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While these open well casings are on property owned by Powertech, these are not wells <br />that were drilled by Powertech or its contractors. In fact, the wells left unprotected were <br />drilled by previous exploratory efforts in the 1980s, and were uncovered by Powertech's <br />geotechnical teams while in the process of locating each bore site. <br />In response to these local community concerns with respect to the potential failures of <br />historic well abandonment, the applicant affirmatively committed to "ensuring that all wells on <br />its properties meet state and local safety requirements and standards." In issuing a permit for <br />injection of contaminated fluids, EPA should hold Powertech to its commitments to the local <br />community and require the applicant to submit this additional information of proper well <br />abandonment as part of the permit review process, and before the grant of any such permit. <br />With respect to the impacts associated with conductivity between aquifers via historic well <br />holes in the direct vicinity of the currently proposed aquifer pump test, Powertech simply asserts that <br />"the condition of the exploration boreholes and monitoring wells installed by others is unknown but <br />will be evaluated through ongoing monitoring during the pumping test and reinjection of the <br />produced fluid." Petrotek Report at 6. However, no information is provided as to what efforts <br />Powertech has made to assess the condition of these holes, what methodology Powertech proposes to <br />use in conducting these evaluations, nor why such information is unavailable from the previous pump <br />tests conducted in the vicinity. <br />In a similar manner, Powertech asserts that a "detailed review of available potentiometric- <br />level data for Section 33 monitoring wells shows the data to be consistent and does not indicate any <br />apparent anomalies, which may be caused by vertical leakage through artificial penetrations." <br />Petrotek Report at 6. Again, the data upon which this review was conducted was not included in the <br />submittals or otherwise publicly available, nor is the methodology or techniques used in conducting <br />such a review evident. As a result, the EPA's administrative record for this permit simply does <br />not contain the necessary data upon which assumptions were made, nor a description of the <br />16