Information Collection 

Request for the Federal 

Requirements under the 

Underground Injection 

Control Program for Carbon 

Dioxide Geological 

Sequestration Wells 
Office of Water (4606M) 

EPA 816-R10-012 

November 2010 

http://water.epa.gov/drink/ 
TABLE OF CONTENTS

1 IDENTIFICATION OF THE INFORMATION COLLECTION....................................... 1 

1(a) Title and Number of the Information Collection ...................................................... 1 

1(b) Short Characterization............................................................................................... 1 

2 NEED FOR AND USE OF COLLECTION........................................................................... 4 

2(a) Need/Authority for the Collection............................................................................. 4 

2(b) Use/Users of the Data................................................................................................ 4 

3 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA.............................................................................................................................. 6 

3(a) Non-duplication......................................................................................................... 6 

3(b) Public Notice Required Prior to ICR Submission to OMB....................................... 6 

3(c) Consultations............................................................................................................. 7 

3(d) Effects of Less Frequent Collection .......................................................................... 8 

3(e) General Guidelines.................................................................................................... 8 

3(f) Confidentiality........................................................................................................... 8 

3(g) Sensitive Questions................................................................................................... 8 

4 RESPONDENTS AND INFORMATION REQUESTED ..................................................... 9 

4(a) Respondents/NAICS Codes ...................................................................................... 9 

4(b) Information Requested .............................................................................................. 9 

4(b)(i) Data Items........................................................................................................... 9 

4(b)(ii) Respondent Activities....................................................................................... 13 

5 INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT.......................................... 17 

5(a) Agency Activities.................................................................................................... 17 

5(b) Collection Methodology and Management............................................................. 17 

5(c) Small Entity Flexibility ........................................................................................... 18 

5(d) Collection Schedule................................................................................................. 18 

6 ESTIMATING BURDEN AND COST OF COLLECTION................................................ 20 

6(a) Estimating Respondent Burden............................................................................... 21 

6(a)(i) Burden to Owners and Operators of CO2 GS Wells........................................ 21 

6(a)(ii) Burden to Permitting Authorities ......................................................................... 23 

6(b) Estimating Respondent Costs.................................................................................. 24 

6(b)(i) Costs to Operators................................................................................................ 24 

6(b)(ii) Costs to Permitting Authorities........................................................................... 25 

6(c) Estimating Agency Burden and Costs..................................................................... 25 

6(d) Respondent Universe............................................................................................... 26 

6(e) Bottom Line Annual Burden and Costs .................................................................. 27 

6(e)(i) Variations in the Annual Bottom Line.............................................................. 28 

6(f) Burden Statement .................................................................................................... 29 

 Page i 
APPENDICES 

 Appendix A: GS Rule Net Change Burden and Costs Spreadsheets 

 Appendix B: GS Rule Selected Alternative Burden and Costs Spreadsheets 

 Appendix C: GS Rule Baseline Burden and Costs Spreadsheets 

 Page ii 
LIST OF EXHIBITS 

Exhibit 6.1a: Average Annual Net Change Burden and Costs for the GS Rule ICR 

(2011 – 2013)........................................................................................................ 21

Exhibit 6.1b: Average Annual Net Change Owner and Operator Burden and Costs for the 

GS Rule ICR (2011 – 2013).................................................................................. 22

Exhibit 6.1c: Average Annual Net Change Permitting Authorities Burden and Costs for 

the GS Rule ICR (2011 – 2013)............................................................................ 23

Exhibit 6.1d: Average Annual Net Change Agency Burden and Costs for the GS Rule 

ICR (2011 – 2013) ................................................................................................ 26

Exhibit 6.2: Bottom Line Average Annual Net Change Burden and Costs for the 

 3-Year ICR Period ................................................................................................ 28

 Page iii 
 Page iv 

ACRONYMS 

AoR Area of Review 

CO2 Carbon Dioxide 

CBI Confidential Business Information 

DOE United States Department of Energy 

EPA United States Environmental Protection Agency 

ER Enhanced Recovery 

FILS Federal Information Locator System 

FOIA Freedom of Information Act 

GS Geologic Sequestration

GWPC Ground Water Protection Council 

ICR Information Collection Request 

IOGCC Interstate Oil and Gas Compact Commission 

MIT Mechanical Integrity Testing 

MOA Memorandum of Agreement 

NAICS North American Industry Classification System 

NIWG National Indian Work Group 

NODA Notice of Data Availability and Request for Comment 

NGO Non-Governmental Organization 

NTC National Tribal Caucus 

O&M Operations and Maintenance 

OGWDW Office of Ground Water and Drinking Water

OMB Office of Management and Budget 

PISC Post-Injection Site Care 

PRA Paperwork Reduction Act 

RICS EPA Regional Indian Coordinators 

SDWA Safe Drinking Water Act 

T&C Technology and Cost 

TDS Total Dissolved Solids 

UIC Underground Injection Control 

USDWs Underground Sources of Drinking Water 
GS Rule ICR November 2010

1 IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title and Number of the Information Collection 

Title: Information Collection Request for the Federal Requirements under the 

Underground Injection Control (UIC) Program for Carbon Dioxide Geologic 

Sequestration Wells (GS Rule) 

OMB Control Number: 2040-0278 

EPA Tracking Number: 2309.01 

1(b) Short Characterization 

 The U.S. Environmental Protection Agency (EPA or the Agency) is promulgating federal 

requirements under the UIC program for carbon dioxide (CO2) geologic sequestration (GS) 

wells. GS is the process of injecting CO2 captured from an emission source (e.g., a power plant 

or industrial facility) into deep subsurface rock formations for long-term storage. It is part of a 

portfolio of options that could help reduce CO2 emissions to the atmosphere and mitigate climate 

change. EPA’s Office of Ground Water and Drinking Water (OGWDW) is promulgating a 

regulation that will require the collection of information to ensure a consistent approach to the 

permitting application and monitoring requirements for all CO2 GS wells. 

The GS Rule establishes a new class of injection well – Class VI – for GS projects based 

on the unique challenges of preventing potential endangerment to underground sources of 

drinking water (USDWs) from these operations. The GS Rule mandates technical criteria for 

geological site characterization; determination of the area of review (AoR) and corrective action; 

well construction and operation; mechanical integrity testing (MIT) and monitoring; and well 

plugging, post-injection site care (PISC) and site closure. The regulation is based on the existing 

Underground Injection Control (UIC) requirements found at 40 CFR Parts 144 through 148, with 

new requirements added to address the unique nature of CO2 injection for GS. The purpose of 

the rulemaking is to assure that GS is conducted in a manner that protects USDWs. The rule will 

also help ensure consistent approaches to permitting GS operations across the United States. 

 Under the GS Rule, operators of GS wells must submit UIC permit applications, which 

contain extensive geologic data and other information, to demonstrate that a site is suitable for 

GS. Operators must also model the extent of the AoR, report on the status of corrective action on 

wells in the AoR, and report on pre-operational logging and testing before obtaining an injection 

permit. Throughout the injection project, operators will monitor the well and the site and submit 

data to the permitting authority on a semi-annual basis. At least every 5 years they will reevaluate the AoR and update the AoR and Corrective Action Plan, as well as other plans as 

needed. Permit holders will be required to plug their injection well(s) and monitor the site for a 

default period of 50 years after injection has ended. The Director has the discretion to shorten or 

lengthen the timeframe based on data submitted as part of the permit application, or collected 

during PISC. Following PISC, operators would be required to demonstrate non-endangerment to 

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GS Rule ICR November 2010

USDWs. Once closure of the site is authorized, operators must close the site and submit a closure 

report. 

 States1

 applying for primacy to oversee Class VI wells will need to submit a primacy 

application as described in 40 CFR 145. Permitting authorities, which include States that obtain 

primacy enforcement responsibility (primacy) to implement the Class VI program, as well as 

EPA Regional offices that directly implement the Class VI program, will collect and review 

permit applications and geological data from operators; receive and review testing and 

monitoring data and updates to AoR and Corrective Action Plans throughout the injection phase; 

review plugging reports and post-injection monitoring reports; and eventually authorize site 

closure. 

 In the case where owners or operators seek a waiver from the requirement that Class VI 

wells inject below the lowermost USDW, owners or operators must submit a supplemental report 

demonstrating that such injection can be performed in a way that protects USDWs. EPA 

Regional offices (and Headquarters) will approve applications for waivers from the requirement 

to inject below the lowermost USDW, as well as review and approve Class VI primacy 

applications. 

