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-0001

Well Name: Spent Pickle 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 28, NW 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 2173 and 4285 feet below ground surface. Injection is permitted into the interval of the lower Mt. Simon Sandstone between the depths of 2723 and 4285 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.

The facility is authorized to inject spent pickle liquor from any ArcelorMittal USA facility provided that characteristics and concentrations of injected waste do not exceed any limits listed in Part III(A) or Part III(D) of this permit.

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 DivisionTABLE OF CONTENTS

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

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

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

B PERMIT ACTIONS............................................................................................................... ... 2
1. Modification, Revocation, Reissuance and Te rmination ..........................................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 Conditi ons ...........................................................3

4. Need to Halt or Reduce Ac tivity Not a Defense .......................................................4

5. Duty to Mi tigate........................................................................................................4

6. Proper Operation and Maint enance.........................................................................4

7. Duty to Provi de Informa tion .....................................................................................5

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

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

10. Monitori ng ................................................................................................................6

11. Signatory Requi rements ..........................................................................................6

12. Reporting Requi rements..........................................................................................6

F CLOSURE ...................................................................................................................... .......... 8
1. Closure Plan ............................................................................................................8

2. Revision of Clo sure Plan..........................................................................................8

3. Notice of Int ent to Close...........................................................................................8

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

5. Closure R eport.........................................................................................................8

6. Standards for We ll Closu re ......................................................................................8

G POST-CLOSU RE CARE.......................................................................................................... 9
1. Post-Closure Plan -.................................................................................................9

2. Duration of Post- Closure Pe riod ..............................................................................9

3. Post-Closure Corre ctive Ac tion................................................................................9

4. Post-Closure Groundwat er Monito ring.....................................................................9

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

6. Notification to State and Local Aut hority ..................................................................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 In tegrity Te sting ....................................................................10

3. Prior Notice and Reporti ng.....................................................................................11

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

5. Loss of Mechanica l Integr it ....................................................................................11

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

I FINANCIAL RESPONSIBILITY .......................................................................................... 12
1. Financial Res ponsibilit y .........................................................................................12

2. Insolvenc y..............................................................................................................12

3. Notifica tion .............................................................................................................13

4. Establishing Other Cover age .................................................................................13J CORRECTIVE ACTION ....................................................................................................... 13
1. Corrective Action under 40 CFR Secti on 146.64 ...................................................13

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

3. Corrective action under the Resource Conservation and Re covery Act ................13

K INJECTION OF RESTRIC TED HAZARDOUS WASTES .................................................. 13
1. Complianc e............................................................................................................14

2. Injection Li mitati ons ...............................................................................................14

3. Petition Update and Amendm ent ...........................................................................14

4. Petition Termi nation...............................................................................................14

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

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

WELL SPECIFIC CONDITION S FOR UIC PERMITS ............................................................. 15
A. CONSTRUCTION .......................................................................................................15

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

2. Casing and Cem enting ..........................................................................................15

3. Tubing and Packer S pecificat ions ..........................................................................15

4. Wellhead Specif ication...........................................................................................15
B. OPERATIONS ............................................................................................................15

1. Injection Pressure Limita tion..................................................................................15

2. Additional Injecti on Limita tion ................................................................................16

3. Annulus Fluid and Pressu re...................................................................................16

4. Annulus/Tubing Pressure Different ial.....................................................................16

5. Warning and Shut -off Syst em ................................................................................16

6. Precautions to Prev ent Well Bl owouts ...................................................................16

C. MONITORING .................................................................................................................. ........ 17
1. Sampling Po int.......................................................................................................17

2. Continuous Monito ring Devi ces .............................................................................17

3. Waste Analysi s Plan ..............................................................................................17

4. Ground Water M onitori ng.......................................................................................17

5. Ambient Moni toring................................................................................................17 D. REPORTING REQUIREMENTS ............................................................................................. 17
1. Monthly R eports .....................................................................................................18

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

3. Annual R eports ......................................................................................................19

4. Reports on We ll Test s............................................................................................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 th e 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 ScheduleIN-127-1W-0001 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 prope rty, 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, tr eatment 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 Envir onmental 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.IN-127-1W-0001 Page 3 of 20



### 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 asserte d, 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 PermitsIN-127-1W-0001 Page 4 of 20

(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 withIN-127-1W-0001 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-0001 Page 6 of 20

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-0001 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-0001 Page 8 of 20

(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); andIN-127-1W-0001 Page 9 of 20

(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 whichIN-127-1W-0001 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 monthsIN-127-1W-0001 Page 11 of 20

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 DirectorIN-127-1W-0001 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 maintainfinancial 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 cal endar 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; orIN-127-1W-0001 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 WASTESIN-127-1W-0001 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-0001 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-0001 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 injec tion 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-0001 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.



