activity which may result in 

noncompliance with permit requirements. 

(c) Compliance Schedules (Section 144.53) - The permittee shall submit reports of 

compliance or noncompliance with, or any progress reports on, interim and final 

requirements contained in any compliance schedule of this permit no later than 30 

calendar days following each schedule date. 

(d) Twenty-four Hour Reporting

(i) The permittee shall report to the Director any permit noncompliance which may 

endanger health or the environment. See, e.g. Part I(H)(5) of this permit. Any 

information shall be provided orally within twenty-four hours from the time the 

permittee becomes aware of the circumstances. Such reports shall include, but 

not be limited to the following information: 

1) Any monitoring or other information which indicates that any contaminant may 

cause an endangerment to an USDW; and 

2) Any noncompliance with a permit condition, or malfunction of the injection 

system, which may cause fluid migration into or between USDWs; and 

3) Any failure to maintain mechanical integrity. 

(ii) A written submission shall also be provided within five working days of the time 

the permittee becomes aware of the circumstances. The written submission shall 

contain a description of the noncompliance and its cause; the period of 

noncompliance, including exact dates and times, and, if the noncompliance has 

not been corrected, the anticipated time it is expected to continue; and steps taken 

or planned to reduce, eliminate and prevent recurrence of the noncompliance. 

(e) Other Noncompliance - The permittee shall report all other instances of 

noncompliance not otherwise reported under Part I(E)12)(c) and (d) of this permit at 

the time monitoring reports are submitted. The reports shall contain the information 

listed in Part I(E)(12)(d)(ii) of this permit. 

(f) Other Information - When the permittee becomes aware of failure to submit any 

relevant facts in the permit application or that incorrect information was submitted in 

a permit application or in any report to the Director, the permittee shall submit such 

facts or corrected information within ten calendar days, unless a longer time period is 

approved by the Director. 
IN-127-1W-0003 

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(g) Report on Permit Review - Within thirty calendar days of receipt of this permit, the 

permittee shall certify to the Director that he or she has read and is personally 

familiar with all terms and conditions of this permit. 

F CLOSURE 

1. Closure Plan - A plan for closure of the well that includes assurance of financial 

responsibility as required in Section 144.52(a)(7), and includes the information, relating 

to plugging and abandonment, required under Section 146.71(a)(4), is found in Part 

III(B) of this permit. The implementation of the Closure Plan is a condition of this 

permit; however, the permittee must receive the approval of the Director to proceed 

before implementing this plan. The obligation to implement the Closure Plan survives 

the termination of this permit or the cessation of injection activities. 

2. Revision of Closure Plan - The permittee shall submit any proposed significant 

revision to the method of closure reflected in the Closure Plan for approval by the 

Director no later than sixty calendar days before closure, unless a shorter time period is 

approved by the Director. 

3. Notice of Intent to Close - The permittee shall notify the Director at least sixty 

calendar days before closure of the well, unless a shorter notice period is approved by the 

Director. 

4. Temporary Disuse - A permittee who wishes to cease injection for longer than 24 

months may keep the well open only if he or she: 

(a) Has received authorization from the Director; and 

(b) Has described actions or procedures, satisfactory to the Director, that he or she will 

take to ensure that the well will not endanger USDWs during this period. These 

actions or procedures shall include compliance with the technical requirements 

applicable to active injection wells unless waived by the Director. 

5. Closure Report - The permittee shall submit a closure report to the Director which 

meets the requirements of Section 146.71(c), within the time frame specified in Section 

146.71(c). 

6. Standards for Well Closure - Prior to closing the well, the permittee shall: 

(a) Observe and record the pressure decay for a time specified by the Director and report 

this information to the Director; 

(b) Conduct mechanical integrity tests as requested by the Director to ensure integrity of 

that portion of the long string casing and cement that will be left in the ground after 

closure. Required testing methods may include any or all of those listed in Section 

146.71(d)(2); and 
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(c) Flush the well with a buffer fluid. 

G POST-CLOSURE CARE 

The permittee shall comply with the requirements for post-closure care and financial 

responsibility for post-closure care found at 40 CFR Sections 146.72 and 146.73. 

1. Post-Closure Plan - The permittee has submitted a plan for post-closure 

maintenance and monitoring, which is included in Part III(B) of this permit. This plan 

includes the information required by Section 146.72(a) and demonstrates how each of 

the applicable requirements of Section 146.72(b) will be met. The obligation to 

implement the post-closure plan survives the termination of this permit or the cessation 

of injection activities. 

2. Duration of Post-Closure Period - The Post-Closure Care Period shall continue at 

least until all of the requirements of the approved post-closure plan and of 40 CFR 

Section 146.72 have been met. Prior to the time that the post-closure care period is due 

to expire, the Director may extend the post-closure care period if he or she finds that the 

extended period is necessary to protect the health of persons or to protect a USDW. 

3. Post-Closure Corrective Action - The permittee shall continue and complete any 

cleanup action required under Section 146.64. 

4. Post-Closure Groundwater Monitoring - The permittee shall continue to 

conduct any groundwater monitoring required under this permit until pressure in the 

injection zone decays to the point that the well's cone of influence no longer intersects the 

base of the lowermost USDW, as identified in the Administrative Record for this permit. 

 The permittee has estimated the time for pressure in the injection zone to decay to this 

point, which is included in the Post-Closure Plan. The Director may extend the period of 

post-closure monitoring if he or she determines that it is necessary to protect the health of 

persons or to protect a USDW. 

5. Survey Plat - The permittee shall submit a survey plat to the local zoning authority 

designated by the Director as required by Section 146.72(b)(3) and submit a copy to the 

USEPA Region 5 Regional Administrator. 

6. Notification to State and Local Authority - The permittee shall provide 

notification and information to State and local authorities as required by Section 

146.72(b)(4). 

7. Retention of Records - The permittee shall retain the records specified by Section 

146.72(b)(5) for a period of three years following well closure and shall deliver those 

records to the Director at the end of the retention period. 

8. Notice in Deed to Property - In accordance with State law, the permittee must 

record a notation on the deed to the facility property or on some other instrument which 
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Page 10 of 20 

is normally examined during title search, that will in perpetuity provide any potential 

purchaser of the property with the information listed in Section 146.72(c). 

9. Financial Responsibility for Post-Closure Care - The permittee has 

submitted, and shall continue to submit, a demonstration of financial responsibility for 

post-closure care, as required in Section 146.73, at the time of the each annual update of 

the financial assurance mechanism after the effective date of this permit, for approval by 

the Director. The obligation to maintain financial responsibility for post-closure care 

survives the termination of this permit or the cessation of injection. 

H MECHANICAL INTEGRITY 

1. Standards - The injection well must have and maintain mechanical integrity consistent 

with 40 CFR Section 146.8(a)(1) and (2). To meet these requirements, mechanical 

integrity demonstrations must be witnessed by an authorized representative of the 

Director unless it proves impossible to resolve scheduling conflicts between the operator 

and the agency. In order to conduct testing without a USEPA representative, the 

following procedures must be followed. 

(a) The owner/operator must submit proposed procedures including the information that 

no USEPA representative is available, and receive permission from the Direct 

Implementation Section of the UIC Branch to proceed; 

(b) The test must be documented using either a mechanical or digital device which 

records the value of the parameter of interest, or by a service company job record; 

(c) A report of the testing including all data available at the conclusion of the test and a 

certification of accuracy which is signed by an authorized representative of the 

company must be submitted to the Direct Implementation Section within ten calendar 

days of the completion of testing; and 

(d) A final report including any additional interpretation necessary for evaluation of the 

testing must be submitted within thirty calendar days after the activity or with the 

next quarterly report, whichever comes later. 

2. Periodic Mechanical Integrity Testing - The permittee shall conduct the 

mechanical integrity testing as follows: 

(a) In accordance with 40 CFR Section 146.68(d)(1), the long string casing, injection 

tubing and annular seal shall be tested by means of an approved pressure test at least 

once every twelve months beginning with the date of the last approved demonstration 

and whenever there has been a well workover in which tubing is removed from the 

well, the packer is reset, or when loss of mechanical integrity becomes suspected 

during operation; 

(b) In accordance with 40 CFR 146.68(d)(2), the bottom-hole cement shall be tested by 

means of an approved radioactive tracer survey at least once every twelve months 
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beginning with the date of the last approved demonstration. The permittee must 

submit logging procedures to the Director for approval before running logs for the 

purpose of meeting this requirement; 

(c) In accordance with 40 CFR Section 146.68(d)(3), an approved temperature, noise, or 

other approved log, shall be run at least once every sixty months beginning with the 

date of the last such log. The Director may require such tests whenever the well is 

worked over. The permittee must submit logging procedures to the Director for 

approval before running logs for the purpose of meeting this requirement; 

(d) In accordance with 40 CFR Section 146.68(d)(4), an approved casing inspection log 

shall be run whenever the owner or operator conducts a workover in which the 

injection string is pulled, unless the Director waives this requirement because a 

casing inspection log has been run in the well within the past 60 months. The 

Director may require that a casing inspection log be run every five years if the 

Director has reason to believe that the integrity of the long string casing of the well 

may be adversely affected by naturally-occurring or man-made events. 

(e) The permittee may use any other test approved by the Director in accordance with the 

procedures in Section 146.8(d). 

3. Prior Notice and Reporting - The permittee shall notify the Director of his or her 

intent to demonstrate mechanical integrity at least thirty calendar days prior to such 

demonstration. At the discretion of the Director a shorter time period may be allowed. 

Reports of mechanical integrity demonstrations which include logs must include an 

interpretation of results by a knowledgeable log analyst. The permittee shall report the 

results of a mechanical integrity demonstration within the time period specified in Part 

II(D) of this permit. 

4. Gauges - The permittee shall calibrate all gauges used in mechanical integrity 

demonstrations to an accuracy of not less than one-half (0.5) percent of full scale, prior to 

each required test of mechanical integrity. A copy of the calibration certificate shall be 

submitted to the Director or his or her representative at the time of demonstration and 

every time the gauge is calibrated. The gauge shall be marked in no greater than five (5) 

psi increments. 

5. Loss of Mechanical Integrity – If the permittee or the Director finds that the well 

fails to demonstrate mechanical integrity as defined by 40 CFR Section 146.8(a)(1) or (2) 

during a test, or fails to maintain mechanical integrity during operation, the permittee 

shall halt the operation immediately and follow the reporting requirements as directed in 

Part I(E)(12) of this permit. The permittee shall not resume operation until mechanical 

integrity is demonstrated and the Director gives written approval to recommence 

injection. If a loss of mechanical integrity is suspected, the permittee shall halt the 

operation immediately and determine whether mechanical integrity has in fact been lost. 

6. Mechanical Integrity Testing on Request From Director - The permittee 

shall demonstrate mechanical integrity at any time upon written notice from the Director 
IN-127-1W-0003 

Page 12 of 20 

whenever the Director has reason to believe, pursuant to 40 CFR Section 146.8(f), that 

the well may have lost mechanical integrity, as authorized by 40 CFR Section 144.17. 