EPA assumes that the GS Rule will be promulgated in 2011; this information collection 

request (ICR) covers the 3-year period from 2011 through 2013. EPA assumes that 32 States will 

apply for primacy during that time. It is estimated that approximately two2

 owners or operators 

of Class VI wells will apply for permits during the three-year ICR clearance period. Of these 

operators approximately one is assumed to be located in States with primacy; approximately one 

is assumed to be in a State where EPA directly implements the UIC Program. This assumption is 

based on the distribution of States that have primacy for other well classes, as described in 

Chapter 5 of EPA’s Cost Analysis for the Federal Requirements Under the Underground 

Injection Control Program for Carbon Dioxide Geologic Sequestration Wells3

. 

This ICR does not estimate the total burden associated with the reporting and 

recordkeeping requirements of the GS Rule. Instead, it calculates the incremental or net change 

in burden associated with any new requirements of the rule, compared to existing UIC 

requirements for Class I non-hazardous wells (the “baseline”). 

EPA estimates that the owners and operators of GS wells will incur an average annual net 

change of 1,549 hours of respondent burden and $0.2 million in labor costs annually responding 

to this information request. Annual capital and operations and maintenance (O&M) costs for 

operators are estimated to increase by $5.8 million and $5.5 million, respectively. The average 

annual net change cost for operators is $11.5 million. In order to perform the activities associated 

with this ICR, EPA estimates that permitting authorities will incur an average annual net change 

of 11,241 hours of burden and $0.6 million in total costs (all labor). Note, in this ICR, burden 

 

1

 Reference to “States” includes Tribes and Territories. 

2

 A detailed description of the GS Rule project deployment schedule is presented in Chapter 3 of the Cost Analysis 

(see Exhibit 3.1). 

3

 U.S. Environmental Protection Agency. 2010. Geologic CO2 Sequestration Technology and Cost Analysis, EPA 

816-R-10-008. 

 Page 2 
GS Rule ICR November 2010

incurred by EPA Regions directly implementing the Class VI rule is combined with burden 

incurred by States to provide an overall burden for permitting authorities. Burden incurred by 

EPA Regions overseeing States’ primacy programs and approving waiver applications is 

presented separately as EPA burden. The estimated EPA burden will increase by 5,123 hours and 

$0.3 million in total costs (all labor) annually. A summary of burden and cost associated with 

this ICR can be found in Exhibit 6.1a. 

The net change burden and costs associated with complying with the rule beyond the first 

3 years after rule promulgation are estimated in Appendix A. Note that these calculations are for 

informational purposes only and are not included in the burden for this ICR clearance period. 

Appendix B estimates the total burden and costs for the selected alternative; Appendix C 

estimates the total burden and costs for the baseline. These appendices are used to calculate the 

net change burden and costs presented in Appendix A. 

This ICR was prepared in accordance with the November 2005 version of EPA’s Guide 

to Writing Information Collection Requests Under the Paperwork Reduction Act (PRA) of 1995 

(or “ICR Handbook”) prepared by EPA’s Office of Environmental Information, Office of 

Information Collection, Collection Strategies Division. The ICR Handbook provides the most 

current instructions for ICR preparation to ensure compliance with the 1995 PRA amendments 

and the Office of Management and Budget’s (OMB) implementing guidelines. 

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GS Rule ICR November 2010

2 NEED FOR AND USE OF COLLECTION 

 The following sections describe the need for this information collection and the legal 

authority under which this information will be collected. 

2(a) Need/Authority for the Collection 

 EPA is promulgating the GS Rule to provide federal requirements for owners and 

operators of CO2 GS wells to protect USDWs from potential contamination. EPA has authority 

to regulate the injection of fluids, including CO2, into the subsurface under the Safe Drinking 

Water Act (SDWA) of 1974, as amended in 1986 and in 1996. The UIC Program, to which this 

regulation adds a sixth class of injection well, was promulgated under Part C of the SDWA. The 

information collected under the GS Rule is required by EPA to carry out its monitoring and 

enforcement responsibilities pertaining to UIC under the SDWA. 

 The GS Rule is based on the existing UIC regulatory framework found at 40 CFR Parts 

144 through 148, with additional new requirements to address the unique nature of CO2 injection 

for GS. The requirements are codified in a new Subpart H of 40 CFR Part 146. The GS Rule is 

also meant to provide regulatory certainty and permitting consistency for CO2 GS projects. 

The chief goal of any federally approved UIC Program is the protection of USDWs. This 

includes not only those aquifers that are presently being used for drinking water, but also those 

that can reasonably be expected to be used in the future. EPA has established through its UIC 

Program regulations that underground aquifers with less than 10,000 mg/L total dissolved solids 

(TDS) and containing a sufficient quantity of ground water to supply a public water system are 

USDWs. 

Section 1421 of the SDWA requires EPA to propose and promulgate regulations 

specifying minimum requirements for effective State programs to prevent underground injection 

that endangers drinking water sources. Section 1421(b) (3)(A) of the Act also provides that 

EPA’s UIC regulations shall “permit or provide for consideration of varying geologic, 

hydrological, or historical conditions in different States and in different areas within a State.” 

EPA promulgated administrative and permitting regulations, now codified in 40 CFR parts 144 

and 146, on May 19, 1980 (45 FR 33290), and technical requirements, in 40 CFR part 146, on 

June 24, 1980 (45 FR 42472). The regulations were subsequently amended on August 27, 1981 

(46 FR 43156), February 3, 1982 (47 FR 4992), January 21, 1983 (48 FR 2938), April 1, 1983 

(48 FR 14146), May 11, 1984 (49 FR 20138), July 26, 1988 (53 FR 28118), December 3, 1993 

(58 FR 63890), June 10, 1994 (59 FR 29958), December 14, 1994 (59 FR 64339), June 29, 1995 

(60 FR 33926), December 7, 1999 (64 FR 68546), May 15, 2000 (65 FR 30886), June 7, 2002 

(67 FR 39583), and November 22, 2005 (70 FR 70513). 

2(b) Use/Users of the Data 

Owners and operators of CO2 injection wells will use information collected in preparing 

their permit applications and associated plans and reports (including the Testing and Monitoring 

Plan, AoR and Corrective Action Plan, Injection Well Plugging Plan, PISC and Site Closure 

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GS Rule ICR November 2010

Plan, and Emergency and Remedial Response Plan) to construct, operate, and close their 

injection well sites. They will use the data they collect to determine whether they are complying 

with permit conditions and to determine whether corrective action or operational adjustments are 

needed. They will also use ambient monitoring data to detect whether the CO2 plume has 

migrated outside of the injection zone. 

 Permitting authorities will use the operator-submitted permit applications and associated 

plans and reports (including the Testing and Monitoring Plan, AoR and Corrective Action Plan, 

Injection Well Plugging Plan, PISC and Site Closure Plan, and Emergency and Remedial 

Response Plan) to determine whether a proposed site is suitable for CO2 GS, whether the 

proposed well meets the criteria specified in the GS Rule, and whether a permit should be 

granted. They will use demonstrations of financial responsibility to ensure that the owner or 

operator is able to pay for operation and any remediation that may be required. Permitting 

authorities will review testing and monitoring reports as well as periodic AoR re-evaluations and 

plans to make sure that Class VI injection wells are in compliance and that no fluid movement 

into or endangerment to USDWs has occurred. Permitting authorities will use reports submitted 

during PISC to assure that the CO2 plume has not moved beyond the confining zone and is not 

endangering USDWs, and before site closure is authorized the CO2 plume has stabilized and 

poses no threat to USDWs. 

EPA will review the State applications for Class VI primacy and determine if the 

proposed State UIC Class VI program can be implemented in a manner that protects USDWs 

before approving the program. 

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GS Rule ICR November 2010

3 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA 

3(a) Non-duplication 

EPA has searched the Federal Information Locator System (FILS) in an effort to ensure 

nonduplication of the data collection efforts. To the best of the Agency’s knowledge, data 

currently required by the GS Rule are not available from any other source.4 

 

3(b) Public Notice Required Prior to ICR Submission to OMB 

As part of the Federal Register notice on the proposed GS Rule, EPA solicited comments 

on this information collection and the estimates in this ICR. EPA solicited comments on specific 

aspects of the proposed information collection, as described below: 

1) Whether the collection of information is necessary for the proper performance of the 

functions of the Agency, including whether the information will have practical utility; 

2) Whether the Agency’s burden estimate is accurate including the validity of the 

methodology and assumptions used; 

3) How to enhance the quality, utility, and clarity of the information to be collected; and 

4) How to minimize the burden on respondents, including use of appropriate automated 

electronic, mechanical, or other technological collection techniques or other forms of 

information technology. 

