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To be consistent with the position taken by EPA in the Responsiveness Summary, and to <br />protect USDWs by minimizing the potential for injectate to move along vertical channels <br />into the overlying Laramie Formation, the final permit should be modified to include the <br />requirement that Maximum Allowable Injection Pressure at the wellhead should be zero <br />psig. <br />CONCLUSION <br />Petitioner respectfully requests that the Board remand the Permit to EPA to make the <br />following modifications: <br />(1) Remove the section of permit condition E.1. allowing Permittee to modify injection <br />procedures. <br />(2) Rewrite permit condition EA to be more specific and to make a distinction between <br />confinement breaches that are serious enough to deny Authorization to Inject and those <br />that appear to be minor and require only additional monitoring. <br />(3) Rewrite permit condition E.S. to define "a significant increase" as an increase above 25% <br />of the background value, depending on evaluation of quality control sample results. <br />(4) Rewrite permit condition F.2. to require that the proposed injection well shall be <br />constructed in compliance with the requirements of the Colorado State Engineer and that <br />written evidence of such compliance shall be provided to EPA. <br />(5) Add a permit condition requiring that Maximum Allowable Injection Pressure at the <br />wellhead should be zero psig. <br />Respectfully submitted on December 3, 2011 <br />/s/ James B. Woodward <br />P.O. Box 599 <br />Wellington, Colorado 80549 <br />Phone 970-897-3029 <br />Fax 970-897-3021 <br />9