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EPA has determined that the injection activity will not endanger groundwater in the <br />injection zone, because it is the same water that was pumped from the injection zone. Nothing <br />will be added to the groundwater after it is pumped from the Upper Fox Hills Formation, and <br />before it is reinjected, that will change the water quality. Therefore, this Draft Permit has no <br />requirements for injectate sampling, analysis, and reporting of results to EPA <br />IV. REASON FOR THE PERMIT <br />The UIC Program, created under the authority of the Safe Drinking Water Act (SDWA), <br />is a preventive program tasked with protecting existing and future underground sources of <br />drinking water (USDWs). The UIC regulates the discharge of fluids into the subsurface through <br />injection wells. An injection well that discharges fluids into or above a USDW is a Class V <br />injection well. Class V wells injecting fluids containing constituents with Primary Drinking <br />Water Standard or Health Advisories may have the potential to contaminate or degrade <br />groundwater, and are usually required to operate under a permit. The groundwater being pumped <br />from, and reinjected into, the Upper Fox Hills Formation has higher concentrations of <br />contaminants regulated under the SDWA than the Laramie Formation. Because the injection well <br />will penetrate the Laramie Formation, EPA is issuing a permit for this injection activity to <br />establish well construction standards as permit requirements for the protection of groundwater in <br />the Laramie Formation from contamination resulting from the proposed injection activities. <br />V. INJECTION WELL CONSTRUCTION DESIGN <br />The permit requires that well construction design prevents movement of injectate <br />into the overlying Laramie Formation. EPA has evaluated the construction design plan that <br />Powertech has proposed for the injection well and has determined that the design is protective of <br />the Laramie Formation groundwater. The injection well will be constructed according to the <br />specifications shown in Figure 4. The cement between the well casing and the borehole wall will <br />prevent the movement of fluids along the injection well and will insolate the injection zone to the <br />"A" Sands of the Fox Hills Formation. Powertech proposed conducting mechanical integrity <br />tests on all wells associated with the aquifer pump test to demonstrate that none of the wells will <br />serve as conduits for the migration of fluids across the confinement zones. The aquifer pump test <br />will also verify the integrity of the injection well and the confining zones. <br />Statement of Basis <br />Powertech (USA), Incorporated. <br />UIC Class V Permit # C051237-08412 <br />Page 2 of 4 <br />Appendix 2