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present significant problems with respect to protecting underground sources of drinking water. <br />The EPA's 1980 Statement of Basis and Purpose (National UIC Program Docket Control <br />Number D 01079) provides a clear description of the problem, at pages 14-15: <br />One of the common ways by which fluids can enter an underground source of drinking <br />water is by migration through improperly abandoned and improperly completed wells. <br />This would occur if fluids moving laterally within an injection zone encountered an <br />improperly abandoned or completed well, and, following the path of least resistance, <br />flowed upward within the well until entering an overlying underground source of <br />drinking water or overflowing onto the land surface. Because of the large number of <br />wells drilled in the past, and because well operation and abandonment have not always <br />benefitted from close regulatory scrutiny, contamination by this route can present a <br />significant risk to public health. <br />[In the case of a potential problem], however, the well operator would be expected to <br />correct it. Correcting the problem could mean that the well operator would have to plug a <br />faulty well at his/her expense. <br />National UIC Program Docket Control Number D 01079, at 14-15 (attached as Exhibit 7). <br />In this case, the extent of the prior drilling in the area is highly significant. As <br />demonstrated by the attached map prepared by Powertech and altered only with respect to <br />identifying local roadways and the location of the injection well (section 33), and entitled "Topo <br />and Drill Hole Location Map, Indian Springs and Centennial Uranium Projects", there are <br />literally thousands of historic wells in the areas proposed by Powertech for in situ leach uranium <br />mining, and many wells in the area proposed for injection under the Draft Permit. (Map attached <br />as exhibit 9); see also Petrotek Report (Exhibit 6) at Figure 12-1. In order to discharge its duties <br />under the Safe Drinking Water Act and the APA, the applicant should be required to provide <br />information demonstrating that these wells have been properly abandoned in a manner that will <br />not allow for communication between the injection area and the overlying underground source of <br />drinking water. <br />13