### 6. Compatibility of Well Material – A plan for monitoring corrosion as required by 40 CFR Section 146.68(c)(2) is found in Part III(H) of this permit. The implementation of the corrosion monitoring plan is a condition of this permit. Continuous corrosion monitoring shall be operational within ninety da ys of the effective date of this permit. At a minimum, the permittee shall report loss of mass, thickness, cracking, pitting and other signs of corrosion at least quarterly.



### D. REPORTING REQUIREMENTS ( Section 146.69)IN-127-1W-0001 Page 18 of 20

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 specific gravity and (5) monthly volume. Average monthly values of flow rate shall be calculated as follows:

Total monthly flow of Spent Pickle Liquor (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;

(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;IN-127-1W-0001 Page 19 of 20

(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 the continuous corrosion monitoring as required by Part II(C)(6) of this permit and described in Part III(H).

(b) Results of Galesville Formation chemistry monitoring as specified in Part III(E) of this permit;

(c) 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-0001 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, MONI TORING 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 PRAC TICABILITY CERTIFICATIONS

H. SPENT PICKLE LIQUOR CORROSION MONITORING PLAN AND COMPLIANCE

SCHEDULEIN-127-1W-0001



### ATTACHMENT A

PARTIAL SUMMARY OF OPERATING, MONITORING AND REPORTING REQUIREMENTS

CHARACTERISTIC LIMITATION MINIMUM

MONITORING FREQUENCY MINIMUM

REPORTING FREQUENCY
Maximum Injection Pressure 1 200 psig 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) 2 175 gallons per minute Continuous Monthly

Cumulative Injected Volume Continuous Monthly

Annulus Fluid Loss or Gain Monthly Monthly

Chemical and Physical Characteristics of Injected Fluid 3 Monthly Monthly

Chromium 4 133 mg/l Monthly Monthly

Nickel 4 50 mg/l Monthly Monthly

pH 4 0 (minimum) Monthly Monthly

1 The Maximum Injection Pressure has been limite d to 200 psig based on a request from the permittee

to allow Standard Annulus Pressure Tests at 300 psig. Th is is well below the value that would be computed based on a fracture gradient calculation.

2 The SPL 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 same rate is used in the modeling presented in the 2007 Petition for Renewal of Exem ption from the Land Disposal

Restrictions dated February 28, 2007.

3 As specified in the Waste Analysis Pla n, which is Part III(D) of this permit.

4 Concentration limit will apply if the 2007 Petition for Renewal of Exemption from the Land Disposal Restrictions, dated Feb. 28, 2007, is approved.IN-127-1W-0001

U.S. Environmental Protection Agency

Underground Injection Control Permit

Class I Hazardous

Permit Number IN-127-1W-0001

ArcelorMittal Burns Harbor, LLC

Burns Harbor, Indiana

Attachment BIN-127-1W-0001

PLUGGING AND ABANDONMENT/PO ST CLOSURE CARE PLANS

40 CFR 144.52(a)(7) requires the permittee to demonstrate adequate fina ncial responsibility and resources to close and abandon the underground inje ction operation in a manner prescr ibed by the Direct or. During the permit application review process, the permittee provided documentation of the financial assurance to plug

and abandon this well and provide adequate post-clos ure care by means of its financial statement (40 CFR144.63(f)). The permitte e may provide alternate financial assu rance 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-cl osure care survives the termination of this permit and the cessation of injection.

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

1. Obtain approval from the regulatory agency pr ior to commencing operations. Conduct the required mechanical integrity testing and ambient monito ring 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 flus h volume will be a mini mum of three wellbore

volumes.

4. Dismantle the wellhead and install blowout preventers.

5. Remove the injection tu bing and seal assembly.

6. Set a cement retainer in the 5 inch Hastelloy cas ing at approximately 2,700 fe et and pressure test

the retainer

7. Squeeze 29.4 cubic feet of epoxy resin through the reta iner. Pull the tubing out of the retainer and spot 11.2 cubic feet balanced epoxy resin cement plug in the 5 inch casing from 2,700 to 2,600

feet.

