Supplementary Information: 

Information Collection Request 

for the Underground Injection 

Control Program 
Office of Water (4606M) 

August, 2011 

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 the Collection ......................................................................................... 2

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

2(b) Practical Utility/Users of the Data ..................................................................................... 6

3. Nonduplication, Consultations, and Other Collection Criteria .............................................. 10

3(a) Nonduplication ................................................................................................................ 10

3(b) Public Notice ................................................................................................................... 11

3(c) Consultations ................................................................................................................... 11

3(d) Effects of Less Frequent Collection ................................................................................ 11

3(e) General Guidelines .......................................................................................................... 12

3(f) Confidentiality ................................................................................................................. 13

3(g) Sensitive Questions ......................................................................................................... 13

4. Respondents and Information Requested ............................................................................... 14

4(a) Respondents/NAICS Codes ............................................................................................. 14

4(b) Information Requested .................................................................................................... 14

5. Information Collected: EPA Activities, Collection Methodology, and Information 

Management .......................................................................................................................... 24

5(a) State and Agency Activities ............................................................................................ 24

5(b) Collection Methodology and Management ..................................................................... 25

5(c) Small Entity Flexibility ................................................................................................... 27

5(d) Collection Schedule ......................................................................................................... 29

6. Estimating the Burden and Cost of the Collection ................................................................. 33

6(a) Respondent Burden.......................................................................................................... 33

6(b) Respondent Costs ............................................................................................................ 38

6(c) Agency Burden and Costs ............................................................................................... 40

6(d) Estimating Respondent Universe and Total Burden and Costs ....................................... 41

6(e) Bottom Line Burden Hours and Costs ............................................................................. 41 

6(f) Reason for Change in Burden .......................................................................................... 42 

6(g) Burden Statement ............................................................................................................ 45
Underground Injection Control Program – Information Collection Request Page ii 

LIST OF EXHIBITS

2-1 Classification of Underground Injection Wells 

2-2 Flow of Information in the UIC Program 

4-1 Respondents’ SIC/NAICS Codes 

4-2 Operator Paperwork Requirements 

4-3 State Reporting Forms 

5-1 Revised State Reporting Frequency 

6-1A Annual Burden and Costs Associated with Class I Wells 

6-1B Annual Burden and Costs Associated with Class II Wells 

6-1C Annual Burden and Costs Associated with Class III Wells 

6-1D Annual Burden and Costs Associated with Class IV/Endangering Class V Wells 

6-1E Annual Burden and Costs Associated with Class V Wells 

6-1F Annual Burden and Costs Associated with Class VI Wells 

6-1G Summary of Annual Operator Burden and Costs 

6-2 Annual Primacy Agency Burden and Cost 

6-3 Annual Agency Burden and Cost 

6-4 Bottom Line Annual Burden and Cost 

6-5 Reasons for Change in Annual Operator Burden 

6-6 Reasons for Change in Annual Primacy Agency Burden 

6-7 Annual Burden and Costs Associated with all Well Classes 
Underground Injection Control Program – Information Collection Request Page iii 

LIST OF APPENDICES

APPENDIX A: Detailed Explanation of Respondent Burden Estimates and Respondent Universe 

APPENDIX B: The National UIC Database 

APPENDIX C: Federal Register Notice on UIC Program Reporting Requirements 

APPENDIX D: UIC Program Burden Reduction Efforts 

APPENDIX E: UIC Reporting Forms 
Underground Injection Control Program – Information Collection Request Page 1 

1. Identification of the Information Collection

1(a) Title and Number of the Information Collection 

 Underground Injection Control Program Information 

 

OMB Control Number: 2040-0042 

EPA Tracking Number: 0370.21 

1(b) Short Characterization 

 The information collected upon extension of the approval of this Information Collection 

Request (ICR) will be used by the U.S. Environmental Protection Agency (EPA) for the 

monitoring and enforcement of the Underground Injection Control (UIC) Program, authorized by 

the Safe Drinking Water Act (SDWA). The purpose of the UIC Program is to establish a 

federal-state regulatory system to ensure that actual or potential underground sources of drinking 

water (USDWs) are not endangered by the underground injection of fluids. 

 Monitoring and enforcement are primarily achieved through initial, quarterly, and annual 

reporting requirements. Information is gathered both at the state1

 program level and at the EPA 

regional level. Each Region has the role of implementing UIC programs for states that do not 

have UIC programs.2 In addition, each Region must compile and submit information to EPA 

Headquarters from all respective state UIC programs. This information is submitted in summary 

paper reports to EPA Headquarters. The method by which primacy programs submit reports to 

EPA is transitioning from paper-based to electronic reporting (e-reporting). Additional details on 

this process are located in Appendix B: The National UIC Database. 

 Section 144.6 of 40 CFR describes the six injection well types (see Exhibit 2-1). EPA 

collects monitoring data and test results from operators of Class I, II, III, and VI3

 injection wells 

and a small percentage of Class V wells. Class IV wells are banned—except for wells used to 

re-inject treated contaminated ground water into the same formation from which it was drawn as 

part of a clean-up authorized by the Resource Conservation and Recovery Act (RCRA) or 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); 

operators of these wells must submit plugging and abandonment reports as they are closed. EPA 

requires operators of existing Class V motor vehicle waste disposal wells (MVWDWs) in ground 

 

1

 Throughout this ICR, reference to “States” includes Tribes and Territories pursuant to 40 CFR 144.3. 2

 Primary enforcement responsibility (primacy) is vested in states that have UIC programs approved by EPA's 

Administrator. “Direct Implementation” (DI) refers to programs in states that are administered directly by EPA 

regional offices. In some states, more than one agency may oversee injection wells of various classes. 3

 Class VI reporting requirements will only be estimated for the last year of this ICR clearance period, when ICR 

No. 2309.01 (OMB Control Number 2040-0278) expires and will no longer cover the associated reporting burden. 

ICR 2309.01 is available through www.regulations.gov under Docket ID EPA-HQ-OW-2008-0390. 
Underground Injection Control Program – Information Collection Request Page 2 

water protection areas or other state-defined sensitive ground water areas to close these wells or 

apply for a permit to continue injecting. In general, Class V operators submit only a small subset 

of the information required of Class I, II, III, and VI well operators. 

Primacy agencies are also respondents in this information collection. EPA collects 

summary information on permits, compliance and enforcement, inspections, mechanical integrity 

testing, and inventory for all well classes from permitting authorities in primacy states. Programs 

that have transitioned to e-reporting provide well-level data related to the same information that 

is in the summary paper reports through a streamlined electronic data flow. (Details on ereporting are included in Appendix B.) 

 EPA estimates that, over the 3 years covered by this request, the total burden on 

underground injection well operators and Primacy agencies associated with UIC requirements 

will be 3,888,501 hours (an average of 1,296,167 hours per year), and the present value cost will 

be $584,526,184 (an average of $194,842,061 per year). The public reporting and 

recordkeeping burden for this collection of information is estimated to average 2.32 hours, or 

$348.87 per response annually. The burden per respondent is 24.1 hours; the cost per 

respondent is $3,623.48. 

2. Need For and Use of the Collection

 This Section describes EPA’s need for the information collected pursuant to this ICR and 

the EPA Regions’ and Headquarters’ use of the collected data. Section 2(a) demonstrates both 

the need and legal authority for information collection. Need is demonstrated by describing the 

potential for contamination of USDWs and the statutory requirements that justify information 

collection to prevent contamination. Legal authority is demonstrated by identifying laws and 

regulations related to waste disposal, injection wells, and the UIC Program. Section 2(b) 

describes the practical utility and the users of the information; it focuses on how data are used to 

accomplish program objectives and manage programs at each level of implementation. 

2(a) Need/Authority for the Collection 

Potential for Contamination

 The fundamental purpose of the UIC Program is to prevent the contamination of current 

and potential USDWs by keeping injected fluids within the well and the intended injection zone. 

There are five major pathways by which injected fluids can migrate into USDWs. The following 

discussion describes each pathway and summarizes information collection requirements to 

monitor for or prevent migration through the pathway. 

Pathway 1: Faulty Well Construction. Contamination through this pathway is caused 

by leaks in the well casing or fluid forced upward between the well's outer casing and the 

well bore. For this reason, the absence of significant leaks and fluid movement in the 
Underground Injection Control Program – Information Collection Request Page 3 

well bore must be demonstrated in the initial permit application, and periodically 

thereafter. 

Pathway 2: Nearby Wells. Fluids from the pressurized area in the injection zone may 

be forced upward through wells in the area of injection. Wells that penetrate the injection 

area in the zone affected by this pressure must be properly constructed or plugged. For 

this reason, plans for plugging deficient wells in the area of an injection well are 

submitted with the permit application. In addition, plugging and abandonment reports 

must be submitted if the operator abandons any well. 

Pathway 3: Faults or Fractures in Confining Strata. Fluids may be forced upward 

out of the pressurized area through faults or fractures in the confining beds. Activities to 

address this contamination pathway are tracked using two information collection 

requirements. First, geologic information submitted with the permit application is 

reviewed to ensure that wells are sited such that they inject below a confining bed that is 

free of known open faults or fractures. Second, injection pressures are monitored so that 

fractures are not propagated in the injection zone or initiated in the confining bed zone. 

Pathway 4: Direct Injection. Class IV wells, which inject into or above USDWs and 

have a high potential to endanger human health, are banned. The exception is wells that 

are used in a RCRA/CERCLA-authorized ground water remediation project. Most Class 

V wells inject nonhazardous fluids into or above formations that contain USDWs. These 

include, but are not limited to, MVWDWs, cesspools, agricultural drainage wells, storm 

water drainage wells, industrial drainage wells, and untreated sewage waste disposal 

wells. In a regulatory effort to address the Class V wells that pose the greatest threat, 

EPA has banned the construction of new large-capacity cesspools and requires operators 

of existing large-capacity cesspools to close their wells. EPA also banned new 

MVWDWs and is requiring operators of existing MVWDWs in defined ground water 

protection areas or other sensitive ground water areas to close these wells or apply for a 

permit to continue injecting.

Pathway 5: Lateral Displacement. Fluid may be displaced from the injection zone into 

hydraulically connected USDWs. Permit information regarding the proximity of 

injection wells to USDWs is considered by the permitting authority in making a 

determination of whether the wells are properly sited. Well operators are required to 

control injection pressure and conduct monitoring and testing to track any lateral 

migration of fluids. 
Underground Injection Control Program – Information Collection Request Page 4 

Legal Authority 

 Injection wells are regulated by EPA's Office of Ground Water and Drinking Water 

(OGWDW), as mandated by Sections 1421, 1422, 1423, 1425, 1431, 1445, and 1450 of the 

SDWA of 1974, as amended. The regulation of hazardous waste injection is jointly authorized 

by the SDWA and RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984 

amended RCRA to prohibit the land disposal of hazardous waste unless it can be demonstrated 

that there will be no migration from the disposal unit for as long as the waste remains hazardous. 

Underground injection of hazardous wastes is included in Section 3004(k) of HSWA as a land 

disposal technique. 

 Under Section 1445 of the SDWA, persons subject to federal or state UIC programs must 

“establish and maintain such records, make such reports, conduct such monitoring, and provide 

such information as the Administrator may reasonably require by regulation to assist him in 

establishing regulations under this title . . .” 

 The specific requirements for the UIC Program are established in the Code of Federal 

Regulations (CFR), Title 40, Sections 144 through 1484

 as follows: 

Section 144 - Underground Injection Control Program. This section describes the 

general requirements of the Program, authorizes certain types of wells, defines permitting 

procedures, and establishes procedures for ensuring financial responsibility for proper 

closure of wells. 

Section 145 - State UIC Program Requirements. This section describes the 

requirements that state programs must meet to gain primacy and the method for obtaining 

program approval. 

Section 146 - UIC Program: Criteria and Standards. This section contains the 

technical criteria and standards that various classes of underground injection wells must 

meet. Monitoring and reporting criteria are outlined for each well class. 

Section 147- State UIC Programs. This section describes the provisions of the UIC 

programs of individual states’, territories’, and tribes’ primacy programs. 

Section 148 - Hazardous Waste Injection Restrictions. This section identifies 

hazardous wastes that are restricted from disposal into Class I hazardous waste injection 

wells. It outlines the standards and procedures by which Class I hazardous waste facility 

operators may petition to dispose of restricted hazardous wastes. 

 

4

 EPA amended 40 CFR, Sections 144 through 147 in 2010 to create standards and criteria for Class VI injection 

wells. Class VI is a new classification for wells injecting carbon dioxide (CO2), captured from an industrial or 

energy-related source into deep subsurface rock formations for long-term storage. 
Underground Injection Control Program – Information Collection Request Page 5 

 These CFR Sections contain information collection requirements that are applicable to 

operators of underground injection wells and to administrators of primacy and direct 

implementation (DI) programs. Exhibit 2-1 describes the six classes of injection wells. A 

summary of the specific requirements for operators is given in Exhibit 4-2, Operator Paperwork 

Requirements; the paperwork requirements for states as respondents are presented in Exhibit 4-3, 

State Reporting Forms. 

Exhibit 2-1 

Classification of Underground Injection Wells 

Class I Wells that inject industrial and municipal waste, including hazardous 

waste, beneath the lowermost formation containing a USDW. 

Class II Wells used to dispose of fluids which are brought to the surface in 

connection with oil or natural gas production; to inject fluids for 

enhanced recovery of oil or natural gas; or to store hydrocarbons. 

Class III Wells that inject fluids for the extraction of minerals including: mining of 

sulfur by the Frasch process; in situ production of uranium or other 

metals such as ore bodies that are not conventionally mined; and 

solution mining of salts or potash. 

Class IV Wells used by generators of hazardous waste or of radioactive waste, 

or by owners or operators of hazardous waste management facilities, to 

inject into or above strata that contain a USDW. These wells are 

banned, unless they are used to re-inject treated contaminated ground 

water into the formation from which it was drawn in a RCRA/CERCLA 

authorized cleanup. 

Class V Injection wells not included in Classes I, II, III, IV, or VI. Typical 

examples include, but are not limited to: agricultural drainage wells, 

storm water drainage wells, industrial drainage wells, untreated sewage 

waste disposal wells, motor vehicle waste disposal wells, and 

cesspools. 

Class VI Wells that inject carbon dioxide (CO2) for long term storage, also known 

as geologic sequestration (GS) wells and are not experimental in 

nature.

Statutory Requirements 

 Section 1421(b) of the SDWA specifies that regulations for state UIC programs must 

contain minimum requirements for effective programs that prevent underground injection that 

endangers USDWs. Therefore, EPA must: 

• Publish minimum national requirements for effective state UIC programs; 

• List states that need UIC programs; 

• Review proposed state programs and approve or disapprove them; 
Underground Injection Control Program – Information Collection Request Page 6 

• Promulgate and enforce UIC programs in those states that choose not to 

participate in or do not develop and operate approved programs; and 

• Evaluate state/regional UIC programs for effectiveness in meeting statutory and 

regulatory requirements. 

 In addition to these regulations, other rules provide EPA with the information it needs to 

administer its program and to determine what new measures, if any, are necessary to achieve its 

statutory mandate. 

2(b) Practical Utility/Users of the Data 

 

 EPA information users include regional and Headquarters staff/managers who make 

decisions regarding UIC regulations, compliance and enforcement actions, funding for state, 

tribal, and regional UIC programs, and strategic and policy issues related to the mission of 

OGWDW and EPA. Primacy agents in states use the summary information reported on the 7520 

forms5

 or an equivalent form to target inspection and enforcement activity, to establish permit 

terms and conditions, to track performance against demands, and to identify violations and assess 

their significance. In addition, the primacy agent can use the summary reports it supplies to EPA 

Headquarters to evaluate its own program activities, such as the number of mechanical integrity 

tests (MITs) witnessed, the number of inspections conducted, and the number of permits 

reviewed. The electronically submitted well-level data is used in a similar manner, but allows for 

a more effective analysis and better understanding by all users. 

 Exhibit 2-2 charts the flow of information from operators, states, and regions to EPA 

Headquarters. Operators submit data to states (in primacy states), or to EPA regional offices (in 

DI states). Each primacy state, in turn, submits the data to its respective EPA regional office, 

which reviews the information and forwards it, along with data from its own DI states, to EPA 

Headquarters. All information in the quarterly, semi-annual, and annual reports received at EPA 

Headquarters is analyzed and stored. These reports are the only data available to EPA 

Headquarters to fulfill the UIC Program’s needs and responsibilities. The following sections 

give a more detailed analysis of the uses of the collected information. 

 Headquarters' Management of the National Program 

 EPA Headquarters uses reported information to respond to information requests and 

perform analyses for EPA management, the Office of Management and Budget (OMB), the 

General Accounting Office (GAO), Congress, and the public. Headquarters oversees primacy 

agents by using the reports to track, evaluate, and report on program performance. Performance 

targets and measures for EPA regional programs are established by EPA and tracked against 

Government Performance and Results Act (GPRA) goals. EPA tracks high priority activities 

that guide the Regions in carrying out UIC Program objectives. EPA negotiates with the 

Regions to obtain commitments for performance based on these guidelines. 

 

5

 The 7520 forms are described in Exhibit 4-3. 
Underground Injection Control Program – Information Collection Request Page 7 

Exhibit 2-2 UIC Program Information Flowchart6

 

6

 Primacy programs utilizing e-reporting submit all data quarterly. 