EPA did not receive comments that specifically referred to the ICR prepared for the 

proposed rule; however, it received several comments (such as the need to increase unit costs) on 

the associated Cost Analysis5

, as well as the Technology and Cost (T&C) Document6 (which 

contains many of the unit costs used to estimate costs for the Cost Analysis and the ICR). For the 

final rule, EPA revised many of the unit costs to incorporate those comments; these changes have 

been incorporated into this ICR. For example, EPA increased the cost associated with seismic 

surveys conducted as part of site characterization by 30 percent, the labor burden for preparing 

semi-annual reports by 25 percent, and the loaded labor rates for geologists and engineers 

preparing permit applications by approximately 75 percent. 

EPA’s responses to comments received on the proposed rule are available at 

http://www.regulations.gov, docket number EPA-HQ-OW-2008-0390. 

 

4

 Simultaneous development of the Mandatory Reporting of Greenhouse Gases: Injection and Geologic 

Sequestration of CO2 Rule (Subpart RR) and the GS Rule was coordinated by EPA, with close consideration for 

potential overlaps in reporting and recordkeeping requirements. Based on the coordinated rule making efforts, EPA 

is minimizing the potential overlap in reporting and recordkeeping requirements to owners and operators of wells 

that may be required to report and record information under both rules. 

5

 U.S. Environmental Protection Agency. 2010. Geologic CO2 Sequestration Technology and Cost Analysis, EPA 

816-R-10-008. 

6

 U.S. Environmental Protection Agency. 2010. Geologic CO2 Sequestration Technology and Cost Analysis, EPA 

816-R-10-008. 

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GS Rule ICR November 2010

In compliance with the PRA (44 USC 3501 et seq.), EPA submitted the ICR for the GS 

Rule to OMB for review and approval prior to proposal. EPA did not receive any comments 

from OMB on the ICR at that time. 

3(c) Consultations 

As described in the previous section, the burden and costs estimated in this ICR are based 

on the T&C document developed for the GS Rule, which was informed by States, U.S. 

Department of Energy (DOE), and public comment. Prior to proposal, the costs in the T&C 

document were reviewed by members of the EPA regulatory workgroup, which included four 

States and the DOE that developed the regulation. For the final rule, EPA revised the T&C 

document to reflect public comments, as described in the previous section. In addition, 

throughout the rulemaking process, the Agency conducted public workshops and public 

hearings, held consultations with specific groups, and attended meetings to ensure transparency 

and facilitate communication with the public and stakeholder groups interested in GS 

technologies, deployment, and associated technical and regulatory issues. 

As part of its outreach, EPA conducted public hearings with participants from industry, 

environmental groups, utilities, academia, States, and the general public. Two separate public 

hearings were held on the proposed GS Rule in September and October 2008, respectively. 

Additionally, a public hearing to solicit public comment on the Notice of Data Availability and 

Request for Comment (NODA) was held in September 2009. Two workshops were also held in 

December 2007 and February 2008. Summaries are available on EPA’s web site, at 

http://www.epa.gov/safewater/uic/wells_sequestration.html. 

 

EPA also coordinated with the Ground Water Protection Council (GWPC), a State 

association that focuses on ensuring safe application of injection well technology and protecting 

ground water resources, and the Interstate Oil and Gas Compact Commission (IOGCC), a 

chartered State association representing oil and gas producing States. Members of IOGCC have 

specific expertise regulating the injection of CO2 for the enhanced recovery of oil and gas in 

depleted oil and gas reservoirs. EPA staff attended national meetings and calls of these 

organizations, as well as those held by technical and trade organizations, NGOs, States, and 

Tribal organizations, to discuss the rulemaking process and GS-specific technical issues. 

In April of 2008, prior to publication of the proposed rule and during development of the 

final rule, the Agency consulted with all Federally-recognized Indian Tribes and invited 

participation in a dedicated GS consultation effort. The EPA Regional Indian Coordinators 

(RICS), National Indian Workgroup (NIWG), National Tribal Caucus (NTC) and the National 

Tribal Water Council contacts were also invited to participate in the consultation. EPA provided 

additional rulemaking updates after publication of the proposal with the above-mentioned groups 

as well as the National Water Program State and Tribal Climate Change Council. The Fort Peck 

Assiniboine & Sioux Tribes and the Navajo Nation received UIC Program primacy for the Class 

II program (under section 1425 of the SDWA) during the proposal period for this rule. 

Therefore, the Agency initiated an additional consultation effort with these Tribal co-regulators 

post-proposal. Documentation of these meetings is available in the Rulemaking docket. 

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GS Rule ICR November 2010

3(d) Effects of Less Frequent Collection 

The testing and monitoring frequencies for some requirements under the GS Rule will be 

established as permit conditions; others, including MITs, are established by regulation. The GS 

Rule will require other parameters to be monitored continuously. These monitoring frequencies 

are based on existing UIC Program regulations for other well classes. EPA believes that the 

monitoring and reporting frequencies established in the GS Rule are the minimum necessary to 

ensure that any leakage would be detected. 

3(e) General Guidelines 

The GS Rule complies with the guidelines (5 CFR 1320.5(d)(2)) implemented under the 

PRA, with some exceptions. One exception is that it requires a response to a request for 

information in less than 30 days, in opposition to the PRA guidelines. Specifically, the GS Rule 

requires notification of the permitting authority within 24 hours if a well loses mechanical 

integrity or if injection may cause endangerment to a USDW. This is consistent with notification 

requirements for permitted wells under existing UIC regulations. The other exceptions are that 

many recordkeeping requirements are longer than PRA guidelines. This longer period reflects 

current UIC Program practices consistent with the time frame associated with the operational and 

post-operational requirements for Class VI injection wells. 

3(f) Confidentiality 

 Owners and operators of injection wells may claim confidentiality on certain information 

provided in the proposed Class VI injection well permit application, as provided in existing 

regulations in 40 CFR 144.5, Confidentiality of Information. If confidentiality is requested, the 

confidential information is treated in accordance with the provisions of 40 CFR 2, Public 

Information. Any confidentiality claim must be made at the time of Class VI injection well 

permit application submission in the manner prescribed by the application form or its 

instructions. In the case of other submissions, respondents may claim confidentiality by stamping 

the words “confidential business information” (CBI) on each page containing such information. 

Claims of confidentiality for the following information will be denied: 

• The name and address of any permit applicant or permittee; 

• Information regarding the existence, absence, or level of contaminants in drinking 

water. 

Information collected under this ICR is intended for the Agency’s and/or State’s internal 

use and there are no plans to routinely release or publish any of the data. However, if no claim of 

confidentiality is made at the time of submission, the information can be made available to the 

public without further notice. Also, all information that is not deemed to be confidential will be 

released to the public if requested under the Freedom of Information Act (FOIA). 

3(g) Sensitive Questions 

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GS Rule ICR November 2010

 The data collection does not ask any sensitive questions concerning sexual behaviors or 

attitudes, religious beliefs, or other matters. 

4 RESPONDENTS AND INFORMATION REQUESTED

 

The following sections provide information on the respondents and the information they 

are requested to provide. 

4(a) Respondents/NAICS Codes 

Respondents to the GS Rule include those who desire to inject CO2 in the subsurface for 

the purpose of long-term storage. They potentially include the owners and operators of coal-fired 

electric power plants and ethanol power plants and the oil and gas extraction industry. The North 

American Industry Classification System (NAICS) code for fossil fuel electric power generation 

is 221112; the code for crude petroleum and natural gas extraction is 211111; and for petroleum 

refining is 324110.7

 States and EPA Regions that provide UIC Class VI Program oversight are 

also respondents. The NAICS code for Tribes is 921150. The code for administration of air and 

water resource and solid waste management programs is 924110. 

4(b) Information Requested 

 The following sections provide details on data items requested and associated activities 

respondents will be required to undertake to provide this information. All data must be submitted 

in electronic format (40 CFR 146.91(e)). 