I FINANCIAL RESPONSIBILITY 

1. Financial Responsibility - The permittee shall maintain financial responsibility and 

resources to comply with the plugging and abandonment (closure) and post-closure care 

requirements of this permit, in a manner consistent with 40 CFR Sections 144.52(a)(7), 

144.60 through 144.70, and 146.73. The permittee must establish financial assurance by 

selecting a mechanism or a combination of more than one mechanism as specified in 

40 CFR Section 144.63, paragraphs (a) through (g). The plan used to calculate the 

amount of financial assurance necessary for closure costs is found in Part III(B) of this 

permit. The permittee shall update the plugging and abandonment costs annually to 

adjust for inflation, in accordance with 40 CFR Section 144.62(b). When the permittee 

updates these costs, the permittee shall also demonstrate that the requirement to maintain 

financial responsibility to comply with the plugging and abandonment (closure) and postclosure care as required by 40 CFR 144.52(a)(7) has been met (the value of the financial 

assurance mechanism(s) is greater than the adjusted costs). 

(a) Pursuant to 40 CFR Sections 144.62(a) and 146.73, the permittee must maintain a 

written cost estimate, in current dollars, for the Closure Plan and Post-Closure Plan as 

specified in 40 CFR Sections 146.10 and 146.72. The closure and post-closure cost 

estimate at any point in the life of the facility operation must equal the maximum cost 

of closure and post-closure at that time. 

(b) Pursuant to 40 CFR Sections 144.62(b) and 146.73, the permittee must adjust the cost 

estimate of closure and post-closure for inflation within thirty calendar days after 

each anniversary of the first estimate. The inflation factor is prescribed in Section 

144.62(b). 

(c) The permittee must revise the closure and post-closure cost estimate whenever a 

change in the Closure Plan or Post-Closure Plan increases the cost of closure. 

(d) If the revised closure and post-closure cost estimate exceeds the current amount of 

the financial assurance mechanism, the permittee shall submit a revised mechanism to 

cover the increased cost within ninety calendar days after the revision specified in 

Part I(I)(1)(b) and (c) of this permit. 

(e) The permittee must keep on file at the facility a copy of the latest closure and postclosure cost estimate prepared in accordance with 40 CFR Section 144.62, during the 

operating life of the facility. 

2. Insolvency - The permittee must notify the Director within ten business days of any of 

the following events: 

(a) The bankruptcy of the trustee or issuing institution of the financial mechanism; or 
IN-127-1W-0003 

Page 13 of 20 

(b) Suspension or revocation of the authority of the trustee institution to act as trustee; or 

(c) The institution issuing the financial mechanism losing its authority to issue such an 

instrument. 

3. Notification - The permittee must notify the Director by certified mail of the 

commencement of voluntary or involuntary proceedings under Title 11 (Bankruptcy), 

U.S. Code, naming the permittee as debtor, within ten business days after the 

commencement of the proceeding. A guarantor of a corporate guarantee must make such 

a notification if he or she is named as debtor, as required under the terms of the 

guarantee. 

4. Establishing Other Coverage - The permittee must establish other financial 

assurance or liability coverage acceptable to the Director, within sixty calendar days of 

the occurrence of the events in Part I(I)(2) or Part I(I)(3) of this permit. 

J CORRECTIVE ACTION 

1. Corrective Action under 40 CFR Section 146.64 - A plan for corrective 

action under 40 CFR 146.64 is not necessary at this time because no improperly plugged, 

completed, or abandoned wells are known to be present in the Area of Review (AOR). 

The permittee shall file a Corrective Action Plan for approval by the Director within sixty 

days of a written determination by the Director that improperly plugged, completed, or 

abandoned wells are present in the AOR. The AOR is specified in the administrative 

record for this permit. 

2. Prohibition of Movement of Fluids into USDWs (Section 144.12) - Should 

upward migration of fluids through the confining zone of this permitted well be 

discovered within the area of review for this well, which is recorded in the administrative 

record, and should this migration of fluids cause the introduction of any contaminant into 

a USDW pursuant to 40 CFR 144.12, the permittee shall immediately cease injection into 

this well until the situation has been corrected and reauthorization to inject has been 

given by the Director. 

3. Corrective action under the Resource Conservation and Recovery Act

- The permittee shall comply with corrective action requirements for all solid waste 

management units at this facility, as required by the Resource Conservation and 

Recovery Act permit-by-rule at 40 CFR Section 270.60. Specific corrective action 

requirements are found in Part III(F) of this permit. 

K INJECTION OF RESTRICTED HAZARDOUS WASTES 
IN-127-1W-0003 

Page 14 of 20 

1. Compliance - The permittee shall comply with all regulations set forth under 40 CFR 

Part 148. The permittee may continue to inject the restricted hazardous wastes specified 

in Part III(D) of this permit as long as all other requirements of this permit and applicable 

regulations are met and at least one of the following remains in effect: 

(a) an extension from the effective date of a prohibition has been granted pursuant to 

40 CFR Section 148.4 with respect to such waste; or 

(b) the exemption granted in response to a petition filed under Section 148.20 to allow 

injection of restricted wastes, with respect to those wastes and wells covered by the 

exemption, remains in effect, and all conditions of the exemption are met. 

2. Injection Limitations 

(a) Characteristics and concentrations of hazardous constituents of injected waste shall 

not exceed any limits listed in Part III(A) or Part III(D) of this permit. 

(b) The monthly average injection rate for the permitted well shall not exceed the 

limitation listed in Part III(A) of this permit. 

3. Petition Update and Amendment 

 The permittee may inject restricted wastes other than those listed in Part III(D) of this 

permit or wastes in concentrations in excess of those listed in Part III(D) of this permit 

only after he or she has (1) submitted a modified petition to the Director and received a 

final Agency approval of the modification(s), and (2) this permit has been modified 

accordingly. 

 The permittee shall notify the Director within 48 hours upon obtaining knowledge that 

information submitted in support of a petition in accordance with 40 CFR Section 148.20 

is false, inaccurate, or incomplete. 

4. Petition Termination

 Upon written notification from the Director that an exemption granted under 40 CFR 

Section 148.20 has been terminated, the permittee shall immediately cease injection of all 

prohibited hazardous wastes. 

5. Petition Review (Section 148.23) 

 When considering whether to reissue this permit upon expiration, the Director may require 

a new or updated petition demonstration if information shows that the basis for granting 

the exemption may no longer be valid. 
IN-127-1W-0003 

Page 15 of 20 

PART II 

WELL SPECIFIC CONDITIONS FOR UIC PERMITS 

A. CONSTRUCTION (Sections 146.62 and 146.65)

1. Siting - The injection well shall inject only into the formation and depths listed on the 

cover page of this permit. At no time shall injection occur into a formation which is, or 

is above, the lowermost formation containing an underground source of drinking water 

within one quarter mile of the well bore. 

2. Casing and Cementing - Notwithstanding any other provisions of this permit, the 

permittee shall case and cement the well in such a manner so as to prevent the 

movement of fluids into or between USDWs for the expected life of the well. The 

casing and cement used in the construction of this well are shown in Part III(C) of this 

permit. 

3. Tubing and Packer Specifications - The permittee shall inject only through 

tubing with a packer set within the long string casing at a point within or below the 

confining zone. The tubing and packer used in the well are represented in engineering 

drawings contained in Part III(C) of this permit. 

4. Wellhead Specification - The permittee shall maintain female couplings and 

valves on the wellhead, to be used for independent injection and annulus pressure 

readings. 

B. OPERATIONS (Section 146.67)

1. Injection Pressure Limitation - Except during stimulation, the permittee shall 

not cause or permit the injection pressure at the wellhead to exceed the maximum 

limitation which is specified in Part III(A) of this permit. In no case, shall injection 

pressure initiate fractures or propagate existing fractures in the confining zone or cause 

the movement of injection or formation fluids into a USDW. The determination of the 

fracture pressure may be performed in conjunction with the drilling of a new disposal 

well. Once a site-specific value for the fracture pressure of the lower Mt. Simon 

Sandstone injection zone has been determined, it will be used in the equation below to 

calculate a revised value for the maximum injection pressure. If, after twenty-four 

months from the effective date of this permit, the fracture pressure of the lower Mt. 

Simon Sandstone has not been determined to the Director’s satisfaction, then the 

maximum instantaneous injection pressure shall be limited to a default minimum 

established according to the following formula: 

[(FG - 0.433 psi./ft. x SG) x Depth - 14.7 psi] 
IN-127-1W-0003 

Page 16 of 20 

where FG is the lowest fracture gradient (0.72 psi/ft) measured in Indiana for the Mt. 

Simon Sandstone, SG is the value for the specific gravity is the highest measured 

specific gravity of the injectate in the past four years and Depth is the depth below 

ground level in feet to the top of the injection interval identified on page 1 of this 

permit. 

2. Additional Injection Limitation - No substances other than those identified in 

Part III(D) of this permit shall be injected.

3. Annulus Fluid and Pressure - The permittee shall fill the annulus between the 

tubing and the long string casing with a fluid approved by the Director and identified in 

the administrative record of this permit. Any change in the annulus fluid shall be 

submitted by the permittee for the approval of the Director before replacement. The 

permittee shall maintain a positive pressure on the annulus as specified in Part III(A) of 

this permit, except during workovers or times of annulus maintenance. 

4. Annulus/Tubing Pressure Differential - Except during workovers or times of 

annulus maintenance, the permittee shall maintain a pressure differential between the 

tubing and annulus as specified in Part III(A) of this permit over the entire length of the 

tubing. 

5. Warning and Shut-off System - The permittee shall continuously operate and 

maintain automatic alarm and automatic shut-off systems to stop injection within thirty 

minutes of either of the following situations: 

(a) Pressure changes in the annulus or annulus/tubing differential signifying possible 

deficiencies in mechanical integrity; or 

(b) Injection pressure, annulus pressure, or annulus/tubing pressure differential 

reaches the limits specified in Part III(A) of this permit. 

A person trained to handle emergency situations must be on site and investigate and 

identify as expeditiously as possible the cause of the alarm or shutoff. The permittee 

must test the warning system and shut-off system at least once every twelve months 

after the last such demonstration. These tests must involve subjecting the system to 

simulated failure conditions and must be witnessed by the Director or his or her 

representative during a regularly scheduled inspection unless it proves impossible to 

resolve scheduling conflicts between the operator and the agency. 

6. Precautions to Prevent Well Blowouts 

(a) The permittee shall maintain on the well at all times a pressure which will prevent the 

return of the injection fluid to the surface and shall take all necessary precautions to 

assure that pressure imbalances which might cause a backflow or blowout do not 

occur. A blowout preventer must be kept in proper operational status during 

workovers which involve tubing or packer removal. 
IN-127-1W-0003 

Page 17 of 20 

(b) In cases where the injected wastes have the potential to react with the injection 

formation to generate gases, the permittee shall follow the procedures below to assure 

that a backflow or blowout does not occur: 

(i) Limit the temperature, pH or acidity of the injected waste; and 

(ii) Develop procedures necessary to assure that pressure imbalances do not occur. 

C. MONITORING (Section 146.68)

1. Sampling Point - The injection fluid samples shall be taken at the sampling location 

as specified in the Waste Analysis Plan, which is included as Part III(D) of this permit. 

2. Continuous Monitoring Devices - The permittee shall install continuous 

monitoring devices and use them to monitor injection pressure, flow rate and the 

pressure on the annulus between the tubing and the long string casing. The monitoring 

results shall be submitted to the Director as specified in Part II(D) of this permit. 

