UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 8 1595 Wynkoop Street Denver, Colorado 80202-1129 http://www.epa.gov/region8 STATEMENT OF BASIS FOR UNDERGROUND INJECTION CONTROL CLASS V DRAFT PERMIT RENEWAL PERMIT NUMBER: MT50733-00000 Applied Materials, Inc. 655 West Reserve Drive Kalispell, Montana 59901 CONTACT: Omar Sierra-Lopez U. S. Environmental Protection Agency Region 8, 8WP-SUI 1595 Wynkoop Street Denver, Colorado 80202-1129 Telephone: (800) 227-8917 x 312-7045
Transcript
UNITED ST A TES ENVIRONMENTAL PROTECTION AGENCY REGION 8
1595 Wynkoop Street Denver, Colorado 80202-1129 http://www.epa.gov/region8
STATEMENT OF BASIS FOR
UNDERGROUND INJECTION CONTROL CLASS V DRAFT PERMIT RENEWAL
PERMIT NUMBER: MT50733-00000
Applied Materials, Inc. 655 West Reserve Drive
Kalispell, Montana 59901
CONTACT: Omar Sierra-Lopez U. S. Environmental Protection Agency
DESCRIPTION OF FACILITY AND BACKGROUND INFORMATION
On September 12, 2016, Applied Materials, Inc. submitted to the Environmental Protection Agency Region 8, a Permit renewal application for their Class V Underground Injection Control injection well. The Permit renewal, if issued, would authorize the discharge of deionized water, deionized water reject, water softener/conditioner backwash and laboratory rinse water into an active Class V shallow disposal system/injection wells located at 655 West Reserve Drive, Kalispell, Montana as shown in Appendix A, Figure 1.
Applied Materials, Inc. is a manufacturing facility that produces equipment for the semiconductor industry. The injectate consists of deionized water, deionized water reject, water softener/conditioner backwash and laboratory rinse water. The average daily injection rate is 1,440 gallons with a maximum of 3,000 gallons a day. The fluids are gravity fed to the disposal wells. There are three disposal wells on the property. East Dry Well 1 (MT50733-03707), East Dry Well 2 (MT50733-07380) and West Dry Well (MT50733-03630). The two East Dry Wells are interconnected via a six inch PVC line, see Appendix A, Figure 1 for the general layout of the facility. Water is collected in a Teflon container and pumped into two resin beds and then into two carbon media tanks. From the carbon tanks it is gravity fed to the East Dry Well 1/East Dry Well 2 through a two inch PVC pipe, double contained in six inch PVC pipe. The West Dry Well in gravity fed via a six inch PVC pipe. The six inch PVC pipe is now a double walled pipe to prevent accidental spillage.
Applied Materials, Inc. has submitted all the required information and data necessary for Permit issuance in accordance with Title 40 Code of Federal Regulations (40 CFR), Parts 144, 146 and 147. A Draft Permit was prepared. Public Notice of the Draft Permit will be published in the Daily Inter Lake.
Authorization to inject is issued for ten (10) years from the effective dat~ of the Final Permit (40 CFR, Section 144.36) unless the Permit is terminated (per Part III, Section B of the Permit). In the event primary enforcement authority (primacy) for the UIC program is delegated to the State of Montana, this Permit may be modified, reissued or terminated by the state. In the absence of such modification, reissuance, or termination, all requirements of this Permit remain in full force and effect. Should this program be so delegated, the EPA UIC Director will notify the Permittee of the name and address of the State UIC Program Director, and the date that primacy is effective.
This Statement of Basis gives the site-specific Permit conditions and reasons for them. Part III of the Permit includes general Permit conditions, for which the content is mandatory and not subject to site-specific differences (based on 40 CFR, Parts 144, 146 and 147); the general Permit conditions are not included in this discussion.
