**Region 5**

**Example: Underground Injection Control Class II Permit Application**

**Attachment A:** Area of review methods. Give the method and, if
appropriate, the calculations used to determine the size of the area of
review (fixed radius or equation). The area of review shall be a fixed
radius of 1/4 mile from the proposed injection well unless the use of an
equation is approved in advance by the Director.

**Attachment B: Area of review**

Submit a topographic map, extending one mile beyond the property
boundaries, showing the proposed injection well and the applicable 1/4
mile radius area of review. The map should include all existing wells,
that penetrate the injection zone, along with any surface bodies of
water, springs, mines (surface and subsurface), quarries, and other
pertinent surface features, including residences and roads, and faults,
if known or suspected. Also submit a tabulation of information on these
wells which will include the following: well name; surface location;
date drilled; state permit #; operator name; total depth and operating
status.

**Attachment C**: **Corrective Action Plan**

Should upward fluid migration occur through the well bore of any
previously unknown, improperly plugged or unplugged well due to
injection of permitted fluids, injection will be shut-in until proper
plugging can be accomplished. The Underground Injection Control Branch
of the USEPA must be notified immediately. Should any problems develop
in the casing of the injection well, injection will be shut-in until
such repairs can be made to remedy the situation**. **Operations shall
not be resumed until the Director gives approval to recommence injection
in writing.

**Attachment D: Maps and Cross Sections of USDWs-** Does not apply to
Class II wells

**Attachment E: Name and Depth of USDWs-** Provide the geologic name and
depth of the formation containing the lowermost underground source of
drinking water (USDW), including the depth to the base of the lowest
USDW and the method of identification and/or sources of information used
to identify the USDW location (USDW is defined as an aquifer or its
portion which contains fewer than 10,000 mg/l of total dissolved
solids).

**Attachment F: Maps and Cross Sections of Geologic Structure of Area-**
Does not apply to Class II injection wells.

**Attachment G: Geologic Data on Injection and Confining Zones-
**Provide the name, depth, thickness, and lithologic descriptions of the
injection and confining zones.

**Attachment H: Operating Data**- Estimate the proposed maximum
injection rate in barrels per day (BBL/Day). The proposed maximum
injection pressure should be calculated using the following formula:
Pmax={\[0.8-(0.433) (specific gravity of injection fluid + 0.05 )\] X
upper depth of injection formation}-14.7. For a fracture gradient above
0.8 psi/ft, the owner/operator needs to submit justification data such
as charts, graphs and jobs tickets from a step rate test or fracturing
operation. Field data from a well in the same field, which is injecting
in the same formation, may be used to justify a fracture gradient of
greater than 0.8 psi/ft. This data should include charts, graphs and job
tickets from a step rate test or fracturing operation on the well.

**Formation Testing Program:** The testing program, if necessary, must
be designed to obtain data on fluid pressure, estimated fracture
pressure, physical characteristics of the injection zone. The permittee
must notify the UIC Branch at least (30) days prior to any testing and
wait for approval.

**Attachment J: Stimulation Program**-Outline any proposed stimulation
program.

**Attachment K: Injection Procedures- **Describe the proposed injection
procedures including pump, tank etc.

**Attachment L: Construction Procedures**-This should include details of
the casing and cementing program, logging procedures, deviation checks,
drilling, testing program, and the nature of the annulus fluid.

\- Surface casing size and weight, setting depth, \# of sacks of cement,
hole size

\- Intermediate casing size and weight, setting depth, \# of sacks of
cement, hole size

\- Longstring casing size and weight, setting depth, \# of sacks of
cement, hole size

\- Size and weight and length of the tubing,

\- Size and model of the packer and the setting depth

For a converted well, the owner/operator must submit along with the
permit application the following information: state completion report,
well rework record and cementing tickets for **[all]{.underline}** work
done on the well.

**Attachment M: Construction Details-**Submit schematic or other
appropriate drawings of the surface and subsurface construction details
of the well. Include a description of the exact point at which the
injection fluid will be sampled. Sample well schematics are attached.

**Attachment N: Changes in Injection Fluid-**Does not apply to Class II
injection Wells

**Attachment O: Plans for Well Failures**-Outline contingency plans to
cope with all shut-ins or well failures, so as to prevent migration of
fluids in any USDW.

**Attachment P: Monitoring Program-**The monitoring program for this
well will consist of compliance with the EPA permit requirements of
filing Monthly, Quarterly and Annual reports.

**Attachment Q: Plugging and Abandonment (P&A) Plan-**Submit a plan for
plugging and abandonment of the well:

\- All uncemented casing ripped.

\- Plug of at least 250 feet immediately above the injection zone or

\- 50 feet of cement immediately above a cast iron bridge plug. 250 feet
is required above cement retainer if situated adjacent to the injection
zone.

\- Cement plug set at least 50 feet above and 50 feet below any casing
rip point.

\- If surface casing is not cemented to surface, a cement plug set at
least 50 feet below the lowest USDW to surface.

\- If surface casing is cemented to surface and extends below the
lowermost USDW, a cement plug from at least 50 feet above the USDW base
to 50 feet below the shoe is required and a cement plug from at least 50
feet depth to the surface is required.

\- If surface casing is cemented to surface and the lowermost USDW is
below the surface casing setting depth, a cement plug from at least 50
feet below the USDW base to 50 feet above the casing shoe is required
and a cement plug from at least 50 feet depth to the surface is
required.

\- If the lowermost USDW depth is less than 500 feet, then set a
continuous cement plug from 50 feet below the lowermost USDW to the
surface.