8. Fill the remainder of the 5 inch ca sing from the top of th e resin with Class “A” cement. This top plug will be pumped in 500-1,000 feet stages and balan ced in place. An appropriate length of the workstring will be pulled and laid down. The workst ring will be reverse-circulated to confirm that it is still in cement from the prev ious 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. The steel plate should be inscribed with the following information:

ArcelorMittal Burns Harbor, LLC Spent Pickle Liquor Well No. 1

Permit No. IN-127-1W-0001 P& A ____.

COST ESTIMATE FOR PLUGGING AND ABANDONMENT OF SPL-1 The estimated cost for plugging and abandoning SPL #1 well is $330,000.IN-127-1W-0001

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, SPL-1, at the Burns Harbor in northern Indiana. This procedure is in accordance with the requirements of Title 40 of the Code of Federal Regulations (40 CF R) 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 requir ed 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 Departme nt 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 slight ly 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 re ference 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, conf irming 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 injecti on zone at the time of closure:

Modeling performed for the ArcelorMittal Burns Harbor , LLC land ban demonstrat ion was base d on average monthly injection rates for year 2006 through ye ar-end 2027 of 300 gallons per minute (gpm) for the waste ammonia wells, 175 gpm for the spen t pickle liquor well, and 100 gpm for the Unit ed States Steel Waste Pickle Liquor No. 2 well.

Incremental model pressure buildup at the Waste Amm onia Liquor Well No. 1 well is 771.4 psi (reservoir pressure of 1,899.3 ps i at 2,751 feet). Incrementa l model pressure bu ildup at the Waste Ammonia Liquor Well No. 2 well is 772.6 ps i (reservoir pressure of 1,900.5 psi at 2,751 feet). Incremen tal model pressure buildup at the Spent Pickle Liquor Well No. 1 well is 572.4 psi (reservo ir pressure of 1,700. 3 psi at 2,751 feet).

3) The predicted time until pressure in th e injection zone decays to the point th at 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 post-injection pressure decay for all three wells is shown in figures in Attachment Q of the permit a pplication, which is part of the Administrative Record for this permit. The graphs show the modeled pres sure increase over the historical injection period (through year-end 2 005), the modeled maximu m injection period (2006 through 2027), and the pressure recovery over a modeled 30-year perio d, assuming that injecti on ceases at year end 2027.IN-127-1W-0001

Pressure recovery begins immediate ly after injection ceases and conti nues to recover over the modeled 30- year period. The pressure in the lo wer Mt. Simon Injection In terval will equilibrate rapidly, and the driving force needed for vertical permeatio n of formation brines and waste fr om the lower Mt. Simon Sandstone into the overlying “B” Cap Shale laye r at all locations will dissipate. There will be no Cone of Influence within 3 years of closure. Asymptotic pressure recovery to the in itial formation pressu re will continue over the 10,000-year time frame. Since pr essure recovery in the injection inte rvals is rapid, the injection-induced driving force for waste moveme nt 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 corr ective 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.

Upon closure of any of ArcelorMittal Burns Ha rbor, LLC injection wells, ArcelorMittal shall:

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

2) Continue post clos ure maintenance and monitori ng 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: Proj ected to be a period of 3 years after closur e of all wells.]

3) Submit a survey plat map to the local zoning authority design ated by the Director, and to the Regional Administrator of the Region 5 EPA offi ce. The survey plat map shall indicate the

location of the closed well relative to permanently surveyed benchmarks.

4) Provide appropriate notification and informati on 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 penetrat e 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 requi re ArcelorMittal Burns Harbor, LLC to deliver the records to the Direct or at the conclusion of the retention period,

and the records shall thereafte r 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 propert y, or on some other instrument that is normally examined during ti tle search, that will in perpetuity provide any potential purchaser of the property with the following information:IN-127-1W-0001

a) The fact that the land has been used to ma nage 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 in jected, 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.