EPA Headquarters Use for Regional Submissions

- National budget and program planning activities 

- Resource allocation and state grant allotments 

- Annual UIC Program report 

- Tracking program performance against expectations and commitments of the Regions 

- Managing information for policy and program activities, briefing of Agency management 

- Assessing progress toward meeting Strategic goals 

- Responses to congressional, OMB, GAO, public (FOIA) information requests 

State/ DI Programs’ Use of Operator Submission

- Target inspection and enforcement activity 

- Establish permit terms and conditions 

- Track performance 

- Identify violations and assess their significance for 

enforcement 

Owner/Operator Submission

- Permit information 

- Annual or quarterly report 

- Notification of: 

o Abandonment 

o Change of well 

ownership

Primacy State Submission 

- Injection well inventory 

- Permit review and issuance 

- Inspections/MIT testing 

- Compliance evaluation 

- Significant noncompliance evaluation 

- UIC Measures data 

- Exceptions list report 

Annually 

SemiAnnually

Quarterly 

DI Program Submission 

- Injection well inventory 

- Permit review and issuance 

- Inspections/MIT testing 

- Compliance evaluation 

- Significant noncompliance evaluation 

- UIC Measures data 

- Exceptions list report 

Annually 

SemiAnnually 

Quarterly 

EPA Regions’ Use of Primacy State Submissions

- Establish budget and planning target

- Negotiate State work plans and track State 

performance against commitments

- Evaluate States against expectations and overall 

Regional performance
Underground Injection Control Program – Information Collection Request Page 8 

 Additionally, EPA’s 2011-2015 Strategic Plan contains a key Strategic Target that, “By 

2015, 90 percent of community water systems will provide drinking water that meets all 

applicable health-based drinking water standards through approaches including effective 

treatment and source water protection.” EPA developed associated Program Activity Measures 

(PAMs) to assess progress toward the strategic goal, including four related to UIC: 

 Percent of Class I, II, and III salt solution wells that lose mechanical integrity and are 

returned to compliance within 180 days thereby reducing the potential to endanger 

underground sources of drinking water. 

 Number of Class V motor vehicle waste disposal (MVWDW) wells and large capacity 

cesspools (LCC) [approximately 23,640 in FY 2010] that are closed or permitted 

(cumulative). 

 Volume of CO2 sequestered through injection as defined by the UIC final rule. 

 Number of permit decisions during the reporting period that result in CO2 sequestered 

through injection as defined by the UIC Final Rule. 

As the program meets the objectives of the PAMs, the measures change to reflect the new areas 

of greatest concern for the program. As a result, the PAMs in the previous ICR have changed. 

 In addition to its use for regional oversight purposes, state and regional information is 

also used to justify future program modifications. For example, the information collected may 

be used to determine if the requirements that pertain to rule-authorized wells or mechanical 

integrity testing are effective. State and regional data are used to support or inform these types 

of decisions. The PAMs also help demonstrate results from environmental grants. 

 Additionally, the Class VI rule follows an adaptive approach to data collection. This 

approach allows EPA to evaluate ongoing research and demonstration projects and gather other 

relevant information, as needed, to make refinements to the requirements for Class VI wells. If 

new information gathered during implementation suggests the requirements need to be revised, 

EPA will initiate the appropriate procedure, including public notice and comment. Alternatively, 

if less information is required adjustments will be made and reflected in subsequent ICRs. 

 Regional Oversight of Primacy Programs 

 The primary use of quarterly, semi-annual, and annual reports submitted to the Regions is 

to help the Regions oversee the performance of the primacy agents. The information is used to 

track individual state progress against commitments and to ensure that state programs have the 

ability to take timely and appropriate action in response to direct threats to the public health due 

to contamination of USDWs. 

 Regions also have enforcement responsibilities and must use well specific information to 

track state enforcement response actions for all significant non-compliers (SNCs), i.e., operators 
Underground Injection Control Program – Information Collection Request Page 9 

of those injection wells that are most likely to contaminate USDWs. The statutory responsibility 

to initiate federal enforcement actions may be delegated to a Region if a primacy state does not 

fulfill its responsibilities. 

 Like EPA Headquarters, the Regions use UIC data to develop regional operating budgets 

and program plans, allocate resources, track state-by-state performance, and respond to inquiries. 

The Regions are responsible for reviewing and verifying the information on the quarterly reports 

before sending them to EPA Headquarters. 

Direct Implementation of State Programs

 In addition to their oversight responsibilities, EPA regional offices must directly 

implement the UIC Program in states without primacy. As administrators of UIC programs in DI 

states, EPA regional offices use information from operators in several ways. 

 First, materials submitted with an initial permit application provide the information 

regional offices need to determine if proposed injection wells will be properly designed, sited, 

and operated to minimize the possibility of USDW contamination. The primary responsibility of 

a regional office is to use well information submitted prior to construction and during completion 

to ensure that injected fluids will remain in the selected injection zone and will not leak into 

areas that could result in contaminated USDWs. 

 Following permit approval and well completion, the permitting authority uses monitoring 

and testing reports submitted by operators to determine if (l) there is a leak in the casing, tubing, 

or packer, or (2) there is significant fluid movement into a USDW through vertical channels 

adjacent to the well bore. Environmental monitoring data required of certain classes of operators 

can provide early warning of USDW endangerment. 

 Regional offices with DI authority also use information required of operators to focus 

efforts on injection wells in need of enforcement attention. Operators who have been out of 

compliance for at least two consecutive quarters are identified on the exceptions list. 
Underground Injection Control Program – Information Collection Request Page 10 

3. Nonduplication, Consultations, and Other Collection 

Criteria

 This Section describes how EPA has no other means available to gather the requested 

information. It also describes EPA’s solicitation of public comments in the Federal Register and 

Agency consultations in developing the burden and cost estimates; describes how less frequent 

reporting may endanger USDWs; and discusses Paperwork Reduction Act (PRA) general 

guidelines and provisions for confidentiality. 

3(a) Nonduplication 

 Well-specific data obtained from injection well operators and the state reports that rely on 

such data comprise virtually all of the information covered by this ICR. To the best of the 

Agency’s knowledge, this information is not required or collected by any other agency or 

regulation. The Department of Energy does collect information relating to production for 

enhanced oil and gas recovery wells in its “Annual Report for Enhanced Oil Recovery (EOR) 

Incentive” (OMB Clearance No. 19054135). This information pertains only to oil production, 

and is related to, but different from, the information EPA uses to evaluate injection well 

operators. However, on a case-by-case basis, permitting authorities may use this information to 

supplement existing information on enhanced recovery wells. 

 Since both Class I hazardous and Class IV wells (now banned) involve the injection of 

hazardous wastes, there is potential overlap between UIC programs under the SDWA and 

hazardous waste regulations promulgated under RCRA. Historically, the regulations established 

provisions for RCRA interim status (Part A permit) [40 CFR 270.64] for Class I hazardous wells 

in states in which no UIC program had been approved or promulgated. The regulations allow the 

UIC permit to be issued in lieu of a Part B RCRA permit if the Class I hazardous waste well 

meets certain conditions specified in 40 CFR 270.64(c). Thus, although Class I hazardous waste 

wells are co-regulated under RCRA and the SDWA, there is no duplication of information 

collection between RCRA and the UIC Program. 

 Data requirements for Class VI wells under the Class VI Rule have some overlap with 

those associated with the Mandatory Reporting of Greenhouse Gases: Injection and Geologic 

Sequestration of CO2 Rule (Subpart RR), 40 CFR part 98. In developing the two rules, staff of 

the Office of Air and Radiation and the UIC program coordinated to consider and minimize the 

potential overlap in reporting and recordkeeping requirements on operators of wells that may be 

subject to both rules. Burden and costs associated with air monitoring are accounted for under 

Subpart RR and therefore are not incorporated into this Programmatic ICR. EPA plans to build 

an electronic database that will house all data related to GS projects, including data reported 

under the GHG and UIC programs; this effort will reduce the potential for overlap in the 

reporting and recordkeeping requirements under the two rules. 
Underground Injection Control Program – Information Collection Request Page 11 

3(b) Public Notice 

 EPA published a notice requesting comment on the burden and cost associated with the 

UIC Program reporting requirements in the Federal Register on [date] (xx FR xxxxx). EPA 

received xx comments on the burden and cost estimates. A copy of the Federal Register notice 

of this information collection is attached to this ICR as Appendix C. 

3(c) Consultations 

 In developing burden and cost estimates and underlying assumptions, EPA consulted 

knowledgeable staff in the most active EPA regional offices and states in the UIC Program. 

Collectively, these offices are the permitting authorities for the majority of injection wells in 

each well class. These staff reviewed the burden and cost tables and recommended adjustments 

to some unit burden and non-labor costs. Their input is reflected in the burden and cost estimates 

in Section 6. Details on the consultation related to the burden and cost to owners or operators of 

Class VI wells can be found in ICR 2309.01. 

3(d) Effects of Less Frequent Collection 

 There are two types of respondents for whom efforts could be made to minimize burden: 

(1) operators of injection wells; and (2) primacy agencies. 

Operators

 All Class I, II, III, and VI operators are required to observe pressure, flow, and 

cumulative volume of injected fluids and demonstrate mechanical integrity. Some operators 

must sample and analyze their injectate and conduct ambient monitoring. These requirements 

provide DI and state primacy programs with crucial information to assess whether injection wells 

pose a potential endangerment to USDWs. In developing the required monitoring and testing 

frequencies, EPA attempted to strike a balance between ensuring protection of USDWs and 

placing an excessive burden on operators. 

 The frequency at which operators must conduct various monitoring and testing activities 

varies with the potential for a particular well class to endanger USDWs. Less frequent 

monitoring and testing might allow injection wells to operate in a manner that could threaten or 

cause considerable damage to USDWs if evidence of such a situation were undiscovered for a 

long time. EPA has determined that the specified monitoring frequencies for each operators of 

well class are at the minimum protective frequency for the following reasons: 

 State and DI programs use injectate pressure and volume data to ensure that the 

pressures caused by injection activities do not cause fractures to initiate in the 

confining zone. Less frequent monitoring would not provide the necessary data to 

ensure that injection does not initiate fractures in the confining zone or that injectate 

or formation fluids are not displaced into USDWs. 
Underground Injection Control Program – Information Collection Request Page 12 

 MITs can reduce the amount of damage a well failure can cause to USDWs by 

detecting those failures. The degree to which this damage can be reduced depends on 

the frequency of MITs. Less frequent MITs would raise the potential for 

contamination of USDWs. 

 Permitting authorities require that operators keep timely data on the chemical 

composition of operators’ injectate to ensure that potentially incompatible injected 

substances will not come into contact with each other. 

 The Class VI rule requires that some parameters 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 

Class VI Rule are the minimum necessary to ensure that any damage to the injection 

well would be detected in a timely manner. 

Injection well operating permits are renewed or reviewed at varying intervals (typically 

every 5 to 10 years, depending on the well class). This is necessary to provide permitting 

authorities an opportunity to review facility operations to ensure that injection operations will not 

endanger USDWs. 

 Primacy Agencies

 EPA solicited input from state UIC Directors, operators, and other interested parties on 

revising the UIC Program to reduce burden. State officials suggested combining, simplifying, or 

eliminating some of the 7520 forms or reducing the frequency at which primacy agents report 

this information to EPA. 

 

Additionally, in 2006, EPA began a Burden Reduction Initiative to address state concerns 

over escalating reporting requirements accompanied by decreases in federal funding. UIC 

reporting was identified as one of the Agency’s 16 priority areas for burden reduction. States 

asked EPA to eliminate duplicative UIC reporting, reduce the frequency of reporting, and reduce 

the data elements requested. EPA is implementing its plan to streamline and reduce UIC 

reporting burden through the National UIC database. The UIC program’s efforts to reduce 

reporting burden can be tracked at http://www.epa.gov/op/burdenredux/. Additional information 

on the burden reduction effort and the National UIC database are presented in Appendix B and 

Appendix D. 

3(e) General Guidelines 

 Two provisions of the UIC regulations exceed the PRA guideline for response time. 

Pursuant to 40 CFR 144.51(l),144.28(b) and 146.94(b), operators are required to report within 24 

hours “any noncompliance which may endanger health or the environment.” This is an 
Underground Injection Control Program – Information Collection Request Page 13 

emergency provision necessary to enable permitting authorities to take timely and appropriate 

steps to reduce or eliminate any potential threat to public health. 

3(f) Confidentiality 

 Operators of injection wells may claim confidentiality, as provided in 40 CFR 144.5 

Confidentiality of Information. If confidentiality is requested, the information is treated in 

accordance with the provisions of 40 CFR Part 2, Public Information. Any confidentiality claim 

must be made at the time of 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” 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; and information regarding the existence, 

absence, or level of contaminants in drinking water. 

 If no claim of confidentiality is made at the time of submission, EPA may make the 

information available to the public without further notice. However, the information is collected 

for the Agency’s internal use and there are no plans to routinely release or publish any of the 

data. 

3(g) Sensitive Questions 

 There are no sensitive questions pertaining to this ICR. 
Underground Injection Control Program – Information Collection Request Page 14 

4. Respondents and Information Requested

 This Section identifies respondents affected by this information collection and describes 

the data items and activities required of operators, states, and DI programs. 

4(a) Respondents/NAICS Codes 

 Operators of injection wells are identified by Standard Industrial Classification (SIC) and 

North American Industry Classification System (NAICS) codes. Operator respondents for 

underground injection wells are categorized by the industries that produce fluid wastes and the 

type of fluid injected into each well class. The SIC and NAICS codes for the operator 

respondents associated with each well class are listed in Exhibit 4-1. 

The NAICS code for State agencies that include drinking water programs is 92411 

(Administration of Air and Water Resources and Solid Waste Management Programs) or 92312 

(Administration of Public Health Programs). 

4(b) Information Requested 

4(b)(1) Data Items, Including Recordkeeping, Required from Operators 

 Required data items vary according to well class and authorization category (i.e., 

permitted well vs. rule-authorized well). The information required of operators is listed in 

Exhibit 4-2. 

Initial Reporting Requirements

 Two methods are available for obtaining approval for underground injection: rule 

authorization and permitting. Class II enhanced recovery (II-R) and hydrocarbon storage wells 

(II-H) in existence before the promulgation of specific permitting regulations are authorized by 

rule for life and do not require permits. All new Class I, II, III, and VI wells require permits. 

New Class V wells may be rule-authorized, although operators of some Class V wells may be 

required to obtain permits. Operators of Class V MVWDWs in state-designated ground water 

protection areas or other sensitive areas that wish to continue operating must obtain a permit. 
Underground Injection Control Program – Information Collection Request Page 15 

Exhibit 4-1 

Respondents’ SIC/NAICS Codes*

UIC 

Class SIC Code NAICS Code (2002) Description

I  Major Group 13 

 Major Group 28 

 Major Group 26 

 Major Group 29 

 Major Group 32 

 Major Group 33 

 Major Group 36 

 Major Group 37 

 Major Group 45 

 Major Group 49 

 Major Group 89 

 Major Group 99

 211 

 325 

 322 

 324 

 327 

 331 

 335 

 336 

 481 

 221 

 54162 

 54169

 Oil and Gas Extraction 

 Chemical Manufacturing 

 Paper Manufacturing 

 Petroleum and Coal Products Manufacturing 

 Nonmetallic Mineral Product Manufacturing 

 Primary Metal Manufacturing 

 Electrical Equipment, Appliance, & Component Mfg. 

 Transportation Equipment Manufacturing 

 Air Transportation 

 Utilities 

 Environmental Consulting Services 

 Other Scientific and Technical Consulting Services

II  1311 

 1321 

 1381 

 211111 

 211112 

 213111

 Crude Petroleum and Natural Gas Extraction 

 Natural Gas Liquid Extraction 

 Drilling Oil and Gas Wells

III  Major Group 10 

 Major Group 14

 212  Mining (except Oil and Gas)

IV  4953  562  Waste Management and Remediation Services

V  01, 02, 074, 075 

 4789, 4953, 9511 

 7542 

 7033, 9111 

 4142, 4212, 4213, 

4581, 5015, 5511, 

5521, 5531, 5541, 

7514, 7515, 7532, 

7533, 7537, 7538, 

7539, 7549, 9111

 111, 112, 54194, 

11521 

 488999, 562213, 

562219, 92411 

 811192 

 7212, 92111 

 441, 484, 485, 

488, 562, 811, 

44711, 44719, 

45299, 48841, 

92111, 532111, 

532112

 Agricultural or storm drainage wells 

 Domestic wastewater disposal wells 

 Car washes 

 Recreational vehicle parks and campsites, executive 

offices (e.g., state parks and campgrounds) 

 Bus charter services, trucking, airports, flying fields, 

and airport terminal services; motor vehicle parts; 

motor vehicle dealers; auto and home supply stores; 

gasoline service stations; passenger car rental or 

leasing; automotive repair and services; executive 

offices (e.g., town garages)

VI  4911 

 4911 

 2911 

 221112 

 211111 

 324110 

 Fossil fuel electric power generation 

 Crude petroleum and natural gas extraction 

 Petroleum refining 

* Note: this list is not totally inclusive, but represents a large portion of the industries that operate injection wells.

Rule-Authorized Wells 

 Wells in existence before the promulgation of specific permitting regulations are 

authorized by rule until regulations require them to be permitted. To meet initial reporting 

requirements, operators of rule-authorized wells are required to submit inventory information 

(i.e., facility name; name and address of the facility’s legal contact; ownership status; and 

operating status of the injection well) to the permitting authority using Form 7520-16 (or a state-
Underground Injection Control Program – Information Collection Request Page 16 

developed equivalent form). Operators must also submit a plugging and abandonment plan and 

information regarding financial responsibility (this requirement does not apply to rule-authorized 

Class V wells). Authorization terminates if the operator fails to supply any required information 

or if the well loses mechanical integrity or contaminates a USDW. EPA is working to develop a 

web-based system that will allow owners or operators in DI program states to submit this 

information over the Internet. Check the status of this effort before finalizing the ICR. 

