ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

1021

NORTH

GRAND

AVENUE

EAST,

P.O.

Box 19276,

SPRINGFIELD,

ILLINOIS

62794-9276, 217-782-3397

JAMES

R.

THOMPSON

CENTER,

100

WEST RANDOLPH,

SUITE

11-300,

CHICAGO,

IL 60601, 312-814-6026

ROD

R.

BLAGOJEVICH,

GOVERNOR

RENEE

CIPRIANO,

DIRECTOR

CLERK’S OFFICE

FEB

-

62004

(217)

782-5544

STATE OF ILLINOIS

TDD:

(217) 782-9143

POllution Control Board

February 4, 2004

Dorothy Gunn, Clerk

Pollution Control Board

100 West Randolph Street

Suite

11-500

Chicago,

IL

60601

RE:

NOTICE OF PROVISIONAL VAIUANCE DENIAL-PV-04-O1

ISG

Hennepinl1558010006-Putnam County/Compliance

DLC File #14-04

Dear Ms. Gunn:

Pursuant to Subsection

37(b)

ofthe Environmental Protection Act (415

JLCS

5/37(b)),

attached is a copy of the

Illinois EPA’s recent denial of a request for provisional variance.

As you know, the Board must maintain for

public inspection copies ofall provisional variances filed with it by the Illinois EPA.

Please

feel free to call me

at the number referenced above should you have any questions.

Sincerely,

Todd Rettig,’ Mgr.

BOL

Section

Division of Legal Counsel

Attachment

ROCKFORD —4302

North Main Street, Rockford,

IL 61103

—

(815) 987-7760

•

DES

PLAINES

—9511

W. Harrison

St.,

Des Plaines,

IL

60016

—

(847) 294-4000

ELGIN

—

595

South State,

Elgin,

IL 60123

—(847) 608-3131

•

PEORIA —5415

N. University St.,

Peoria,

IL 61614— (309) 693-5463

BUREAU

OF

LAND

-

PEORIA

—

7620 N.

University St.,

Peoria, IL 61614— (309) 693-5462

•

CHAMPAIGN —2125

South First Street, Champaign,

IL 61820— (217) 278-5800

SPRINGFIELD

—4500 S.

Sixth Street Rd., Springfield,

IL 62706 —(217) 786-6892

•

COLLINSVILLE

—2009 MalI

Street, Collinsville,

IL 62234 —(618) 346-5120

MARION

—2309 W. Main

St.,

Suite 116, Marion,

IL 62959 —(618) 993-7200

PRINTED

ON

RECYCLED

PAPER

---

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

1021

NORTH

GRAND

AVENUE

EAST,

P.O.

Box

19276,

SPRINGFIELD,

ILLINOIS

62794-9276, 217-782-3397

JAMES

R. THOMPSON

CENTER,

100 WEST RANDOLPH,

SUITE 11-300, CHICAGO,

IL 60601,

312-814-6026

ROD

R.

BLAGOJEVICH,

GOVERNOR

RENEE CIPRIANO,

DIRECTOR

(217) 782-5544

TDD:

(217) 782-9143

February 4, 2004

Mr. Cory J. Peruba

Environmental, Health

& Safety Manager

International Steel Group

R.R. #1,

P.O. Box

325

Route 71

& 1-180

Hennepin, Illinois 61327

-

Re:

PROVISIONAL VARIANCE DENIAL

-

PV-04-O1

ISG Hermepinl 1558010006-Putnam County/Compliance

DLC File #14-04

Dear Mr. Peruba:

The Illinois Environmental Protection Agency (“Illinois EPA”) is in receipt ofyour letter dated

December 29,

2003, and received by the Illinois EPA on January 5, 2004, in which you request a

provisional variance from UIC

Pern-iit, UIC-004-W1-JL condition which requires Mechanical

Integrity Testing of ISG Hennepin’s Class I Injection Well No.

1

during calender year 2003.

Pleasebe advised this request for a provisional

variance is denied.