ArcelorMittal Burns Harbor, LLC shall comply with th e 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-0001

U.S. Environmental Protection Agency

Underground Injection Control Permit

Class I Hazardous

Permit Number IN-127-1W-0001

ArcelorMittal Burns Harbor, LLC

Burns Harbor, Indiana

Attachment CIN-127-1W-0001



### ATTACHMENT D

SOURCE AND ANALYSIS OF WAST E AND WASTE ANALYSIS PLAN

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

1. Spent Pickle Liquor, a listed hazardous wa ste bearing the RCRA Hazardous waste code K062, 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 form ation that is captured during well stimulations or workovers; and 6. Rain water that is collected in sp ill 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 Wast e Analysis Plan is included below, though the attachments and appendices to the Pl an are not. They are found in th e Administrative Record for this permit.

.IN-127-1W-0001

ARCELORMITTAL BURNS HARBOR, LLC.

WASTE ANALYSIS PLAN

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

EFFECTIVE: February 2009IN-127-1W-0001

Table of Contents

Section Page

I. Scope and Applicability 1

II. Responsible Charge and Plan Administration 1

III. Description of Waste Streams 1 B. Spent Pickle Liquor 2

IV. Description of Groundwater Monitoring Well 2

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

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 ConcludedIN-127-1W-0001



### 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 Coupl ed 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 Petr oleum 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 Us ing 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 Phenat e Colorimetry using EPA Method 350.1 and

SM Method 4500-NH3 G

J. Chloride (Silver Nitrate Titr ation) Using Standard Met hods Method 4500-Cl B and SW846 Method 9253

K. Cyanide, Total, Amenable, and Weak Ac id Dissociable by Mi di 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

iiIN-127-1W-0001

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 Depart ment 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-127-1W-0004) dispose of Waste Ammonia Liquor (WAL), which is characteristically h azardous (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 ne w well (Permit No. IN-127-1W-0007) will be designed to also dispose of WAL. The following provides a descripti on 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 - Fac ility Map). WAL from coking operations (a coal carbonization process) is a wastewater that is genera ted 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 concentr ations of organic contaminants. The primary contaminant, as the waste name implies, is ammoni a (2003 average concentration of 4,138 milligrams per liter). The WAL also contains phenols (2003 aver age concentration of 1128 mg/L), cyanide (2003 average concentration of 53 mg/L), and several ot her organic contaminants, such as aniline, benzene and naphthalene, at lesser concentrations.

Coal is the principal input into the coking opera tion 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 separati on 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 hol ding 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, wh ich is contained within the coal, during the coking process. In order to maintain proper liquid equ ilibrium 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 remova l 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)IN-127-1W-0001

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 prepar ation for further processing in the cold mill. The SPL is primarily water (about 87%), hydrochloric acid (2 003 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 Pl ant or to a railroad tank car/truck loading facility for use as a substitute for a commercial chemical pr oduct. SPL that cannot be used in this manner is transferred to the SPL well system for processing and dis posal 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 inst all a groundwater monitoring well in the Galesville Sandstone Formation, which is the lo wer most formation located immediately above the confinement formation for deepwell injection activities.

The operational plan for this well requires con tinuous pressure monitoring to confirm that the pressurization of the subsurface formations is consiste nt with the no-migration model simulation submitted in support of the exemption as well as to provide early detecti on 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.

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. B ased 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 constitu ent basis. Based on this information and EPA’s Regional Guidance #8 for “Preparing a Waste Analys is 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 MonthlyIN-127-1W-0001

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 con tinuously, except during periods of instrument maintenance and calibration, and record ed 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. Wh en 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 follow ing parameters will be analyzed under this WAP at the frequency indicated.

Parameter Frequency of Analysis Chromium, Total Monthly Iron, Total Monthly 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 Histor ical, 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 ha ve 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 orIN-127-1W-0001

routinely analyzed under this WAP. ***Guidance constituents are those constituents in gro undwater 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 WA L to one of the two well heads for injection.

The samples will be collected into clean, pre-preserved, labeled sample bottles supplied by the analytical laboratory. In order to obt ain 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 immers ing 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 w ill continue until all of the sample bottles have been filled. Upon completion of the sampling even t, 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 cust ody 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 freque ncy 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 d eepwell control room. SPL contains a very small amount of suspended solids and is injected in termittently because Burns Harbor continues to pursue recycling options. Therefore, this samp le 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 dr ainpipe using a dedicated long-handled polyethylene dipper. The sample collector w ill 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, pre-preserved, labele d 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 sam pling 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 Ga lesville 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-127-1W-0001

In accordance with the “Drilling, Testing and Operational Plan” for the Galesville Sandstone Groundwater Monitoring Well (February, 1991), the sa mpler will arrive at the well site and determine the static water level within the well. Upon obtaining th e 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 c onductivity, 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, prepreserved, labeled sample bottles supplied by the analy tical 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 hi s 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 – ArcelorMi ttal 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 dir ectly 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 decont amination of the sampling equipment is not

necessary.

