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RESPONSIVENESS SUMMARY FOR VICTOR FINE FOODS UIC PERMIT COMMENT: One, commento .expressed .. .the opinion . that. underground injection is "an unsound environmental practice". 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- editions will permit the injection of Class I (non-hazardous) 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 (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 migrating up- ward toward the shallow aquifers which are the source of drinking and irrigation water. COMMENT: One party inquired about the adequacy of the confining layer, specifically as to whether it is continuous and of suitable thickness. RESPONSE: The confining layer is the sequence of rocks known as the Nortonville shale. This massive formation appears in and can be correlated between all well logs from nearby wells and is ap- proximately 300 feet thick at the location of the proposed injec- tion well. There is no reason to believe that it pinches out or even thins significantly near the proposed injection well. COMMENT: One party requested clarification of the statement on page 4 of the fact sheet that "the majority of voids are not interconnected". RESPONSE: This statement is a general description of the micro- scopic porosity of marine shales, such as the Nortonville forma-