4(b)(i) Data Items 

Owners and Operators 

EPA will require those seeking permits to own and operate CO2 GS wells to submit the 

following items in order to characterize the proposed site, as described in more detail in 40 CFR 

146.82(a): 

• Information required in 40 CFR 144.31 (e)(1) through (6); 

• A map showing the injection well(s) and the applicable AoR; 

• Information on the geologic structure and hydrogeologic properties of the proposed 

storage site and overlying formations; 

• A tabulation of all wells within the AoR which penetrate the injection or confining 

zone(s); 

• Maps and stratigraphic cross sections indicating the general vertical and lateral limits 

of all USDWs, water wells and springs within the AoR, their positions relative to the 

injection zone(s) and the direction of water movement, where known; and 

 

7

 2007 NAICS Codes. http://www.census.gov/naics/2007/NAICOD07.HTM. The NAICS codes provided above is 

not an exhaustive list. 

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GS Rule ICR November 2010

• Baseline geochemical data on subsurface formations, including all USDWs in the 

area of review. 

In unique situations, owners and operators may request a waiver to the requirement to 

inject below the lowermost USDW and must submit, at the time of permit application, a 

supplemental report that includes the following (40 CFR 146.95(a)): 

• A demonstration that the injection zone is appropriate and meets certain conditions; 

• A demonstration that the confining zone is appropriate and meets certain conditions; 

• A demonstration, using computational modeling (in conjunction with AoR modeling) 

that the USDWs above and below the injection zone will not be endangered; 

• A demonstration that well design and construction will ensure isolation of the 

injectate, and meet well construction requirements of 40 CFR 146.95(f); 

• A description of how the Monitoring and Testing Plan and any other plans will be 

tailored to address injection above the lowermost USDW; 

• Information on public water systems that use USDWs in the AoR; and 

• Any other information required by the permitting authority. 

In addition, owners and operators must submit the following plans and proposals with 

their applications (40 CFR 146.82(a)): 

• Proposed operating data; 

• Proposed pre-operational formation testing program; 

• Proposed stimulation program; 

• Proposed procedure to outline steps necessary to conduct injection operation; 

• Schematic or other appropriate drawings of the surface and subsurface construction 

details of the well; 

• Injection well construction procedures that meet requirements of 146.86; 

• Proposed AoR and Corrective Action Plan that meet requirements of 146.84; 

• A demonstration that the applicant has met financial responsibility requirements 

under 146.85; 

• Proposed Testing and Monitoring Plan required by 146.90; 

• Proposed Injection Well Plugging Plan required by 146.92; 

• Proposed PISC and Site Closure Plan required by 146.93(a); 

• Proposed Emergency and Remedial Response Plan required by 146.94(a); and 

• A list of contacts for States, Tribes, and Territories within the AOR 

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GS Rule ICR November 2010

• Any other information requested by the permitting authority. 

After construction of the well but before operation begins, owners or operators must 

submit the following information (40 CFR 146.82(c)): 

• The AoR based on modeling, using data obtained during logging and testing of the 

well and the formation; 

• Any updates, based on data obtained during logging and testing, to geologic and 

hydrogeologic data initially submitted with the permit application; 

• Information on the compatibility of the CO2 stream with fluids in the injection zone 

and minerals in both the injection and the confining zone(s); 

• Results of the formation testing program; 

• Final injection well construction procedures that meet requirements of 146.86; 

• The status of corrective action on wells in the AoR; 

• All available logging and testing program data on the well (collected under 40 CFR 

146.87); 

• A demonstration of mechanical integrity prior to commencing injection pursuant to 

146.89; 

• Any updates to the proposed AoR and Corrective Action Plan, Testing and 

Monitoring Plan, Injection Well Plugging Plan, PISC and Site Closure Plan, or the 

Emergency and Remedial Response Plan needed to address new information 

collected during logging and testing; and 

• Any other information requested by the Director. 

Once an operating permit has been issued, EPA will require semi-annual reports of the 

following (40 CFR 146.91(a)): 

• The characteristics of injection fluids, injection pressure, flow rate, volume, and 

annular pressure; 

• A description of any events that required shutdown or that resulted in an exceedance 

of operating parameters specified in the permit; 

• Monthly and cumulative volume or mass of CO2 injected; 

• Monthly annulus fluid volume added; and 

• The results of any monitoring conducted under the Monitoring and Testing Plan. 

Although reporting is semi-annual, many of the monitoring requirements are more 

frequent; some are continuous. Some frequencies are specified in the GS Rule; others will be 

site-specific and will be established and documented in the Monitoring and Testing Plan. 

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GS Rule ICR November 2010

Within 30 days, owners must report results of MITs, well workovers, and any other test 

required by the Director (40 CFR 146.91(b)). They must also notify the director 30 days in 

advance of a planned well workover, planned stimulation activities, or any other planned test of 

the well (40 CFR 146.91(d)). 

Certain events require the owner or operator to notify the State within 24 hours. These are 

associated with triggers indicating potential endangerment to USDWs and include the following 

(40 CFR 146.91(c)): 

• Evidence that the injected CO2 stream and associated pressure front may cause 

endangerment to a USDW; 

• Noncompliance with a permit condition, or a problem with the injection system, that 

may cause fluid migration into or between USDWs; 

• Any triggering of a shut-off system; 

• Failure to maintain mechanical integrity; and 

• Any release of gas to the atmosphere or biosphere, at sites where soil or air 

monitoring is required. 

At least every 5 years (or when changes in site-specific operational conditions established 

up front and specified in the plans warrant re-evaluation), operators must also re-evaluate the 

AoR and submit an amended AoR and Corrective Action Plan as needed to the permitting 

authority (40 CFR 146.84). Operators must also annually update the cost information supporting 

their financial responsibility determinations and annually provide an inflation update (40 CFR 

146.85). The final rule also requires owners and operators to revise their monitoring and testing 

and emergency and Remedial Response Plans at least every 5 years, as needed, based on the 

AoR reevaluation or other relevant data. Where no revision is needed, owners or operators must 

demonstrate that this is the case (40 CFR 146.90; 40 CFR 146.94). 

Following the injection phase (i.e., during well plugging and PISC) the owner or operator 

must submit the following information (40 CFR 146.92; 40 CFR 146.93): 

• A notification of intent to plug injection wells, along with any revisions made to the 

original Plugging Plan submitted with the permit application; 

• A plugging report after plugging is complete; 

• A revised PISC and Site Closure Plan: where no revision is needed, demonstrate that 

that is the case; 

• Periodic reports of the results of post-injection ground water quality monitoring and 

the position of the CO2 plume and pressure front; 

• A non-endangerment demonstration that the CO2 plume has stabilized and there is no 

threat to USDWs following the PISC period; 

 Page 12 
GS Rule ICR November 2010

• Notice of intent for site closure and, if needed, a revised PISC and Site Closure Plan; 

and 

• A site closure report and copy of recording of a notation on the deed to the property 

regarding the fact that injection occurred. 

Permitting Authorities 

Permitting authorities will be required to review all the items submitted by owners and 

operators (see above). 

States seeking primacy for administrating a Class VI program must receive approval for 

their program from EPA. States that do not currently have primacy under SDWA Section 1422 

must include the following (40 CFR 145.22): 

• A letter from the governor requesting program approval; 

• A complete program description (as described in 40 CFR 145.23); 

• An attorney general’s statement, as required by 40 CFR 145.24; 

• A memorandum of agreement (MOA) with the Regional administrator, as required by 

40 CFR 145.31(b); 

• Copies of all applicable State statutes and regulations; and 

• A showing of the State’s public participation activities, as required by 40 CFR 

145.31(b). 

According to the GS Rule, States may submit their Class VI primacy application 

electronically. 

4(b)(ii) Respondent Activities 

Owners and Operators 

In general, owners and operators seeking to obtain permits for CO2 GS wells will be 

involved in the following collection activities: 

• Reading and understanding the GS Rule; 

• Gathering new or existing geological data and other site information required as part 

of the permit application, including maps, geological and geochemical data, and data 

on existing wells in the AoR; 

• Developing plans and procedures that must be submitted with the permit application, 

including the proposed operating data, proposed formation testing program, proposed 

stimulation program, proposed injection procedure, schematics of well construction, 

Testing and Monitoring Plan, proposed area of review and Corrective Action Plan, 

 Page 13 
GS Rule ICR November 2010

injection well construction procedures, proposed Injection Well Plugging Plan, 

proposed PISC and Site Closure Plan, and proposed emergency and Remedial 

Response Plan (40 CFR 146.82(a)); 

• Developing a report including the information required as part of a waiver 

application, if applying for a waiver (40 CFR 146.82(d)); 

• Demonstrating financial responsibility and resources for corrective action, injection 

well plugging, post-injection site care and closure, and emergency and remedial 

response; and 

• Compiling the above information and preparing the permit application. 

