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surface to a depth of about 1050 feet. The long string casing is 7 inches in diameter and if completed in the Primary Injection Formation, it will run from the ground surface to a depth of about 5300 feet. If the well is completed in the Alternate Injection Formation, the long string casing will run from the ground surface to about 9500 feet. As required by 40 CFR §146. 12, the wastewater is to be injected through tubing with a packer set near the bottom of the long string casing. The tubing will be a 3-1/2 inch outside diameter tubing and will be equipped with a tension-set packer set at 100 feet above the injection zone. After the packer is set, the annulus will be pressurized and the pressure will be recorded continuously to detect leaks. The draft permit requires the permittee to construct the injection well in accordance with EPA regulations for Class I injection wells. The well must inject beneath the lowermost USDW and the well must be cased and cemented to prevent the movement of fluids into or above USDWs. Additionally, injection between the outermost casing protecting underground sources of drinking water and the well bore is prohibited. The maximum injection rate shall be limited to 150 gallons per minute (gpm) . The draft permit requires that the annular space between the tubing and the casing be filled with fresh water containing bacteria and corrosion inhibitors or similar nonhazardous corrosion inhibiting fluid. The annular pressure will be limited by the permit to a minimum operating value of 100 psig for leak detection. The permittee is required to continuously monitor the fluid level in the annular space. A total annular fluid volume change exceeding two gallons at Standard Temperature and Pressure (STP) would constitute a significant leak. The permittee is required to notify EPA when the total annular fluid volume varies from the above range. Maintaining a positive annular pressure will allow for continuous mechanical integrity monitoring of the casing, tubing, and packer. The draft permit specifies that the EPA, Region 9 , be notified within 24 hours of noncompliance. This verbal notification of noncompliance must be followed by written notice within five days. Well repair and mechanical integrity testing are required if the problem is found to be within the well . 10