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(2) Permit condition EA. requiring review of aquifer pump test results by the Director and <br />allowing "additional monitoring requirements" upon a finding by the Director that a <br />breach in confinement is indicated by the aquifer pump test results. <br />(3) Permit condition E.S. stating that the Director will review the analytical results from the <br />samples of stored groundwater and require that "corrective action" be performed if the <br />concentration of any analyzed constituent over the permit limit also shows a "significant <br />increase" from the levels measured in the groundwater sample described in Section <br />E.1(a). <br />(4) Permit condition F.2. requiring Permittee to demonstrate Part II Mechanical Integrity by <br />submitting to the Director a well completion report. <br />In addition, Petitioner believes the following new permit condition should be included in the <br />Permit: <br />(5) A condition specifying a Maximum Allowable Injection Pressure of zero psig at the <br />wellhead. <br />FACTUAL BACKGROUND <br />On April 30, 2009, EPA received an application for a Class V Underground Injection <br />Control (UIC) permit submitted by Permittee. Permittee proposes to reinject groundwater <br />pumped from the upper portion of the Fox Hills Formation during an aquifer pump test back into <br />the same aquifer using the pumping well that pumped the groundwater to the surface. EPA <br />issued a Final Permit to authorize the injection of groundwater back into the aquifer from which <br />it was pumped. The pump test and injection site is located in NE quarter of Section 33 in <br />Township 10 North and Range 67 West, Weld County, Colorado. This location is 17 miles <br />2