After submitting the UIC permit application but before beginning operation of a Class VI 

well, owners and operators must conduct testing and submit additional information. Activities 

include the following: 

• Submitting all logging and testing data; results of formation testing; and data on 

compatibility of the CO2 stream with fluids and minerals in the injection and 

confining zones, and well materials; 

• Demonstrating mechanical integrity of the well; 

• Calculating the AoR using computational models, based on data obtained during 

logging and testing; and 

• Providing information on status of corrective action on wells in the AoR. 

Once operation commences, owners and operators must monitor the well and submit 

semi-annual reports. They must monitor the following: 

• Chemical and physical characteristics of the CO2 stream; 

• Injection pressure, flow rate and volume, and pressure on the annulus, and annulus 

fluid volume (using continuous recording devices); 

• Alarms and automatic shut-off systems; and 

• Corrosion of well materials. 

In addition, at least once per year operators must demonstrate external mechanical 

integrity and report the results of testing. Throughout the injection phase, operators must monitor 

ground water quality, track the CO2 plume and pressure front, and perform any soil gas/ surface 

air monitoring or other required monitoring, as specified in their approved Testing and 

Monitoring Plans. 

At least every 5 years, the owner or operator must re-evaluate the AoR by rerunning the 

delineation models to incorporate operational and monitoring data. Based on this, the operator 

must revise the AoR and Corrective Action Plan, if needed. This reevaluation also triggers 

 Page 14 
GS Rule ICR November 2010

revisions to monitoring and testing, and emergency and Remedial Response Plans every 5 years, 

as needed. Where no revision is needed, owners or operators must demonstrate that none is 

required. 

At the end of an injection project, the operator must submit a notice of intent to plug the 

injection well and a notice of intent for site closure. During the PISC phase, operators will 

monitor ground water quality, track the position of the CO2 plume and pressure front as well as 

report to the permitting authority on the results as specified in their approved PISC Plans. 

Following the post-injection monitoring, operators will perform a non-endangerment 

demonstration to show that there is no threat to USDWs, and that no further monitoring is 

necessary. At this point, if closure of the site is authorized, the owner or operator must submit a 

site closure report and must record a notation on the deed to the property regarding the fact that 

injection occurred on the site.

Recordkeeping activities include maintaining the AoR and Corrective Action Plan, the 

Well Plugging Plan, the Emergency and Remedial Response plan, and the PISC and Site Closure 

Plan. Operators must also maintain and adjust cost information associated with their financial 

responsibility determinations. 

Additionally, owners and operators of Class VI wells are required to keep records 

associated with permit application throughout the life of the geologic sequestration project and 

until 10 years after site closure. Owners and operators must also keep all reports required by 40 

CFR 146.90(b) through 146.90(i) for 10 years. Data on the nature and composition of all injected 

fluids must be kept until 10 years after site closure, and the Director may require owners and 

operators to deliver these records to the Director at the conclusion of the required period. The 

Director may require owners and operators to keep any of the above records for longer than 10 

years after site closure (40 CFR 146.91(f)). 

Permitting Authorities 

 Permitting authorities may serve in the role of respondents when reviewing and 

evaluating information and reports submitted by owners or operators. Permitting authorities are 

anticipated to be involved in the following activities: 

• Read and understand the rule; train staff; 

• Modify or develop data management systems to receive and evaluate information 

related to GS activities, as required; 

• Review permit applications and prepare permits; issue notice and oversee public 

comment period on draft permit; 

• Review waiver applications and issue public notice on proposed waiver, if applicable; 

• Review pre-operational testing and logging data, AoR evaluations, and the status of 

corrective action; 

• Review reports from operators as described in 40 CFR 146.91; 

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GS Rule ICR November 2010

• Review AoR re-evaluations and updates to the AoR and Corrective Action Plan, 

Monitoring and Testing Plan, and Emergency and Remedial Response Plan; 

• Modify permits as necessary to incorporate and reflect updated plans; 

• Review notices of intent to plug wells; 

• Review post-injection monitoring data and non-endangerment demonstrations and 

determine whether to authorize site closure; 

• Review notices of intent to close GS sites and site closure reports; and 

• Maintain records of the above information submitted by operators. 

States are required to maintain records of Class VI injection well operation verification 

activities and each determination made, and report to EPA under the UIC program in accordance 

with reporting requirements at 40 CFR 144.8 through the UIC Program. 

States must develop and submit their proposed UIC Class VI program to EPA for 

approval of primary enforcement authority. State primacy applications for UIC Programs must 

include the items described in 40 CFR 145.23. 

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GS Rule ICR November 2010

5 INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT 

The following sections describe the Agency activities related to analyzing, maintaining, 

and distributing the information collected. 

5(a) Agency Activities 

The Agency will be responsible for promulgating the GS Rule and overseeing its 

implementation. EPA Regions and EPA Headquarters will have different responsibilities. If a 

State does not seek or obtain approval for primacy of the Class VI program, EPA Regions will 

directly implement the program (see section 4b(ii) of this document). (For this ICR, the burden 

for EPA Regions conducting these implementation activities is combined with that for States 

with primacy to provide an overall burden for all permitting authorities.) Regions will review 

primacy applications submitted by the States in coordination with EPA headquarters. Lastly, 

Regions review waiver applications after States with primacy make an initial recommendation on 

whether to grant a waiver. The Regions will concur or not concur with the States’ decision 

(146.95(d)(2)). 

Headquarters will also be responsible for updating the UIC database to enable it to hold 

Class VI compliance data and permit application data. 

5(b) Collection Methodology and Management 

EPA will require the reporting of data from owners or operators in an electronic format 

acceptable to the Director for site, facility, and monitoring information.8

 Long-term retention of 

records in an electronic format may also be required at the Director's discretion. For records 

stored in an electronic format, information should be maintained digitally in multiple locations 

(i.e., backed-up) in accordance with best practices for electronic data. 

Electronic reporting involves transmitting UIC data in a standard electronic format that 

can be readily incorporated into Headquarters UIC databases without manual data entry. 

Electronic reporting supports the Agency’s effort to streamline the UIC Program by reducing the 

reporting burden on the States and improving EPA’s data collection methods. Electronic 

reporting offers an opportunity to: 

• Reduce data entry; 

• Reduce mailing costs; 

• Reduce the routine process of handling paperwork; 

 

8

 To provide flexibility to owners and operators, during the initial year after rule promulgation, the UIC database 

will accept either hardcopy or electronic data submissions. 

 Page 17 
GS Rule ICR November 2010

• Reduce or eliminate the need to store large quantities of paper documents; and 

• Increase the accuracy of reports submitted to EPA.

 In 2007, EPA began creating a national UIC database for well, facility, and compliance 

data submitted by permitting authorities. The national UIC data model contains approximately 

120 data elements related to various aspects of the UIC Program. At this time, several permitting 

authorities are actively participating in use of the national UIC database. EPA encourages States 

to work with EPA Regional offices as much as possible in order to use the new database system 

for reporting of information regarding Class VI wells. The database includes a mechanism to 

electronically transfer data between existing State and EPA Regional databases and 

Headquarters’ database, eliminating the need for State UIC Program Directors to complete paper 

reporting forms. (The burden and cost associated with developing and maintaining the national 

UIC database is accounted for in the UIC Program ICR; the GS Rule is assumed to add a 

negligible cost to this requirement due to the small number of GS sites.)

5(c) Small Entity Flexibility 

In general, a small entity is defined as: (1) a small business with annual revenue less than 

$6 million according to Small Business Administration size standards; (2) a small governmental 

jurisdiction that is a government of a city, county, town, school district or special district with a 

population of less than 50,000; or (3) a small organization that is any not-for-profit enterprise 

which is independently owned and operated and is not dominant in its field. In some cases, 

however, industries propose different standards for small businesses. 