Permitted Wells7

 

 Operators of permitted wells must follow a two-step permit application procedure. The 

operator must submit a permit application prior to construction, and a completion report before 

commencing injection. (Instead of submitting a completion report, owners or operators of Class 

VI wells must submit final site characterization information before commencing injection.) 

Operators must include the following information with their permit applications: 

• Inventory Information: name of the facility, name and address of legal contact, 

ownership of facility, NAICS/SIC code(s), and a description of the activities 

requiring a permit [all well Classes]; 

 List of Landowners: a list of landowners within one-quarter mile of the facility 

 (in DI programs) [all well Classes];8

 • Area of Review Methods: methods and calculations used to determine the area of 

review (AoR) [Classes I, II, III, and VI]; 

• Maps of Wells/Area of Review: a tabulation of all wells within the AoR (within 

1/4 mile of the well, or within 2 miles of a Class I hazardous well, or as defined 

by computational modeling for a Class VI well) that penetrate the injection zone 

or the confining zone [Classes I, II, III, and VI]; 

• Corrective Action Plan: a plan for corrective action for wells within the AoR that 

are not properly plugged [Classes I, II, III, and VI]; 

• Geological and Hydrogeological Data: maps and cross sections of USDWs, and 

data (including maps and cross sections) on the local and regional geology of the 

confining zone [Classes I, III, and VI] or names and depths of USDWs [Class II]; 

 

7

 Permits may be issued on an area basis as well as on an individual basis, except for hazardous waste injection 

wells and Class VI wells. Refer to Section 5(b) for a description of how the permitting process minimizes the 

information burden on owners and operators. 

8

 This requirement may be waived if the Regional Administrator determines that it is too burdensome (e.g., if the 

well is located in a populated area). Some regions may also require operators to notify all landowners of their intent 

to construct the well. 
Underground Injection Control Program – Information Collection Request Page 17 

Exhibit 4-2 

Operator Paperwork Requirements

Activity Class 

I-H I-N II III V * VI 

 Provide Inventory Information  

 Permit Application 

 List of Landowners      

 Area of Review Methods     

 Maps of Wells/Area of Review     

 Corrective Action Plan     

 Maps and Cross Sections of USDWs    

 Names and Depths of USDWs  

 Maps and Cross Sections of Local and Regional Geology    

 Geological Data on Injection and Confining Zones  

 Operating Data     

 Formation Testing Program    

 Stimulation Program    

 Injection Procedures    

 Construction Details    

 Changes in Injected Fluid  

 Plans for Well Failures/Emergency and Remedial Response Plan    

 Ambient Monitoring Program    

 Plugging and Abandonment Plan     

 Financial Assurance     

 Post Injection Site Care Plan   

 Completion Report 

 Results of Logs and Tests Performed During Construction     

 MIT Results     

 Anticipated Maximum Injection Pressure & Flow Rate     

 Formation Testing Results     

 Actual Injection Procedure     

 Hydrogeological Compatibility/ Compatibility of Well Materials    

 Status of Corrective Action     

 Monitoring and Reporting 

 Analyze and Report on Chemical Composition of Injectate      

 Record and Report Injection Pressure, Volume, & Flow Rate     

 Perform and Report on MIT     

 Conduct and Report on Ambient Monitoring    

 Conduct and Report on Pressure Fall-Off Test   

 Recordkeeping 

 Retain Monitoring, Testing, Permitting Records      

 Closure 

 Closure Report (DI only)     

 * Operators of rule-authorized Class V wells will submit inventory information only; Class V wells that are issued 

permits will be subject to the other paperwork requirements listed. 
Underground Injection Control Program – Information Collection Request Page 18 

• Operating Data: a description of the proposed operation, including rates and 

volumes of fluids to be injected, injection pressures, and sources and constituent 

analyses of injection fluids [Classes I, II, III, and VI]; 

• Formation Testing Program: a description of the proposed formation testing 

program [Classes I, III, and VI, optional for Class II]; 

• Stimulation Program: a description of the proposed stimulation program 

[Classes I, III, and VI, optional for Class II]; 

• Injection Procedures: a description of the proposed injection procedure [Classes 

I, III, and VI, optional for Class II]; 

• Construction Details: construction plans, including schematic drawings of the 

surface and subsurface details of the system [Classes I, II, and VI]; 

• Changes in Injected Fluid: expected changes in pressure, native fluid 

displacement, and direction of movement of injected fluid [Classes I, III, and VI]; 

• Plans for Well Failures: plans for contingency action in the case of shut-ins or 

well failures [Classes I and III, optional for Class II]. Owners or operators of 

Class VI wells must submit an emergency and remedial response plan; 

• Ambient Monitoring Program: planned ambient monitoring program, including 

the location of monitoring wells and monitoring devices, and the proposed 

sampling frequency. Class VI operators must also describe how they will monitor 

the position of the CO2 plume and pressure front [Classes I, III, and VI, optional 

for Class II]; 

• Plugging and Abandonment Plan: plans for closing the well, including type and 

placement of plugs to be used [Classes I, II, III, and VI] and a post injection site 

care plan (PISC) for Class VI; and 

• Financial Assurance: evidence of financial responsibility for closing the well, 

such as surety bonds or financial statements [Classes I, II, III, and VI]. Class VI 

financial responsibility demonstrations must also address corrective action, PISC, 

and emergency and remedial response. 

 Upon approval of the permit application, the operator may begin to construct the well. 

Following construction, the operator of a new well must submit a completion report prior to 

being authorized to inject. Completion reports must include the following information: 

• The results of deviation checks, other logs and tests [Classes I, II, III, and VI]; 
Underground Injection Control Program – Information Collection Request Page 19 

• Demonstration of mechanical integrity (i.e., the results of a casing pressure test; 

radioactive tracer survey of the bottom-hole cement; and/or temperature, noise, or 

other logs to check for movement along the borehole) [Classes I, II, III, and VI]; 

• Anticipated maximum injection pressure and flow rate [Classes I, II, III, and VI]; 

• The results of formation fluid sampling, and testing of the injection and confining 

zones [Classes I, II, III, VI]; 

• Actual injection procedures [Classes I, II, III, and VI]; 

• Report on hydrogeological compatibility and the compatibility of well materials 

[Classes I, and III, and VI]; 

• The status of corrective action at improperly abandoned wells within the AoR 

[Classes I, II, III, and VI]; and 

• The final delineated area of review and any updates to the required project plans 

based on computational modeling of the AoR [Class VI]. 

 Operators of Class I hazardous waste wells must adhere to more stringent permit 

application requirements than those required of Class II, III, or V wells. Operators seeking an 

exemption from the prohibition from injecting any of the Class I listed hazardous wastes must 

submit the following information in addition to the information described above: 

• No Migration Petition. Operators of Class I hazardous waste injection wells 

must demonstrate, usually by computer modeling, that their wastes will not 

endanger USDWs. The operator must provide sufficient information to 

demonstrate that the hazardous constituents of wastes will not migrate from the 

disposal site. In particular, the petition must prove that the waste will not reach 

the roof of the injection zone or a conduit within the injection zone within 10,000 

years. This is known as the Fluid Flow Petition. 

• Hydrogeological Compatibility/Compatibility of Well Material Report. 

Operators of Class I hazardous waste wells must demonstrate hydrogeological 

compatibility (i.e., that the waste stream and its anticipated reaction products will 

be compatible with both the geologic material of the injection zone and any 

previously injected fluids), and compatibility of well materials (i.e., that the waste 

stream will be compatible with the well materials that come in contact with the 

waste). 

• Waste Analysis Plan. Class I hazardous waste well operators must develop and 

follow an approved written waste analysis plan that describes procedures for a 

detailed chemical and physical analysis of a representative sample of their waste. 
Underground Injection Control Program – Information Collection Request Page 20 

The waste analysis plan must specify (1) the parameters within which the waste 

will be analyzed and the rationale for selecting these parameters; (2) the test 

methods that will be used to test for these parameters; and (3) the sampling 

method that will be used to obtain a representative sample of the waste to be 

analyzed. 

 • Other Information. Operators of Class I hazardous waste wells must also submit 

a description of the hydrogeological and geochemical conditions at the site; the 

physicochemical nature of the waste stream; and proof of conformance with AoR 

requirements. 

 Class V facilities generally are rule-authorized. However, under the 1999 Class V rule, 

operators of Class V MVWDWs in ground water protection areas or other sensitive ground water 

areas must apply for a permit to continue injecting. Permitting authorities may also require other 

Class V operators to apply for a permit to commence or to continue injecting. Typically, the 

permit application process for Class V operators is less complex than for other well classes—

operators are typically required to submit a description of the activities requiring a permit, 

inventory information, topographic maps, and a plugging and abandonment plan which includes 

a demonstration of financial responsibility for closure. 

 Operators of Class VI wells must submit and gain approval for a series of project-specific 

plans, including: an Area of Review and Corrective Action Plan, a Testing and Monitoring Plan, 

an Injection Well Plugging Plan, a Post-Injection Site Care (PISC) and Site Closure Plan, and an 

Emergency and Remedial Response Plan. 

Monitoring and Testing Requirements 

 All Class I, II, III, and VI operators must observe injection pressure, rate, and cumulative 

volume and demonstrate mechanical integrity. Requirements for other monitoring and testing 

activities vary by class. The specific monitoring and testing activities for each well class 

include: 

 Monitor injection pressure, flow rate, and cumulative volume of injected fluids 

[continuously for Class I hazardous and Class VI, weekly for Class II disposal 

wells (II-D), monthly for Class II-R, and semi-monthly for Class III]; temperature 

of injected fluids and annulus pressure between the tubing and the long string 

casing [Class I]; 

 Conduct chemical monitoring of injectate as described in a waste analysis plan or 

as specified by the permitting authority [Classes I, II, VI, and permitted Class V 

MVWDWs]; 

 Conduct annual sludge monitoring [permitted Class V MVWDWs]; 
Underground Injection Control Program – Information Collection Request Page 21 

 Test for internal and external mechanical integrity of the well casing, via: 

— casing pressure test [annually for Class I hazardous and Class VI; every 5 

years for Class I nonhazardous, Class II, and Class III salt solution mining]; 

— radioactive racer survey of the bottom-hole cement [annually for Class I 

hazardous]; 

— temperature, noise, or other logs to test for movement of fluid along the 

borehole [every 5 years for Class I and Class III (salt solution mining)];9

— continuous monitoring of injection pressure, volume, and rate to demonstrate 

internal mechanical integrity [Class VI]; 

 Conduct ambient monitoring, including a pressure fall-off test [annually for Class 

I and VI]; 

 Monitor wells completed in the injection zone and in overlying USDWs [semimonthly for active Class III wells, monthly for Class III facilities in restoration 

and per the approved testing and monitoring plan for Class VI]; and 

 Monitor the movement of the CO2 plume and pressure front using direct methods 

and indirect (geophysical) methods, unless the Director determines this is not 

feasible [Class VI]. 

 

Reporting and Recordkeeping Requirements 

 All permitted and rule-authorized wells must report to state or DI agencies on the results 

of required monitoring and testing.10 In addition, operators must notify the permitting authority 

of any planned changes to the facility; changes that may result in noncompliance; progress in 

meeting the milestones of a compliance schedule; any loss of mechanical integrity or other 

indication of possible endangerment of a USDW within 24 hours; or any noncompliance with 

permit conditions. 

 Scheduled reporting requirements include the following: 

 Class I hazardous well operators report quarterly on monitoring results; and annually 

on MITs and to update their plugging and abandonment cost estimates. 

 Class I nonhazardous well operators are required to report quarterly on injectate 

monitoring, annually on ambient monitoring, and on MITs every 5 years. 

 

9

 Substitute MIT methods (e.g., review of cementing record) may be approved by the Director. 10 In accordance with the Paperwork Reduction Act of 1995, the reporting requirements covered by this information 

collection are consistent with the reporting and recordkeeping activities currently in practice by the respondents. For 

example, respondents generally may report required information in either electronic or hard-copy format, whichever 

is compatible with their facility practices. 
Underground Injection Control Program – Information Collection Request Page 22 

 Class II operators must report monitoring data annually, and on MITs every 5 years. 

 Class III operators report quarterly on monitoring and on MITs every 5 years. 

 Class V MVWDW operators that obtain a permit must report annually on injectate 

and sludge monitoring. 

 Class VI well operators must submit semi-annual reports. 

 Owners or operators of Class VI wells must also reevaluate the AoR at least every five 

years and submit a report to the permitting authority. Following the reevaluation, operators must 

update the AoR and Corrective Action Plan, Testing and Monitoring Plan, and Emergency and 

Remedial Response Plan based on the results of the revised AoR or submit information that no 

updates to the plans are necessary. 

 For rule-authorized wells in DI states, the Regional Administrator may require operators 

to submit additional information, as needed, to determine if a well poses a hazard to USDWs. 

Such information may include evidence of ground-water monitoring, including periodic reports 

of such monitoring; periodic reports on analysis of injected fluids; and a description of the 

geologic strata through and into which injection is taking place. 

 Operators must maintain monitoring information, calibration and maintenance records, 

required reports, application data, and monitoring results for 3 years; and keep their most recent 

plugging and abandonment cost estimate for 1 year. 

Closure Requirements

 When closing their wells, operators must submit to the permitting authority a plugging 

and abandonment report demonstrating that the well was plugged in accordance with the 

plugging and abandonment plan (this requirement does not apply to rule-authorized Class V 

wells). Operators who choose to plug in a manner different from the one specified in their 

plugging and abandonment plan must first submit and obtain approval for a revised plugging and 

abandonment plan. 

 Class I hazardous waste well operators must also conduct a pressure fall-off test and 

demonstrate mechanical integrity before plugging the well and report the results of these tests 

with their closure reports. 

 Additionally, Class VI well operators must revise their PISC and Site Closure Plans or 

demonstrate that no revision is needed; conduct and report the results of post-injection ground 

water quality monitoring and the position of the carbon dioxide plume and pressure front 

throughout the PISC period; complete a non-endangerment demonstration that the carbon 

dioxide plume has stabilized and there is no threat to USDWs following the PISC period; and 
Underground Injection Control Program – Information Collection Request Page 23 

submit a site closure report including a copy of the recording notation on the deed to the property 

regarding the fact that injection occurred to complete well closure. 

4(b)(2) Data Items Including Recordkeeping, Required from States 

 Primacy and DI agencies submit information on wells within their jurisdiction to 

Headquarters via the 7520 forms. (Primacy agencies are not required to report on the 7520 

forms, but must supply all of the information on the federal forms; many states opt to use the 

7520 forms, however.) Each of the forms that agencies must submit as respondents, the 

reporting frequency, and the data items reported are listed in Exhibit 4-3. Copies of the forms 

are provided in Appendix E. 

Exhibit 4-3 

State Reporting Forms

Form Frequency Information Collected

Permit Review and Issuance 

(7520-1) 

 

Annual Information on permit determinations (i.e., the number of 

permits issued and not issued, and permit modifications), 

permit file reviews, the number of rule-authorized wells 

reviewed, AoR reviews, and corrective action performed.

Compliance Evaluation 

(7520-2A)

Semi-annual Enforcement actions, including administrative actions and 

civil and criminal actions. 

Compliance Evaluation - 

Significant Noncompliance 

(7520-2B)

Semi-annual Operators of injection wells identified as being in 

significant noncompliance (SNC) with statutory 

requirements and enforcement actions against SNCs and 

returns of wells to compliance; contamination of USDWs; 

and closures.

Mechanical Integrity 

Test/Remedial Actions 

(7520-3)

Annual Results of inspections and MITs and remedial actions 

conducted for any test failures.

Quarterly Exceptions List 

(7520-4)

Quarterly Wells that have remained in SNC for 2 or more 

consecutive quarters and have not been returned to 

compliance or been subject to a formal enforcement 

action.

 Programs that have chosen to transition to e-reporting must report the agreed upon UIC 

data elements quarterly. As part of the data flow process, the primacy program and EPA agree to 

timelines and the data that will be submitted in a Trading Partner Agreement (TPA). The TPA 

also documents the primacy program’s agreement to submit data electronically through the 

National UIC database rather than in an alternate format. The frequency of submission is also 

agreed upon in the TPA and, while this may result in some data being reported more frequently 

than via the 7520 paper forms, it ensures data integrity. In addition, submitting a sub-set of the 

data requires the same effort as reporting a full data set. All of the data in the National UIC 

database data model are need to fulfill the UIC program’s reporting requirements. 
Underground Injection Control Program – Information Collection Request Page 24 

5. Information Collected: EPA Activities, Collection 

Methodology, and Information Management

 Section 5(a) describes state oversight of operators and EPA activities with respect to 

program management. Section 5(b) describes how EPA will manage the information collected; 

Section 5(c) discusses how this information collection addresses the needs of small businesses; 

and Section 5(d) presents EPA’s justification for the information collection schedule. 

5(a) State and Agency Activities 

5(a)(1) State Activities

 Under Section 1422 of the SDWA, states that adopt UIC regulations that are at least as 

stringent as the federal requirements may be granted primacy for the UIC Program. Under 

SDWA Section 1425, state programs that regulate oil and gas-related injection must demonstrate 

that their program “represents an effective program to prevent underground injection which 

endangers drinking water sources” in order to be granted primacy. 