The materials submitted by

ISG Hennepin in support oftheir request for a provisional variance fail to demonstrate that the

conditions of UTC

Permit, UIC-004-W1-JL would impose an arbitrary orunreasonable hardship.

You may seek a regular variance by petitioning the Illinois Pollution Control Board pursuant to

Section

35(a)

of the Act.

Sincerely,

Todd Rettig, Ivjgf’~

BOL Section’

Division ofLegal Counsel

ROCRPORD

—4302 North

Main Street, Rockford,

IL 61103

—

(815) 987-7760

•

DES

PLAINES

—9511

W.

Harrison

St.,

Des

Plaines, IL 60016

—

(847) 294-4000

ELGIN

—595 South State,

Elgin,

IL 60123 —(847) 608-3131

•

PEORIA

—5415

N. University

St.,

Peoria, IL 61614— (309) 693-5463

BUREAU OF

LAND

-

PEORIA

—7620 N. University

St.,

Peoria,

IL 61614— (309) 693-5462

•

CHAMPAIGN

—2125 South First Street, Champaign,

IL 61820— (217) 278-5800

SPRINGFIELD

—4500 S. Sixth Street

Rd., Springfield,

IL 62706 —(217)

786-6892

•

COLLINSVILLE

—2009 MaIl

Street, Collinsville,

IL 62234 —(618)

346-5120

MARION

—

2309 W. Main

St.,

Suite

116, Marion,

IL 62959 —(618) 993-7200

DO..

~-..,‘,..

,-~,..,

OCrVrI

Cr,

Papco

---

International Steel Group

Hennepin,

Inc.

RR #1,

P0

Box 325,

Rt.

71

&

-180,

Hennepin,

Illinois 61 327

December 29, 2003

Illinois Environmental Protection Agency

Division ofLandPollution Control

1021 N. Grand Avenue East

Springfield, II

62702

ATTN.

Mr. Todd Rettig

Re:

Application for a Provisional Variance from the Annual and Five Year Mechanical Integrity

Testing Requirements of ISG Hennepin’s Class I Injection Well No.

1,

Permit No.

UIC-004-W1-JL

Dear Mr. Rettig:

ISG Hennepin

Inc.

(ISG)

is

applying

for a Provisional Variance to the mechanical

integrity testing

requirements ofthe facility’s UndergroundInjection Control Well No. WDW-1-(InjectionWell No.

1)

and

Galesville Monitor

Well

(Monitor

Well).

UTC

Permit,

T.JIC-004-W1-JL,

requires the

annual

mechanical

integrity testing

listed

in

Sections

I, Permit

Conditions

(H)(30)

for the

WDW-1

and

Attachment G, (1

5)(d)

specifies a series ofmechanical integritytests required every five years on the

Monitor Well.

ISG is requesting a variance from the mechanical integrity testing required by Permit

No.

UTC-004-W1-JL for the calendar year 2003.

The Provisional Variance is requested to allOw the

review

of ISG’s

permit

modification

request

submitted

to

the

illinois

Environmental

Protection

Agency

(IEPA),

Division of Land

and

Pollution

Control

on

September

19,

2003.

In the

permit

modification,

ISG is

requesting that the permit be

amended

to

be

in

line

with the current state

and

federal criteria and standards formechanical integrity testing.

The primary reason

for requesting the

Provisional

Variance

is

to

obtain

relief

from

the

five-year

mechanical integritytests on the Monitor Well until JEPA rules on ISG’s permit modification request.

The five-year mechanical integrity tests

are due in the calendar year 2003,

and will not be

due again

until

the year

2008.

The

five-year

testing

currently required on

the monitor

well

submits

ISG

to

significant risk and cost during the workoverrequired to perform the specified logs on the well.

ISG

proposes to perform the 2003 mechanical integrity testing on both wells within 30 days ofIEPA ruling

on

the permit

modification request.

If the

permit

modification is

approved,

ISG

will

perform

the

testing

according

to

the

testing

requirements

included

in

the modified

permit

and,

if the permit

modification is denied, ISG will perform the testing currently specified in the UTC Permit,

UTC-004-

W1-JL.