I. REASON FOR THE PERMIT
The UIC Program, created under the authority of the Safe Drinking Water Act (SDWA), is a preventive program tasked with protecting underground sources of drinking water (USDWs). Shallow disposal systems that discharge certain types of fluids into the subsurface are known as Class V wells. These disposal systems consist of subsurface fluid distribution systems defined as an assemblage of perforated pipes, drain tiles, or other similar mechanisms intended to distribute fluids below the surface of the ground ( 40 CFR Section 144.3). Class V wells with waste streams potentially containing constituents with Primary Drinking Water
Applied Materials, Inc. 655 West Reserve Drive
Kalispell, Montana 59901 Page 2 of4
Standards or Health Advisories that have the potential to contaminate or degrade groundwater are required to operate under a permit. Permit requirements generally include monitoring the concentrations of contaminants of concern in waste fluids being released into the subsurface. The permit may also include Best Management Practices designed to restrict or minimize the volume of contaminants released into the subsurface.
In order to demonstrate compliance with permit limits, analytical results of fluid samples must verify that all the analyzed constituent concentrations do not exceed the values established by permit limits. The permit limits have been established using Primary Drinking Water Standards, called Maximum Contaminant Limits or MCLs, for drinking water, Region 8 limits, and Health Advisories to prevent endangerment to USDWs. These constituents are included in Appendix B, of the Permit.
Best Management Practices
Applied Materials, Inc. will use best management practices, as defined in Part II, Section D.5 of the Permit, for the disposal of waste fluids into the Class V shallow disposal system. To reduce possible contamination of the wastewater, all accidental spills of fluids in the drywell area must be absorbed with an absorbent material and disposed of as a solid waste per the requirements of the Resource Conservation and Recovery Act (RCRA). The Permittee will inspect the Dry Wells monthly and repair and leaking piping as needed. Maintenance records shall be kept on site. These best management practices will significantly reduce the amount of contaminants migrating into the ground water.
II. AREA HYDROLOGY
Underground Sources of Drinking Water (USDWs)
A USDW is defined by UIC regulations as an aquifer, or a portion thereof, which contains less than 10,000 milligrams per liter total dissolved solids, and which is being used or could be used as a source of drinking water. Material at the ground surface is glacial material composed of unconsolidated sand, gravel, cobbles, silt and clay. There is a lower, unnamed artesian aquifer about 200 feet below the surface of the ground. The confining lay of clay about 100 feet thick, would not permit any downward percolation of water into the artesian aquifer. A drinking water well within ¼ mile radius of the Class V wells is owned by Applied Materials, Inc. and is upgradient from the West Drywell and downgradient from the East Drywells.
III. SAMPLING AND REJJORTING OF RESULTS
Shallow Injection Well Sampling Program
The Permittee is required to sample separately the West Drywell and the first of the two East Drywells. The Permittee is required to collect quarterly fluid samples from the West Drywell and the East Drywell 1. The sampling point for the West and East Drywells will be at the discharge pipe prior to entering the drywell. The list of constituents to be analyzed are Total Metals and Volatile Organic Compounds found in Appendix B, Tables I and 2 of the Permit. The
Applied Materials, Inc. 655 West Reserve Drive
Kalispell, Montana 5990 I Page 3 of4
sampling techniques utilized must be adequate to provide a representative sample of wastewater constituents and to allow the fluid sample to be analyzed using the EPA methods indicated. These constituents were selected for analysis based on their potential for deteriorating the aquifer quality. The analyzing laboratory will provide a written report of all the results and laboratory documentation of quality control.
Reporting of Results
The report ofanalytical results from first sample collected will be sent to the Director no later than one ( 1) week after the Permittee has received the analytical results from the laboratory. Subsequent reports are due no later than January 1, April 1, July 1 and October 1 of each year. The next sampling report is due September 1, 2017.
Water Quality of Waste Fluids
The facility has submitted the analytical results of the West Dry well and the East Dry wells fluids with the Permit renewal application. None of the constituents exceeded the Permit limits specified in Appendix B.