“Continuous” shall mean a minimum sampling frequency of once every five seconds 

and a minimum recording frequency of once every five minutes of the average of all 

five-second readings during the previous recording interval. 

3. Waste Analysis Plan - The permittee shall comply with the Waste Analysis Plan 

which is included in this permit as Part III(D). 

4. Ground Water Monitoring - The permittee shall comply with the Ground Water 

Monitoring Plan which is found in Part III(E) of this permit. The permittee shall use 

fluid sampling methods, and sample and data analyses which provide reliable ground 

water monitoring results. 

5. Ambient Monitoring - Pursuant to 40 CFR Section 146.68(e), the permittee shall 

monitor the pressure buildup in the injection interval, including, at a minimum, a shut 

down of the well for a time sufficient to conduct a valid observation of the pressure 

fall-off curve at least every twelve months. The permittee shall use the results of each 

test to calculate, at a minimum, reservoir transmissivity, wellbore skin, and static 

reservoir pressure. For each test occasion, the permittee may elect to conduct this test 

in one of the permittee’s wells on a rotational basis. 
IN-127-1W-0003 

Page 18 of 20 

D. REPORTING REQUIREMENTS (Section 146.69)

The permittee shall submit all required reports to the Director at the following address, no 

later than the end of the month following the reporting period: 

United States Environmental Protection Agency 

77 West Jackson Boulevard (WU-16J) 

Chicago, Illinois 60604-3590 

ATTN: Direct Implementation Section 

In all reports, actual values for reporting parameters shall be provided. It shall not be 

acceptable to report “NA” or other non-data values where data is actually available. Tubing 

pressure and injection pressure shall be synonymous. 

1. Monthly Reports. The permittee shall submit monthly reports of the following 

information: 

(a) Results of the injection fluid analyses specified in the approved Waste Analysis 

Plan, as provided in Part III(D) of this permit. In reporting fluid analyses, the 

permittee shall identify the waste components of the waste stream as described in 

the approved Waste Analysis Plan. 

(b) A tabulation of (1) monthly average flow rate, (2) monthly average temperature, 

(3) monthly minimum pH, (4) monthly maximum pH, (5) monthly maximum 

specific gravity and (6) monthly volume. Average monthly values of flow rate 

shall be based on the total from all wells injecting waste ammonia liquor and 

calculated as follows: 

Total monthly flow of waste ammonia liquor through all WAL wells (gallons)

 1440 minutes/day * number of days in the month 

(c) A tabulation of (1) daily maximum injection pressure, (2) daily minimum annulus 

pressure, (3) daily minimum value of the difference between simultaneous 

measurements of annulus and injection pressure, (4) daily volume; (5) daily 

minimum temperature, (6) daily maximum temperature and (7) daily average 

temperature; 

(d) A graph or chart representation of the continuous monitoring as required in Part 

II(C)(2) of this permit or the daily average values of these parameters. The 

injection pressure, flow rate, and annulus pressure shall be submitted on a single 

graph, using contrasting symbols or colors, or in another manner approved by the 

Director; 

(e) Total volume of fluid injected, (i) in the reporting month, (ii) in the current 

calendar year, and (iii) to date since operation of the well began. For these three 

periods, the permittee shall specify separately: the volume of waste injected and 

the volume of make-up water, if known; 
IN-127-1W-0003 

Page 19 of 20 

(f) A tabulation of monthly volumes of annulus liquid loss and/or gain, including 

additions by the permittee, (1) in the reporting month, and (2) in each of the 

previous 12 reporting months; 

(g) Results of Galesville Formation pressure monitoring as specified in Part III(E)(5) 

of this permit; 

(h) Any noncompliance with conditions of this permit, including but not limited to any 

event that exceeds operating parameters for annulus pressure or injection pressure 

or annulus/tubing differential as specified in the permit; and 

(i) Any event which triggers an alarm or shutdown device required in Part II(B)(5) of 

this permit. 

2. Quarterly Reports - The permittee shall submit quarterly reports. The reports are 

due by the last day of the month following the end of the quarter and shall contain 

results of the following activities conducted during the quarter: 

(a) Results of Galesville Formation chemistry monitoring as specified in Part III(E) of 

this permit; 

(b) Results of any other test of the injection well required by the Director that are not 

included elsewhere. 

3. Annual Reports - The permittee shall report the following at least every twelve 

months: 

(a) Update of the plugging and abandonment (closure) cost estimate and post-closure 

cost estimate to adjust for inflation as required by Section I(I)(1)(b); 

(b) Update of the plugging and abandonment cost estimate of the Galesville 

Monitoring Well as required by Part III(E)(8). 

(c) When the permittee updates these costs, the permittee shall also demonstrate that 

the requirement to maintain financial responsibility to comply with the plugging 

and abandonment (closure) and post-closure care as required by 40 CFR 

144.52(a)(7) has been met (the value of the financial assurance mechanism(s) is 

greater than the adjusted costs) as required by Section I(I) 

4. Reports on Well Tests - Within thirty calendar days after the activity or with the 

next quarterly report, whichever comes later, the permittee shall report to the Director 

the results of demonstrations of mechanical integrity, any well workover, or results of 

any other tests required by this permit such as the pressure fall-off testing required by 

40 CFR Section 146.68(e) and Part II(C)(5) of this permit or required by the Director 

and the Galesville monitoring required by section III(E)(7) of this permit. 
IN-127-1W-0003 

Page 20 of 20 

PART III 

ATTACHMENTS 

These attachments include, but are not limited to, permit conditions and plans concerning 

operating procedures, monitoring and reporting, as required by 40 CFR Parts 144, 146 and 148. 

The permittee shall comply with these conditions and adhere to these plans as approved by the 

Director, as follows: 

A. SUMMARY OF OPERATING, MONITORING AND REPORTING REQUIREMENTS 

B. CLOSURE PLAN 

C. CONSTRUCTION DETAILS 

D. WASTE ANALYSIS PLAN 

E. GROUNDWATER MONITORING REQUIREMENTS FOR THE GALESVILLE 

SANDSTONE GROUNDWATER MONITORING WELL 

F. CORRECTIVE ACTION UNDER THE RESOURCE CONSERVATION AND 

RECOVERY ACT 

G. WASTE MINIMIZATION AND PRACTICABILITY CERTIFICATIONS 

H. SPENT PICKLE LIQUOR CORROSION MONITORING PLAN AND COMPLIANCE 

SCHEDULE 
IN-127-1W-0003 

ATTACHMENT A 

PARTIAL SUMMARY OF OPERATING, MONITORING AND 

REPORTING REQUIREMENTS

CHARACTERISTIC LIMITATION MINIMUM 

MONITORING 

FREQUENCY 

MINIMUM 

REPORTING 

FREQUENCY 

Maximum Injection 

Pressure1

977 psig for the first twentyfour months of this permit, 

thereafter 743 psig shall be 

the limit unless Part II(B)(1) 

of this permit has been 

satisfactorily completed 

Continuous Monthly 

Annulus Pressure 100 psig minimum Continuous Monthly 

Annulus/Tubing Pressure 

Differential 

100 psig over injection 

pressure minimum 

Continuous Monthly 

Injection Rate (on a 

monthly average)2

240 [300] gallons per minute 

(plant-wide, cumulatively 

covering all WAL injection 

wells) 

Continuous Monthly 

Cumulative Injected 

Volume 

 Continuous Monthly 

Annulus Fluid Loss or 

Gain 

 Monthly Monthly 

Chemical and Physical 

Characteristics of 

Injected Fluid3

 Monthly Monthly 

Benzene Concentration4 50 [220] mg/l, based on an 

annual average 

Monthly Monthly 

Naphthalene 

Concetration5 

260 mg/l, based on an annual 

average 

Monthly Monthly 

Phenol Concentration5 3,780 mg/l, based on an 

annual average 

Monthly Monthly 

Pyridine Concentration6 60 [116] mg/l, based on an 

annual average 

Monthly Monthly 

Selenium Concentration7 5.0 mg/l, based on an annual 

average 

Monthly Monthly 

1

 The initial value for the Maximum Injection Pressure limit is taken from the permit 

issued to Bethlehem Steel in 1986. The maximum injection pressure is dependent upon 
IN-127-1W-0003 

depth and specific gravity of the injected fluid. The revised value was calculated using 

the following formula: 

MIP = [{0.72 psi/ft - (0.433 psi/ft)(specific gravity)} x depth] - 14.7 psi. 

 The value for the fracture gradient is the lowest fracture gradient measured in Indiana 

for the Mt. Simon Sandstone (0.72 psi/ft), the value for the specific gravity is the 

highest measured specific gravity of the injectate in the past four years (1.020) and the 

value for depth is the top of the Lower Mt. Simon Sandstone injection interval 

identified on page 1 of this permit (2715 feet below ground surface). The MIP will be 

revised when a site-specific value for the fracture gradient is determined, as discussed 

in Part II(B)(1). 

2 The current rate limit is based on the modeling presented in the Petition for an 

Exemption to the Hazardous Waste Injection Restriction Program dated August 1988. 

The 2007 Petition for Renewal of Exemption from the Land Disposal Restrictions dated 

February 28, 2007, used a rate of 300 gpm. The rate limit will change to this value if 

the exemption is granted. The rate shall be calculated as discussed in Part II(D)(1). 

3

 As specified in the Waste Analysis Plan, which is Part III(D) of this permit 

4 The value of the limit on benzene concentration (50 mg/l) is the based on the Petition 

for an Exemption to the Hazardous Waste Injection Restriction Program dated August 

1988. The 2007 Petition for Renewal of Exemption from the Land Disposal 

Restrictions dated February 28, 2007, used a value of 220 mg/l. The concentration 

limit will change to this value if the exemption is granted. 

5

 The values of the limits on naphthalene and phenol concentrations are based on the 

2007 Petition for Renewal of Exemption from the Land Disposal Restrictions dated 

February 28, 2007. These concentration limits apply if the exemption is granted. 

6

 The value of the limit on pyridine concentration (60 mg/l) is based on the Land Ban 

Exemption Modification granted April 7, 1998 following the request from Bethlehem 

Steel Corp. dated April 3, 1998 and the supporting March, 1998 Request for 

Modification prepared by Texas World Operations, page 1. The 2007 Petition for 

Renewal of Exemption from the Land Disposal Restrictions dated February 28, 2007, 

used a value of 116 mg/l. The concentration limit will change to this value if the 

exemption is granted. 

7

 The value of the limit on selenium concentration (5 mg/l) is the based on the Petition 

for an Exemption to the Hazardous Waste Injection Restriction Program dated August 

1988. The 2007 Petition for Renewal of Exemption from the Land Disposal 

Restrictions dated February 28, 2007, used the same value. 
IN-127-1W-0003 

U.S. Environmental Protection Agency 

Underground Injection Control Permit 

Class I Hazardous 

Permit Number IN-127-1W-0003 

ArcelorMittal Burns Harbor, LLC 

Burns Harbor, Indiana 

Attachment B
IN-127-1W-0003 

PLUGGING AND ABANDONMENT/POST CLOSURE CARE PLANS 

40 CFR 144.52(a)(7) requires the permittee to demonstrate adequate financial responsibility 

and resources to close and abandon the underground injection operation in a manner 

prescribed by the Director. During the permit application review process, the permittee 

provided documentation of the financial assurance to plug and abandon this well and provide 

adequate post-closure care by means of its financial statement (40 CFR144.63(f)). The 

permittee may provide alternate financial assurance if approved by the Director as described in 

Part I(H)(1). The permittee has acknowledged that the obligation to maintain financial 

responsibility for post-closure care survives the termination of this permit and the cessation of 

injection.