ISG

operates a

Class

I hazardous

injection well

for the disposal of pickling and

galvanizing

waste

generated during the manufacture ofsteel at ISG Hennepin Inc.

The injection well is permitted for the

disposal of6,701,400

gallons ofwastewater per month.

The injection well is located

390 feet north

and 191

feet west ofthe southeast corner of the southwest quarter of the southwest quarter ofSection

3, Township 32 North, Range 2 West ofthe 3~

Principal Meridian, Putnam County, Illinois.

WDW-1

is permitted for injection into the Mt. Simon interval.

The injection zone is defined as extending from

the

top

the Lomard Dolomite

Member at ±2,902feet

to

the base

of the

Mt.

Simon

Sandstone

at

---

•

Page2

±4,868

feet.

The monitor well was designed and completedin the Galesville formation at ±2,708

feet,

which is

the

first permeable zone immediately overlying

the

confining zonein WDW-1.

The variance will not result in any adverse environmentalimpacts.

The variance

is requested to allow

an

extension

so

that

the

EPA

can

complete the

review

of ISG’s

permit

modification

prior

to

perfonning the facilities required 2003 mechanical integrity testing.

The permit modification request

was submitted to remove unnecessary, risky,

and expensive annual and five-year mechanical integrity

tests from the permit.

The additional testing on the monitor well will result in an estimated additional

cost to

ISG of approximately $70,000.

ISG-Hennepin, Inc. is having a difficult time turning a profit

and this additional cost would be very difficult (and unnecessary) to absorb.

ISG hasnot applied for orbeen granted a provisional variance within the calendar year.

Permit ModificationRequestJustification

ISG’s

UIC

permit

includes

requirements

to

perform

annual

and

five

year

mechanical

integrity

temperature surveys on Injection Well No.

1 and to pull the tubing and packer at least once every five

years to run a cement bond/evaluation log and casing inspection log on both wells.

The permit

also

requires that

an Oxygen Activation (OA) Log be performed every five years on the Monitor Well:

These requirements

exceed the illinois EPA and US EPA Underground Injection Control Criteria and

Standards

for mechanical

integrity testing of Class

I Hazardous Injection

Wells.

ISG

submitted

a

permit modification request to amend the

permit to

be in line with the

state and federal

criteria and

standards formechanical integritytesting.

The

mechanical

integrity

testing

requirements

in

35

illinois

Administrative

Code,

Section

730.1 68(d)(3) and (4) for temperature and casing inspection logs for Class I Hazardous injection wells

are presentedbelow:

3)

An

approved

temperature,

noise,

or other approved

log must be run

at

least once every

five years. to test for movement offluid alongthe borehole.

The Agency mayrequire such

tests whenever thewell is worked over;

4)

Running casing inspection logs.

A)

Casing

inspection logs

must be

run whenever the owner or operator conducts

a

workover in which

the

injection

string

is

pulled,

unless

the

Agency by

permit

allows otherwise:

i)

due

to

well

construction

or

other

factors

that

limit

the

test’s

reliability, or

ii)

based on the satisfactory results ofa casing inspection log run within

the previous five years.

The federal mechanical integrity testing standards for Class I Hazardous Injection Wells is included in

40 CFR

§

146.68(d).

The requirements for running a temperature log and casing inspection log are in

§l46.68(d)(3) and

(4),

and are presented below:

3)

An approved temperature, noise, or other approved log shallbe runat least once every five

years to

test for movement of fluid along the borehole.

The Director may require such

tests whenever the well is worked over;

---

•

Page3

4)

Casing inspection logs shall be run whenever the owner or operator conducts a workover

in

which the injection string is pulled, unless the Director waives the requirement due

to

well construction or

other

factors

which

limit the

test’s

reliability,

or

based

upon

the

satisfactory

results

of a

casing

inspection

log run within the

previous

five

years.

The

Director mayrequire that a casing inspection log be run every five years, if he has reason

to believe that the integrity ofthe long string casing ofthe well maybe adversely affected

by naturally occurring or man-made events;

Injection Well No.

