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.file:///C|/Users/Kristy/Desktop/KristyMaterials/CommentsToPDF/EPA-HQ-OW-2008-0390-0105.txt [11/18/2010 10:29:52 PM] Document ID: EPA-HQ-OW-2008-0390-105

Last Name: Sachau

First Name: B.

Title:

Organization:

City: Florham Park

State: NJ

Zip Code: 07392

Phone Number:

Fax Number:

Country Code:

Email Address: bk1492@aol.com

Current Category Code: 263

Comment: i elieve these wells are extremely dangerous. it would be far better to

see that less carbon dioxide is formed. i see little to no effort in that regard

and ask for more effort on that. these wells are an accident waiting to happen.

look at how the army orps of engineers built the leveees in new orleans - that

is an indication of the quality of construction that can happen in the usa.

b sachau

15 elm st florham park nj07392

bk1492@aol.comLetter ID: 0105

Commenter: B. Sachau

Letter ID: 0105 Comment ID: 21939 Letter Lines: 15 to 19

Comment Code: 1340 1.1.3.2 Oppose use of GS in general

Comment Code: 1600 1.3 Risk Associated with CO2 GS

Comment: i elieve these wells are extremely da ngerous. it would be far better to

see that less carbon dioxide is formed. i s ee little to no effort in that regard

and ask for more effort on that. these we lls are an accident waiting to happen.

look at how the army orps of engineers bui lt the leveees in new orleans - that

is an indication of the quality of cons truction that can happen in the usa.

Individual Response: EPA recognizes that injecting large volumes of CO2 for GS poses unique

challenges that, if not properly managed, could endanger drinking water s ources and have other

adverse impacts. However, the fi nal, tailored, Class VI require ments address the large volumes

of CO2 injected, its buoyancy, potential corrosivity in the pr esence of water, and potential

impurities in the CO2 stream. In addition, EPA expects the tailored permitting, siting,

construction, operation, monitoring, and post-injection site care re quirements in the GS rule to

prevent leakage from injection formations a nd protect USDWs. EPA acknowledges the comment

on reduction of carbon emissions. This comment is outside the scope of the UIC Program’s

authority under the GS rulemaking.

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