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Therefore, the Final Class V Permit allows a maximum injection pressure of zero <br />at the wellhead. A pump will be used to move the stored groundwater from the <br />storage tanks to the wellhead. At the wellhead, the groundwater will be gravity <br />fed into the injection well. <br />On page 22, EPA responds to a commenter's question about confinement breaches: <br />Even if the aquifer-pump test identifies a breach in a confinement zone, as long as <br />injection into the Class V well is not under pressure, the proposed injection <br />activity will not result in any movement of groundwater across a confinement <br />zone that is not already occurring under present conditions. As stated above, the <br />Final Class V Permit limits the maximum allowable injection pressure to be zero <br />at the wellhead. <br />EPA must have thought this permit condition was important since it was discussed five <br />different times in the Responsiveness Summary. But oddly, the condition is missing <br />from the final permit. It is unclear if the omission was an oversight or was intentional. In <br />email communications following issuance of the final permit, EPA confirmed that "EPA <br />has committed to limiting the maximum allowable injection to zero pressure pounds per <br />square inch gauge (psig) at the wellhead." The email states that the requirement will be <br />specified in the Authorization to Inject, but EPA appears to leave the door open to a <br />different requirement based on the results of the aquifer pump test: <br />The details of this plan, and the Authorization to Inject requirements are very <br />much dependent on the data produced by the aquifer pump test. DRMS and EPA <br />will review the data and impose requirements for reinjection based on the aquifer <br />characteristics. <br />8