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ARGUMENTS <br />Petitioner makes the following arguments with respect to the permit conditions included <br />above: <br />(1) Permit condition E.1. allows the Director to add "additional monitoring requirements" <br />upon notice from the Permittee of "any modification in injection procedures that might <br />result in the potential for the injectate to move outside the A2 sandstone." The EPA has <br />taken 19 months to review the Permittee's proposed injection procedures. This should be <br />sufficient time to understand the potential of such procedures to result in the movement <br />of injectate outside of the A2 sandstone. Presumably, EPA has established permit <br />conditions that would prevent such movement. However, permit condition E.1. appears <br />to give Permittee the ability to modify its injection procedures in a way that might result <br />in a potential for the injectate to migrate into the overlying Laramie Formation, an <br />Underground Source of Drinking Water ("USDW"). Such a modification to procedures <br />could occur simply by the Permittee notifying the EPA, and would not be subject to <br />public review and comment. Since the Permit was written based on the injection <br />procedures proposed by Permittee, this section of permit condition E.1. is not protective <br />of USDWs and should be removed from the Permit. <br />(2) Permit condition E.4. requires review of aquifer pump test results by the Director and <br />allows "additional monitoring requirements" upon a finding by the Director that a breach <br />in confinement is indicated by the results. Such a breach in confinement between the A2 <br />sandstone and the overlying Laramie Formation creates the potential for the injectate to <br />migrate into a USDW. Permit condition E.4. is vague and makes no distinction between <br />4