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submit this additional information of proper well abandonment as part of the permit review <br />process, and before the grant of any such permit. <br />Overall, the SWDA and associated regulations provide that "no injection shall be <br />authorized by permit or rule if it results in the movement of fluid containing any contaminant <br />into Underground Sources of Drinking Water" 40 C.F.R. § 144.1(g). In order to ensure <br />compliance with the SDWA and EPA regulations, the applicant must present significantly more <br />detailed evidence with respect to the existence and potential cross-aquifer communication that <br />may result from these historic wells, and require proper abandonment be completed prior to <br />issuing a permit for injection. In fact, the applicant is on record as committing to However, as it <br />currently stands, the record is insufficient to demonstrate that the applicant can achieve the <br />protection of all USDW. As such, the strictures ofthe APA preclude the issuance of a permit in <br />this case until the applicant can provide sufficient evidence demonstrating the ability to comply <br />with applicable law. <br />Lastly, any permit issued should require complete reporting of water quality data <br />encountered before, during, and after the pumping and injecting. While any approved pump test <br />is ongoing, should any communication between aquifers be encountered, and the permit should <br />include a provision for re-assessment of the viability of injection pursuant to the permit, as this <br />new information would be critical to protecting underground sources of drinking water. Should <br />such cross-communication be discovered, the existing permit should be suspended or voided <br />pending additional review by the EPA. <br />Given the complexity of these issues, we continue to express a high level of concern with <br />the proposed reinjection activities, and based on the current record urge the EPA to deny the <br />proposed permit. At minimum, given the extensive amount of data and information that the EPA <br />requires (as identified herein) in order to process the proposed permit for injection, we hereby <br />request that the agency provide an additional public comment period to facilitate review of any <br />amended Draft Permit or Statement of Basis and Purpose that may be forthcoming in the future. <br />We understand that such additional review is not uncommon, and given the controversy <br />surrounding the impacts associated with Powertech's proposed activities, is entirely appropriate. <br />In addition, we are currently conducting ongoing research into such things as historic drilling <br />records in the area, and reserve the right to supplement these comments should additional <br />relevant information become available. Lastly, we hereby incorporate herein by reference all of <br />the public comments submitted in this comment period, to the extent these comments address <br />issues or detail facts or evidence not included herein. <br />We look forward to reviewing the EPA's responses to these comments, and please do not <br />hesitate to contact me directly with any questions regarding these comments. <br />Sincerely, <br />/s/ Jeffrey C. Parsons <br />Jeffrey C. Parsons