EPA expects that Class VI wells will be owned and operated by fossil fuel power 

generators, oil and gas extraction companies, and oil and gas refineries. Because the resources 

necessary to construct injection wells that meet the standards of the GS Rule are significant, EPA 

believes that none of the owners or operators of Class VI wells will be small entities. Therefore, 

EPA assumes that the GS Rule will cause no significant impact on small entities. 

5(d) Collection Schedule 

The final GS Rule is scheduled for promulgation in 2011; this ICR covers the first three 

years of implementation (2011 through 2013). States wishing to obtain EPA approval for their 

Class VI programs will complete and submit Class VI primacy applications to EPA within 270 

days of GS Rule promulgation. Under 40 CFR 145.31(e), EPA has 90 days to review each 

application. No other deadlines apply to owners or operators or to States during the ICR 

clearance period. 

Because this ICR covers only the first three years of a regulation that will cover injection 

operations with potentially long life spans (i.e., up to 40 years of injection and 50 years of postinjection monitoring), EPA assumes that only a limited portion of the paperwork burden for GS 

projects will be captured in this ICR. EPA anticipates that the majority of the activities during 

the information collection will be associated with States applying for primacy. 

 Page 18 
GS Rule ICR November 2010

EPA estimates that approximately two operators are assumed to submit permit 

applications during the ICR clearance period. Operators will conduct these activities during the 

second and third years of the ICR period. EPA predicts that CO2 GS well operators will begin to 

submit monitoring data and conduct MIT during the third year, but that they will not perform 

AoR re-evaluations, plug their injection wells, or perform PISC within the period covered by this 

ICR. 

EPA estimates that 32 States will apply for primacy in the first year of the collection. 

This is a conservative estimate based on the number of States with existing plans for GS 

operations or with existing Class II wells that may be subject to conversion to Class VI. 

Permitting authorities will review permit applications during the second and third years 

of the ICR period. 

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GS Rule ICR November 2010

6 ESTIMATING BURDEN AND COST OF COLLECTION 

 This section contains EPA’s estimates of the burden and costs to respondents (i.e., well 

owner/operators and permitting authorities) associated with CO2 GS Rule paperwork 

requirements, and federal burden and costs for reviewing respondent submissions. Section 6(a) 

provides burden estimates for all respondent types. Section 6(b) contains estimates of respondent 

costs for the information collection. Section 6(c) summarizes federal burden and costs as users of 

respondent data. Section 6(d) describes the respondent universe and the total burden and cost of 

this collection to respondents. Section 6(e) presents bottom line burden and costs for all 

respondents, and the burden statement for this information collection is in Section 6(f). 

 The burden and cost estimates for this ICR were derived from unit cost estimates in the 

Geologic CO2 Sequestration Technology and Cost Analysis9

. Because so many activities are 

included in each rule requirement, the unit burden and cost associated with each activity are not 

shown in this section but are presented in detail in Chapter 5 (and associated appendices) of the 

Cost Analysis for the Final GS Rule10. Appendix A, Ex. A.1.1 of this ICR contains a detailed list 

of each activity for which owner or operator burden is incurred (and for which a unit burden and 

cost has been estimated). Each activity is assigned an identification number (e.g., A-2) used to 

identify the activity in subsequent exhibits. Activities are grouped into larger categories that 

generally correspond to specific rule sections. For instance, under the site characterization 

category (which corresponds to 40 CFR 146.82), activities include seismic surveys to identify 

faults and fractures in confining units, analysis of seismic history, literature searches to obtain 

geomechanical information, and cores and tests to obtain geomechanical information, among 

others. Similarly, a list of activities for permitting authorities is presented in Exhibit A.2.1. 

 Because site characterization costs for GS wells differ with the geology of the site, the 

size of the project, and whether an operator applies for a waiver, EPA estimated burden and cost 

for five different types of GS projects. EPA divided the projects by formation type into saline 

formations and depleted oil and gas reservoirs (Enhanced Recovery (ER) operations) and then 

further subdivided based on whether the owner or operator was applying for a waiver and the 

size of the project. The five categories of projects are below: 

• Saline formation, pilot-scale; 

• Saline formation, large-scale, non-waivered; 

• Saline formation, large-scale, waivered; 

• Depleted oil and gas reservoir, (ER, large-scale) non-waivered; and 

• Depleted oil and gas reservoir, (ER, large-scale) waivered. 

 For each type of project, the appendices present burden and costs incurred by owners and 

operators, and by permitting authorities. Appendix A presents the incremental burden and costs 

for moving from the information collection requirements of the UIC program for the baseline 

 

9

 U.S. Environmental Protection Agency. 2010. Geologic CO2 Sequestration Technology and Cost Analysis, EPA 

816-R-10-008. 

10 U.S. Environmental Protection Agency. 2010. Draft Cost Analysis for the Federal Requirements Under the 

Underground Injection Control Program for Carbon Dioxide Geologic Sequestration Wells (Final GS Rule), EPA 

816-R10-013.

 Page 20 
GS Rule ICR November 2010

scenario (Class I non-hazardous wells) to the selected alternative (Class VI rule) over the ten 

years following rule promulgation. EPA assumes that without the GS Rule, owners and operators 

would have constructed and operated GS wells according to UIC requirements for Class I nonhazardous wells, the standard used for construction of many experimental GS wells. Reporting 

and recordkeeping burden and costs for the selected alternative and baseline are presented in 

Appendix B and C, respectively. The incremental burden and costs presented in Appendix A are 

obtained by subtracting the burden and cost for complying with the baseline scenario from the 

full burden and cost of complying with the selected alternative. 

EPA estimates that the average annual net change burden (for owners/operators, 

permitting authorities, and the Agency) for the ICR clearance period is 17,913 hours, for a total 

of 53,740 burden hours. The average annual net change cost is $12.3 million, for a total cost of 

$36.9 million from 2011 through 2013. Average annual net change burden and costs are 

provided in Exhibit 6.1a below. 

Exhibit 6.1a: Average Annual Net Change Burden and Costs for the GS Rule ICR 

(2011 – 2013) 

Source 

Category

Annual 

Respondents

Annual 

Responses

Annual 

Burden (hrs)

Annual Labor 

Cost ($) 

Annual 

Capital Cost 

($) 

 Annual O&M 

Cost ($) 

 Total Annual 

Cost ($) 

Owners and 

Operators 1.0 6.9 1,549 204,574 5,827,027 5,454,346 11,485,946

Permitting 

Authorities 10.7 23.6 11,241 555,763 - - 555,763

Agency 1.0 11.7 5,123 256,880 - - 256,880

Total 12.6 42.3 17,913 1,017,217 5,827,027 5,454,346 12,298,589

Source: Appendix A.3.2d 

Notes: 

1. Detail may not add exactly to total due to independent rounding. 

2. “Annual Burden Hours” reflects an annual average for all project types over the 3-year ICR period.

6(a) Estimating Respondent Burden 

6(a)(i) Burden to Owners and Operators of CO2 GS Wells 

 EPA’s estimate of the annual reporting and recordkeeping burden to owners and 

operators associated with submitting permit applications (and applying for waivers from the 

requirement to inject below the lowermost USDW), delineating the AoR and performing 

corrective action, pre-operational testing, testing and monitoring, and reporting and 

recordkeeping during the ICR clearance period is presented in Exhibit 6.1b. 

 Page 21 
GS Rule ICR November 2010

Exhibit 6.1b: Average Annual Net Change Owner and Operator Burden and Costs 

for the GS Rule ICR (2011 – 2013) 

Source 

Category

Annual 

Respondents

Annual 

Responses

Annual 

Burden (hrs)

Annual Labor 

Cost ($) 

Annual 

Capital Cost 

($) 

 Annual O&M 

Cost ($) 

 Total Annual 

Cost ($) 

Saline Pilot - - - - - - -

Saline Large, 

Non-Waivered 0.9 4.9 1,089 145,151 5,459,317 4,189,789 9,794,257

Saline Large, 

Waivered 0.1 2.1 461 59,423 367,710 1,264,556 1,691,689

ER, NonWaivered - - - - - - -

ER, Waivered - - - - - - -

Total 1.0 6.9 1,549 204,574 5,827,027 5,454,346 11,485,946

Source: Appendix A.3.2a 

Notes: 

1. Detail may not add exactly to total due to independent rounding. 

2. “Annual Burden Hours” reflects an annual average for all project types over the 3-year ICR period. 