The plugging and abandonment plan for the WAL-1 well is as follows. 

1. Obtain approval from the regulatory agency prior to commencing operations. 

Conduct the required mechanical integrity testing and ambient monitoring testing and 

submit the test data to the regulatory agency. 

2. Move in and rig up a workover rig. 

3. Flush the wellbore with water. The total flush volume will be a minimum of three 

wellbore volumes. 

4. Dismantle the wellhead and install blowout preventers. 

5. Remove the injection tubing and seal assembly. 

6. Set a cement retainer in the 5-1/2-inch casing at 2,650 feet and pressure test the 

retainer 

7. Squeeze Class A cement to fill injection zone and casing below the cement retainer. 

Cement volume to be pumped will be equal to the openhole and casing volume 

beneath the retainer plus 25% excess. 

8. Fill the remainder of the 5-1/2 casing from the top of the retainer with Class “A” cement. 

This top plug will be pumped in 500-1,000 feet stages and balanced in place. An 

appropriate length of the workstring will be pulled and laid down. The workstring 

will be reverse-circulated to confirm that it is still in cement from the previous stage 

and the process will be repeated until the cement is 3 feet below the surface. 

9. Rig down and move out the workover equipment. 

10. Wait on cement for at least eight hours. 

11. Cut off the casing 3 feet below ground level. Weld a steel plate on top of the casing. 
IN-127-1W-0003 

The steel plate should be inscribed with the following information: 

 ArcelorMittal Burns Harbor, LLC 

 Waste Ammonia Liquor Well No. 1 

 Permit No. IN-127-1W-0003 

 P& A ____. 

COST ESTIMATE FOR PLUGGING AND ABANDONMENT OF WAL-1

The estimated cost for plugging and abandoning WAL #1 well is $90,800. 

POST CLOSURE CARE PLAN 

The procedures for post closure care described herein are to be initiated upon permanent 

cessation of injection, and closure (plugging and abandonment) of ArcelorMittal Burns 

Harbor, LLC, WAL-1, at Burns Harbor in northern Indiana. This procedure is in 

accordance with the requirements of Title 40 of the Code of Federal Regulations (40 

CFR) Section 146.72 regarding post-closure. Any proposed significant revisions to this 

plan over the life of the well will be submitted not latter than the date of the closure report 

required under 40 CFR 146.71 (a) (7) (c). 

The following information is a required part of the post closure plan: 

1) Pressure in the injection zone before injection began: 

In order to develop a better estimate of initial conditions in the lower Mt. Simon 

Injection Interval, original measured lower Mt. Simon pressures from the Indiana 

Department of Transportation well near Valparaiso and the Midco Superfund well 

near Gary were evaluated. The original formation pressure measured in the Indiana 

Department of Transportation well (July 1999) was 1,433.6 pounds per square inch 

(psi) at a depth of 3,500 feet, and the original formation pressure measured in the 

Midco Superfund well (September 1993) was 1,024.46 psi at a depth of 2,462 feet. 

These pressures are equivalent to an initial gradient of approximately 0.41 psi/ft in the 

lower Mt. Simon Sandstone. Note that this gradient value is slightly lower than the 

0.42 psi/ft used in the original modeling. However, the 0.41 psi/ft gradient is based on 

more recent, high-quality bottomhole pressure data that was not available at the time 

of the original exemption. Using this revised formation pressure of 0.41 psi/ft and the 

model reference depth of 2,751 feet results in a calculated initial pressure of 1,127.9 

psi for the lower Mt. Simon Injection Interval. Subsequent static pressures at the 

Midco site have ranged from 0.41 psi/ft to 0.42 psi/ft, confirming the validity of the 

original measured value. Therefore, a value of 1,127.9 psi was assigned as the “zero” 

pressure at the reference model depth of 2,751 feet. 

2) Anticipated pressure in the injection zone at the time of closure: 

Modeling performed for the ArcelorMittal Burns Harbor, LLC land ban demonstration was 

based on average monthly injection rates for year 2006 through year-end 2027 of 300 gallons 
IN-127-1W-0003 

per minute (gpm) for the waste ammonia wells, 175 gpm for the spent pickle liquor well, and 

100 gpm for the United States Steel Waste Pickle Liquor No. 2 well. 

Incremental model pressure buildup at the Waste Ammonia Liquor Well No. 1 well is 771.4 

psi (reservoir pressure of 1,899.3 psi at 2,751 feet). Incremental model pressure buildup at the 

Waste Ammonia Liquor Well No. 2 well is 772.6 psi (reservoir pressure of 1,900.5 psi at 2,751 

feet). Incremental model pressure buildup at the Spent Pickle Liquor Well No. 1 well is 572.4 

psi (reservoir pressure of 1,700.3 psi at 2,751 feet). 

3) The predicted time until pressure in the injection zone decays to the point that the well's cone 

of influence no longer intersects the base of the lowermost underground source of drinking 

water: 

Pressure recovery is the ability of a formation to return to near-original formation pressure 

once injection has ceased. The DuPont Multilayer Pressure Model prediction of the postinjection pressure decay for all three wells is shown in figures in Attachment Q of the permit 

application, which is part of the Administrative Record for this permit. The graphs show the 

modeled pressure increase over the historical injection period (through year-end 2005), the 

modeled maximum injection period (2006 through 2027), and the pressure recovery over a 

modeled 30-year period, assuming that injection ceases at year end 2027. 

Pressure recovery begins immediately after injection ceases and continues to recover over the 

modeled 30-year period. The pressure in the lower Mt. Simon Injection Interval will 

equilibrate rapidly, and the driving force needed for vertical permeation of formation brines 

and waste from the lower Mt. Simon Sandstone into the overlying “B” Cap Shale layer at all 

locations will dissipate. There will be no Cone of Influence within 3 years of closure. 

Asymptotic pressure recovery to the initial formation pressure will continue over the 10,000-

year time frame. Since pressure recovery in the injection intervals is rapid, the injectioninduced driving force for waste movement also diminishes rapidly. 

4) Predicted position of the waste front at closure: 

The predicted position of the waste front at the time of well closure (the year 2027 in the 

ArcelorMittal Burns Harbor, LLC land ban demonstration) is approximately 5,500 

feet from the Waste Ammonia Liquor wells and 4,800 feet from the Spent Pickle Liquor 

No. 1. 

5) Status of any cleanups required under 40 CFR 146.64: 

The cited regulation concerns corrective actions for wells within the area-of-review. No 

corrective actions are currently underway or planned within the ArcelorMittal Burns 

Harbor area-of-review. 

6) Estimated costs of post closure care: 

The estimated costs of post closure care are $2,500. 
IN-127-1W-0003 

Upon closure of any of ArcelorMittal Burns Harbor, LLC injection wells, 

ArcelorMittal shall: 

1) Continue and complete any cleanup action required under 40 CFR 146.64, if 

applicable. 

2) Continue post closure maintenance and monitoring of any ground water monitoring wells 

required under the applicable permits until pressure in the injection zone decays to the 

point that the injection well's cone of influence no longer intersects the base of the 

lowermost underground source of drinking water (top of the Maquoketa Shale). 

[Note: Projected to be a period of 3 years after closure of all wells.] 

3) Submit a survey plat map to the local zoning authority designated by the Director, and 

to the Regional Administrator of the Region 5 EPA office. The survey plat map shall 

indicate the location of the closed well relative to permanently surveyed benchmarks. 

4) Provide appropriate notification and information to state and local authorities that 

have cognizance over drilling activities to enable them to impose such appropriate 

conditions on subsequent drilling activities that may penetrate the well's confining or 

injection zone. 

5) Retain, for a period of three years following well closure, records reflecting the 

nature, composition and volume of all injected fluids. The Director shall require 

ArcelorMittal Burns Harbor, LLC to deliver the records to the Director at the 

conclusion of the retention period, and the records shall thereafter be retained 

at a location designated by the Director for that purpose. 

6) Upon closure of the well in accordance with the approved closure plan, ArcelorMittal 

Burns Harbor, LLC shall record a notation on the deed to the facility property, or on 

some other instrument that is normally examined during title search, that will in 

perpetuity provide any potential purchaser of the property with the following 

information: 

a) The fact that the land has been used to manage and dispose hazardous waste(s) in 

deep wells, 

b) The name(s) of the state agencies and/or local authorities with which the survey 

plat map was filed, and the address of the regional EPA office to which it was 

submitted. 

c) The type and volume of waste injected, the injection interval or intervals into which it 

was injected, the name(s) of the generator(s) of the waste and the time period over 

which the injection occurred. 
IN-127-1W-0003 

ArcelorMittal Burns Harbor, LLC shall comply with the post closure financial 

assurance requirements of 40 CFR 146.73, and acknowledges that the obligation 

to maintain financial responsibility for post closure care survives the termination of the 

UIC Permit(s) or the cessation of injection. 



IN-127-1W-0003 

ATTACHMENT D 

SOURCE AND ANALYSIS OF WASTE AND WASTE ANALYSIS 

PLAN

The permittee is allowed to inject waste into this well limited to the following: 

1. Waste Ammonia Liquor, which may bear RCRA hazardous waste codes D010, 

D018, D038; 

2. Fresh water (during well tests and when the system is switched between waste 

streams), 

3. A buffer fluid (during well tests and during well abandonment only); 

4. Formation water from the Galesville Sandstone formation that is collected during 

sampling or workovers; 

5. Formation water from the Mt. Simon Sandstone formation that is captured during 

well stimulations or workovers; and 

6. Rain water that is collected in spill containment and directed to the tar decanters or 

that is collected in the sluice pits. 

The waste may be generated by any facility owned by ArcelorMittal Burns Harbor’s 

parent company, ArcelorMittal USA, Inc. 

The concentrations of key constituents of the waste stream shall be limited as shown in 

Attachment A. 

The text of the ArcelorMittal Burns Harbor Waste Analysis Plan is included below, 

though the attachments and appendices to the Plan are not. They are found in the 

Administrative Record for this permit. 

. 
IN-127-1W-0003 

ARCELORMITTAL BURNS HARBOR, LLC. 