1

UIC Permit, UTC-004-W1-JL, requires the following mechanical integrity testing in Sections I, Permit

Conditions

(H)(30)(c),

(f),

and

(g)

for Injection

Well

No.

1

which

exceed

the

state

and

federal

standards and are overly burdensome and expensive forISG:

c)

The

Permittee will

demonstrate

the

absence of significant

fluid

movement

into

an

underground

source

of

drinking

water

through

vertical

channels

adjacent

to

the

injection wellbore by use ofa temperature log to be conducted annually and whenever

the well is worked over.

f)

A cement bond log/evaluation will be run in the entire length ofthe long string casing

at leastonce every five years.

-

g)

A

casing

inspection

log

will

be

run

with

the

cement bond

log

to

determine

the

thickness and condition ofthelong string casing at least once every fiveyears.

The state regulations require that a temperature survey be performed at least every five years arid state

that the director may require a temperature survey when a workover is performed on the well.

ISG

requested the following changes in thepermit modification request to Pen-nit Condition (H)(30)(c):

c)

The

Permittee

will

demonstrate

the

absence

of

significant

fluid

movement

into

an

underground source of drinking water through vertical channels adjacent to the injection

well bore by use ofa temperature log to be conducted at least once every five years

and

whenever thewell is worked over.

The state regulations require that casing inspection logs shall be run whenever the owner or operafor

conducts a workover in which the injection string is pulled, unless the Directorwaives the requirement

due to well construction or other factors which limitthe test’s reliability, orbased upon the satisfactory

results of a

casing inspection log

run within the previous

five

years.

ISG requested the

following

changes in the permit modification request to Permit Conditions (h)(30)(f) and (g):

f)

A cement bond log/evaluation will be run whenever the owner or operator conducts a

workover

in

which

the

injection

string

is

pulled,

unless

the

Director

waives

the

requirement due to

well construction or other factors which limit the test’s reliability,

or based upon the satisfactory results of a cement bond log/evaluation run within the

previous five years.

The Director may require that a cement

bond log/evaluation be

run every

five years, if he has reason to believe that the integrity ofthe cement in the

long string casingborehole annulus ofthe well maybe adversely affected by nsturally

occurring or man-made events.

g)

A

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

the

---

•

Page4

requirement

due to

well construction or other factors which limit the test’s reliability,

or based upon the satisfactory results ofa casing inspection log runwithin theprevious

five years.

The Director may require that a casing inspection

log be run every five

years, if he has reason to believe that the integrity ofthe long string casing of the well

may be adversely affected by naturallyoccurring orman-made events.

Galesville Monitor Well

UIC

Permit, UTC-004-Wl -JL,

Attachment G,

(1

5)(d)

specifies a series of mechanical integrity tests

required every five

years

on

the Monitor

Well.

The

five-year mechanical

integrity tests

currently

required are listed below:

i.

Oxygen activation log

ii.

Annulus pressuretest of300 psi for one hour

iii.

Cement bond log

iv.

Casing inspection log

v.

Multi-finger mechanical caliper

The

testing

listed above

far

exceeds the

five-year

mechanical integrity testing required of a Class I

Hazardous

Injection

Well

by

illinois

EPA

or

USEPA

Standards.

The

standards

for

a

Class

I

Hazardous Injection Well do not require that the tubing and packerbe removed from a well to perform

mechanical

integrity testing,

unless

the Director has reason to

believe

that the integrity of the long

string casing ofthe well may be adversely affected by naturally occurring or man-made events.

-

Why

should a major workoverbe performed on a monitor welljust to run mechanical integrity logs when it

is not required ofa Class IHazardous InjectionWell?

The wellwas installed to monitor the formation pressure and constituents in the first aquiferabove the

Injection Zone, the Galesville Formation.

The well is designed to monitor the formation pressure and

to sample the formation fluid from the Galesville Formation.

Thepermit also requires that the tubing-

casing annulus

be pressure tested to

300 psi

to

verify the

mechanical

integrity of the well tubulars

prior to

collecting a formation sample.