 In addition to the reporting activities described in Section 4(b)(2), state primacy agencies 

are responsible for permitting the wells within their states. Primacy agents receive and review 

permit applications from operators, solicit and respond to public comments, and issue final 

decisions on permit applications. States also review completion reports and associated testing 

results to verify that new wells have been constructed in accordance with construction standards. 

 State agencies review injectate and ambient monitoring data submitted by operators; they 

also review MITs and pressure fall-off tests. Many states witness some or all MITs and well 

plugging. State primacy agencies also respond to occasional reporting submitted by operators, 

conduct periodic permit reviews, and respond to operators’ requests for permit modifications. 

 State agencies also report to EPA on the status of their programs. The mechanisms by 

which states report are the paper-based 7520 forms (or equivalent reporting), web-based 

reporting on UIC program measures and inventory, and the National UIC database. 

5(a)(2) Agency Activities 

 EPA regions oversee injection wells in those states that do not have approved primacy 

programs. The regions perform the same activities as state primacy agents. In addition, regional 

offices review no-migration petitions submitted by Class I hazardous facility operators in both 

primacy and DI states. Regional staff review reports on MITs and pressure fall-off tests 

performed in DI states, and in some cases, tests on wells in primacy states. DI programs also 

review closure reports required of operators when they abandon their wells. 
Underground Injection Control Program – Information Collection Request Page 25 

 EPA Headquarters activities consist of compiling the regional summary information on 

permit reviews and issuance, compliance evaluation, enforcement and inspections information, 

and inventory and measures data. 

 EPA regions and Headquarters complete data quality and assurance reviews of the data 

submitted to the National UIC database. 

5(b) Collection Methodology and Management 

 Current reporting from operators to states/DI programs and from states and DI programs 

to Headquarters is primarily accomplished by completing the UIC Program’s 7520 reporting 

forms. The complete set of PDF-format 7520 reporting forms is available to be downloaded on 

OGWDW’s web site (www.epa.gov/safewater/uic/7520s.html), as well as on GSA’s web site. 

(Appendix E of this ICR contains copies of all the UIC reporting forms.) 

 State and DI programs maintain detailed data about each well regulated under the UIC 

Program. Collection of data from individual operators and quality assurance is the responsibility 

of the individual state and DI programs. These data are the source of summary information 

submitted to the Regions and EPA Headquarters for oversight and program management. Most 

use some type of electronic data management system to maintain this data—EPA estimates, 

based on a recent database cataloging effort, that approximately 100 state and DI UIC program 

databases are in use. 

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

can be readily incorporated into Headquarters’ UIC database 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; 

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

 Increase the accuracy of reports submitted to OGWDW and the Office of Enforcement 

and Compliance Assurance. 

 EPA deployed a well-specific database to collect and store data to support UIC 

programmatic data needs in 2007. The National UIC database provides a mechanism to 

electronically transfer data between existing state and DI databases and Headquarters’ database, 

eventually eliminating the need for states to complete paper reporting forms. 

 EPA estimates that, by January 2012 (the beginning of this information collection), 14 

programs will have transitioned to electronic-reporting (e-reporting). Nine additional programs 

are expected to transition to e-reporting in 2012, 16 programs are expected to do so in 2013, and 
Underground Injection Control Program – Information Collection Request Page 26 

the remaining 19 programs are expected to transition in 2014. The time needed for a program to 

move from initial discussion to e-reporting depends on many variables, including available 

funding and FTEs. 

 Initially states will incur a “start up” cost to initiate the transfer of their data to the 

National UIC database. Once the data flow is in place, states will incur minimal cost to transfer 

data to Headquarters quarterly; this cost will be lower than the current annual reporting costs to 

states associated with gathering data and completing the reporting forms. 

Under the current, paper-based system, each state spends about $7,600 annually to 

accomplish the required reporting. Following the investment in the data transfer, states will 

incur lower annual costs: an estimated cost of about $2,650 to enter data and transfer it to 

Headquarters quarterly. Along with the reduced cost, e-reporting has resulted in data quality 

improvement. 

Even taking into account the costs of the initial phase-in, EPA estimates that the 

cumulative costs to states for data development and data management via the database are lower 

than they would have been to report by paper during the same time frame. To support states’ 

start-up efforts, EPA has made grant funds available through the Exchange Network Grant. 

These funds can be used to upgrade current systems, to establish electronic data flow from 

operators, or to establish the data flow to EPA. 

 Until the transition to e-reporting is complete, programs report to Headquarters via paper 

forms and the inventory and measures web site. Headquarters continues to support collection of 

UIC Program Activity Measures and inventory data through a secure web site. 

EPA is also developing a data system to collect and manage data on Class VI wells. All 

data, including permit applications, operating data, and testing and monitoring data, will be 

submitted directly to the GS Data System by owners or operators, as required at 40 CFR 

146.91(e). Permitting authorities will provide compliance and enforcement related data to the 

GS data system. The GS data system will inter-link with the National UIC database. 

Verify/update this as GSDS decisions are made. 

 Appendix B describes the data transfer activities in detail, the schedule by which states 

are expected to begin the data transfer, and the eventual burden and cost savings to states 

associated with the National UIC database. 
Underground Injection Control Program – Information Collection Request Page 27 

5(c) Small Entity Flexibility

 Few, if any, small businesses are operators of Class I, Class III, or Class VI injection 

wells. In contrast, many Class II and Class V operators affected by this collection are small 

entities. This collection reduces, to the extent practicable and appropriate, the burden on persons 

that provide information to or for EPA, including with respect to small entities, as defined by the 

Regulatory Flexibility Act [5 USC 601(6)], the use of such techniques as: 

 Establishing differing compliance or reporting requirements or timetables that 

take into account the resources available to those who are to respond; 

 Clarification, consolidation, or simplification of compliance and reporting 

requirements; or 

 An exemption from coverage of the collection of information, or any part thereof. 

Class I

 The size standard the Small Business Administration uses to define “small business” 

varies by SIC code. Class I wells typically involve the following SIC codes: 

 Major Group 13: Oil and gas extraction 

 Major Group 28: Chemicals and allied products 

 Major Group 26: Paper and allied products 

 Major Group 29: Petroleum and coal products 

 Major Group 32: Stone, clay and glass products 

 Major Group 33: Primary metal industries 

 Major Group 36: Electrical and electronic machinery 

 Major Group 37: Transportation equipment 

 Major Group 45: Transportation by air 

 Major Group 49: Electric, gas, and sanitary services 

 Major Group 89: Services not elsewhere classified 

 Major Group 99: Non-classifiable establishments 

 The small business size standards for firms in these SIC code groups vary from 500 to 

1,500 employees, except for SIC code 4953, for which the size standard is $3.5 million or less in 

revenues. Most of the firms that own or operate Class I injection wells exceed both the 500-

employee and the 1,500-employee standard. Examples include Allied Chemical, Bethlehem 

Steel, Dow Chemical, DuPont, Exxon, General Electric, Monsanto, and Shell. The hazardous 

waste disposal firms that own and operate Class I wells (SIC code 4953) are believed to exceed 

the $3.5 million revenue standard. 
Underground Injection Control Program – Information Collection Request Page 28 

Class II

 Oil and gas extraction firms fall into three SIC categories: 

 SIC code 1311 (crude petroleum and natural gas); 

 SIC code 1321 (natural gas liquids); and 

 SIC code 1381 (drilling oil and gas wells). 

 All of these categories have small business size standards of 500 employees. According 

to Dun and Bradstreet Market Analysis Profile, more than 90 percent of the firms in these SIC 

codes are small businesses, using the 500-employee standard. Even though many of the operable 

Class II injection wells are owned and operated by large businesses, industry observers believe 

that as many as half of the Class II wells are owned and operated by firms that are below the 

500-employee size standard. 

 Section 1421 of the SDWA states that regulation of Class II wells must be kept to a 

minimum, while at the same time ensuring that USDWs will not be endangered. Recognizing 

this intent, EPA has minimized reporting requirements for Class II wells in the following ways. 

First, while operators of Class I and Class III wells report injection fluid characteristics quarterly, 

Class II operators report this information annually. Second, Class I monitoring requirements 

include the installation and use of continuous recording devices to monitor injection pressure, 

flow rate, volume, and annulus pressure [40 CFR 146.13]. In contrast, Class II operators are 

only required to observe injection pressure, flow rate, and cumulative volume and to record these 

measurements at least monthly [40 CFR 146.23]. 

 The UIC regulations [40 CFR 146.14, 146.24, 146.34] define the information the UIC 

Program Director must consider in authorizing Class I, II, and III wells, respectively. Less 

information is required on Class II wells than other types of wells. For permitting of Class I and 

Class III wells, maps and cross sections detailing geologic structure may be required, whereas 

Class II well operators must provide only a description of geologic conditions. Finally, while the 

permitting authority may require Class I operators to provide detailed construction procedures, 

including a cementing program; logging procedures; deviation checks; and a drilling, testing, and 

coring program, Class II well operators need not submit this information. 

 EPA has also recognized the needs of operators of Class II wells in other ways. For 

example, oil and gas wells are often temporarily abandoned, especially by small businesses that 

operate at marginal production rates. To accommodate this situation, the regulations specify that 

cessation of operation does not require plugging (and associated information collection) until two 

years have elapsed. 
Underground Injection Control Program – Information Collection Request Page 29 

Class III

 Operators of this class of wells fall into the following categories: 

 SIC Major Group 10 (metal mining) and 

 SIC Major Group 14 (mining and quarrying of non-metallic minerals). 

 The size standard for both groups is 500 or fewer employees. According to the preamble 

to the 1980 UIC regulations (45 FR 42472), the operators of these wells are large, diversified 

corporations, well above the size standard of 500 employees. There is no reason to believe that 

there has been any material change in the size of the firms since that analysis was done. 

Class V

 EPA estimates that the majority of facilities affected by the Class V Rule will be small 

businesses. To reduce the impact of the rule on small entities, EPA has attempted to keep 

recordkeeping, reporting, and other administrative requirements for these operators to a 

minimum in order to provide regulatory relief to small entities while protecting drinking water 

supplies. Most Class V facilities do not have collection requirements other than to provide 

inventory information. EPA also convened a Small Business Advocacy Review Panel, as 

required by the Small Business Regulatory Enforcement Fairness Act (SBREFA), to explore 

options for minimizing economic impacts on small entities. 

 The economic analysis prepared for the 1999 final Class V rule includes a complete, final 

Regulatory Flexibility Analysis addressing all activities, including reporting and recordkeeping 

activities, required of small entities. 

Class VI 

 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 Class VI 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 reporting requirements for Class VI well owners or operators 

will cause no significant impact on small entities. 

5(d) Collection Schedule 

 EPA developed the schedule for information collection and reporting to minimize the 

amount of information collected while ensuring that sufficient information is available for 

appropriate and timely oversight, evaluation, and enforcement. The rationale for operator and 

state reporting frequencies is described below. Section 4 presents a complete description of the 

collection requirements. 
Underground Injection Control Program – Information Collection Request Page 30 

 5(d)(1) Operator Reporting 

 In determining the reporting schedule for each class of wells, EPA considered the 

potential for each class to contaminate USDWs. Operators of Class I, III, and some Class V 

wells must report monitoring results quarterly; Class II operators report annually; Class VI 

operators report semi-annually. The regular reporting of these data is essential to protecting 

USDWs. Specific operator reporting schedules for each well class are presented in Tables A-1 

through A-6 of Appendix A. 

 5(d)(2) State Reporting 

 Exhibit 5-1 summarizes the frequencies at which state primacy agencies must report UIC 

data, including the 7520 forms and Program Activity Measures (PAMs). The paragraphs 

following the Exhibit present the justification for the reporting frequencies. 

 In response to President Clinton’s April 24, 1995, directive to reduce regularly scheduled 

reporting frequencies by one-half, except in cases where such action would not adequately 

protect the environment, in FY 1996 EPA reduced the frequency of certain state UIC reporting. 

EPA has also discontinued the requirement that states submit the grant utilization form (7520-5). 

As Section 5(b) discusses, upon implementation of the National UIC database, states UIC 

flowing data to Headquarters will no longer be required to submit the 7520 forms and inventory 

and PAM data. 

Exhibit 5-1 

State Reporting Frequencies

Reporting Activity Frequency

Form 7520-1: Permit Review and Issuance Annual 

Form 7520-2A: Compliance Evaluation Semi-annual 

Form 7520-2B: Compliance Evaluation for Significant Noncompliance Semi-annual 

Form 7520-3: Mechanical Integrity Test/Remedial Actions Annual 

Form 7520-4: Quarterly Exceptions List Quarterly 

Inventory Reporting Annual 

Program Activity Measures Semi-annual 
Underground Injection Control Program – Information Collection Request Page 31 

7520-1: Permit Review and Issuance. Permits are the core of the UIC Program, and annual 

permit information is used for program management purposes. The Program uses permit 

information to evaluate events that delay or accelerate the permitting process. Delays in the 

permitting process may result in the states' inability to meet program objectives and prevent 

states from meeting schedules. A permitting process that is too lengthy could have a detrimental 

impact on industry. Conversely, favorable developments may occur that enable the states to 

meet time schedules and goals sooner than anticipated. Both occurrences have a potential for 

shifts in workload and resource distribution. 

7520-2A: Compliance Evaluation; 7520-2B: Significant Non-compliance. The justification for 

semi-annual reporting of compliance information is based on EPA efforts to be routinely and 

frequently informed of violations to regulations in effect under Section 1421 of the SDWA. EPA 

must remain informed in order to (a) oversee and encourage states' actions on resolving 

violations or enforcing against violators, and (b) to take direct federal action where appropriate 

state actions have not occurred in a timely manner or have not been successful. 

EPA would be unable to effectively carry out the Congressional direction for federal 

enforcement on violators if it only had access to data annually. Prior to 1987, states provided 

EPA with the above information on an annual basis. States then agreed to voluntarily supply the 

data on a quarterly basis when it became obvious that EPA Headquarters could not direct an 

effective federal enforcement program using data received only once a year. EPA later 

determined that semi-annual reporting of this information is sufficiently frequent to track 

compliance information. 

7520-3: Inspections/Mechanical Integrity Testing. Inspections are the principal method of 

identifying instances of noncompliance. Annual inspection information is used to monitor 

states’ performance on inspections. Inspections have resulted in criminal indictment and 

imprisonment of well owners. Annual inspection information ensures that inspections are being 

performed on a continual basis throughout the year. The MIT is the principal method used to 

determine whether a well is operating in a protective manner. Annual MIT information is used 

to evaluate the MIT program. 

7520-4: Quarterly Exceptions List. EPA needs quarterly information on SNCs that have been 

out of compliance for two or more consecutive quarters. The Agency uses this information to 

determine whether timely and appropriate actions have been taken by primacy authorities and to 

track enforcement activities, as these wells pose the greatest threat to USDWs. 

Inventory Reporting. Annual reporting on inventory data, as required by 40 CFR 144.8, is 

necessary for effective oversight of the UIC Program. Primacy states, Regions, and EPA 

Headquarters need to be routinely and frequently informed of changes in the number and 

operating characteristics of injection wells to monitor and regulate underground injection 

effectively and to continue protecting USDWs from contamination. 
Underground Injection Control Program – Information Collection Request Page 32 

PAMs Data. EPA Headquarters needs to collect PAM data semi-annually to meet the Office of 

Water's reporting schedules to assess progress toward meeting Agency Strategic Targets for 

achieving minimized risk to public health. Mid-year and end-of- year reporting supports national 

assessments of Water Program performance and recommendations for management actions to 

strengthen performance. 

National UIC Database. Data submissions by those states using the National UIC database 

occur quarterly; this frequency allows EPA to ensure public health protection and to meet all 

above mentioned obligations. Transferring data to EPA via the National UIC database will 

eliminate the need for the paper-based reporting described above. Note that reporting via the 

National UIC database is voluntary. See Appendix B for more information on reporting via the 

National UIC database. 
Underground Injection Control Program – Information Collection Request Page 33 

6. Estimating the Burden and Cost of the Collection

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

injection well operators and state primacy agencies) associated with UIC paperwork 

requirements, and federal burden hours and costs for reviewing respondent submissions. 

Section 6(a) provides estimates of burden hours 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) covers aggregate burden hours and costs for all respondents, and Section 6(f) explains 

the reasons for the change in estimated respondent burden hours and costs from the 

approved ICR burden. Section 6(g) presents the burden statement for this information 

collection. 

6(a) Respondent Burden 

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

 Operators of injection wells incur reporting burden associated with the following types 

of activities: permitting and startup of operations, ground water and injectate monitoring and 

well testing during well operation, reporting of monitoring results and other events, 

recordkeeping, and well closure. 

EPA estimates that the annual burden on the 53,714 owners or operators of injection 

wells will be 1,074,821 hours over the 3 years covered by this ICR. This is summarized in 

Exhibits 6-1A through F. See Appendix A for detail on the assumptions used to calculate 

the owner/operator burden and detailed burden and cost calculations. 

1) Class I Well Operators

The total annual burden on the 342 operators of Class I wells nation-wide is estimated to 

be 100,983 hours. See Exhibit 6-1A. Of this total, EPA estimates the annual burden for the 

59 operators of Class I hazardous wells to be 23,337 hours, and the burden for 283 operators 

of Class I non-hazardous wells to be 77,646 hours annually. 