 The annual average net change burden to owners and operators of Class VI wells 

nationwide during the ICR clearance period is estimated to be 1,549 hours. The activities during 

the ICR clearance period include the following: preparing the permit application and applying 

for waivers (ten percent of owners and operators are assumed to apply for waivers), performing 

geological site characterization, developing necessary plans, and pre-operational testing and 

reporting, including modeling the AoR and performing all pre-operational corrective action. 

Owners and operators will also begin collecting operating and monitoring data as required by the 

Monitoring and Testing Plan and will begin submitting semi-annual reports. They will also begin 

periodic MIT. The burden is assumed to be incurred by owners and operators with projects in 

large saline aquifers. No pilot saline projects or enhanced recovery projects are expected to begin 

during the ICR period. 

 EPA does not expect that any operators will conduct activities associated with periodic 

AoR re-evaluations, plan updates, injection well plugging, or PISC during the three years 

covered by this ICR. These will occur in subsequent ICR periods (see Appendix A, Exhibit A.3.2 

for net change burden for years 4-10 following promulgation. 

EPA recognizes that many UIC information collection activities are performed by 

contractors. The operator unit burden estimates reported in this section represent a composite of 

the operator time required to both perform an information collection activity and to supervise a 

contractor when the contractor performs the activity. Contractor services are not generally 

broken out into labor and other costs for this ICR; therefore, all contractor costs are considered 

O&M costs. 

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GS Rule ICR November 2010

6(a)(ii) Burden to Permitting Authorities 

 Permitting authorities’ burden associated with implementing Class VI programs arises 

from program oversight and reviewing and responding to permit applications (including 

applications for waivers from the requirements to inject below the lowermost USDW) and preoperational reports, operator testing and monitoring reports, AoR re-evaluations, and plugging 

and post-injection reports submitted by operators. Note that permitting authority burden includes 

burden for EPA Regions directly implementing the Class VI rule in States that do not have 

primacy, as well as burden for States. Average annual net change permitting authority burden 

associated with oversight of Class VI programs is presented in Exhibit 6.1c. 

Exhibit 6.1c: Average Annual Net Change Permitting Authorities Burden and 

Costs for the GS Rule ICR (2011 – 2013) 

Source 

Category

Annual 

Respondents

Annual 

Responses

Annual 

Burden (hrs)

Annual Labor 

Cost ($) 

Annual 

Capital Cost 

($) 

 Annual O&M 

Cost ($) 

 Total Annual 

Cost ($) 

Saline Pilot - - - - - - -

Saline Large, 

Non-Waivered 0.6 1.1 10 518 - - 518

Saline Large, 

Waivered 0.1 1.2 9 463 - - 463

ER, NonWaivered - - - - - - -

ER, Waivered - - - - - - -

ProjectIndependent 

Activities 10.7 21.3 11,221 554,783 - - 554,783

Total 10.7 23.6 11,241 555,763 - - 555,763

Source: Appendix A.3.2b 

Notes: 

1. Detail may not add exactly to total due to independent rounding. 

2. “Annual Burden Hours” reflects an annual average for all project types over the 3-year ICR period. 

3. The net change in “Annual Burden” for large saline non-waivered projects is positive due to an increase in the 

burden for permitting authorities to review monitoring reports submitted by operators under the selected alternative 

in comparison to the baseline. 

 EPA estimates that the average annual net change burden to permitting authorities 

associated with this information collection will be 11,241 hours. The burden is allocated as 

follows: 

• The majority of the burden is associated with completing primacy applications and 

staff training, which will impose an average annual net change burden of 11,221 

hours during the 3 years covered by this ICR, as shown in the “Project Independent 

Activities” row of Exhibit 6.1c. EPA estimates that applying for primacy will require 

0.5 full-time equivalents (FTEs), or 1,040 hours, per State. 

• Permitting authorities will spend an average of 19 hours annually overseeing 

approximately two Class VI well operators. This includes reviewing permit and 

waiver applications (if needed) for Class VI wells, writing permits, and reviewing 

AoR studies and pre-operational data. EPA estimates that 32 of 57 States (or 56% 

 Page 23 
GS Rule ICR November 2010

percent of States) will apply for and gain primacy within the first year of the 

clearance period. Therefore, EPA estimates that 56 percent of the burden for these 

activities will be incurred by States and the remaining 44 percent will be incurred by 

EPA Regions. Ten percent of applications received from large scale projects are 

assumed to include waiver applications. Permitting authorities will also begin to 

review operational and monitoring data submitted in semi-annual reports, along with 

MIT results. 

During the ICR clearance period, EPA predicts that primacy agencies will not spend any 

time reviewing AoR re-evaluations, updates to AoR and Corrective Action Plans and other plans, 

or plugging and post-injection monitoring reports submitted by operators of Class VI sites, 

because no sites are expected to reach that phase during this period. This burden is expected to 

be incurred after the ICR clearance period. Appendix A, Exhibit A.3.2 presents the burden and 

costs for years 1-10 following rule promulgation. 

6(b) Estimating Respondent Costs 

6(b)(i) Costs to Operators 

 Exhibit 6.1b shows the average annual net change costs for owners and operators of Class 

VI injection wells over the 3-year ICR clearance period. The average annual net change costs are 

approximately $11.5 million, which consists of $0.2 million in labor costs, $5.8 in capital costs 

and $5.5 million in O&M costs. An example of capital costs associated with reporting 

requirements under the GS Rule is installation and construction of monitoring wells. Examples 

of O&M costs include sampling costs, such as those for samples collected to develop 

geochemical baselines for the injection and confining zones. 

 For costing purposes, EPA estimated the base hourly labor rates for two occupations: 

geologists and mining and geological engineers. EPA obtained the rates for geologists from the 

American Association of Petroleum Geologists’ 2008-2009 annual salary survey. Assuming 15-

19 years of experience, the rate is $67.02 (based on an annual salary of $139,400).11 EPA 

obtained rates for mining and geological engineers from the Society for Petroleum Engineers 

annual survey. For a reservoir engineer with 11-15 years of experience, the rate is $69.14 (based 

on an annual salary of $143,800).12 EPA multiplied these rates by a loading factor of 1.6, as 

suggested by EPA’s November 2005 ICR Handbook, to account for overhead and benefits. Thus, 

the loaded labor rate for geologists is $107.23, and the rate for engineers is $110.62. 

 

 

11 http://www.aapg.org/explorer/salarysurvey.cfm 12 Society for Petroleum Engineers Annual Membership Salary Survey Highlight Report. Prepared by Western 

Management Group. September 2008. p. 12 

http://www.spe.org/spe-site/spe/spe/career/salary_survey/08SalarySurveyHighlights.pdf 

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GS Rule ICR November 2010

6(b)(ii) Costs to Permitting Authorities 

 Exhibit 6.1c shows that the average annual net change cost to permitting authorities is 

estimated at $0.6 million, all of which is labor cost. For this ICR, EPA assumed that the average 

hourly labor rate for a State employee is $30.90, based on the Bureau of Labor Statistics average 

hourly wage for workers in the life, physical, and social science occupations in 2008.13 This rate 

was multiplied by 1.6 to get a loaded rate of $49.44. The base hourly labor rate for EPA Regions 

directly implementing the Class VI program in States without primacy is $31.34. This rate is 

based on federal employee pay scales issued by the U.S. Office of Personnel and Management14

and was multiplied by 1.6 for a loaded rate of $50.14. As described in section 6(a)(ii), EPA 

estimates that 56 percent of the burden associated with reviewing permit applications will be 

incurred by States, and 44 percent will be incurred by EPA Regions. 

 The incremental non-labor costs (capital and O&M) to permitting authorities associated 

with the Class VI program are estimated to be negligible. 

6(c) Estimating Agency Burden and Costs 

 EPA Regions will have oversight responsibilities for the Class VI program. These include 

reviewing primacy applications, as well as reviewing waiver applications after States have 

reviewed them (in States that do not have primacy, burden to EPA Regions for reviewing waiver 

applications is counted as permitting authority burden). Regions will review primacy 

applications submitted by the States and reviewing waiver applications passed on by States. 

 

 EPA estimates that EPA Headquarters will spend 2 FTEs, or 4,160 hours, annually to 

update the data systems to manage Class VI data. 

 The total annual net change Agency burden associated with the reporting and 

recordkeeping requirements of the GS Rule is 5,123 hours. As explained in section 6(b)(ii), EPA 

assumes the average hourly labor rate for salary and overhead and benefits for Agency staff to be 

$50.14. The annual net change Agency cost associated with this collection is $0.3 million. A 

summary of Agency costs is presented in Exhibit 6.1d. 