WASTE ANALYSIS PLAN 

FOR 

UIC PERMIT NOS. IN-127-1W-0001, 0003, 0004 AND 0007 

EFFECTIVE: February 2009 
IN-127-1W-0003 

Table of Contents

Section 

 Page

 I. Scope and Applicability 

 1 

II. Responsible Charge and Plan Administration 1 

III. Description of Waste Streams 1 

 A. Waste Ammonia Liquor 

1 

 B. Spent Pickle Liquor 

 2 

IV. Description of Groundwater Monitoring Well 

V. Waste Characterization 

3 

 A. Waste Ammonia Liquor 

3 

 B. Spent Pickle Liquor 

 4 

VI. Groundwater Characterization 

A. Galesville Sandstone Groundwater Monitoring Well 4 

VII. Waste Analysis Plan Quality Assurance/Quality Control 5 

 A. Description of Sampling 

 5 

1. Sampling Methods for Waste Ammonia Liquor 5 

2. Sampling Methods for Spent Pickle Liquor 

5 

3. Sampling Methods for Galesville Sandstone Groundwater 

6 

4. Sampling Information 

6 

B. Description of Analytical Methods 

7 

1. Equipment Cleaning Blanks 

7 

2. Trip Blanks 

 7 

3. Duplicate Samples and Field Blanks 

7 

4. Sample Chain of Custody Protocol 

7 

5. Equipment Calibration 

8 
IN-127-1W-0003 

6. Data Reduction / Data Validation 

8 

7. Internal Quality Control 

9 

8. Laboratory Audits 

 10 

9. Corrective Action 

 10 

Tables

Table 1 - Historic Waste Analytical Results 

 

Table 2 - Analytical Methods 

Table 3 - Estimated Quantitation Limits (EQL’s) for Targeted Parameters in 

 Milligrams per Liter (mg/L) or as noted 

i 

Table of Contents Concluded

Attachments: Note: These attachments are in the Administrative 

Record for this Permit

Attachment 1 – Facility Map 

Attachment 2 – Waste Ammonia Liquor Appendix IX Analysis 

Attachment 3 – Spent Pickle Liquor Appendix IX Analysis 

Attachment 4 – Sample Label, Sample Seal and Chain of Custody Form 

Appendices

Appendix 1 – Laboratory Standard Operating Procedures

A. Metals Using Inductively Coupled Plasma Emission Spectroscopy 

B. Preparation of Aqueous Samples and Extracts for Total, Total Recoverable or 

Dissolved Metals Analysis by Inductively Coupled Plasma Spectroscopy

C. Volatile Organic Compounds and Volatile Petroleum Hydrocarbons Using EPA 

Method 624 and SW-846 Method 8260B

D. Semi-Volatile Organic Compounds (SVOA) by EPA Method 625 and SW-846 

Method 8270 C

E. Preparation of Aqueous Samples Using Manual Liquid-Liquid Extraction

F. Specific Gravity Using SM Method 2710 F and Density Using a Modified SM 

Method 2710 F

G. Electrometric Determination of pH 

H. Acidity Using SM Method 2310 B and EPA Method 305.1 

I. Ammonia-Nitrogen by Automated Phenate Colorimetry using EPA 

Method 350.1 and SM Method 4500-NH3 G 
IN-127-1W-0003 

J. Chloride (Silver Nitrate Titration) Using Standard Methods Method 4500-

Cl B and SW-846 Method 9253 

K. Cyanide, Total, Amenable, and Weak Acid Dissociable by Midi 

Distillation and Automated Colorimetry 

L. Phenolics, Total Recoverable Using Automated Colorimetry 

M. Sulfate by EPA Method 375.4 and SW-846 Method 9038 

N. Total and Recoverable Sulfide 

ii
IN-127-1W-0003 

SECTION I - SCOPE AND APPLICABILITY

 As required by Federal Regulation 40 CFR 146.13(b)(1) and 146.68(a), this waste 

analysis plan describes the wastes that are disposed via deepwell injection as well as the 

procedures that will be periodically followed to obtain a detailed chemical and physical analysis 

of the waste streams. 

SECTION II - RESPONSIBLE CHARGE AND PLAN ADMINISTRATION

 The Manager of the Environmental Management Department is in charge of this Waste 

Analysis Plan (WAP). His responsibilities, which may be carried out by qualified persons under 

his supervision, include the following: 

1. Periodic review of the WAP in order to ensure its continued applicability. 

2. Ensure that all required analyses are performed. 

3. Record keeping of analytical results and quality assurance. 

SECTION III - DESCRIPTION OF WASTE STREAMS

 ArcelorMittal Burns Harbor currently operates three Class I deepwells for the disposal of 

two hazardous waste streams. Two of the wells (Permit Nos. IN-127-1W-0003 and IN-127-1W0004) dispose of Waste Ammonia Liquor (WAL), which is characteristically hazardous (toxicity 

characteristic) for the constituents selenium, benzene and pyridine. One of the wells (Permit No. 

IN-127-1W-0001) disposes of Spent Pickle Liquor, which is a listed hazardous waste (K062). A 

new well (Permit No. IN-127-1W-0007) will be designed to also dispose of WAL. The following 

provides a description of how each waste stream is generated, stored and transported prior to 

disposal. 

A. Waste Ammonia Liquor (WAL) 

WAL is generated at the Coke Oven Coal Chemical plant, which is located in the 

southwest corner of the Burns Harbor (See Attachment 1 - Facility Map). WAL from 

coking operations (a coal carbonization process) is a wastewater that is generated from 

the ". . . extraction, beneficiation and processing of ores and minerals (including coal)" 

[40 CFR 261.4(b) (7)]. WAL primarily consists of water (roughly 99%) that contains 

high concentrations of organic contaminants. The primary contaminant, as the waste 

name implies, is ammonia (2003 average concentration of 4,138 milligrams per liter). 

The WAL also contains phenols (2003 average concentration of 1128 mg/L), cyanide 

(2003 average concentration of 53 mg/L), and several other organic contaminants, such 

as aniline, benzene and naphthalene, at lesser concentrations. 

Coal is the principal input into the coking operation and coke, coal tar and coke 

oven gas are the principal outputs. Ammonia liquor is recirculated in a closed-loop 

recycle system to cool and cleanse the coke oven gas produced by the coking process. 

The water, tars and solids are scrubbed from the gas flow to one of three decanters where 

phase separation is allowed to occur. The water phase (ammonia liquor) floats on top of 

the coal tar and overflows a fixed weir that discharges to a holding tank. The majority of 

ammonia liquor is recirculated from the holding tank to the coke oven gas main as 

flushing liquor for further gas cooling and cleansing. Excess water is introduced into the 

closed-loop system primarily as a result of the liberation of moisture, which is contained 

within the coal, during the coking process. In order to maintain proper liquid 
IN-127-1W-0003 

equilibrium within the closed-loop system, the excess or waste ammonia liquor (WAL) is 

discharged to the WAL system for processing and disposal. 

The WAL is initially processed through the WAL Clarifier for tar and sediment 

removal through gravimetric settling. The overflow from the clarifier is discharged to 

spiral cooler heat exchangers in order to lower the temperature of the WAL. After 

cooling, the WAL is pumped to one of three pressure filters for initial filtration. 

Following this initial filtration, the WAL is directed to one of four polishing filters for the 

removal of fine particulates. After final filtering, the WAL is directed to one of the two 

injection wells for final disposal. 

B. Spent Pickle Liquor (SPL) 

 SPL is generated as a by-product of the steel sheet pickling operation, 

which is located in about the center of Burns Harbor (see Attachment 1 - Facility Map). 

The continuous pickling operation uses a hydrochloric acid solution in a cascading (e.g., 

counter-current flow) system to remove scale and rust from the steel strip in preparation 

for further processing in the cold mill. The SPL is primarily water (about 87%), 

hydrochloric acid (2003 average free acid concentration of 0. 4 percent), and iron (2003 

average concentration of 12 percent) as ferrous chloride. The SPL will also contain minor 

concentrations (i.e., <100 mg/L) of other metals (e.g., chromium, nickel) that are 

typically present in the steel processed. 

The hydrochloric acid solution is maintained at a concentration of approximately 6 

percent in tank number 3 and is heated using steam. The acid flows toward tank number 1 

as it loses strength. The acid in tank number 1 typically contains less than 1.0 percent of 

free acid and overflows to a 35,000-gallon storage tank, at which point it is considered to 

be SPL. The SPL from this tank can be transferred to Burns Harbor’s Secondary 

Wastewater Treatment Plant or to a railroad tank car/truck loading facility for use as a 

substitute for a commercial chemical product. SPL that cannot be used in this manner is 

transferred to the SPL well system for processing and disposal by deepwell injection. If 

the SPL is to be deep well injected, the SPL from the storage tank is pumped using the 

filter feed pumps to a pressure filtration system for solids removal. The SPL then flows 

through a heat exchanger for temperature adjustment prior to flowing to the deep well for 

disposal. 

SECTION IV – Description of Groundwater Monitoring Well

 On August 1, 1990, the United States Environmental Protection Agency granted Burns 

Harbor a Final exemption for Continued Injection of Hazardous Waste Subject to the Land 

Disposal Restrictions of the Hazardous and Solid Waste Amendments of 1984. This exemption, 

which was subsequently modified on March 17 and April 7, 1998, required Burns Harbor to 

install a groundwater monitoring well in the Galesville Sandstone Formation, which is the lower 

most formation located immediately above the confinement formation for deepwell injection 

activities. 

 The operational plan for this well requires continuous pressure monitoring to confirm that 

the pressurization of the subsurface formations is consistent with the no-migration model 

simulation submitted in support of the exemption as well as to provide early detection of 

anomalous activity within the injection zone. In addition, the well is periodically sampled and the 

groundwater is analyzed in order to confirm that waste is not migrating out of the injection zone. 
IN-127-1W-0003 

SECTION V - WASTE CHARACTERIZATION

A. Waste Ammonia Liquor (WAL) 

Attachment 2 contains a copy of an Appendix IX analysis performed on WAL in 

October 1993 and August 2004. Based on this analysis as well as other hazardous waste 

analyses performed, WAL periodically exceeds the Toxicity Characteristic Leaching 

Procedure (TCLP) maximum concentration specified in 40 CFR 261.24, Table 1 for 

Selenium, Benzene and Pyridine. In addition, the WAL injected contains less than one 

percent suspended solids. Therefore, under the TCLP procedure, the WAL is analyzed 

on a total constituent basis. Based on this information and EPA’s Regional Guidance #8 

for “Preparing a Waste Analysis Plan at Class I Injection Well Facilities” (January 21, 

1994), the following parameters will be analyzed under this WAP at the frequency 

indicated. 

 Parameter Frequency of Analysis

 Selenium, Total Monthly 

 Benzene, Total Monthly 

 Pyridine, Total Monthly 

 Toluene Monthly* 

 Phenols (4AAP) Monthly 

 Nitrogen-Ammonia Monthly 

 Specific Gravity Monthly 

 Total Cyanide Monthly 

 Naphthalene Monthly 

 pH Continuous** 

 Temperature Continuous** 

 Sulfide Monthly 

 * This constituent has been added to the list because it was 

present in the waste analysis provided in Attachment 2 at a 

concentration greater than 0.01%. After one year of sampling for this 

constituent, Burns Harbor may petition to remove this constituent from 

the monthly monitoring list if it is not consistently present above this 

0.01% threshold. 

**Temperature and pH are monitored continuously, except during periods of 

instrument maintenance and calibration, and recorded on strip chart recorders at the 

Waste Ammonia Liquor Pump Station. Grab samples are obtained five days per week 

(i.e., Monday through Friday) to verify calibration of the instruments. 

B. Spent Pickle Liquor (SPL)

Attachment 3 contains a copy of an Appendix IX analysis that was performed 

on SPL during October, 1993 and August, 2004. When SPL is disposed as a waste, it is a 

listed hazardous waste with an EPA hazardous waste number K062. Based on the waste 

code inventory found at 40 CFR 268.43 and EPA’s Regional Guidance #8 for “Preparing 

a Waste Analysis Plan at Class I Injection Well Facilities” (January 21, 1994), the 

following parameters will be analyzed under this WAP at the frequency indicated. 