 The requirements for Class I operators are among the most stringent in the UIC 

Program. Operator activities associated with Class I facilities include permitting and startup related reporting, permit renewals and modifications, monitoring, reporting and 

recordkeeping, and closure-related paperwork. Operators of Class I hazardous wells must 

also perform an extensive no-migration demonstration that their wastes will not endanger 

USDWs. 

 Appendix A summarizes the assumptions used to calculate the owner/operator burden 

and provides detailed burden and cost calculations. Table A-1 of Appendix A presents cost 

and burden estimates specific to Class I wells.
Underground Injection Control Program – Information Collection Request Page 34 

Exhibit 6-1A 

Annual Burden and Cost Associated with Class I Wells 

2012-2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 100,983 $4,534,259 $28,828,844 $33,363,103 5,266.7 19.17 $6,334.68 

Primacy States 4,463 $184,860 $0 $184,860 1,477.3 3.02 $125.13 

DI Programs 6,256 $259,164 $0 $259,164 710.1 8.81 $364.95 

TOTAL 111,702 $4,978,284 $28,828,844 $33,807,127 7,454.2 14.99 $4,535.31 

Note: numbers may not appear to add due to rounding. 

2) Class II Well Operators 

 As shown in Exhibit 6-1B, EPA estimates the total annual burden on the 15,085 

operators of Class II wells (associated with the oil and natural gas industry) to be 

872,778 hours. Class II well operators perform many of the same types of activities as 

Class I wells, including submitting permit applications and completion reports, 

monitoring and testing, reporting and recordkeeping, and closure-related paperwork. 

 Class II wells that conduct hydraulic fracturing are using diesel and are subject to 

the Class II UIC requirements at Subpart C of 40 CFR 146. EPA is currently 

developing guidance for permitting of hydraulic fracturing wells that use diesel. When 

the guidance is finalized, EPA anticipates that the burden associated with Class II 

permits may increase upon release of the. We will use information on the number of 

these wells for the final ICR if we have such information before publishing it. 

 See Appendix A (particularly Table A-2) for details on the assumptions used to 

calculate the owner/operator burden and cost associated with the requirements for Class 

II wells.

Exhibit 6-1B 

Annual Burden and Cost Associated with Class II Wells 

2012-2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 872,778 $37,262,581 $84,338,754 $121,601,334 388,781.0 2.24 $312.78 

Primacy States 127,190 $5,268,725 $0 $5,268,725 84,624.8 1.50 $62.26 

DI Programs 7,079 $293,231 $0 $293,231 5,010.9 1.41 $58.52 

TOTAL 1,007,047 $42,824,536 $84,338,754 $127,163,290 478,416.7 2.10 $265.80 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 35 

3) Class III Well Operators

 The estimated total annual burden on the 141 operators of Class III facilities is 

48,051 hours. See Exhibit 6-1C. Operators of these wells associated with mining 

operations incur burden associated with permit applications and completion reports, 

monitoring, reporting and recordkeeping, and closure-related paperwork. 

Based on information that the number of Class III sites (sites where mining 

occurs and has these wells) decreased over the period 2007 to 2011, which includes the 

period of the current ICR, and with dated information that only 6% of the current 141 

Class III sites (number as of February, 2011) are uranium mining sites, the draft ICR 

calculates burden assuming that the number of sites will not increase and that only 6% 

of these sites are for uranium mining. Before EPA finalizes this ICR, the Agency will 

investigate whether these assumptions are reasonable in light of a current understanding 

that at least the number of uranium mining sites will likely increase during the ICR 

Renewal period. Based on this investigation, EPA will re-estimate the burden associated 

with Class III wells for the final ICR. 

 Appendix A (particularly Table A-3) presents details on the assumptions used to 

calculate the owner/operator burden and cost associated with the requirements for Class 

III wells. 

Exhibit 6-1C 

Annual Burden and Cost Associated with Class III Wells 

2012-2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 48,051 $1,897,957 $674,486 $2,572,442 5,186.7 9.26 $495.97 

Primacy States 3,363 $139,330 $0 $139,330 584.9 5.75 $238.21 

DI Programs 258 $10,694 $0 $10,694 337.9 0.76 $31.64 

TOTAL 51,673 $2,047,980 $674,486 $2,722,465 6,109.5 8.46 $445.61 

Note: numbers may not appear to add due to rounding.

4) Class IV/Endangering Class V Well Operators

 Class IV wells and Class V wells that are found to be endangering USDWs are 

banned from injection, and owners of these wells are required to close them and submit 

plugging and abandonment reports to states or DI programs. The exception to the ban is 

for those Class IV wells used to inject contaminated ground water that has been treated 

and re-injected into the same formation from which it was drawn. These wells are 

authorized by rule for the life of the well if such subsurface emplacement of fluid is 

approved by EPA or a state pursuant to the provisions for the cleanup of releases under 

CERCLA or RCRA. 
Underground Injection Control Program – Information Collection Request Page 36 

 EPA estimates that the burden on the 990 operators of these wells that are subject 

to this information collection will be 9,900 hours annually. See Exhibit 6-1D and 

Appendix A. 

Exhibit 6-1D 

Annual Burden and Cost Associated with Class IV Wells 

2012-2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 9,900 $232,551 $0 $232,551 990.0 10.00 $234.90 

Primacy States 758 $31,399 $0 $31,399 758.0 1.00 $41.42 

DI Programs 232 $9,610 $0 $9,610 232.0 1.00 $41.42 

TOTAL 10,890 $273,561 $0 $273,561 1,980.0 5.50 $138.16 

Note: numbers may not appear to add due to rounding.

5) Class V Well Operators

 The total annual burden on the 37,155 operators of Class V wells with reporting 

requirements under this information collection is estimated to be 38,924 hours. See 

Exhibit 6-1E and Appendix A. 

All operators of Class V wells must submit inventory information before they 

may begin operating their wells. In addition, the 1999 Class V Rule provided additional 

requirements for owners of MVWDWs and large-capacity cesspools. Facilities that 

wish to continue operating MVWDWs must apply for permits. MVWDWs and largecapacity cesspools that close are required to submit pre-closure notifications. 

Although the Class V Rule required that all of these facilities be closed or apply 

for a permit by January 2007, EPA understands that some of these activities may not be 

complete due to resource issues. Thus, some permitting/closure burden is included in 

this ICR. In addition, operators of MVWDWs that opted to apply for (and received) 

permits must monitor their injectate and sludge and submit annual monitoring reports.

Exhibit 6-1E 

Annual Burden and Cost Associated with Class V Wells 

2012-2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 38,924 $836,719 $6,775,837 $7,612,555 44,921.2 0.87 $169.46 

Primacy States 14,722 $609,854 $0 $609,854 25,358.2 0.58 $24.05 

DI Programs 7,902 $327,338 $0 $327,338 13,621.0 0.58 $24.03 

TOTAL 61,548 $1,773,910 $6,775,837 $8,549,747 83,900.4 0.73 $101.90 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 37 

6) Class VI Well Operators

 EPA finalized requirements for owners or operators of Class VI GS wells in 

2010 (75 FR 77230). Concurrent with publishing the Class VI Rule, EPA obtained 

OMB clearance for paperwork burden associated with the requirements for Class VI 

wells (ICR No. 2309.01, OMB control number 2040-0278). The clearance period of 

that ICR is from 2011 through 2013. Therefore, this UIC Programmatic ICR only 

estimates the burden and cost to owners or operators and primacy agencies associated 

with implementing the Class VI rule in 2014 (i.e., year 3 of this information collection). 

 EPA estimates that the burden on the 1.8 Class VI well operators subject to this 

information collection during the clearance period will be 4,184 hours annually for 

activities associated with a permit application. See Exhibit 6-1F and Appendix A. 

Exhibit 6-1F 

Annual Burden and Cost Associated with Class VI Wells 

2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 4,184 $450,133 $19,767,163 $20,217,296 8.4 496.76 $2,400,153.83 

Primacy States 35 $2,331 $0 $2,331 3.0 11.69 $774.73 

DI Programs 2,432 $161,169 $0 $161,169 24.7 98.55 $6,531.68 

TOTAL 6,651 $613,633 $19,767,163 $20,380,796 36.1 184.21 $564,460.74 

Note: numbers may not appear to add due to rounding.

Exhibit 6-1G summarizes the operator burden and costs, by well type (from 

Exhibits 6-1A through F). Exhibit 6-2, in the next section, provides a similar summary 

for primacy agencies. 

Exhibit 6-1G 

Summary of Annual Operator Burden and Cost (based on above exhibits) 

2012-2014

Respondent Type Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Class I Operators 100,983 $4,534,259 $28,828,844 $33,363,103 5,266.7 19.17 $6,334.68 

Class II Operators 872,778 $37,262,581 $84,338,754 $121,601,334 388,781.0 2.24 $312.78 

Class III Operators 48,051 $1,897,957 $674,486 $2,572,442 5,186.7 9.26 $495.97 

Class IV Operators 9,900 $232,551 $0 $232,551 990.0 10.00 $234.90 

Class V Operators 38,924 $836,719 $6,775,837 $7,612,555 44,921.2 0.87 $169.46 

Class VI Operators 4,184 $450,133 $19,767,163 $20,217,296 8.4 496.76 $2,400,153.83 

TOTAL 1,074,821 $45,214,199 $140,385,082 $185,599,282 445,154.1 2.41 $416.93 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 38 

6(a)(ii) Burden to Primacy Agencies

 EPA estimates that the annual burden on the 58 state primacy agencies that 

oversee the various classes of injection wells is 221,346 hours for the years 2012 

through 2014. Exhibit 6-2 shows the annual Primacy agency burden hours associated 

with oversight of each class of injection well. Appendix A describes the bases for the 

burden estimates. 

 State primacy agencies’ burden as users or reviewers of operator-submitted data 

associated with implementing Class I through Class VI UIC programs arise from 

processing permit applications and completion reports, reviewing monitoring and testing 

data, and responding to closure reports submitted by operators within their states. 

 

The burden to states as respondents is associated with compiling and reporting 

data using the 7520 forms and the UIC measures reporting process or submission to the 

National UIC database. By the end of the clearance period, EPA estimates that all 

primacy agencies will transfer data to EPA Headquarters to populate the National UIC 

database. Appendix B describes the costs to states associated with this effort. 

Exhibit 6-2 

Annual Primacy Agency Burden and Cost 

2012-2014

Respondent Type Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Class I Programs 4,463 $184,860 $0 $184,860 1,477.3 3.02 $125.13 

Class II Programs 127,190 $5,268,725 $0 $5,268,725 84,624.8 1.50 $62.26 

Class III Programs 3,363 $139,330 $0 $139,330 584.9 5.75 $238.21 

Class IV Programs 758 $31,399 $0 $31,399 758.0 1.00 $41.42 

Class V Programs 14,722 $609,854 $0 $609,854 25,358.2 0.58 $24.05 

Class VI Programs 35 $2,331 $0 $2,331 3.0 11.69 $774.73 

Subtotal -Operator 

Oversight 150,532 $6,236,499 $0 $6,236,499 112,806.3 1.33 $55.29 

States as 

Respondents 70,814 $2,933,405 $72,876 $3,006,281 533.7 132.69 $5,633.26 

TOTAL 221,346 $9,169,904 $72,876 $9,242,780 113,339.9 1.95 $81.55 

Note: numbers may not appear to add due to rounding.

6(b) Respondent Costs

6(b)(i) Cost to Operators

 Exhibits 6-1A through F and 6-1G show the total costs for owners and operators 

of various classes of injection wells over the 3-year ICR clearance period. Annual costs 

to injection well operators are estimated at approximately $185.6 million, which consists 
Underground Injection Control Program – Information Collection Request Page 39 

of $140.4 million in non-labor costs and $45.2 million in labor costs. 

 EPA determined operator labor cost by estimating the mix of legal, managerial, 

technical, and clerical time needed to perform each collection activity. For Classes I, II, 

and III, the labor cost estimate is based on average hourly estimates for salary and 

overhead of $74 for legal staff, $80 for managerial staff, $46 for technical staff, and $27 

for clerical staff. For Classes IV and V, hourly salary and overhead rates are estimated 

to be slightly less: $58 for managerial staff, $25 for technical staff, and $18 for clerical 

staff (no legal staff labor is assumed for these operators). For Class VI, the labor cost 

estimate is based on average hourly estimates for salary and overhead of $111 for 

mining and geological engineers and $107 for geoscientists. Contractor time (which is 

included in the non-labor costs in this ICR) was estimated to be approximately $80 per 

hour. 

 EPA estimated non-labor costs from data provided by staff in EPA Regions and 

state primacy agencies, and from operators and other sources. This ICR assumes there 

are no capital costs to operators–large capital expenditures associated with underground 

injection (e.g., construction costs and monitoring equipment) are considered to be 

customary business practice. All non-labor costs to operators associated with this 

collection are operating and maintenance (O&M) costs, such as the cost of contractor 

services or laboratory fees associated with injectate, sludge, or ground water monitoring. 

6(b)(ii) Cost to Primacy Agencies

 Exhibit 6-2 shows that the annual cost to primacy agencies is estimated at 

approximately $9.24 million, of which most ($9.17 million) is labor cost. For this ICR, 

EPA assumed that the average hourly labor rate for a state employee is $41.42. This 

estimate is based on a federal GS-9, Step 10 salary on the 2011 federal pay scale, 

increased by 60 percent to account for overhead costs. (This is the inflation factor 

recommended in EPA’s ICR Handbook.) 

 The non-labor costs (capital and O&M) to states in this ICR are estimated to be 

$72,876. These include capital/start-up costs associated with purchasing computer 

hardware to allow data transfer to Headquarters to populate the National UIC database. 

The remaining non-labor costs to states are the cost of contractor support for database 

development. 
Underground Injection Control Program – Information Collection Request Page 40 

6(c) Agency Burden and Costs 

 EPA’s regional offices implement the UIC Program for all well classes in 10 

states and have oversight responsibility for a subset of well classes in 6 states. The 

paperwork requirements for DI programs are roughly the same as those for the state 

primacy programs. In addition, EPA regions review all no-migration petitions submitted 

by Class I hazardous facility operators in both primacy and DI states in their region. In 

addition, EPA Headquarters spends an estimated 2 FTEs, or 4,160 hours annually in its 

oversight responsibilities for the UIC Program activities related to this information 

collection. Headquarters activities include gathering and reviewing 7520 forms, analysis 

of inventory and measures data, and development of the National UIC database. The 

total annual burden for federal DI programs associated with the above activities is 

28,319 hours. See Exhibit 6-3. 

 EPA assumes the average hourly labor rate for salary and overhead and benefits 

for Agency staff to be $41.42. This estimate is based on a federal GS-9, Step 10 salary 

on the 2011 federal pay scale, increased by 60 percent to account for overhead costs. 

The annual federal cost associated with this collection is $1,233,529. The breakdown of 

Agency cost associated with each well class is presented in Exhibit 6-3. 

Exhibit 6-3 

Annual Agency Burden and Cost 

2012-2014

Respondent Type Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Class I DI 

Programs 6,256 $259,164 $0 $259,164 710.1 8.81 $364.95 

Class II DI 

Programs 7,079 $293,231 $0 $293,231 5,010.9 1.41 $58.52 

Class III DI 

Programs 258 $10,694 $0 $10,694 337.9 0.76 $31.64 

Class IV DI 

Programs 232 $9,610 $0 $9,610 232.0 1.00 $41.42 

Class V DI 

Programs 7,902 $327,338 $0 $327,338 13,621.0 0.58 $24.03 

Class VI DI 

Programs 2,432 $161,169 $0 $161,169 24.7 98.55 $6,531.68 

Headquarters 

Management 4,160 $172,324 $0 $172,324 1.0 4,160.00 $172,323.84 

TOTAL 28,319 $1,233,529 $0 $1,233,529 19,937.6 1.42 $61.87 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 41 

6(d) Estimating Respondent Universe and Total Burden and Costs

 EPA estimates that 53,714 owners or operators of injection wells and 58 primacy 

agencies are subject to the UIC Program’s information collection requirements outlined 

in Section 6(a). The number of responses for each well class and activity are shown in 

Exhibits 6-1A though 6-1F, and summarized in Exhibit 6-1G. The estimates of the 

number of state responses are shown in Exhibit 6-2. This number, known as 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 or well closures 

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

and the frequency with which they must comply with those requirements. Part 2 of 

Appendix A provides more detail on EPA’s assumptions about the number of 

respondents that perform each collection activity. 

 EPA estimates that the total annual respondent burden over the 3 years covered 

by this ICR is 3.89 million hours. The total cost to respondents is $584.5 million. 

6(e) Bottom Line Burden Hours and Costs

 The bottom line burden hours and costs appear in Exhibit 6-4. 

