This comment letter response contains two parts:   

(1) The original submittal from the commenter.

(2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the

original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA‐assigned comment code; and an

individual response. These are described and explained below.  

• The data base contains Comment text from the letters submitted by commenters.  

Many hard copy letters were scanned into electronic format for inclusion in the data

base. As a result, there may be some typographical errors attributable to optical

character recognition issues.  However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and

appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique

Comment ID.  Additionally, one or more Comment Codes (i.e., unique topic area ID) was

assigned to each discrete point raised by a commenter. This information was added to

the data base. To inform final rulemaking decisions, all comments and information

received on a given topic were reviewed by technical experts in each rule area (e.g., on

construction requirements).  

• Following decisions on the final rule requirements, Individual responses were drafted

by topic area to ensure completeness and consistency of the responses with the final

rule and other responses to similar comments.  Each discrete point made by a

commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.

Each letter response is a compilation of each comment and its individual response,

compiled in the order of the original comment letter.  As a result of this process, there is

repetition in the response text.  The Agency believes this approach ensures completeness

and attention to each comment letter that was submitted.   

• All comments in a topic area were reviewed, evaluated, and responded to concurrently.  

Responses on each topic area are compiled and are also available in the rulemaking docket.
Will waivers negate any of the scientific evidence and make sequestration restrictions mute and 

potentially dangerous. What are the criteria for earthquake areas. 

Joyce Dillard 

dillardjoyce@yahoo.com 
Letter ID: 0364  

Commenter: Joyce Dillard  

   

Letter ID: 0364 Comment ID: 28291 Letter Lines: 18 to 20  

Comment Code: 3310 3.3.1. Site Characterization  

Comment: Will waivers negate any of the scientific evidence and make sequestration  

restrictions mute and potentially dangerous. What are the criteria for  

earthquake areas.  

Individual Response: EPA stresses that determinations about the appropriateness of waivers will be

based on carefully planned and collected site‐specific information. All owners or operators of proposed

GS sites must provide extensive geologic information about the site, including its seismic history per

§146.82(a)(3)(v). For additional information on geologic characterization of GS sites, see the preamble to

the final rule and the responses to comments on the proposed GS rule.

EPA clarifies that the requirements at §146.95 for owners and operators seeking injection depth waivers

are intended to add to and modify the requirements that all GS well owners or operators must meet,

including those for site‐specific geologic characterization and an evaluation of seismic risk, to ensure

that the proposed site is evaluated in the context of the presence of USDWs above and below the

injection zone. EPA anticipates that issuance of waivers will be limited to circumstances where there are

deep USDWs and/or where the lack of a waiver of injection depth requirements would result in

impractical or technically infeasible well construction, and where USDW protection is demonstrated and

maintained through the life of the GS project.