**Example of how to calculate cement plug:**

From Halliburton cementing Tables: Section #210 Capacity:

5-1/2\" casing and 15.5 lb weight 7.483 ft/ft^3^

7-7/8\" hole 2.9565 ft/ft^3^

For Class A cement, the slurry volume is 1.18 ft^3^/sack of cement

For cement plug calculation in open hole and across perforations, 20%
excess cement is used. Example: \# of sacks = [(bottom of plug- top of
plug) x 1.2]{.underline}

1.18ft^3^/sack x2.9565ft/ft^3^

For cement plug calculation inside 5-1/2 casing and weight 15.5#:

Example: \# of sacks =[ bottom of plug - top of plug]{.underline}

1.18 ft^3^/sacks x 7.483 ft/ft^3^

An actual P&A plan sample is attached.

Include a detailed plugging cost estimate from an independent contractor
which is broken down to include costs of cement, labor, rig time,
materials, etc.

**Attachment R: Necessary Resources: **Submit evidence to verify that
the financial resources that are necessary to close, plug and abandon
the well are available. One of the following mechanisms may be used to
meet the UIC requirements:

1\) A Surety Bond along with a Standby Trust Fund

2\) A Letter of Credit along with a Standby Trust Fund

3\) A Trust Fund

4\) State Mechanisms (the permittee needs to provide a copy of the state
mechanism such as a surety bond, a letter of credit, a certificate of
deposit or a blanket bond) along with a letter requesting acceptance of
the state mechanism. Whenever a state blanket bond is used as a
financial mechanism to cover the cost of plugging the well, the
permittee is required to provide a list of all wells (producers and
injectors) covered by the blanket bond and the estimated plugging cost
for each well.

5\) Financial Statement Coverage - the following are required when
financial statement coverage is used as financial mechanism: chief
financial officer's letter, an independent auditor's opinion of
examination of the company's financial statements and a public
accounting firm's statement of validation of the financial information
in the chief financial officer's letter. Enclosed is a brochure
discussing financial mechanisms.

**Attachment S: Aquifer Exemptions-**If an aquifer exemption is
requested, submit data necessary to demonstrate that the aquifer meets
the following criteria: (1) does not serve as a source of drinking
water; (2) cannot now and will not in the future serve as a source of
drinking water; and (3) the TDS content of the ground water is more than
3,000 and less than 10,000 mg/l and is not reasonably expected to supply
a public water system. Submit data to demonstrate that the aquifer is
expected to be mineral or hydrocarbon producing, or can be demonstrated
by a permit applicant as part of a permit application for a Class II
operation to contain hydrocarbons that considering their quantity and
location are expected to be commercially producible.

**Attachment T: Existing EPA Permits-**List program and permit number of
any existing EPA permits, for example, NPDES, PSD, RCRA, etc.

**Attachment U: Description of business** Give a brief description of
the nature of the business,

( As an example, the company is involved in the exploration, production,
and marketing of crude oil and natural gas).

**APPENDIX** should include the following:

1\) List of names and addresses of all landowners of record within the
1/4 mile radius area of review of the proposed injection well along with
a map showing landowners.

2\) Evidence to verify that you have provided the State Historic
Preservation Office (SHPO) with a topographic map which clearly shows
any existing and all proposed road construction or improvement leading
up to the site. This information, which is required in order to complete
the process of coordination specified in the National Historic
Preservation Act, Section 106, should be submitted directly to the State
Historic Preservation Office. A copy of the SHPO letter clearing the
project must be submitted to the UIC Branch. You may contact SHPO at the
following address:

Kristine Wilson, Environmental Review Coordinator

State Historic Preservation Office

Bureau of History

717 West Allegan Street, 5th floor

Lansing, Michigan 49918

3\) If the proposed well location is in a county that borders the Great
Lakes, the owner or operator needs to provide evidence that they have
contacted the State Coastal Zone Management Program (CZMP) notifying
them of the proposed activity. A copy of the CZMP letter clearing the
project must be submitted to the UIC Branch. You may contact CZMP at the
following address:

Cathy Cunningham, Land and Water Management Analyst

Michigan Department of Natural Resources

Division of Land and Water Management

Coastal Management Program, P.O. Box 30458

Lansing, Michigan 48909

4\) Record of state completion and/or plugging for all area of review
wells if applicable.

5\) An analysis of the physical and chemical characteristics of the
injection fluid, along with the description of the source of the
injection fluid. The fluid analysis shall include, but not be limited to
the following: Sodium, Calcium, Magnesium, Barium, Total Iron, Chloride,
Sulfate, Carbonate, Bicarbonate, Sulfide, Total Dissolved Solids, pH,
Resistivity (ohm-meters), and Specific Gravity.

Plug #1

a\) Number of sacks from 2000 feet to 1800 feet with 20 % excess

\# of sacks = [( 2000 feet- 1800 feet) X 1.2]{.underline} = 69 sacks

1.18 ft^3^/sack X 2.9565 ft/ft^3^

b\) Number of sacks from 1800 feet to 1550\'(250\' above injection zone)

\# of sacks = [ 250 feet ]{.underline} = 29 sacks

1.18 ft^3^/sack X 7.483 ft/ft^3^

Plug #2

\# of sacks from 750\' (50\' below surface casing shoe) to 550\' (50\'
above lowest USDW)

\# of sacks = [ 750\'-550\'\_\_\_\_\_\_\_\_ ]{.underline}

1.18 ft^3^/sack X 7.483 ft/ft^3^

Plug #3

\# of sacks from 50\' to surface

\# of sacks = [ 50\'\_\_\_\_\_\_\_\_\_ ]{.underline}

1.18 ft^3^/sack X 7.483 ft/ft^3^

**[Figures]{.underline}**