Exhibit 6-4

Bottom Line Annual Burden and Cost 

2012-2014

Number of Respondents 53,772 = 53,714 Operators (from EPA inventory) + 

 58 Primacy agencies 

Total Annual Responses 558,494 = 445,154 Operator responses (from Exhibit 6-1G) + 

 113,340 Primacy agency responses (from Exhibit 6-2) 

Number of Responses per 

Respondent 

 

10.4 = 558,494 Total annual responses from above/ 

 53,772 Total respondents from above 

Total Respondent Hours 1,296,167 = 1,074,821 Operator burden hours (from Exhibit 6-1G) + 

 221,346 Primacy agency burden hours (from Exhibit 6-2) 

Hours per Response 2.3 = 1,296,167 Total annual hours from above/ 

 558,494 Total responses from above 

Annual O&M and Capital 

Cost $140,457,959 = $140,385,082 Operator non-labor cost (from Exhibit 6-1G) + 

 $72,876 Primacy agency non-labor cost (from Exhibit 6-2) 

Total Respondent Cost $194,842,061 = $185,599,282 Operator cost (from Exhibit 6-1G) + 

 $9,242,780 Primacy agency cost (from Exhibit 6-2) 

Total Hours (Respondents) 1,324,486 = 1,296,167 Total respondent hours from above + 

 28,319 Total EPA hours (from Exhibit 6-3) 

Total Cost (Respondents 

plus Agency) 

 

$196,075,591 = $194,842,061 Total respondent cost from above + 

 $1,233,529 Total EPA cost (from Exhibit 6-3) 

Note: Detail may not add exactly to total due to independent rounding.
Underground Injection Control Program – Information Collection Request Page 42 

6(f) Reason for Change in Burden 

 The total annual approved burden on operators and states associated with the 

UIC Program is 1,000,648 hours. This ICR requests total annual respondent burden of 

1,296,167 hours. Thus, there is a net increase in burden of 295,519 hours between the 

approved and requested amounts. Of this, 233,836 hours is increased operator burden 

and 61,683 is increased primacy agency burden. 

 This section discusses the change in burden to operators of injection wells and 

primacy states between the burden requested in this ICR and the approved burden. The 

burden changes are the result of program changes and adjustments and affect well 

operators and the agencies that oversee them to varying degrees. 

 Exhibits 6-5 and 6-6 summarize the burden impacts of these changes to operators 

and primacy agencies, respectively. The paragraphs following the tables describe these 

changes. 

Exhibit 6-5 

Reasons for Change in Annual Operator Burden (Hours) 

Operator type 

Approved 

Burden This ICR Net Change Reasons for Change 

Class I Operators 88,434 100,983 12,549

Adjustment due to inventory increases since the 

last ICR. 

Class II Operators 593,332 872,778 279,447

Adjustments to inventory, permit applications 

submitted, and MITs performed. 

Class III 

Operators 55,387 48,051 -7,336

Adjustment due to decrease in the number of 

Class III facilities. 

Class IV 

Operators 9,900 9,900 0

None. 

Class V 

Operators 93,933 38,924 -55,009

Program change reflecting a reduction in the 

number of permitted MVWDW facilities, partially 

offset by an upward adjustment in the number of 

inventory forms submitted. 

Class VI 

Operators 0 4,184 4,184

Program change associated with incorporation of 

the Class VI rule to the UIC programmatic ICR. 

Total 840,985 1,074,821 233,836
Underground Injection Control Program – Information Collection Request Page 43 

 

Exhibit 6-6 

Reasons for Change in Annual Primacy Agency Burden (Hours)

Agency type 

Approved 

Burden This ICR Net Change Reasons for Change 

Class I Primacy 4,854 4,463 -391

Program change due to completion of Florida 

primacy application, offset by adjustment due to 

inventory increases since the last ICR. 

Class II Primacy 45,761 127,190 81,429

Adjustments due to inventory changes and the 

number of permit applications and MIT results 

reviewed. 

Class III Primacy 3,367 3,363 -4

Adjustment due to decrease in the number of 

Class III facilities. 

Class IV Primacy 758 758 0 None. 

Class V Primacy 16,216 14,722 -1,493

Program change reflecting a reduction in the 

number of permitted MVWDW facilities, partially 

offset by an upward adjustment in the number of 

inventory forms reviewed. 

Class VI Primacy 0 35 35

Program change associated with incorporation of 

the Class VI rule to the UIC programmatic ICR. 

States as 

respondents 88,708 70,814 -17,893

Program changes associated with transition to 

electronic reporting and addition of two new tribal 

primacy agencies reporting. 

Total 159,663 221,346 61,683

Program Changes 

Program changes that affect the UIC reporting burden in this ICR include the following: 

 Florida Class I Rule activities. EPA assumes that all facilities subject to the 

Florida rule have completed permit applications. Further, the state of Florida has 

completed its primacy application. Elimination of these activities reduces the 

operator burden by 1,472 hours and primacy agency burden by 531 hours. These 

facilities are subject to the same monitoring and reporting requirements as other 

Class I non-hazardous facilities. 

 Activities associated with the Class V Rule. Based on PAMs data, EPA assumes 

that fewer facilities than previously estimated have permits and are therefore 

closing their wells. This means that fewer operators are conducting injectate and 

sludge sampling. This reduces the burden estimate on Class V well operators by 

64,442 hours. This is partially offset by an adjustment in inventory activities, as 

described below. 

 Class VI Rule. Activities associated with obtaining Class VI permits and 

operating GS facilities are accounted for in the third year of this clearance 

period. Because EPA assumes that early implementation of GS technology will 

be limited, this program change accounts for an additional 4,184 operator hours 

and 35 primacy agency hours. 
Underground Injection Control Program – Information Collection Request Page 44 

 National UIC database. EPA Headquarters continues to populate a national 

database to streamline reporting from states and DI programs to Headquarters. 

States that are reporting data to the National UIC database no longer complete 

the paper-based forms. This has resulted in a reduction of over 20,000 agency 

burden hours annually. Appendix B describes the development and 

implementation of the National UIC database, and compares the reporting costs 

for states with and without a national database. 

 Addition of tribal primacy agencies. Two tribes (Navajo and Fort Peck) received 

primacy to implement Class II programs since the last ICR. These tribes will 

incur burden associated with preparing and submitting 7520 forms and reporting 

on the UIC measures. This adds 2,442 hours to this ICR estimate. 

Adjustments 

Adjustments that affect the UIC reporting burden in this ICR include the following: 

 Inventory changes. Between 2007 and 2011, the national injection well inventory 

increased by approximately 119,000 wells—the majority of the increase is in the 

Class V inventory. Increases in the Class I and Class II inventories have resulted 

in an additional 40,270 hours in this ICR estimate. Inventory data also show that 

the number of Class III facilities is 15 percent lower than in the last ICR; this has 

reduced the Class III operator burden estimate by approximately 7,300 hours. 

EPA also estimates that the number of Class V well operators submitting 

inventory data increased, adding 9,434 hours to this ICR estimate. 

 Other adjustments relate to assumptions about the number of Class II operators 

that will be submitting permit applications—EPA estimates a significant increase 

in the number of permit applications submitted by owners or operators and 

reviewed by primacy agencies. EPA also adjusted the number of MITs 

performed by Class II owners or operators. These two adjustments (both of 

which are based on consultations with the states) added approximately 253,000 

hours to this ICR estimate. 

UIC Program Burden Reduction Efforts 

EPA continues to explore options to reduce the reporting burden and cost to 

respondents, while maintaining the protective components of the UIC Program. This is 

primarily being accomplished by increasing the use of electronic reporting methods. 

EPA’s efforts are briefly described below and discussed in further detail in Appendix D. 

 EPA’s National UIC database allows electronic transfer of data between 

existing state and DI databases and Headquarters’ database. When fully 

populated, the National UIC database will eliminate the need for state UIC 

Program Directors to complete paper reporting forms, because Headquarters 
Underground Injection Control Program – Information Collection Request Page 45 

would be able to collect data for and prepare national annual reports using the 

information in the database. As part of this effort, EPA encourages primacy 

programs to develop electronic reporting from operators to primacy programs. 

See additional discussion of the National UIC database in Section 5(b) of this 

ICR and in Appendix B. 

 EPA continues to explore a web-based system through which Class V well 

operators could submit inventory and well closure information. This system, if 

implemented, will make two existing UIC reporting forms (Form 7520-16, Well 

Inventory form and 7520-17, Class V Well Pre-Closure Notification form) 

available online. The web entry option would offer many benefits to operators 

and oversight agencies, including: reducing burden and cost to operators (e.g., 

no need to mail the hardcopy form); eliminating physical data entry for States 

and any potential transcription errors; and facilitating the notification process 

associated with the submissions. 

6(g) Burden Statement

 EPA estimates that, over the 3 years covered by this request, the total annual burden 

on underground injection well owners/operators and primacy agencies associated with 

UIC requirements will be 1,296,167 hours and the present value cost will be $194.8 

million per year. See Exhibit 6-7. 

Exhibit 6-7 

Annual Burden and Cost Associated with All Well Classes 

2012-2014

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor Cost Total Cost Responses Burden/ 

Response 

Cost/ 

Response 

Operators 1,074,821 $45,214,199 140,385,082 185,599,282 445,154.1 2.41 $416.93 

Primacy States 221,346 $9,169,904 $72,876 $9,242,780 113,339.9 1.95 $81.55 

Respondent 

total 1,296,167 $54,384,103 $140,457,959 $194,842,061 558,494.0 2.32 $348.87 

EPA 28,319 $1,233,529 $0 $1,233,529 19,937.6 1.42 $61.87 

TOTAL 1,324,486 $55,617,632 $140,457,959 $196,075,591 578,431.6 2.29 $338.98 

Note: numbers may not appear to add due to rounding.

The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 2.32 hours per response. 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 
Underground Injection Control Program – Information Collection Request Page 46 

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 this ICR under Docket ID No. EPA-HQ-OW-2003-0017, 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 through 

http://www.regulations.gov. Use www.regulations.gov 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-2003-0017, 

and OMB control number 2040-0042 in any correspondence. 

Underground Injection Control Program – Information Collection Request Page A-1 

Appendix A: Detailed Explanation of Respondent Burden Estimates and Respondent Universe 

 Respondents for this information collection include operators of Class I – VI wells and state primacy 

agencies. The first part of this Appendix contains EPA’s estimates of respondent burden associated with UIC 

paperwork requirements. The second part of this Appendix provides EPA’s assumptions about the number of 

respondents subject to each information collection activity. 

A.1 Estimating Respondent Burden 

 EPA has calculated respondent burden hours for each information collection, reporting, and 

recordkeeping activity required of well operators and state primacy agencies. Because required data items vary 

by well class, separate operator and state burden estimates have been prepared for each class. Tables A-1 

through A-7 contain detailed estimates of the number of respondents and unit burden hours for required 

paperwork-related activities. 

 EPA recognizes that many UIC information collection activities are performed by contractors. The 

operator unit burdens reported in this appendix represent a composite of the operator time needed to both 

perform an information collection activity and to supervise a contractor when the contractor performs the 

activity. The mix of operator versus contractor labor varies by activity and by well class. Contractor costs are 

included in the estimates of operator unit costs. 

Burden Associated with Class I Wells 

 EPA’s estimate of the annual paperwork burden on operators for permitting, monitoring and testing, 

reporting and recordkeeping, and closing their facilities and state burden for administering Class I hazardous 

and Class I nonhazardous programs are presented in Tables A-1A and Table A-1B, respectively. Legal, 

managerial, technical, and clerical staff hours are shown; Column A presents the total unit burden for each 

activity.
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response T

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Initial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time 0.0 0.25 0.25 0.0 0.5 $31 $0 8 Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, description of the business.

One-time

3.0 2.0 9.0 6.0 20.0 $954 $0 8 

In DI programs, gather and submit a list of landowners within one-quarter mile of the facility boundary.

One-time

4.0 0.0 0.0 1.2 5.2 $329 $0 2 

Prepare and submit a map and tabulation of all wells within the AoR.

One-time

0.0 1.5 5.5 0.0 7.0 $370 $21,605 8 

Prepare and submit AoR protocol. One-time

0.0 0.0 1.3 0.0 1.3 $59 $837 8 

Prepare and submit maps/cross sections of local and regional geology, USDWs.

One-time

0.0 1.5 16.0 0.0 17.5 $850 $44,856 8 

Develop formation testing and stimulation programs and injection procedures.

One-time

0.0 2.0 5.0 1.0 8.0 $414 $6,439 8 

Prepare and submit contingency plans for shut-ins or well failures.

One-time

0.0 3.0 10.0 2.0 15.0 $749 $250 8 

Prepare and submit ambient monitoring plan. One-time

0.0 3.0 0.0 0.0 3.0 $235 $4,221 8 

Prepare and submit Corrective Action Plan. One-time

0.0 2.0 3.0 2.3 7.3 $358 $10,695 8 

Prepare and submit descriptions of logs and tests, construction schematics & operating data.

One-time

0.0 2.0 8.0 5.0 15.0 $658 $5,366 8 

Prepare and submit closure plan, including demonstration of financial responsibility.

One-time

0.0 1.0 3.0 2.6 6.6 $286 $1,581 8 

Prepare and submit post-closure care plan. One-time

0.0 1.4 2.0 1.4 4.8 $239 $1,946 8 

Requirements for active hazardous waste facilitiesGather and submit dates of well operation and specific waste information.

One-time

0.0 0.0 26.6 11.4 38.0 $1,519 $8,156 8 

Gather and submit hazardous waste release information.

One-time

0.0 1.9 30.4 22.8 55.1 $2,150 $4,078 0 

Underground Injection Control Program -- Information Collection Request 
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response T

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Develop waste analysis plan. One-time

0.0 1.9 15.2 1.9 19.0 $896 $2,719 8 

Prepare and submit schedule of construction logs and tests.

One-time

0.0 0.0 0.5 0.5 1.0 $36 $0 8 

Requirements associated with completion reportsPrepare and submit completion report. One-time 0.0 0.0 1.5 2.5 4.0 $135 $0 8 Submit results of deviation checks, other logs and tests; sample formation fluids; test injection and confining zones.

One-time

0.0 0.0 6.0 1.0 7.0 $301 $32,908 8 

Demonstrate mechanical integrity (i.e., casing pressure test, radioactive tracer survey of bottom-hole cement, and noise/temperature logs to check for movement along the borehole).

One-time

0.0 2.0 18.0 0.0 20.0 $981 $21,462 8 

Submit information on the anticipated maximum pressure and flow rate.

One-time

0.0 0.0 2.0 0.0 2.0 $91 $143 8 

Submit results of the injection zone and confining zone testing programs.

One-time

0.0 1.0 4.0 0.0 5.0 $262 $35,770 8 

Submit actual injection procedure. One-time 0.0 0.0 1.0 0.0 1.0 $46 $143 8 Demonstrate hydrogeologic compatibility/ compatability of well materials.

One-time

0.0 2.0 6.0 0.0 8.0 $433 $7,154 8 

Prepare and submit information on the calculated AoR.

One-time

0.0 0.0 2.0 0.0 2.0 $91 $2,862 8 

No-migration petition requirementsGather and submit waste information and present modeling data to demonstrate that wastes will not migrate from injection zone.

One-time

0.0 24.0 120.0 30.0 174.0 $8,191 $751,170 8 

Requirements associated with permit renewals/modifications and petition modificationsSubmit updated components of permit application attachments.

Occasional

0.0 9.0 41.5 21.0 71.5 $3,173 $10,588 12 

Prepare and submit request for Permit Modification.

One-time

0.0 2.0 6.0 2.0 10.0 $487 $6,152 5 

Prepare and submit Petition Modification. One-time

0.0 24.0 120.0 30.0 174.0 $8,191 $711,075 6 

Underground Injection Control Program -- Information Collection Request 
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response T

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Monitoring/Testing Requirements (Per Facility)Use continuous recording devices to monitor injection pressure, flow rate, volume, and temperature.

Continuous

0.0 0.0 5.7 0.0 5.7 $260 $0 59 

Conduct chemical monitoring of injected wastes as prescribed in waste analysis plan.

As specified in WAP

0.0 0.0 38.0 0.0 38.0 $1,734 $4,292 238 

Conduct additional chemical monitoring as specified by the Director.

Varies

0.0 0.0 7.6 0.0 7.6 $347 $858 24 

Conduct casing pressure test and radioactive tracer survey of bottom-hole cement.

Annual

0.0 3.8 5.2 0.0 9.0 $540 $5,926 48 

Conduct casing pressure test, radioactive tracer of bottom-hole cement, and noise/temperature logs to check for movement along the borehole.

Every 5 years

0.0 1.0 7.0 0.0 8.0 $399 $40,778 12 

Conduct casing inspection log at workover. Occasional

0.0 3.8 8.0 0.0 11.8 $668 $7,111 3 

Conduct pressure fall-off test. Annual

0.0 6.0 18.0 0.0 24.0 $1,299 $16,592 59 

Conduct ambient monitoring. Annual

0.0 0.4 1.9 0.0 2.3 $117 $5,723 59 

Reporting Requirements (Per Facility)Prepare and submit report on maximum injection pressure, total injectate volume, and monitoring and testing results.

Quarterly

0.0 4.0 15.0 6.0 25.0 $1,492 $0 238 

Prepare and submit report on mechanical integrity testing.

Annual

0.0 1.0 2.0 1.0 4.0 $234 $1,288 59 

Notify Director within 24 hours of: planned physical changes to facility, changes that may result in noncompliance, compliance or noncompliance with a compliance schedule, any indication of possible endangerment of a USDW, or all other noncompliance.

Occasional

0.0 1.0 2.0 3.0 6.0 $234 $0 1 

Prepare and submit revised plugging and abandonment cost estimate.

Annual

0.0 1.0 0.0 0.0 1.0 $74 $0 59 

Prepare and submit report on: events exceeding operating parameters or triggering alarms; changes in annular fluid volume; workovers or other testing.

Occasional

0.0 1.0 1.0 1.0 3.0 $152 $0 3 

Underground Injection Control Program -- Information Collection Request 
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response T

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Recordkeeping Requirements (Per Facility)Maintain monitoring information, calibration and maintenance records, required reports, application data, monitoring results, and most recent plugging and abandonment cost estimate.

