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COMMENT: Several commentors indicated displeasure with the en- vironmental compliance record of the permittee and expressed con- cerns about the impacts of current disposal practices on the shallow ground water and on the Mokelumne River. RESPONSE: Throughout the permitting process, EPA has been in contact with the California Regional Water Quality Control Board (CRWQCB) which regulates the current disposal practices at the Victor plant site. We are familiar with the permittee's environ- mental compliance record and we concur with the CRWQCB's deter- mination that current disposal practices at the site are environ- mentally damaging. EPA and the Regional Board feel that deep well injection is environmentally preferable to the current dis- posal practices and that the quality of the shallow ground water and the Mokelumne River will be improved by granting this permit. COMMENT: One commentor described an open, unfenced drainage ditch, apparently on Victor property near the Mokelumne River School, and expressed concern that this ditch presented a danger to children living nearby. RESPONSE : The EPA appreciates this concern. However, this agency has no authority to address this issue as it does not directly relate to the proposed injection well. This commentor may wish to contact the San Joaquin County Health Department to explore possible remedies for this problem. Harding Lawson Associates, consultants to Victor Fine Foods, have requested several changes, mostly of a technical nature, in the final permit. These are addressed below. Section references are to the draft permit. COMMENT: The permittee has requested permission to apply a biocide, a surfactant, and an oxygen scavenging compound to the injectate to reduce concentrations of slime-forming bacteria and maintain high injectivity in the well. RESPONSE: The request to use a rapidly degradable surfactant and oxygen scavenging compounds is granted, provided that injection of these compounds does not cause a violation of any other part of the permit. The request to use a biocide was first brought to the agency prior to publication of the notice, draft permit, and fact sheet. At that time, EPA personnel began an investigation into the toxicity of the suggested biocide in order to determine whether its application to a underground source of drinking water was ap-