2. Trip Blanks Each time a group of sample bottles is prep ared 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 bl ank 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 and returned (unopened) to the laboratory in a manner identical to the handling procedure used for the e nvironmental 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 id entified and corrective action will be initiated.

3. Duplicate Samples and Field Blanks

• Duplicate Analysis: Duplicate sample s will be obtained dur ing each quarterly sampling event of the Galesville groundwater monitoring well. One duplicate sampleIN-127-1W-0001

of either the WAL or SPL during each monthly sampling event will be collected. The duplicate samples will be analy zed 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. Th ese 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 du e 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, th e individuals relinquis hing and receiving will sign, date and note the time on the record.

Samples will be properly packaged for ship ment 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 replacemen t 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 instrument s, 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. Th e field sampler will verify calibration of the instruments prior to beginning the sample event a nd 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 laboratory will be conducted following the general procedures below, although internal la boratory procedural documen tation 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.IN-127-1W-0001

Data reduction reporting procedures will be those specified in the SW-846 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, bu t 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 quantitati on 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 sa mple 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: prog ram quality assurance and analytical method quality control.

The analytical laboratory will have a wr itten Quality Assurance / Quality Control program, which provides rules and guidelines to en sure 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 Assuran ce 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 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 laborat ory 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 procedur es 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 a nd 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 nonconformance with the QC criteria will be reanal yzed 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 document ation 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.IN-127-1W-0001

9. Corrective Actions Corrective actions will be implemented when any aspect of the analytical or sampling method does not achieve the project objectives. Th is may entail re-sampling and/or reanalyzing (for a particular parameter) the waste streams, re -calibrating 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 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/LIN-127-1W-0001

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-0001

Table 3 - Estimated Quantitation Limits (EQL’s) for Targeted Pa rameters 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 0 F 2 0 F 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-0001



### ATTACHMENT E

GROUNDWATER MONITORING REQUIR EMENTS for the GALESVILLE
SANDSTONE GROUNDWATER MONITORING WELL

1. Galesville Sandstone Gr oundwater Monitoring Well

Operation of the Galesville Sandstone Groundwat er Monitoring Well (Galesville well) is a condition (Condition #3) of the existing exemption fr om the land disposal restrictions of the 1984

Hazardous and Solid Waste Amendments to the Re source 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 c ondition remains in force, the requirement for the permittee to operate and monitor the Galesville well continues.

The Galesville Sandstone Groundwat er Monitoring Well (Gal esville well) is lo cated approximately 100 feet west of the Waste Ammonia Liquor Injection Well #2 (U.S. EPA Permit #IN-127-1W0004). The Galesville well monitors the Galesville Sandstone formation, th e first aquifer overlying the injection zone, between the depths of 1921 a nd 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 record ing pressure measurements of the Galesville

Sandstone formation and collection of connate water samples from the Galesville Sandstone formation for chemical analysis. The specifi c monitoring and reporting requirements for the

Galesville well are described in Part s III(E)(2) through (6) of this permit.

2. Galesville Sandstone Formation Water Sampling

Each quarter, the permittee shall co llect water from the Galesville well for the purpose of chemical analysis. The permittee shall analyze the water sa mples 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 gather ed since the well was first sample d in 1995 plus the first eight, independent, and statistically va lid analytical results for each parameter obtained after the effective date of this permit shall be used to es tablish 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 ti me 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 Li mits to establish the permissible amount of variance that subsequent results may exhi bit 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 permitt ee 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 eachIN-127-1W-0001

parameter detected during establishment of the base line shall take place at least quarterly. The

minimum detection threshold values in the Wa ste 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 electe d by the permittee to investigate an out-of-range value, the third consecutive valu e of any single parameter that is outside the limits established

under the Shewart CUSUM tables shall be consid ered 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 certa inty 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 sa mples analyzed quarterly as specified in Part II(D)(2) of this permit. Each re port shall include graphical illustra tion of the parameter values as a function of sample date, showing all samples take n during the life of the Galesville well. Upon written request from the Director, the permittee sh all provide laboratory reco rds of analyses which may include electronic tapes with spectral files to independently ve rify the analytical results of samples taken for organic chemistry, or other standard la boratory records.