3 years

0.0 0.0 0.0 5.0 5.0 $134 $0 59 

Closure Requirements (Per Well)Prepare and submit notice of intent to close. One-time

0.0 0.5 0.0 1.0 1.5 $67 $0 1 

Prepare and submit closure report. One-time 0.0 2.0 8.0 0.0 10.0 $524 $2,862 1 Conduct pressure fall-off test prior to well closure.

One-time

0.0 1.0 5.0 0.0 6.0 $308 $16,592 1 

Demonstrate mechanical integrity (i.e., casing pressure test, radioactive tracer of bottom-hole cement, and noise/temperature logs to check for movement along the borehole) prior to closure.

One-time

0.0 2.0 18.0 0.0 20.0 $981 $26,784 1 

Notify state or local zoning or drilling authorities and Regional Administrator following closure.

One-time

0.0 0.5 1.0 3.0 4.5 $166 $0 1 

TOTAL 1,153 Notes:(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-1A (continued)

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States

ABCD

Hours and Costs per Response Total Hours 

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit Nonlabor 

Cost

Number of 

State 

Responses 

 To

Ho

Initial/Start-upPermit ApplicationsConsider the permit application, AoR, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and construction procedures as required at 146.70 and prepare draft permit.

One-time

40.0 $1,657 $0 6 

 

Provide public notice of issuance of a draft permit or intent to deny.

One-time

1.0 $41 $0 6 

 

Consider public comments. One-time

6.0 $249 $0 6 

 

Issue final permit decision. One-time 2.0 $83 $0 6 

 

Respond to comments. One-time

7.0 $290 $0 6 

 

Review notice of completion of construction. One-time

2.0 $83 $0 6 

 

No-Migration Petitions Review and respond to petition request. One-time 18.0 $746 $0 6 

 

Public notice/public comment. One-time 10.0 $414 $0 6 

 

Review and respond to petition modification request. One-time

10.0 $414 $0 4 

 

Permit renewals/modificationsReview and respond to requests for permit modifications or reissuance. Occasional 30.0 $1,243 $0 9 

 

Underground Injection Control Program -- Information Collection Request 
Table A-1A (continued)

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States

ABCD

Hours and Costs per Response Total Hours 

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit Nonlabor 

Cost

Number of 

State 

Responses 

 To

Ho

Monitoring/TestingReview quarterly monitoring and testing results. Quarterly 1.5 $62 $0 169 

 

Review casing pressure test and radioactive tracer survey of bottom-hole cement.

Annual

4.0 $166 $0 34 

 

Review casing pressure test, radioactive tracer survey of bottom-hole cement, and logs.

Every 5 years

4.0 $166 $0 8 

 

Review pressure fall-off test. Annual 2.0 $83 $0 32 

 

Other ReportingRespond to periodic notifications by owners and operators. Occasional 2.0 $83 $0 4 

 

ClosureReview closure and post-closure plans prior to approving plugging and abandonment.

One-time

2.0 $83 $0 1 

 

Witness and review pressure fall-off test prior to authorizing closure.

One-time

24.0 $994 $0 1 

 

TOTAL 

353 

Notes:(A) For quarterly activities, the number of responses = number of facilities X 4.(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-1B

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators

AB C D 

Hours and Costs per Response Total 

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Non-Labor 

Cost (B)

No. of 

Responses

Initial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time 0.0 0.25 0.25 0.0 0.5 $31 $0 14 Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, relevant maps and cross sections, construction specifics, description of the business, proposed injection, formation testing, and stimulation 

One-time

3.0 2.0 9.0 6.0 20.0 $954 $0 14 

In DI programs, gather and submit a list of landowners within one-quarter mile of the facility boundary. 

One-time

4.0 0.0 0.0 1.2 5.2 $329 $0 4 

Prepare and submit a map and tabulation of all wells within the AoR.

One-time

0.0 1.5 5.5 0.0 7.0 $370 $17,284 14 

Prepare and submit maps/cross sections of local and regional geology, USDWs.

One-time

0.0 1.5 16.0 0.0 17.5 $850 $44,856 14 

Prepare and submit descriptions of logs and tests, construction schematics and operating data.

One-time

0.0 2.0 8.0 2.5 12.5 $591 $5,366 14 

Develop formation testing and stimulation programs and injection procedures.

One-time

0.0 2.0 7.0 1.0 10.0 $506 $6,439 14 

Prepare and submit contingency plans for shut-ins or well failures.

One-time

0.0 3.0 10.0 2.0 15.0 $749 $250 14 

Prepare and submit ambient monitoring plan. One-time

0.0 3.0 3.0 3.0 9.0 $456 $4,221 14 

Prepare and submit Corrective Action Plan. One-time

0.0 2.0 3.0 2.3 7.3 $358 $8,227 14 

Prepare and submit closure plan, including demonstration of financial responsibility.

One-time

0.0 1.0 3.0 2.6 6.6 $286 $1,581 14 

Requirements associated with completion reportsPrepare and submit completion report. One-time

0.0 0.0 1.5 2.5 4.0 $135 $0 14 

Prepare and submit a report of deviation checks and other logs and tests during 

One-time

0.0 0.0 6.0 1.0 7.0 $301 $32,908 14 

Demonstrate mechanical integrity (i.e., casing pressure test and noise/temperature logs to 

One-time

0.0 2.0 3.5 0.0 5.5 $319 $9,300 14 

Submit information on the anticipated maximum pressure and flow rate.

One-time

0.0 0.0 2.0 0.0 2.0 $91 $143 14 

Underground Injection Control Program -- Information Collection Request 
Table A-1B

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators

AB C D 

Hours and Costs per Response Total 

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Non-Labor 

Cost (B)

No. of 

Responses

Submit results of the formation testing program. 

One-time

0.0 1.0 4.0 0.0 5.0 $262 $35,770 14 

Submit actual injection procedure. One-time

0.0 0.0 1.0 0.0 1.0 $46 $143 14 

Demonstrate hydrogeologic compatibility/ compatibility of well materials.

One-time

0.0 2.0 6.0 0.0 8.0 $433 $7,154 14 

Requirements associated with permit renewals/modificationsSubmit updated components of permit application attachments.

Occasional

0.0 8.0 11.0 2.0 21.0 $1,193 $5,008 20 

Prepare and submit request for permit modification.

Occasional

0.0 2.0 6.0 0.0 8.0 $433 $3,577 9 

Monitoring/Testing Requirements (Per Facility)Analyze injected fluids. Per permit

0.0 0.0 38.0 0.0 38.0 $1,734 $2,862 1,131 

Monitor injection pressure, flow rate and volume, and annulus pressure.

Continuous

0.0 0.0 5.7 0.0 5.7 $260 $0 283 

Demonstrate mechanical integrity (i.e., casing pressure test and noise/temperature logs to check for movement along the borehole).

Every 5 years

0.0 1.0 8.0 0.0 9.0 $445 $17,670 57 

Conduct pressure fall-off test. Annual 0.0 8.0 16.0 0.0 24.0 $1,367 $16,592 283 Conduct ambient monitoring. Annual 0.0 0.4 1.5 0.0 1.9 $100 $5,723 283 Reporting Requirements (Per Facility)Report on: physical, chemical, and other characteristics of injected fluids; injection pressure, flow rate, and volume; and monitoring of USDWs.

Quarterly

0.0 0.0 4.0 12.0 16.0 $504 $0 1,131 

Report results of ambient monitoring and pressure fall-off test.

Annual

0.0 2.0 6.0 4.0 12.0 $540 $1,185 283 

Notify Director within 24 hours of: planned physical changes to facility, changes that may result in noncompliance, compliance or noncompliance with a compliance schedule, any indication of possible endangerment of a 

Occasional

0.0 1.0 2.0 3.0 6.0 $251 $0 14 

Underground Injection Control Program -- Information Collection Request 
Table A-1B

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators

AB C D 

Hours and Costs per Response Total 

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Non-Labor 

Cost (B)

No. of 

Responses

Submit periodic updates of financial responsibility for closure that account for inflation. 

Occasional

0.0 1.0 0.0 0.0 1.0 $80 $0 94 

Report results of: any required mechanical integrity tests, other required tests, and well workovers.

Occasional

0.0 1.0 2.0 1.0 4.0 $198 $1,288 3 

Recordkeeping Requirements (Per Facility)Maintain monitoring information, calibration and maintenance records, required reports, application data, and monitoring results.

At least 3 years

0.0 0.0 0.0 4.0 4.0 $107 $0 283 

Closure Requirements (Per Well)Notify the Director before conversion or abandonment of the well or, in the case of area permits, before closure of the project.

One-time

0.0 0.5 0.0 1.0 1.5 $67 $0 1 

TOTAL 

4,114 

Notes:(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-1B (continued)

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous 

ABCD

Hours and Costs per Response Total Hours 

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit NonLabor Cost

Number of 

State 

Responses

Total 

Hour

Initial/Start-upPermit applicationsConsider the permit application, AoR, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and construction procedures as required at 146.14 and issue notice of intent to deny.

One-time

20.0 $828 $0 1 

Consider the permit application, AoR, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and construction procedures as required at 146.14 and prepare draft permit.

One-time

40.0 $1,657 $0 9 

Provide public notice of issuance of a draft permit or intent to deny.

One-time

1.0 $41 $0 10 

Consider public comments. One-time 6.0 $249 $0 10 Issue final permit decision. One-time

2.0 $83 $0 10 

Respond to comments. One-time

7.0 $290 $0 10 

Review notice of completion of construction. One-time 2.0 $83 $0 10 Permit renewals/modificationsReview and respond to requests for permit modifications or re-issuance.

Occasional

30.0 $1,243 $0 14 

Monitoring/TestingReview casing pressure test and logs. Every 5 years 4.0 $166 $0 40 

Underground Injection Control Program -- Information Collection Request 
Table A-1B (continued)

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous 

ABCD

Hours and Costs per Response Total Hours 

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit NonLabor Cost

Number of 

State 

Responses

Total 

Hour

Review pressure fall-off test. Annual 2.0 $83 $0 200 Review monitoring data submitted by operators.

Quarterly

2.0 $83 $0 802 

Other ReportingRespond to periodic notifications by owners and operators.

Occasional

1.0 $41 $0 7 

ClosureReview plugging and abandonment report. One-time 1.0 $41 $0 1 TOTAL 1,124 Notes:(A) For quarterly activities, the number of responses = number of facilities X 4.(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-13 

 Class I facility operators rely on contractors to assist them with most information collection activities, 

including initial/start-up activities (e.g., permit applications, completion reports, and no-migration petitions); 

monitoring and testing (e.g., ambient monitoring, pressure fall-off tests, and MITs); closure-related reporting; 

and other paperwork activities (e.g., permit and no-migration petition modifications). The operator burdens 

presented in Column A of Tables A-1A and A-1B largely reflect the time it takes to oversee and furnish 

information to contractors. The costs associated with contractor labor and other contractor services are 

presented in Column C of Tables A-1A and A-1B. 

 EPA estimates that 70 percent of the new Class I permits issued will be for newly constructed wells at 

existing facilities, and that much of the information these applicants are required to submit is likely to have been 

developed in connection with permitting other wells and, therefore, already exists for the facility. EPA assumes 

the remaining 30 percent of permits will be issued for wells at new facilities, and the burden associated with 

applying for a permit will be greater. Thus, the unit burdens presented in this ICR are a composite of the 

burdens for permitting new wells at both new and existing facilities. 

 EPA assumes that some activities required of Class I permit applicants are customary business practices. 

The burden presented in this ICR is the incremental time and cost of presenting the information in a format 

acceptable to permitting authorities and for using EPA-approved tests. 

 Knowledge of subsurface geology is necessary to site a well and locate a subsurface zone suitable for 

injection. EPA assumes that 50 percent of the geological characterization required of permit applicants 

is customary business practice. Most of the incremental ICR burden is attributable to the requirement to 

submit detailed maps of local geology. 

 Operators would customarily develop and conduct formation testing and stimulation programs for the 

same reasons they would develop geological data. EPA estimates that 50 percent of the required 

program development and testing is customary business practice. 

 Operators would probably develop and retain contingency plans to reduce potential liability should a 

well failure occur and develop closure plans to reduce potential liability when they close their facilities. 

EPA assumes that 25 percent of the burden of developing these plans is customary business practice. 

 Facility engineers would normally prepare construction schematics and operating data during the 

planning and design of an injection facility; EPA estimates that 75 percent of the burden associated with 

compiling this data is customary business practice. 

 As part of their overall industrial process, operators would normally develop injectate composition data 

and test the compatibility of the waste stream with well materials. EPA assumes that 50 percent of the 

time and cost of developing a waste analysis plan and conducting waste compatibility testing is 

customary business practice. 

 During construction, operators would probably conduct deviation checks and other logs to verify that 

drilling is progressing within expected parameters. EPA estimates that 50 percent of the requirement to 

conduct deviation checks and other logs and tests is customary business practice. 

 Operators would routinely observe injection pressure, flow rate, volume, and temperature, and analyze 

the chemical composition of their wastes to verify the proper operation of their wells; EPA assumes that 

nearly all the burden for continuous monitoring and 75 percent of the burden of performing chemical 

analyses of injectate is customary business practice. 
Underground Injection Control Program – Information Collection Request Page A-14 

Class I Hazardous Facilities 

 Operator activities associated with Class I hazardous facilities include: permitting and start-up-related 

reporting; permit renewals and modifications of permits or petitions; monitoring; reporting and recordkeeping; 

and closure-related paperwork. 

 Initial Permitting/Start-up

 EPA estimates that, of the new Class I hazardous waste facility operating permits that are issued each 

year, most will be for new wells at existing facilities. Thus, in some cases, operators will adapt existing 

materials for their permit applications. Note that for permitting activities, the unit burdens are expressed on a 

per-application basis. 

 EPA estimates that the operator burden associated with applying for Class I hazardous waste injection 

permits will be 224 hours per permit. (This unit burden incorporates the above assumptions about customary 

business practices.) Table A-1A contains burden estimates for specific components of the permit application. 

EPA’s calculation of operator burden and contractor labor costs above customary business practices is based on 

the following assumptions: 

 Operators, rather than contractors, will gather the facility description and location information necessary 

to complete the permit application form; 

 AoR studies in support of the application will encompass portions of previous AoR studies at the 

facility; 

 The burden for developing a corrective action plan is based on the assumption that 10 percent of 

operators will be required by the permitting authority to revise their corrective action plans; and 

 The requirement that operators of active hazardous waste facilities gather and submit site investigation 

information [40 CFR 144.31(g)(3)] duplicates Resource Conservation and Recovery Act (RCRA) 

requirements and is not included in this burden estimate. Other activities that operators of active 

hazardous waste facilities must perform (e.g., developing a waste analysis plan) are included in this 

estimate. 

 EPA estimates that the burden on Class I hazardous facility operators associated with preparing and 

submitting completion reports will be 49 hours per facility. The burden to perform specific activities related to 

completion reports is presented in Table A-1A. As with permitting activities, EPA anticipates that much of the 

testing reported in the completion report would normally be performed in the course of business. 

 In addition to submitting permit applications, operators of newly constructed hazardous Class I wells 

will submit no-migration petitions to the EPA Regional Administrator. EPA assumes that no-migration petition 

requirements impose an additional 174 burden hours on each operator. EPA anticipates that operators already 

have compiled much of the extensive data required to support a no-migration petition in the process of 

permitting and preparing petitions for existing wells at their facilities, during the permit application process, or 

as a customary business practice. 

 Permit Renewals and Modifications

 Class I operating permits are valid for up to ten years, after which operators must apply to renew their 

permits. Additionally, from time to time, operators of Class I hazardous facilities may need to modify their 
Underground Injection Control Program – Information Collection Request Page A-15 

permits or their no-migration petitions. Paperwork submittals include: permit renewals, permit modifications, 

and petition modifications. 

 EPA anticipates that the burden associated with renewing permits for a Class I hazardous facility will be 

71.5 hours per renewal. Requirements for permit renewals vary among states and regions, ranging from 

submitting a letter of intent to continue operating the facility to submitting an application that is similar in scope 

to one for a new permit. EPA assumes that, for renewal applications, Class I hazardous facility operators will 

be required to submit facility identification information and those attachments that have changed or been 

updated since their last application, such as the AoR, corrective action plan, closure plan, waste identification 

information, and financial responsibility information. EPA assumes that Class I hazardous facility operators 

will not be required to submit no-migration petitions in support of permit renewal applications. 

 EPA estimates the operator burden for overseeing contractor activities associated with preparing and 

submitting a request for a permit modification is 10 hours per facility, and the burden associated with modifying 

a no-migration petition is 174 hours. 

 Monitoring/Testing

 As indicated above, EPA assumes that operators of Class I hazardous facilities would routinely observe 

injection pressure, flow rate, volume, and temperature in the normal course of business. EPA estimates an 

incremental annual burden of 5.7 hours per facility beyond customary business practice to meet UIC reporting 

requirements. 

 Class I hazardous facility operators must also monitor the chemical composition of their wastes 

according to the waste analysis plans submitted with their permit applications. As with monitoring of injection 

pressure, flow rate, and volume, EPA assumes that operators would perform some chemical monitoring during 

the course of business. EPA estimates the additional annual burden for chemical monitoring is 38 hours per 

facility per quarter for operators to collect samples and send them to commercial laboratories for analysis. In 

addition, EPA assumes that, for various reasons, permitting authorities will require 10 percent of facilities to 

conduct additional monitoring under 40 CFR 146.68(a)(3), and that the total burden will be 7.6 hours per 

facility per quarter. EPA assumes that all monitoring will be conducted quarterly. 