 

 Parameter Frequency of Analysis

 Chromium, Total Monthly 

 Iron, Total Monthly 
IN-127-1W-0003 

 Free Acid Monthly 

 Specific Gravity Monthly 

 Nickel, Total Monthly 

 pH Monthly 

 Temperature Continuous* 

*Temperature is monitored continuously, except during periods of instrument 

maintenance and calibration, and recorded on strip chart recorders at the Spent Pickle 

Liquor Pump Station. 

SECTION VI – GROUNDWATER CHARACTERIZATION

 

As of February 2008, Burns Harbor has sampled the Galesville 

formation 57 times. The following lists the constituents that will continue to 

be sampled under this WAP. A brief rationale why the constituent will be 

sampled is also provided. 

Parameter Frequency of Analysis Rationale

Acidity Quarterly Historical*, Waste Character** 

Ammonia as N Quarterly Historical, Waste Character 

Chloride Quarterly Historical, Waste Character, 

Guidance*** 

Cyanide Quarterly Historical, Waste Character 

Phenols (4AAP) Quarterly Historical, Waste Character 

Sulfate Quarterly Historical, Guidance 

Iron, Total Quarterly Historical, Waste Character 

Sodium Quarterly Historical, Guidance 

Calcium Quarterly Historical, Guidance 

* Historical constituents are those constituents that have been analyzed for during each of the 57 

previous sample events. 

**Waste Character constituents are those constituents in the waste streams that are either known 

to be present or routinely analyzed under this WAP. 

***Guidance constituents are those constituents in groundwater that EPA’s regional guidance 

specifies be analyzed. 

SECTION VII - WASTE ANALYSIS PLAN QUALITY ASSURANCE/QUALITY 

CONTROL

A. Description of Sampling 

1. Sampling Methods for Waste Ammonia Liquor (WAL)

Samples of WAL will be obtained at the frequency specified in Section 

V 

of this WAP. Samples will be obtained from the sample tap located at the Waste 

Ammonia Liquor Pump Station. This line taps off of the main injection line after 

all filter devices and immediately prior to the valve that directs the WAL to one 

of the two well heads for injection. 
IN-127-1W-0003 

The samples will be collected into clean, pre-preserved, labeled sample 

bottles supplied by the analytical laboratory. In order to obtain the samples, the 

sample collector will open the sample tap and allow WAL to flow from the tap 

for at least 30 seconds. He will fill each of the supplied sample bottles with 

WAL without immersing the sample tap line into the sample. When each bottle 

is full, the sample collector will seal that bottle, place it into the sample cooler, 

and begin to fill the next bottle. This will continue until all of the sample bottles 

have been filled. Upon completion of the sampling event, the sample collector 

will record the sample date, time, and his initials on each sample bottle's label, 

complete a sample bottle seal and place it on each sample bottle and complete the 

chain of custody form (See Attachment 4 for examples of the sample label, 

sample seal and chain of custody form). The sample collector will then place ice 

and the completed chain of custody form (sealed in a plastic bag) into the cooler, 

and transport the cooler to the designated pick-up location for the analytical 

laboratory. 

 2. Sampling Methods for Spent Pickle Liquor (SPL)

Samples of SPL will be obtained at the frequency specified in Section V 

of this WAP. Samples will be obtained from the drain valve of the 35,000-gallon 

spent pickle liquor storage tank located west of the spent pickle liquor deepwell 

control room. SPL contains a very small amount of suspended solids and is 

injected intermittently because Burns Harbor continues to pursue recycling 

options. Therefore, this sample location allows for the collection of SPL samples 

that are representative of the material that may be injected. In addition, this 

sample location provides a reliable and readily available sampling point for SPL. 

The samples will be collected from the drainpipe using a dedicated longhandled polyethylene dipper. The sample collector will open the drain valve and 

allow SPL to flow from the drain line for at least 30 seconds. He will then rinse 

the dipper at least three times with the SPL flowing from the drain lines. After 

rinsing, he will collect the sample and transfer it from the dipper into clean, prepreserved, labeled sample bottles supplied by the analytical laboratory. When 

each sample bottle is full, the sample collector will seal that bottle, place it into 

the sample cooler and begin to fill the next bottle. This will continue until all 

sample bottles have been filled. Upon completion of sampling events, the sample 

collector will record the sample date, time, and his initials on each sample bottle's 

label; complete a sample bottle seal and place on each sample bottle and 

complete the chain of custody form (see Attachment 4 for examples of the 

sample label, sample seal and chain of 

custody form). The sample collector will then place ice and the completed chain 

of custody form (sealed in a plastic bag) into the cooler, and transport the cooler 

to a designated pickup location for the analytical laboratory. 

 3. Sampling Methods for Galesville Sandstone Groundwater

Samples of the groundwater in the Galesville Sandstone 

Formation will be obtained at the frequency specified in Section VI of 

this WAP. Samples will be obtained from the well using the dedicated 

pump system. 

In accordance with the “Drilling, Testing and Operational Plan” for the 

Galesville Sandstone Groundwater Monitoring Well (February, 1991), the sampler will 
IN-127-1W-0003 

arrive at the well site and determine the static water level within the well. Upon obtaining 

the static water level, the sampler will turn on the dedicated pump. The sampler will 

continue pumping, with periodic monitoring for flow rate, pH, temperature, 

reduction/oxidation potential and conductivity, until a minimum of three well volumes 

have been evacuated from the well. Once three well volumes have been evacuated and at 

least three of the four monitored parameters (pH, temperature, reduction/oxidation 

potential and conductivity) have stabilized, he will begin to collect the samples by 

directing the pump discharge into clean, pre-preserved, labeled sample bottles supplied 

by the analytical laboratory. When each sample bottle is full, the sample collector will 

seal that bottle, place it into the sample cooler and begin to fill the next bottle. This will 

continue until all sample bottles have been filled. Upon completion of sampling, the 

sample collector will record the sample date, time, and his initials on each sample bottle's 

label; complete a sample bottle seal and place on each sample bottle and complete the 

chain of custody form (see Attachment 4 for examples of the sample label, sample seal 

and chain of custody form). The sample collector will then place ice and the completed 

chain of custody form (sealed in a plastic bag) into the cooler, and transport the cooler to 

a designated pickup location for the analytical laboratory. 

Results of analyses performed in accordance with this plan will be kept on file by 

the Environmental Management Department for a minimum of five (5) years. 

4. Sampling Information Summary

i. Sample Collector – ArcelorMittal Burns Harbor 

Representative or contract 

 employee. 

ii. Sample Collection Method - Refer to Sections VII.A.1, 2 & 3 

iii. Sample Collection Point - Refer to Sections VII.A.1, 2 & 3 

iv. Sample Preservation - Parameter specific. To be provided by the analytical 

 laboratory, as needed. 

v. Sample Frequency - Refer to Sections V & VI. 

vi. Analytical Method for Parameter Detection/Quantification - Refer to Table 2 

vii. Anticipated Analytical Method Accuracy - Refer to Table 1 

viii. Anticipated Analytical Method Quantification Limit - Refer to Table 3 

ix. Field Documentation of Sampling - Refer to Section VII.B.4. 

B. Description of Analytical Methods

1. Equipment Cleaning Blanks 

The WAL samples will be collected directly from a sample tap into clean, 

pre-preserved and labeled sample bottles supplied by the analytical laboratory. 

The SPL will be collected from a drainpipe using a dedicated long handled 

polyethylene dipper. The Galesville groundwater will be collected from the 

pump discharge that is dedicated to this well. Therefore, cross-contamination is 

eliminated and decontamination of the sampling equipment is not necessary. 

2. Trip Blanks

Each time a group of sample bottles is prepared for volatile organics 

analysis (e.g., benzene and toluene analysis) during a sampling event at the WAL 

or Galesville well, a 40- millilter Volatile Organics Analysis (VOA) trip blank 

bottle will be included in each shipping container that contains VOA sample 

bottles. The VOA trip blank bottles are filled with deionized analyte free water 

by the laboratory. The trip blanks will be transported to the sampling location 
IN-127-1W-0003 

and returned (unopened) to the laboratory in a manner identical to the handling 

procedure used for the environmental samples. These trip blanks will be 

analyzed for the same VOA parameters identified in Sections V and VI. If 

contaminants are found in the blanks, the source of the contamination will be 

identified and corrective action will be initiated. 

3. Duplicate Samples and Field Blanks

•Duplicate Analysis: Duplicate samples will be obtained during each 

quarterly sampling event of the Galesville groundwater monitoring well. 

One duplicate sample of either the WAL or SPL during each monthly 

sampling event will be collected. The duplicate samples will be analyzed 

for the same source-specific parameters identified in Sections V and VI. 

•Field Blanks: Field blanks will be obtained during each quarterly 

sampling event of the Galesville groundwater monitoring well. These 

blanks will be analyzed for the same constituents as the groundwater 

samples. Field blanks will not be obtained during the routine sampling 

of the waste streams due to the potential for contamination. 

4. Sample Chain of Custody Protocol 

Samples will be collected following the above sampling procedures. The 

sampling times and dates, sample description, volume and number of containers 

will be noted. Sample identification will be assigned prior to sample collection. 

Samples will be accompanied by a properly completed chain of custody 

form. The sample identification and locations will be listed on the chain of 

custody form. When transferring the possession of samples, the individuals 

relinquishing and receiving will sign, date and note the time on the record. 

Samples will be properly packaged for shipment and dispatched to the 

appropriate laboratory for analysis, with a signed chain of custody record 

enclosed in each sample box or cooler. 

5. Equipment Calibration 

Calibration of laboratory equipment will be based on written procedures. 

Records of calibration, repairs, or replacement will be filed and maintained by 

laboratory personnel performing quality control activities. These records will be 

filed at the location where the work is performed. For all instruments, the 

laboratory will maintain a factory trained repair staff with in-house spare parts or 

will maintain service contracts with vendors. 

 Calibration of the field instruments at the Galesville sample station will 

be evaluated quarterly by on-site instrument personnel. The field sampler will 

verify calibration of the instruments prior to beginning the sample event and will 

note the results in the field logbook. 

6. Data Reduction/Data Validation

The laboratory will perform analytical data reduction and validation 

under the direction of the Laboratory QA Officer. The Laboratory QA officer is 

responsible for assessing data quality and advising of any data which were rated 

"preliminary" or "unacceptable" or other notations which would caution the data 

user of possible unreliability. Data reduction, validation, and reporting by the 
IN-127-1W-0003 

laboratory will be conducted following the general procedures below, although 

internal laboratory procedural documentation will take precedence. 

• Raw data produced by the analyst is turned over to 

the respective area supervisor. 

• The area supervisor reviews the data for attainment 

of quality control criteria as outlined in the project 

guidelines and/or established U.S. EPA methods, and 

for overall reasonableness. 

 • Upon acceptance of the raw data by the area supervisor, 

a computerized report is generated and sent to the 

Laboratory QA Officer. 

 • The Laboratory QA Officer will complete an audit of reports 

at a frequency of at least one in twenty, and an audit of 

every report for consistency. 

• The QA officer and area supervisors will decide whether 

any sample reanalysis is required. 

• Upon acceptance of the preliminary reports by the QA 

Officer, final reports will be generated. 

Data reduction reporting procedures will be those specified in the SW846 method for inorganic and organic analyses. 

The laboratory will prepare and retain full analytical and QC 

documentation. Such documentation need not be hard (paper) copy, but may be 

in other storage media (e.g. magnetic tape). As needed, the laboratory will 

supply a hard copy of the retained information. 