4. Pressure Sampling

The Galesville well shall maintain a capability to measure pressure in the Galesville Sandstone Formation. Formation pressure shall be continuous ly 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 co rrect each recorded formation pressure value for changes in simultaneous barometric pressure valu es. 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.

The permittee shall calibrate all gauges in use for pressure measurements at the Galesville well at least annually. The calibration sh all ensure that the precision value of 0.1 psi is maintained.

5. Reporting Pressure Data

The permittee shall report values of Galesville Form ation pressure data each month as specified in Part II(D)(1). Each report shall include a tabu lation and graphical representation of the daily maximum values for the Galesville Formation pre ssure, the barometric pressure, and the maximum injection pressure recorded from any well injectin g waste ammonia liquor on that day. Each report shall also include a graph showi ng 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 fl uctuations in the Galesville Formation pressure and the injection pr essure(s) clearly.

6. Mechanical IntegrityIN-127-1W-0001

The Galesville well shall maintain mechanical in tegrity to ensure that chemical and pressure samples taken from the well are representative of th e Galesville Sandstone Formation. In order to

determine that the well maintain s mechanical integrity, the pe rmittee shall conduct a standard annulus pressure test at least onc e every twelve months. The standa rd annulus pressure test must be witnessed by an authorized repr esentative of the Director unless it proves impossible to resolve scheduling conflicts between the op erator and the agency. In orde r to conduct testing without a USEPA representative, the procedures discusse d in Section I(H)(1) must be followed. The minimum annulus test pressure shall be 300 psi a nd 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 repor t of such failure shall

be made to the Director within 24 hours of the fa ilure 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 inte grity 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 Di rector for approval at least 30 days in advance of the scheduled date to commence the well workover. Each workover

shall conclude with a demonstrati on of mechanical integrity as speci fied 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).

8. Plugging and Abandonment

The Galesville well shall remain act ive 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 identif ied 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 Gale sville 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 th an sixty calendar days be fore 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 th e well. The permittee shall maintain an adequate financial mechanism to properly plug and abando n 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 adju sted as needed each year. The permittee shall, within 45 days of its comple tion, submit a report of the pl ugging and abandonment of the

Galesville well.IN-127-1W-0001



## 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 Resource Conservation a nd Recovery Act (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 enviro nment, 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 su ch actions. You are not relieved of any responsibility to clean up a release that has migrated beyond the f acility boundary where offsite access is denied.

C. CORRECTIVE MEASURES IMPLEMENTATION

1. The permittee submitted a Corrective Measures Implementation (CMI) Workplan to EPA for approval. This workplan describes the groundwat er monitoring program that will be used to evaluate the plume stability demonstration at nor th 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 th e existing and future groundwater monitoring network, constituents for analysis, sampling and reporting schedule, and criteria for termination of the program. Procedural, quali ty control and administrative func tions were also addressed in the Workplan as well as a schedule for im plementation of the groundwater monitoring program. The Workplan was approved by EPA on November 14, 2006. The permittee shall implement the work required under the appr oved 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 EPA for approval. For the south facilit y, corrective action is regarded as “complete with controls,” and the outlined conditions represent the necessary controls. Permittee sh all comply with the following conditions:

(a) On-site land use shall be limited to indus trial purposes until the pe rmittee can demonstrate

that levels of contaminants in so il are protective for other land uses;

(b) Groundwater underlying the Fa cility within the shallow a quifer shall not be used for consumptive purposes unless levels of contam inants are stable and below appropriate screening levels and shall not be used fo r direct contact purposes unless levels ofIN-127-1W-0001

contaminants are below industrial screening levels;

(c) The permittee submitted a notic e to be filed in the office of the Porter County Recorder for

all successors-in-title th at the Facility is subject to th e conditions of this permit for 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 EPA.

