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RESPONSIVENESS SUMMARY FOR VICTOR FINE FOODS UIC PERMIT COMMENT: Several commentors expressed the opinion that under- ground injection is an undesirable practice and should be prohibited. RESPONSE: The practice of disposing of certain wastes by under- ground injection was recognized by Congress in Part C of the Safe Drinking Water Act of 1974 (and amendments) . In carrying out the wishes of Congress to allow this practice, EPA set up a permit- ting system whereby a proposed injection well is investigated to assure that geological conditions are appropriate and that no un- derground sources of drinking water are endangered by the proposed action. EPA has examined geological, geophysical, and hydrologic in- formation on the proposed well site and has determined that con- ditions will permit the injection of Class V wastes at the Victor Fine Foods site without endangering the shallow ground waters used for drinking and irrigation by area residents. There are several aspects of the Lodi site which make it particularly suitable for underground injection. Wastes will be injected at a depth of approximately 2700 feet. Above the injec- tion formation is a thick (nearly 300 foot) sequence of marine shales referred to as a confining layer. These rocks are ideally suited to the task of preventing the injected fluids from migrat- ing upward toward the shallow aquifers which are the source of drinking and irrigation water. COMMENT: Several commentors stated that Victor Fine Foods should not be allowed to collect the injectate samples required in the permit and requested that EPA perform the monitoring. RESPONSE: EPA agrees that monitoring by an independent organiza- tion is preferable to self-monitoring. Unfortunately EPA does not have the resources available to perform the monitoring, and the Agency does not have the regulatory authority to require the permittee to retain an outside firm for this purpose. After discussions with this agency, Victor Fine Foods has voluntarily agreed to contract with outside firms to collect, transport, and analyse the water samples required by the permit. Initially, Victor has selected SOCI, Inc. of Rio Vista, Califor- nia to collect the water samples and transport them to Analab of Sacramento for analysis. Victor Fine Foods will never have cus- tody of the water samples and the laboratory will send a copy of results directly to EPA.