Laboratory detection limits and/or quantitation limits for analytical data 

produced are contained in Table 3. Data on reporting limits and method 

detection limits can be found in the individual Standard Operating Procedures 

(SOPs) in Appendix 1. The reporting limit for each chemical parameter will also 

be indicated on the analytical reports provided to Burns Harbor and regulatory 

agencies by the laboratory conducting the analysis. The data in Table 3 assumes 

that there are no severe interferences, and that sample dilutions are not required 

due to excessive concentrations of target analytes. 

7. Internal Quality Control 

There will be two types of quality assurance used to ensure the 

production of analytical data of known documented usable quality: program 

quality assurance and analytical method quality control. 

The analytical laboratory will have a written Quality Assurance / Quality 

Control program, which provides rules and guidelines to ensure the reliability 

and validity of work conducted at the laboratory. Compliance with the QA/QC 

program will be coordinated and monitored by the laboratory’s Quality 

Assurance Department, which is independent of the operating departments. 

 The objectives of the laboratory QA/QC program are to: 

• Ensure that all procedures are documented, including 
IN-127-1W-0003 

any changes in administrative and/or technical procedures. 

• Ensure that all analytical procedures are conducted 

according to sound scientific principles and have been validated. 

• Monitor the performance of the laboratory by a systemic 

inspection program and provide for corrective action as 

necessary. 

• Collaborate with other laboratories in establishing quality levels, 

as appropriate. 

 • Ensure that all data are properly recorded and archived. 

All procedures are documented in writing as either Standard Operating 

Procedures (SOPs) or Methods of Procedures (MP) which are audited and 

controlled by the QA Department. Internal quality control procedures for 

analytical services will be conducted by the laboratory in accordance with their 

SOP and the individual method requirements in a manner consistent with 

appropriate SW-846, 40 CFR Part 136, or other validated analytical methods. 

These specifications include the types of audits required (sample spikes, 

surrogate spikes, reference samples, controls, blanks), the frequency of each 

audit, the compounds to be used for sample spikes and surrogate spikes, and the 

quality control acceptance criteria for these audits. 

The laboratory will document, in each data package provided, that both 

initial and ongoing instrument and analytical QC functions have been met. Any 

samples analyzed in non-conformance with the QC criteria will be reanalyzed by 

the laboratory, if sufficient sample volume is available. 

8. Laboratory Audits

The QA Manager will perform internal laboratory audits. The system 

audits will include an examination of laboratory documentation on sample 

receiving, sample log-in, sample storage, chain of custody procedures, sample 

preparation and analysis, instrument operating records, etc. The performance 

will be conducted on an annual basis. 

9. Corrective Actions

Corrective actions will be implemented when any aspect of the analytical 

or sampling method does not achieve the project objectives. This may entail resampling and/or reanalyzing (for a particular parameter) the waste streams, recalibrating an analytical device, or any such action. The action level for each 

such process will be shown in tabular form. 

Table 1 – Historic Waste Analytical Results

CONSTITUENTS WASTE MINIMUM MAXIMUM UNITS 

Chromium SPL 59.8 89.7 mg/L 
IN-127-1W-0003 

Lead SPL 0.0 22.5 mg/L 

Selenium WAL 0.80 3.03 mg/L 

Benzene WAL 3 21.7 Mg/L 

Pyridine WAL 0.0 31.2 mg/L 

Specific 

Conductivity SPL 90,000 328,000 Umhos 

Specific 

Gravity SPL/WAL 1.09/1.00 1.33/1.01 G/cc 

TDS SPL 38,710 395,100 mg/L 

TOC SPL/WAL 150/1060 150/1060 mg/L 

Sulfide WAL 72 76 mg/L 
IN-127-1W-0003 

Table 2 – Analytical Methods 

Constituent Waste Ammonia Liquor 

Analytical Method 

Spent Pickle Liquor 

Analytical Method 

Galesville Sandstone 

Groundwater Analytical 

Method 

Total Selenium E200.7 NA NA 

Total Benzene SW8260B NA NA 

Total Pyridine SW8270C NA NA 

Toluene SW8260B NA NA 

Specific Gravity M2710 F M2710 F NA 

pH SW4500-H B SW4500-H B NA 

Temperature NA NA NA 

Total Chromium NA E200.7 NA 

Acidity NA E305.1MOD* E305.1 

Ammonia as N E350.2 NA E350.2 

Chloride NA NA M4500-C1 B 

Cyanide E335.2 NA SW9012 

Phenol (4AAP) E420.2 NA SW9066 

Sulfate NA NA E375.4 

Total Iron NA E200.7 SW6010B 

Sodium NA NA SW6010B 

Calcium NA NA SW6010B 

Naphthalene SW8270C NA NA 

Sulfide E376.2 NA NA 

 

Notes: 

SW = Analytical Method specified in SW-846 

E = Analytical Method specified in Methods for Chemical Analysis of Water and Wastes. 

M = Analytical Method specified in Standard Methods for the Examination of Water and 

Wastewater. 

D = Analytical Method specified by the American Society for Testing and Materials (ASTM) 

* Procedure is modified to deal with concentrations significantly higher than the analytical 

method is designed for. 
IN-127-1W-0003 

Table 3 - 

Estimated Quantitation Limits (EQL’s) for Targeted Parameters in Milligrams per Liter (mg/l) or 

as noted

Constituent Waste Ammonia Liquor 

EQL (mg/l) 

Spent Pickle Liquor 

EQL (mg/l) 

Galesville Sandstone 

Groundwater EQL 

(mg/l) 

Total Selenium 0.005 NA NA 

Total Benzene 0.005 NA NA 

Total Pyridine 0.010 NA NA 

Toluene 0.005 NA NA 

Specific Gravity 0.001 T/4C 0.001 T/4C NA 

pH 0.02 pH units 0.02 pH units NA 

Temperature 2 0F 2 0F NA 

Total Chromium NA 0.01 NA 

Acidity NA 2 2 

Ammonia as N 0.1 NA 0.1 

Chloride NA NA 50 

Cyanide 0.005 NA 0.005 

Phenol (4AAP) 0.05 NA 0.05 

Sulfate NA NA 200 

Total Iron NA 1 1 

Sodium NA NA 40 

Calcium NA NA 20 

Naphthalene 0.01 NA NA 

Sulfide 1 NA NA 

 

Note: Data in this table assumes no sample dilutions have been performed. 
IN-127-1W-0003 

ATTACHMENT E

GROUNDWATER MONITORING REQUIREMENTS for the GALESVILLE 

SANDSTONE GROUNDWATER MONITORING WELL

1. Galesville Sandstone Groundwater Monitoring Well 

Operation of the Galesville Sandstone Groundwater Monitoring Well (Galesville 

well) is a condition (Condition #3) of the existing exemption from the land disposal 

restrictions of the 1984 Hazardous and Solid Waste Amendments to the Resource 

Conservation and Recovery Act. The initial exemption was issued on August 1, 

1990, and was subsequently modified on March 17, 1998 and April 7, 1998. As long 

as the exemption condition remains in force, the requirement for the permittee to 

operate and monitor the Galesville well continues. 

The Galesville Sandstone Groundwater Monitoring Well (Galesville well) is located 

approximately 100 feet west of the Waste Ammonia Liquor Injection Well #2 (U.S. 

EPA Permit #IN-127-1W-0004). The Galesville well monitors the Galesville 

Sandstone formation, the first aquifer overlying the injection zone, between the 

depths of 1921 and 1947 feet below Kelly Bushing (KB). The KB is approximately 

20 feet above ground surface. 

The purpose of the Galesville well is to provide assurance that no upward migration 

of injected hazardous waste occurs. Monitoring includes recording pressure 

measurements of the Galesville Sandstone formation and collection of connate water 

samples from the Galesville Sandstone formation for chemical analysis. The specific 

monitoring and reporting requirements for the Galesville well are described in Parts 

III(E)(2) through (6) of this permit. 

2. Galesville Sandstone Formation Water Sampling 

Each quarter, the permittee shall collect water from the Galesville well for the 

purpose of chemical analysis. The permittee shall analyze the water samples for all 

the parameters specified in the Waste Analysis Plan (Part III(D) of this permit). 

During any sample collection event, the EPA or its representatives will have an 

opportunity to obtain split samples. 

 a. Establishment of baseline

All of the analytical data gathered since the well was first sampled in 1995 plus 

the first eight, independent, and statistically valid analytical results for each 

parameter obtained after the effective date of this permit shall be used to establish 

the chemical baseline of the Galesville Formation water for that parameter. The 

baseline shall be determined as the average of the first eight qualifying analytical 

results, while at the same time calculating both Upper and Lower Tolerance 

Limits as available from Shewart CUSUM control charts. The permittee shall use 

the boundaries of the Upper and Lower Tolerance Limits to establish the 
IN-127-1W-0003 

permissible amount of variance that subsequent results may exhibit without 

falling outside the baseline. 

b. On-going monitoring

After establishment of a baseline value for each parameter shown in the Waste 

Analysis Plan (Part III(D)), the permittee may either (1) elect to discontinue 

sampling for a parameter (if all eight baseline values show non-detections at the 

specified sample minimum detection threshold), or (2) continue to sample for 

each parameter. The continued sampling for each parameter detected during 

establishment of the baseline shall take place at least quarterly. The minimum 

detection threshold values in the Waste Analysis Plan will continue to apply. 

If a sample result falls outside the baseline Upper and Lower Tolerance Limits, 

then the permittee may elect to either (1) engage in trend analysis to determine if 

the out-of-range value represents real change, or (2) re-sample the Galesville well 

to determine if the out-of-range result is reliable. For either method elected by the 

permittee to investigate an out-of-range value, the third consecutive value of any 

single parameter that is outside the limits established under the Shewart CUSUM 

tables shall be considered a possible breach of the confining zone defined by this 

permit, initiating the need for dialogue between the Director and the permittee, 

calling into question the reasonable degree of certainty that all hazardous wastes 

injected by the permittee shall remain confined in the injection zone for a period 

of at least 10,000 years. 

3. Reporting Water Analysis Results 

The permittee shall report the results of water samples analyzed quarterly as specified 

in Part II(D)(2) of this permit. Each report shall include graphical illustration of the 

parameter values as a function of sample date, showing all samples taken during the 

life of the Galesville well. Upon written request from the Director, the permittee shall 

provide laboratory records of analyses which may include electronic tapes with 

spectral files to independently verify the analytical results of samples taken for 

organic chemistry, or other standard laboratory records. 

4. Pressure Sampling 

The Galesville well shall maintain a capability to measure pressure in the Galesville 

Sandstone Formation. Formation pressure shall be continuously monitored and shall 

be recorded at least once every four hours. Formation pressure shall be measured by 

dedicated equipment capable of a precision of at least 0.1 psi. The permittee shall 

correct each recorded formation pressure value for changes in simultaneous 

barometric pressure values. To make this correction, the permittee may either 

directly measure the barometric pressure at the Galesville well, or obtain a barometric 

pressure value from a nearby source at the time of the Galesville Sandstone 

Formation pressure recording. 
IN-127-1W-0003 

The permittee shall calibrate all gauges in use for pressure measurements at the 

Galesville well at least annually. The calibration shall ensure that the precision value 

of 0.1 psi is maintained. 