(d) Permittee intends to reserve in any future c onveyance by permittee of an interest in all or part of the property the right to enforce the restrictions a nd covenants in the restrictive covenant for ArcelorMittal Burns Harbor, LLC and 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 pur poses. Prior to any such transfer, deed restrictions (including a restrict ive covenant) shall be created and recorded that are specific to the designated parcel. The deed restri ctions shall provide th at 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 EPA. The transferee would assume primary responsibility for maintaining the required institutional cont rols in accordance with the

restrictive covenants se t forth in the deed.

3. The permittee shall conduct regular cap inspecti ons and perform a maintenance program at IA3 following a schedule, procedures and correctiv e measures as described in the CMI Work

Plan.

4. The permittee has provided financial assuran ce in the amount specified by the Regional Administrator for necessary corrective measures activities, based on cost estimates and other relevant information, as require d by 40 CFR 264.101(b) and (c).



### D. NEWLY IDENTIFIED SWMUs OR RELEASES

The permittee must notify the Regional Administrato r 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.

E. CORRECTIVE ACTION FOR NEWLY IDENTIFIED SWMUs AND RELEASES

The Regional Administrator will review the info rmation 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 Regi onal Administrator that furthe r investigation is necessary.

F. DISPUTE RESOLUTION

1. If the permittee disagrees, in whole or in part , with EPA’s disapproval or modification of any submission required by this Section of the perm it, the permittee must notify the EPA of its objections by providing the Regi onal Administrator a written st atement of position within 14 days of receipt of EPA’s disapproval or modi fication. The permittee’s statement of positionIN-127-1W-0001

must set forth the specific matters in dispute, and the position that th e permittee asserts should be consistent with the require ments of this permit. The pe rmittee’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 fr om EPA’s receipt of its position statement to meet or confer with EPA to attempt to resolv e 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 agreemen t with 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 c ondition of this permit, and the permittee must comply with the terms and conditions of EPA’s decision resolving the dispute.

4. Not withstanding the invocation of this disp ute resolution procedure, the permittee must proceed to take any action required by those por tions of the modified and approved submission that EPA determines are not substantially affect ed by the dispute. This action must follow the

schedule contained in the submission.IN-127-1W-0001



### ATTACHMENT G

Spent Pickle Liquor Waste Minimization and Practicability Certification

Spent Pickle Liquor (SPL) is generated as a by- product of the steel sheet pickling operation. The continuous pickling operation used a hydrochloric acid solution, in a cascading (e.g., counter-current flow) system, to remove scale and rust from the steel strip prior to further finishing.

SPL is a listed hazardous waste (40 CFR 261, Code K 062) when disposed. The SPL contains a high percentage of iron, some trace metals consistent with the composition of the steel being pickled, chloride salts and some free hydrochloric acid. The SPL has a relatively high specific gravity (typically 1.20 to 1.30).

The Burns Harbor division generates a very clean SPL with very low concentrations of trace metals. This makes the material ideally suited as a substi tute for commercial products that are used at municipal wastewater treatment plants fo r sludge conditioning and phosphorous removal.

Bethlehem Steel continues to activ ely pursue the sale of this by-product to municipal wastewater treatment plants. Only that portion of the SPL that cannot be marketed as a by-product is injected into the deepwell.

This Waste Minimization Certification was submitted September 18, 2001.IN-127-1W-0001



### ATTACHMENT H

SPENT PICKLE LIQUOR CORROS ION MONITORING PLAN and
COMPLIANCE SCHEDULE

1. Two sealed access panels with screw-on caps will be installed on the injection line downstream of the injection pumps.

2. Two (2) screw cap assemblies with coupons perman ently affixed to the caps will be prepared. One will have a fiberglass-reinforced plas tic (Red Box 2000) coupon and one will have a Hastelloy C-276 coupon.

3. The new coupon assemblies will be processed usi ng the following procedure before installation.

(a) Rinse coupon and cap with distilled water. (b) Dry in a 103 ° C oven for at least 2 hours. (c) Remove from oven and allow to cool to room temperature in a dessicator. (d) Weigh the coupon on a certified scale to ±0.01 grams.

4. The coupon assemblies will be installed in the a ccess panels using the screw-on caps. (Note: insure that the injection pumps are o ff and flagged out during installation.)

5. Once per calendar quarter, the coupons will be re moved, visually inspected for cracking are any other physical abnormalities and subjected to the processing outlined in step 3 above.

6. Report the results of the insp ection and processing to EPA.

This Corrosion Monitoring Plan is to be implemente d within 90 days of the effective date of this permit.