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Recent monitoring reports submitted to the CVRWQCB indicate that the flow rate and TDS of the process waste water are significantly less than reported above. This is probably due to in-plant source control and a new water supply well. 5. WELL CLASSIFICATION The proposed injection well is a Class I well, according to 40 CFR §144 . 6, because the disposal well will inject fluids beneath the lowermost Underground Source of Drinking Water (USDW) . The injection fluid is not classified as a Resource Conservation and Recovery Act (RCRA) hazardous waste. 6. AQUIFER EXEMPTION No aquifer exemption is necessary for this activity. 7 . VARIANCES The applicant has requested an alternative to the require- ments of the UIC program. If TDS levels less than 10, 000 ppm are encountered in the injection zone, the applicant will request a Class V UIC Well Permit. 8 . AREA OF REVIEW The radius of endangering influence is calculated to deter- mine possible effects of pressure build-up on wells within the area. The distance at which the pressures in the in- jection zone may cause migration of the injection or forma- tion fluid into the USDW is considered the radius of review. Three methods are commonly used to calculate the area of review when applying for a UIC permit. These are the fixed ; radius method, the volumetric method, and the pressure build-up method. The fixed radius method involves the selection of a fixed distance as the radius around the well. The volumetric method uses a simple equation relat- ing the total volume of fluid to be injected during the life of the well to the radius. The pressure build-up t method is more involved and can be solved in several dif- ferent ways. (A fourth method, which is optional, involvep numerical modeling. ) The applicant has considered all three methods. (The ap- plicant will complete the optional method after the drill- ing and testing program provides the data needed for modeling. ) EPA has reviewed the submitted calculations and concludes that a three-mile radius is a conservative es- timate for the radius of influence. The draft permit re- quires the applicant to.conduct tests of the injection zone 6