The well is not a dynamic injection well subject to elevated

pressures

and erosion

from the injection of waste fluids, but is

a static well designed to

monitor the

formation pressure and to collect quarterly samples offormation fluids.

The formation pressure in the

Galesville interval is continuously monitored by the well.

The

mechanical

integrity of the

Monitor

Well

is

verified

by

the

continuous

monitoring

of the

Galesville

formation

pressure,

quarterly

annulus

pressure

tests,

and

the

quarterly

fluid

samples

collected

and

analyzed from the

interval.

The

loss of the mechanical

integrity of the well will

be

detected during pressure monitoring by a change in

formation pressure, during the quarterly annulus

pressure tests,

or during

the analysis of the

quarterly

fluid

samples

collected

from

the

Galesville

Formation.

Fluid samples are analyzed for the constituents listed in Attachment D ofthe permit.

The process of pulling the tubing

and packer to perform an oxygen activation log, cement bond

log,

casing inspection log,

and multi-finger mechanical caliper log on the Monitor Well is

not necessary

and also interferes with the designed purpose ofcontinuously monitoring the formation pressure and

sampling

the formation fluids

for constituents

on

a quarterly basis.

The required workover and the

logging

include

a

significant

risk

of

introducing

constituents

to

the

monitored

interval.

The

---

•

PageS

continuous

pressure monitoring

will

be

interrupted

unnecessarily,

and

most

likely

will

be

slightly

shifted

due

to

errors

associated

with

the removal

and

reinstallation

of

the

pressure

monitoiing

equipment.

The mechanical integrity of the Monitor Well is verified

continuously by the formation

pressure monitoring and

quarterly during

each sampling event.

The required five-year mechanical

integritytesting on thewell is not needed, is detrimental to the design purpose forthe well installation,

and is extremely expensive and risky for the

operator.

ISG requested the following changes to

LTIC

Permit, UIC-004-Wl-JL, Attachment G,

(l5)(d)

in the permit modification request:

d.

Every yearthe mechanical integrityofthe well will be verified by an annulus pressure

test

to

300

psi

for one

hour.

The Director may require additional

tests such

as

an

Oxygen Activation

Log,

Cement

Bond

Log,

or Casing

Inspection

Logs, if he

has

reason

to

believe

that

the integrity of the

long

string

casing

of the

well

may

be

adversely affected by naturallyoccurring orman-made events.

ISG

has

requested

that

these

modifications

be

made

to

Permit

No.

UTC-0004-Wl-JL

prior

to

performing the

2003

mechanical

integrity testing

on the facility’s

wells.

ISG plans to

schedule the

2003 testing immediately afler receiving IEPA’s decision on the requested testing.

ISG is requesting relieffrom performing the 2003 annual and five-year mechanical integrity tests until

IEPA

rules on

ISG’s permit modification request.

ISO is

requesting a Provi~ionalVariance to

the

performing the 2003

mechanical integritytesting ofthe facility’s Underground Injection Control Well

No. WDW-l

and Galesville Monitor Well while ISG’s permit modification request submitted to the

Illinois

Environmental

Protection

Agency

(EPA),

Division

of Land

and

Pollution

Control

is

reviewed.

ISG

appreciates your consideration of the requested Provisional

Variancc.

Mr.

Steve Nightingale

(RCRA Unit

Manager) and

Ms.

Rebecca Vershaw (Environmental Protection

Geologist, BOL) are

both aware and have expressed support of our position. Please do not hesitate to contact either if you

have

any questions. If you have any questions

or need

additional information, please contact me at

(815)

925-2133.

Respectfu

Cory J.

Peruba

Environmental, Health,

& Safety Manager

Cc:

Ms.

Rebecca Vershaw

IEPA-BOL

Field Operations Section

4302 North Main Street

Rockford,

Illinois 61103

Mr. Steve Nightingale

IEPA-BOL

P.O.

Box 19276

Springfield,

II

62794-9276

Keith Nagle