5. Reporting Pressure Data 

The permittee shall report values of Galesville Formation pressure data each month as 

specified in Part II(D)(1). Each report shall include a tabulation and graphical 

representation of the daily maximum values for the Galesville Formation pressure, the 

barometric pressure, and the maximum injection pressure recorded from any well 

injecting waste ammonia liquor on that day. Each report shall also include a graph 

showing the daily Galesville Formation pressures recorded at six hour intervals (i.e., 

four data points per day) and the maximum injection pressures (recorded at the same 

intervals) from any well injecting waste ammonia liquor on that day. The six-hour 

graph axes must be scaled in increments small enough to indicate fluctuations in the 

Galesville Formation pressure and the injection pressure(s) clearly. 

6. Mechanical Integrity 

The Galesville well shall maintain mechanical integrity to ensure that chemical and 

pressure samples taken from the well are representative of the Galesville Sandstone 

Formation. In order to determine that the well maintains mechanical integrity, the 

permittee shall conduct a standard annulus pressure test at least once every twelve 

months. The standard annulus pressure test must be witnessed by an authorized 

representative of the Director unless it proves impossible to resolve scheduling 

conflicts between the operator and the agency. In order to conduct testing without a 

USEPA representative, the procedures discussed in Section I(H)(1) must be followed. 

The minimum annulus test pressure shall be 300 psi and the duration shall be at least 

one hour. No more than 3% change in the test pressure is permissible during the 

standard annulus pressure test. If the Galesville well fails a standard annulus pressure 

test, then an oral report of such failure shall be made to the Director within 24 hours 

of the failure and a written report of the failure shall be submitted to the Director 

within 30 days of the failure. The permittee shall make attempts to restore the well’s 

mechanical integrity as soon after a failure as practical. During a time when the well 

lacks mechanical integrity, the well’s condition shall be noted on any written 

monitoring reports submitted to the Director.

7. Galesville Well Workovers 

The permittee shall submit any plan to workover the Galesville well to the Director 

for approval at least 30 days in advance of the scheduled date to commence the well 

workover. Each workover shall conclude with a demonstration of mechanical 

integrity as specified in Part III(E)(6) of this permit. Reports of the workover shall be 

submitted to the Director within the time frame specified in Part II(D)(4). 
IN-127-1W-0003 

8. Plugging and Abandonment 

The Galesville well shall remain active until the highest pressure in the injection zone 

declines to a value insufficient to cause fluid to move to the base of the lowermost 

underground source of drinking water (USDW), as identified in the administrative 

record for this permit, unless the Director determines that additional ground water 

monitoring is required to protect USDWs. The current Closure Plan to plug and 

abandon the Galesville well is part of this attachment. The permittee shall submit any 

proposed significant revision to the method of closure reflected in the Closure Plan 

for approval by the Director no later than sixty calendar days before closure, unless a 

shorter time period is approved by the Director. Final plugging of the well shall 

include installation of a permanent marker to identify the well. The permittee shall 

maintain an adequate financial mechanism to properly plug and abandon the 

Galesville well, until the well has been completely plugged and abandoned. The 

estimate of the cost to properly plug and abandon the Galesville well shall be updated 

at least once every twelve months, and the financial mechanism to meet or exceed the 

estimated cost shall be adjusted as needed each year. The permittee shall, within 45 

days of its completion, submit a report of the plugging and abandonment of the 

Galesville well. 
IN-127-1W-0003 

ATTACHMENT F

CORRECTIVE ACTION AT THE FACILITY 

UNDER SECTION 3004(U) OF THE RESOURCE 

CONSERVATION AND RECOVERY ACT

A. CORRECTIVE ACTION AT THE FACILITY 

In accordance with Section 3004(u) of RCRA and the regulations promulgated pursuant to 

that Section, you must institute Corrective Action as necessary to protect human health and 

the environment for all releases of hazardous waste(s) or hazardous constituent(s) from any 

solid waste management units (SWMUs) at the facility, regardless of the time at which waste 

was placed in such units. 

B. CORRECTIVE ACTION BEYOND THE FACILITY BOUNDARY 

In accordance with Section 3004(v) of RCRA and the regulations promulgated pursuant to 

that Section, you must implement Corrective Action(s) beyond the facility property 

boundary, where necessary to protect human health and the environment, unless you 

demonstrate to the satisfaction of the Regional Administrator that, despite your best efforts, 

you were unable to obtain the necessary permission to undertake such actions. You are not 

relieved of any responsibility to clean up a release that has migrated beyond the facility 

boundary where offsite access is denied. 

C. CORRECTIVE MEASURES IMPLEMENTATION 

1. The permittee submitted a Corrective Measures Implementation (CMI) Workplan to the 

U.S. EPA for approval. This workplan describes the groundwater monitoring program 

that will be used to evaluate the plume stability demonstration at north facility location 

IA-1 and the performance of monitored natural attenuation at north facility location IA-3, 

as described in the Corrective Measures Proposal. The Workplan addressed the existing 

and future groundwater monitoring network, constituents for analysis, sampling and 

reporting schedule, and criteria for termination of the program. Procedural, quality 

control and administrative functions were also addressed in the Workplan as well as a 

schedule for implementation of the groundwater monitoring program. The Workplan was 

approved by U.S. EPA on November 14, 2006. The permittee shall implement the work 

required under the approved CMI Workplan in accordance with its approved schedule. 

2. The permittee submitted institutional controls to restrict land use and groundwater use 

within the property boundaries described in Figure 1 for the north and south facilities to 

the U.S. EPA for approval. For the south facility, corrective action is regarded as 

“complete with controls,” and the outlined conditions represent the necessary controls. 

Permittee shall comply with the following conditions: 
IN-127-1W-0003 

(a) On-site land use shall be limited to industrial purposes until the permittee can 

demonstrate that levels of contaminants in soil are protective for other land uses; 

(b) Groundwater underlying the Facility within the shallow aquifer shall not be used for 

consumptive purposes unless levels of contaminants are stable and below appropriate 

screening levels and shall not be used for direct contact purposes unless levels of 

contaminants are below industrial screening levels; 

(c) The permittee submitted a notice to be filed in the office of the Porter County 

Recorder for all successors-in-title that the Facility is subject to the conditions of this 

permit for U.S. EPA review and approval. The notice summarizes the contamination 

remaining on the Facility, the potential hazards to human health and the environment 

from such contaminants and the manner in which persons may obtain further 

information from the U.S. EPA. 

(d) Permittee intends to reserve in any future conveyance by permittee of an interest in all 

or part of the property the right to enforce the restrictions and covenants in the 

restrictive covenant for ArcelorMittal Burns Harbor, LLC and U.S. EPA and its 

authorized representatives as a third party beneficiary. 

(e) The permittee has indicated that it intends to transfer ownership of a portion of the 

south facility known as the “Little Calumet Restoration Area” for environmental 

education, wildlife habitat and appropriate recreational purposes. Prior to any such 

transfer, deed restrictions (including a restrictive covenant) shall be created and 

recorded that are specific to the designated parcel. The deed restrictions shall provide 

that excavation and/or movement of any material in waste piles shall not be permitted 

unless done in accordance with a health and safety plan approved by U.S. EPA. The 

transferee would assume primary responsibility for maintaining the required 

institutional controls in accordance with the restrictive covenants set forth in the deed. 

3. The permittee shall conduct regular cap inspections and perform a maintenance program 

at IA-3 following a schedule, procedures and corrective measures as described in the 

CMI Work Plan. 

4. The permittee has provided financial assurance in the amount specified by the Regional 

Administrator for necessary corrective measures activities, based on cost estimates and 

other relevant information, as required by 40 CFR 264.101(b) and (c). 

D. NEWLY IDENTIFIED SWMUs OR RELEASES 

The permittee must notify the Regional Administrator of any new SWMU identified at the 

facility within 30 days of discovery in accordance with 40 CFR 270.14(d). The permittee 

must also submit all available information pertaining to any release of hazardous waste(s) or 

hazardous constituent(s) from any new or existing SWMU to the Regional Administrator 

within 30 days of discovery. 
IN-127-1W-0003 

E. CORRECTIVE ACTION FOR NEWLY IDENTIFIED SWMUs AND RELEASES 

The Regional Administrator will review the information provided in the above condition and 

may as necessary require further investigations or corrective measures. The permittee must 

submit a written RCRA Facility Investigation Work Plan to the Regional Administrator 

within 90 days after written notification by the Regional Administrator that further 

investigation is necessary. 

F. DISPUTE RESOLUTION 

1. If the permittee disagrees, in whole or in part, with the U.S. EPA’s disapproval or 

modification of any submission required by Section G of the permit, the permittee must 

notify the U.S. EPA of its objections by providing the Regional Administrator a written 

statement of position within 14 days of receipt of the U.S. EPA’s disapproval or 

modification. The permittee’s statement of position must set forth the specific matters in 

dispute, and the position that the permittee asserts should be consistent with the 

requirements of this permit. The permittee’s position statement must provide the basis 

for its position, and must include all supporting documentation. 

2. The permittee will have an additional 14 days from the U.S. EPA’s receipt of its position 

statement to meet or confer with the U.S. EPA to attempt to resolve the dispute. If 

agreement is reached, the permittee must submit a revised submission, if necessary, and 

implement the submission in accordance with the agreement. 

3. If the permittee is not able to reach agreement with the U.S. EPA within the 14-day 

period, the Regional Administrator or his or her delegate will issue a written decision 

resolving the dispute. That written decision will become an enforceable condition of this 

permit, and the permittee must comply with the terms and conditions of the U.S. EPA’s 

decision resolving the dispute. 

4. Not withstanding the invocation of this dispute resolution procedure, the 

permittee must proceed to take any action required by those portions of the 

modified and approved submission that the U.S. EPA determines are not 

substantially affected by the dispute. This action must follow the schedule 

contained in the submission. 
IN-127-1W-0003 

ATTACHMENT G 

Waste Ammonia Liquor Waste Minimization and Practicability 

Certification

Waste Ammonia Liquor (WAL) is generated as a by-product of the coking operation. 

Coal is the input to the coke operation and coke, coke oven gas and coal tar are the 

principal outputs. The WAL is recirculated in a closed-loop recycle system and is used to 

cool and cleanse the coke oven gas produced. The clean coke oven gas is used as a fuel 

throughout the plant. 

Excess water is introduced into the closed-loop WAL system primarily as a result of the 

liberation of moisture, which is contained within the coal, during the coking process. The 

excess WAL is removed from the closed-loop system and disposed via the deepwells. 

Bethlehem has also actively pursued eliminating any additional sources of water that 

could potentially enter this closed-loop system. These types of activities have included: 

• Replacing the steam aspiration system at the No. 2 Coke Oven Battery with highpressure WAL aspiration. 

• Using WAL to cool the seals on the WAL recycle pumps rather than lake water. 

These activities have significantly reduced the volume of WAL injected by reducing the 

potential sources of fresh water addition to the closed-loop recycle system. For example, 

the average daily amount of WAL injected into the deepwells in 1996 was about 244,000 

gallons. In 2000, the daily amount injected averaged about 191,000 gallons. Bethlehem 

will continue to watch the amounts of WAL disposed and evaluate if further waste 

reduction methods can be implemented. 

This Waste Minimization Certification was submitted September 18, 2001.