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. 1 ~ • ~~~ graphical and hydraulic character of each unique project. Adoption of standardized rules in some of the above areas appears to result in inadequate protection in some cases and may cause undue restraint in others. We recommend that MOE consider making chanyes in the review process of items (1), (3), and (4) above. These changes are described below. 6.5 Proposed Modifications to Present Rules and Procedures 6.5.1 Operatiny Fluid Levels; It is proposed that MUE consider some modification of the methods it uses to determine the operatiny pressures for individual infection wells. The maximum allowable operat- iny fluid level is presently set at the elevation of the land surface at the wellhead in the case of the two wells presently operating. A5 described in Chapter 5, aliowiny this operating level may, in some cases, involve some risk that injected or native brines could move upward in conduits throuyn the confininy beds and into underground sources of drinkiny water. (Insufficient data are available to deter- mine if this is true at presently operatiny wells.) This rule does not consider the density of the fluid in the wellbore, with the result that the maximum allowable bottom-hole pressure corresponds to the pressure that could be yenerated by a column of salt-saturated brine with a specific yravity of approximately 1.2, or up to 2UX more pressure than wouto exist at the base of a column of fresh to brackish water. Since, in a worst-case situation, this operatiny level could yener- I ate fluid levels in the disposal zone SU to lU0 feet (15 to 3U m) above land surface, it is important to perform a more detailed analysis of ' local conditions to determine the likelihood that this could occur, and in what size area, in order to yauye the possible effects on local ground-water resources. We propose that the object of such an analysis be the determination of the size of the "critical area" where water 1'l l