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Part II, Section A.5 of the permit be clarified as to what level <br /> of changes in the well design and construction at the time of <br /> drilling need to be reported to EPA. <br /> RESPONSE: The agency acknowledges that real world conditions do <br /> sometimes require changes in the proposed well design and con- <br /> struction. After careful consideration the agency has decided* to <br /> .. let..this. .portion of the :periait stand :unaltered,. . : -However.; the <br /> Agency does agree to be available by telephone to advise the per- <br /> mittee on the level of reporting needed for changes during con- <br /> struction. <br /> COMMENT: The consultants for the permittee request clarification <br /> of Part II, Section B.7 regarding the amount of time over which a <br /> two-gallon leak from the annulus would be permitted before <br /> reporting would be required. <br /> RESPONSE: The agency acknowledges that a two-gallon leak from <br /> the annulus over many years does not necessarily indicate failure <br /> of the well system and *may not be cause for' shutting down the in- <br /> jection system. The current requirement for reporting any two- <br /> gallon leak will remain in the permit. Once reported, the Agency <br /> will consider the length of time that was required for this leak <br /> to occur before recommending further action. <br /> COMMENT: The consultants for the permittee request a reduction <br /> in the frequency of monitoring of the injectate for those com- <br /> pounds which appear at consistently low levels. <br /> RESPONSE: In view of the high cost of chromatographic analysis <br /> of volatile organic compounds and pesticides, the Agency has <br /> agreed to a change in the permit requirements. The final permit <br /> will require monthly monitoring for those compounds in the first <br /> year of operation. Any compounds not detected will revert to <br /> yearly monitoring at that time. If these compounds are detected <br /> subsequent to this monitoring reduction, or if EPA so requests in <br /> writing, monthly monitoring may again be required. <br /> COMMENT: The consultants for the permittee inquire whether a <br /> provision for automatic shut down of the well in case of malfunc- <br /> tion is required. <br /> RESPONSE: The draft permit did not require automatic shut down. <br /> However, since the comment letter was filed, the permittee has <br /> chosen of its own accord to install such an automatic shut down <br /> system. The final permit will be amended to require that the <br /> automatic shut down system be installed and maintained. The per- <br /> mit will also require that a trained operator be present whenever <br /> the well is in operation. <br />