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end December 24, 2009. Petitioner again timely submitted comments on the re-issued Draft <br />Permit. December 24, 2009 CARD comment letter attached (without exhibits) as Exhibit 3. <br />EPA issued a Final Permit on December 3, 2010. <br />An individual permit was necessary in this case because of the risk of contamination to <br />underground sources of drinking water. Powertech proposes conducting an aquifer pump test <br />which will involve pumping groundwater from the A2 sandstone within the Upper Fox Hills <br />Formation. While the injection well is screened only within the A2 sandstone aquifer in the <br />Upper Fox Hills Formation, the injection well intersects the overlying Laramie Formation, which <br />holds aquifers that provide underground sources of drinking water. As explained by EPA: <br />The groundwater in the A2 sandstone contains concentrations of constituents regulated <br />under the Safe Drinking Water Act (SDWA) that exceed drinking water standards. These <br />constituents include uranium, antimony, and radium The Laramie Formation contains <br />aquifers that do not exceed the SDWA drinking water standards for uranium, antimony, <br />and radium. The main purpose of the UIC Class V Permit is to protect the aquifers in the <br />Laramie Formation from contamination during injection. <br />Responsiveness Summary for the UIC Class V Final Permit Decision, at 1 (attached as Exhibit <br />4). <br />In issuing the Final UIC Permit, EPA deliberately refused to review critical and relevant <br />information upon which the EPA based its fundamental conclusions that the injection permit <br />would be protective of underground sources of drinking water. This information includes <br />existing data in the possession of the applicant derived from the applicant's previous aquifer <br />pump tests conducted in the same area and geologic formations as the proposed reinjection well. <br />This prior pump test data formed the basis of the applicant's expert conclusions included in the <br />permit application materials, upon which EPA expressly relied in making a determination that <br />the injection permit would provide sufficient protection for underground sources of drinking <br />water. Despite the admitted relevance of this information and express reliance upon it in the