 

13 Occupational Employment and Wages, 2008. Table 1. National employment and wage data from the Occupational 

Employment Statistics survey by occupation, May 2008. http://www.bls.gov/news.release/pdf/ocwage.pdf. 14 Salary Table 2008-GS, Incorporating the 2.5 Percent General Schedule Increase, Effective 2008. Hourly/Overtime 

Rates by Grade and Step. Grade 12, Step 5. http://www.opm.gov/oca/08tables/html/gs_h.asp. 

 Page 25 
GS Rule ICR November 2010

Exhibit 6.1d: Average Annual Net Change Agency Burden and Costs for 

the GS Rule ICR (2011 – 2013) 

Source 

Category

Annual 

Respondents

Annual 

Responses

Annual 

Burden (hrs)

Annual Labor 

Cost ($) 

Annual 

Capital Cost 

($) 

 Annual O&M 

Cost ($) 

 Total Annual 

Cost ($) 

Saline Large, 

Waivered 0.1 0.1 3 143 - - 143

ER, Waivered - - - - - - -

ProjectIndependent 

Activities 1.0 11.7 5,120 256,737 - - 256,737

Total 1.0 11.7 5,123 256,880 - - 256,880

Source: Appendix A.3.2c 

Notes: 

1. Detail may not add exactly to total due to independent rounding. 

2. “Annual Burden Hours” reflects an annual average for all project types over the 3-year ICR period. 

6(d) Respondent Universe 

 In this section, EPA describes the number of respondents subject to each paperwork 

activity in this ICR. The respondent universe is based on EPA’s assumptions of the number of 

permittees subject to each paperwork requirement, e.g., the number of permit applications 

expected, or the percent of permittees subject to monitoring or reporting requirements and the 

frequency with which they must comply with those requirements. The frequency at which each 

activity is performed is presented in the burden and cost tables.

 EPA estimates that 32 States will apply for and gain primacy within the first year of the 

clearance period. This number represents 56 percent of the 57 States, tribes, and territories 

currently active in the UIC program. EPA assumes that no tribes will seek primacy for Class VI 

wells during the information collection period. 

 EPA estimates that approximately two GS projects will begin the deployment process in 

years two and three of the ICR clearance period. This is based on the deployment schedule in the 

cost model for the Cost Analysis for the Final GS Rule15. EPA predicts that approximately one of 

the two GS projects will be located in States with primacy; thus it is estimated that 

approximately one State will incur paperwork burden associated with operator submittals. EPA 

assumes the other GS project will be permitted under the authority of a program directly 

implemented by the EPA Regions. 

During the three years covered by this ICR, approximately two operators will apply for a 

permit (including those who apply for a waiver). It is estimated that approximately one owner or 

operator will apply for a permit in the second year of the ICR clearance period, and 

approximately one owner or operator will apply in the third year. 

 

15 U.S. Environmental Protection Agency. 2010. Draft Cost Analysis for the Federal Requirements Under the 

Underground Injection Control Program for Carbon Dioxide Geologic Sequestration Wells (Final GS Rule), EPA 

816-R10-013. 

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GS Rule ICR November 2010

6(e) Bottom Line Annual Burden and Costs 

 This section provides a description of bottom line estimates for implementing the federal 

requirements for underground injection of CO2 for the purpose of GS. The bottom line net 

change burden hours and costs for owners and operators, permitting authorities, and the Agency 

are the summaries of the hours and costs collectively incurred for all activities associated with 

the change in moving from the information requirements of the UIC program for Class I nonhazardous wells (baseline) to the selected alternative under the GS Rule over the three years 

covered by this ICR. The first part of this section describes the estimated average annual net 

change costs and hourly burdens for owners and operators and permitting authorities. The second 

part discusses the potential net change cost and burden to EPA. Figure 6.2 presents a summary of 

the average annual net change respondent burden over three years for owners and operators, 

permitting authorities, and EPA. All additional exhibits relating to this ICR are in Appendix A, 

B, and C. 

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GS Rule ICR November 2010

Exhibit 6.2: Bottom Line Average Annual Net Change Burden and Costs for the 

3-Year ICR Period 

11.6 (=)

1.0 (+) Owners and Operators

10.7 Permitting Authorities

30.6 (=)

6.9 (+) Owners and Operators

23.6 Permitting Authorities

7.2 (=)

6.9 (/) Total annual Owners and Operators responses (from above)

0.97 Total annual number of Owners and Operators respondents (from above)

2.2 (=)

23.6 (/) Total annual Permitting Authority responses (from above)

10.7 Total annual number of Permitting Authority respondents (from above)

12790.5 (=)

1549.5 (+) Owners and Operators hours

11241.0 Permitting Authority hours

223.0 (=)

1549.5 (/) Total Owner and Operator annual hours (from above)

6.9 Total Owner and Operator responses (from above)

475.7 (=)

11241.0 (/) Total Permitting Authority annual hours (from above)

23.6 Total Permitting Authority responses (from above)

 $ 11,281,372 (=)

 $ 11,281,372 (+) Owners and Operators Capital and O&M costs

 $ - Permitting Authority Capital and O&M costs

 $ 12,041,709 (=)

 $ 11,485,946 (+) Owners and Operators costs

 $ 555,763 Permitting Authority costs

 $ 17,913 (=)

 $ 12,791 (+) Total respondent hours (from above)

 $ 5,123 Total EPA hours

 $ 12,298,589 (=)

 $ 12,041,709 (+) Total respondent cost

 $ 256,880 Total EPA cost

2) Permitting Authorities include States, Tribes, and Regions acting on behalf of States and Tribes without primacy.

Total Annual Cost (resp. plus 

Agency) 

Notes: 

1) Detail may not add exactly to totals due to rounding.

Total Annual Respondent 

Burden Hours

Hours per Response for Owners 

and Operators

Hours per Response for 

Permitting Authorities

Annual O&M and Capital Cost

Total Annual Respondent Cost

Total Annual Hours (resp. plus 

Agency) 

Annual Number of Respondents

Total Annual Responses

Annual Number of Responses 

per Owner/Operator

Annual Number of Responses 

per Permitting Authority

6(e)(i) Variations in the Annual Bottom Line 

The burden and costs incurred by respondents to the CO2 GS Rule differ over each of the 

3 years covered by this ICR. The differences are due primarily to the fact that States applying for 

primacy will do so only during the first year of the ICR period. The EPA burden associated with 

reviewing primacy applications will be incurred during the same year. In addition, the 

approximately two operators assumed to apply for Class VI permits will apply only during the 

second and third years of the ICR period. Permitting authority oversight burden during the ICR 

clearance period will vary accordingly, as States and EPA Regions respond to UIC permit 

applications and waiver applications by reviewing the applications and writing permits. Owners 

and operators are expected to begin collecting monitoring data, conducting MIT, and submitting 

semi-annual reports during the third year of the ICR period. Permitting authorities will review 

 Page 28 
GS Rule ICR November 2010

 Page 29 

 

these data. Appendix A, Exhibit A.3.2 presents the burden and costs for years 1-10 following 

rule promulgation. 

6(f) Burden Statement 

The annual net change public reporting and recordkeeping burden for this collection of 

information is estimated to average 1,549 hours per CO2 GS well owner/operator respondent per 

year, 1,054 hours per permitting authority respondent per year, and 5,123 hours for the Agency 

per year for the 3-year ICR period.16 

 Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA's 

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for the GS Rule 

under Docket ID No. EPA-HQ-OW-2008-0438, which is available for public viewing at the 

Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution 

Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 

a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for 

the Reading Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 

566-2426. An electronic version of the public docket is available at http://www.regulations.gov. 

This site can be used to submit or view public comments, access the index listing of the contents 

of the public docket, and to access those documents in the public docket that are available 

electronically. Once in the system, select “search,” then key in the docket ID number identified 

above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office 

of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk 

Office for EPA. Please include the EPA Docket ID No. (EPA-HQ-OW-2008-0438), and OMB 

control number (2040-0278) in any correspondence. 

16 The average burden hours were calculated by dividing the annual burden hours (from Figure 6.1a-d) by 

the annual number of respondents (from Figure 6.2), e.g., for owners and operators, 1510 ÷ 1.0 = 1510.