 The burden associated with conducting annual MITs (i.e., conducting a casing pressure test and 

radioactive tracer survey) is estimated to be 9 hours per facility, and the burden associated with conducting fiveyear MITs, which also include temperature, noise, or other logs to check for movement along the borehole, is 

estimated to be 8 hours per facility. 

 Operators must conduct casing inspection logs when their wells are worked over. EPA estimates the 

total annual burden will be 11.8 hours per log. 

 Class I hazardous facility operators must conduct a pressure fall-off test every year; EPA estimates that 

the annual burden associated with this requirement will be 24 hours per facility. EPA estimates that the total 

burden associated with required annual ambient monitoring at Class I hazardous facilities will be 2.3 hours per 

facility. 

 Reporting and Recordkeeping 

 Operators of each Class I hazardous facility will spend 104 hours per facility reporting the results of 

required monitoring and testing each year: this includes 25 hours per report (100 hours annually) for quarterly 

monitoring reports, and 4 hours to report on the results of MITs. In addition, EPA assumes that 5 percent of 

operators will spend 3 to 6 hours annually submitting various occasional reports (e.g., on changes to the facility; 
Underground Injection Control Program – Information Collection Request Page A-16 

planned workovers; noncompliance or anticipated noncompliance; or events triggering alarms or shutdown 

devices). Operators will also spend one hour submitting revised plugging and abandonment cost estimates. 

 EPA estimates the annual recordkeeping burden for Class I hazardous facilities to be 5 hours. 

Operators must maintain monitoring information, calibration and maintenance records, required reports, 

application data, and monitoring results for three years; and keep their most recent plugging and abandonment 

cost estimate for one year. 

 Closure

 EPA estimates that the total annual burden associated with closure of a Class I hazardous well is 42 

hours. This includes 1.5 hours to notify the Regional Administrator prior to closing, 6 hours to perform 

pressure fall-off tests, 20 hours for MITs, and 10 hours for a closure report. EPA assumes that the operator will 

not revise the closure plan or the post-closure care plan. The operator will also spend 4.5 hours on third-party 

notification activities, such as notifying state or local zoning or drilling authorities and the Regional 

Administrator following closure. 

Class I Nonhazardous Facilities 

 Paperwork requirements for operators of Class I nonhazardous facilities include permitting and start-uprelated reporting, permit renewals and modifications, monitoring and testing, reporting and recordkeeping, and 

closure-related paperwork activities. 

 Initial Permitting/Start-up

 As is the case for Class I hazardous facilities, EPA estimates that the majority of the new nonhazardous 

waste injection permits issued each year will be for new wells at existing facilities. Unit burdens are reported 

on a per-application basis. 

 Requirements associated with permit applications add 110.6 hours to the customary business activities 

of Class I nonhazardous facility operators. Column A of Table A-1B presents EPA’s estimates of burdens for 

specific components of a permit application. Class I nonhazardous waste injection well permit applicants must 

submit much of the same information as operators of hazardous facilities. EPA assumes that the burden on 

nonhazardous facilities is the same as that for Class I hazardous waste facilities, with the exception of the 

following: 

 Class I nonhazardous facility operators will study a smaller AoR. Consequently, the burden for the AoR 

study and for developing a corrective action plan for wells in the AoR will be lower for these operators. 

 Nonhazardous facility operators are not required to develop waste analysis plans or plans to reduce the 

quantity or toxicity of their injectate; nor are they required to gather and submit hazardous waste release 

information. 

 EPA estimates that the unit burden on Class I nonhazardous facility operators for preparing and 

submitting completion reports is 32.5 hours. This unit burden varies from that for Class I hazardous facilities, 

as Class I nonhazardous facility operators are not required to submit information on the calculated AoR. 

Burden estimates for specific activities associated with completion of new wells are presented in Column A of 

Table A-1B. 
Underground Injection Control Program – Information Collection Request Page A-17 

 Permit Renewals/Modifications

 As with hazardous facility operators, EPA assumes that applicants for nonhazardous injection permit 

renewals will submit only those attachments to the application form that have changed since the original permit 

application. Preparing and submitting the updated materials needed for a permit renewal application will take 

an estimated 21 hours. EPA estimates the operator burden associated with contractor oversight to gather the 

necessary information for a permit modification to be 8 hours. 

 Monitoring/Testing

 EPA assumes that operator staff will observe and record injection pressure, flow rate, volume, and 

temperature and sample their injectate periodically as normal business activities. However, to comply with UIC 

requirements, operators spend more time on these activities than they otherwise would. Class I nonhazardous 

facility operators will spend 38 hours to monitor their injectate; 5.7 hours to monitor injection pressure, flow 

rate, and volume; 1.9 hours to conduct ambient monitoring; and 24 hours to conduct an annual pressure fall-off 

test. In addition, approximately 20 percent of operators will spend 9 hours to demonstrate mechanical integrity 

(i.e., five-year MIT). 

 Reporting and Recordkeeping 

 Operators will spend 16 hours per facility reporting quarterly on the chemical and physical 

characteristics of injectate, flow rate, and volume. Class I nonhazardous facility operators will spend 12 hours 

per facility reporting on the results of ambient monitoring and the pressure fall-off test. 

 EPA assumes that Class I nonhazardous facility operators will spend one hour each year to update and 

submit revised plugging and abandonment cost estimates. EPA also assumes that operators will spend 4 to 6 

hours submitting additional reports (e.g., of changes to the facility, planned workovers, noncompliance or 

anticipated noncompliance, or events triggering an alarm or shutdown). 

 EPA estimates the annual recordkeeping burden on Class I nonhazardous facilities to maintain 

monitoring information, calibration and maintenance records, required reports, application data, and monitoring 

results for three years will be 4 hours per facility. 

 Closure

 EPA estimates the annual burden on operators of Class I nonhazardous facilities associated with closure 

is 1.5 hours, for notifying the Director. 

Burden on Primacy Agencies Associated with Class I Wells 

 State primacy agencies’ burden associated with implementing Class I programs arises from program 

oversight and reviewing and responding to permit applications, completion reports, monitoring and testing data, 

and closure reports submitted by operators within their states. State burden associated with oversight of Class I 

programs is presented in Column A of Tables A-1A and A-1B. 

 EPA estimates that states will spend from 20 to 58 hours per permit application reviewing applications 

for hazardous or nonhazardous Class I wells (depending on whether the permit is issued or denied), and 30 

hours reviewing requests for permit modifications or renewals. EPA regional offices review all no-migration 

petitions and petition modification requests submitted by operators of Class I hazardous waste injection 

facilities; however, state primacy agencies assist the regions with this review. States spend 28 hours per nomigration petition application and 10 hours per petition modification request on this assistance. 
Underground Injection Control Program – Information Collection Request Page A-18 

 State primacy agencies spend from 1 to 4 hours per report reviewing monitoring and MIT data or 

occasional reports submitted by operators (details are presented in Tables A-1A and A-1B). States spend one 

hour reviewing plugging and abandonment reports submitted by operators of Class I nonhazardous waste 

facilities, and 26 hours reviewing reports and testing results associated with closure of hazardous waste 

facilities. 

Burden Associated with Class II Wells 

 EPA’s estimates of the annual paperwork burden on operators for permitting, monitoring and testing, 

reporting and recordkeeping, and closing wells, and state burden for administering Class II programs, are 

presented in Table A-2. 

Class II Operators 

 Initial Permitting/Start-up

 EPA anticipates that 28 percent of Class II permit applications will be for area permits and 73 percent 

will be for individual permits. On average, each area permit application will cover 3.1 wells. EPA or state 

primacy agencies will deny applications that do not meet construction standards, and others will be withdrawn 

by owners. 

 The average burden for preparing permit application forms and the supporting documentation is 

approximately 67 hours per application. The time that a particular operator will spend on a permit application 

will likely vary, depending on the specific state submission requirements, the operator’s level of experience, 

whether the application is for an individual or an area permit, the use of contractors, and other factors. The 

following paragraphs summarize the burdens for various components of a Class II permit application. 

 EPA estimates that operators will spend 2.5 hours to read the application directions and fill out the 

permit application form. With respect to the supporting documentation, EPA assumes that operators would 

normally prepare a well schematic and some geological, hydrogeological, and operating data in the course of 

business, and/or utilize existing data for the project. For area permits, the operator generally submits supporting 

data for a representative well. Table A-2 provides estimates of the time required, beyond what is considered 

customary business practice, to prepare the attachments to a Class II permit application. EPA estimates that 

permit applicants will spend an average of: 

 9.5 hours to prepare geological data on injection and confining zones; 

 6 hours to prepare plugging and abandonment plans; 

 2.5 hours to identify and determine depth to the bottom of USDWs; 

 3 hours to prepare schematics of the wells; 

 2 hours to prepare proposed operating data; and 

 20 hours to prepare financial responsibility information. 
Table A-2

Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

ABCD

Hours and Costs per Response T

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No. of Responses 

Initial/Start-up Requirements Requirements associated with permit applications (Per Permit Application)Read permit application directions. One-time 0.0 0.0 0.5 0.5 1.0 $36 $0 6,038 Gather and submit: a description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, topographic maps, description of the business.

One-time

0.1 0.0 1.0 0.4 1.5 $64 $0 6,038 

For DI programs, gather and submit a list of all land owners within one quarter mile of the facility boundary. 

One-time

0.2 0.0 0.0 1.0 1.2 $42 $180 294 

Prepare and submit plugging and abandonment plan.

One-time

0.0 0.6 4.8 0.6 6.0 $283 $0 6,038 

Show evidence of financial responsibility for closure.

One-time

0.0 5.0 5.0 10.0 20.0 $894 $0 6,038 

Prepare and submit proposed Corrective Action Plan.

One-time

0.0 0.3 2.9 0.2 3.4 $162 $0 604 

Prepare and submit revised Corrective Action Plan.

One-time

0.0 1.0 9.6 0.7 11.3 $536 $0 121 

Prepare and submit Area of Review map. (State/DI Program performs study)

One-time

0.0 0.0 1.0 0.0 1.0 $46 $36 1,342 

Prepare and submit Area of Review map and study.

One-time

0.0 0.1 2.9 2.0 5.0 $194 $195 1,139 

Prepare and submit proposed operating data. One-time

0.0 0.1 1.8 0.1 2.0 $93 $0 6,038 

Prepare and submit geological data on the injection and confining zone.

One-time

0.0 0.5 8.0 1.0 9.5 $432 $0 6,038 

Prepare and submit name and depth to bottom of USDWs.

One-time

0.0 0.1 2.3 0.1 2.5 $116 $215 6,038 

Prepare and submit schematic of the well. One-time

0.0 0.0 2.8 0.2 3.0 $133 $0 6,038 

Underground Injection Control Program -- Information Collection Request 
Table A-2

Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

ABCD

Hours and Costs per Response T

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No. of Responses 

Requirements associated with completion reports (Per Well)Prepare and submit completion report. One-time

0.0 0.0 1.5 2.5 4.0 $135 $0 1,725 

Perform and report on appropriate logs and other tests during construction.

One-time

0.0 0.2 1.9 0.2 2.4 $113 $4,292 259 

Demonstrate mechanical integrity. One-time

0.0 0.0 7.0 0.0 7.0 $319 $193 1,725 

Requirements associated with permit reviews/modifications (Per Permit/Per Operator)Respond to issues raised during permit review.

Every 5 years

0.0 0.5 2.0 0.5 3.0 $144 $0 1,509 

Prepare and submit request for permit modification.

Occasional

0.0 0.4 2.8 0.8 4.0 $181 $0 2,263 

Monitoring/Testing Requirements (Per Operator)Monitor the nature of injected fluids. As necessary 

to obtain representative 0.0 0.0 2.0 0.0 2.0 $91 $43 60,340 

Record injection pressure, flow rate, and cumulative volume.

At least every 30 days. 0.0 0.0 0.6 0.3 0.8 $33 $0 181,021 

Demonstrate mechanical integrity. Every 5 years

0.0 0.0 3.0 0.0 3.0 $137 $1,932 40,730 

Reporting Requirements (Per Operator)In DI programs, gather and submit groundwater monitoring data, analyses of injected fluids, a description of geologic strata, and other items as requested.

Occasional

0.0 3.0 22.0 5.0 30.0 $1,377 $0 3 

In DI programs, notify Regional Administrator 30 days prior to MIT.

Every 5 years

0.0 0.0 0.5 0.5 1.0 $36 $0 78 

Notify Director of (1) any planned physical changes to facility; (2) changes that may result in noncompliance, (3) permit transfers, (4) compliance or noncompliance with compliance schedules, (5) possible endangerment to a USDW.

Occasional

0.0 1.0 1.5 2.5 5.0 $215 $0 905 

Report monitoring data, including monthly records of injected fluids, any changes in characteristics or sources of injected fluids.

Annual

0.0 0.0 3.3 1.7 5.0 $197 $0 15,085 

Report MIT results. Annual 0.0 0.0 1.0 0.0 1.0 $46 $0 15,085 

Underground Injection Control Program -- Information Collection Request 
Table A-2

Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

ABCD

Hours and Costs per Response T

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No. of Responses 

Recordkeeping Requirements (Per Operator)Retain records of permitting data, nature and composition of injected fluids, and all monitoring results.

At least 3 years

0.0 0.0 1.0 3.0 4.0 $126 $0 15,085 

Closure Requirements (Per Operator)In DI programs, notify director of revisions to plugging and abandonment plan.

One-time

0.0 0.5 2.5 1.0 4.0 $181 $0 1 

Notify the Director before conversion or abandonment of the well, or in the case of area permits, before closure of the project.

One-time

0.0 1.0 0.0 2.0 3.0 $133 $0 1,044 

In DI programs, submit a plugging and abandonment report within 60 days after plugging a well.

One-time

0.0 0.0 4.5 1.5 6.0 $246 $258 51 

Other Requirements (Per Operator)In DI programs, submit revised demonstration of financial responsibility.

Occasional

0.0 0.5 0.5 1.0 2.0 $89 $0 73 

TOTALS 388,781 

Note: Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-2 (continued)

Annual Paperwork Burden and Costs Associated with Class II Wells: States

ABCD E 

Hours and Costs per Response Total Hours and Cos

Description of Requirement Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Total Hours/Y

Initial/Start-upPermit applications (Per Permit Application)Review permit application and supporting documentation and prepare draft permit.

One-time

6.0 $249 $0 5,743 34,

Consider public comments. One-time 2.0 $83 $0 5,743 11,Issue final permit decision. One-time 2.0 $83 $0 5,743 11,Respond to comments. One-time 4.0 $166 $0 5,743 22,Review operator's AoR map and study. One-time 5.0 $207 $0 1,083 5,Review operator's AoR map and perform AoR study.

One-time

2.5 $104 $0 1,342 3,

Review completion report. One-time 2.0 $83 $0 1,641 3,Permit reviews/modifications (Per Operator)Review each permit to determine whether it should be modified, revoked and reissued, or terminated.

Every 5 years

1.0 $41 $0 1,435 1,

Review request for permit modification or reissuance. Occasional 4.0 $166 $0 2,153 8,

Monitoring/Testing (Per Operator)Review mechanical integrity test data submitted by operators.

Every 5 years

0.5 $21 $0 38,746 19,

Review monitoring data submitted by operators.

Annual

0.3 $10 $0 14,351 3,

RecordkeepingMaintain administrative record in DI programs.

One-time

1.0 $41 $0 0 

Underground Injection Control Program - Information Collection Request 
Table A-2 (continued)

Annual Paperwork Burden and Costs Associated with Class II Wells: States

ABCD E 

Hours and Costs per Response Total Hours and Cos

Description of Requirement Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Total Hours/Y

Other Reporting (Per Operator)Respond to periodic notifications by owners and operators.

Occasional

2.0 $83 $0 861 1,

Closure (Per Operator)For DI programs, review plugging and abandonment report.

One-time

1.0 $41 $0 0 

TOTAL 84,625 127,Note: Numbers may not add due to rounding

Underground Injection Control Program - Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-24 

 Based on previous studies of state AoR practices and requirements, EPA projects that state primacy 

agencies and EPA Regions will determine that a complete AoR is not necessary for approximately 60 percent of 

Class II permit applicants.1 A complete AoR study may not be performed because the: 

 AoR is entirely overlapped by the AoRs of wells previously studied. 

 State primacy agency has cross-referenced AoR studies, ensuring AoR coverage. 

 Operator has been granted a state variance based on factors relating to geologic setting and/or well 

conditions. 

 Well is located in a unitized project, and many of the elements of AoR studies were previously 

performed during unitization. 

 Previous EPA studies also have shown that many state primacy agencies perform all or most of the tasks 

involved in the AoR study. In these cases, the operator typically submits only a map of the AoR and a list of 

wells in the AoR. EPA projects that approximately 19 percent of applicants will submit an AoR map and an 

AoR study as part of the permit application. Each AoR map and study will require an average of 5 hours of 

operator time.2

 Another 22 percent of applicants will submit an AoR map and a listing of the wells in the AoR, 

and the state primacy agency will perform most or all of the tasks involved in the AoR study. The operator time 

needed to prepare the map and listing of wells is about one hour. 

 Based on the historical incidence of corrective action, EPA assumes that operators will incur different 

burdens to prepare a corrective action plan. EPA estimates that 90 percent of permit applicants will submit brief 

corrective action plans demonstrating that corrective action is not necessary to address potential conduits to 

USDWs in the AoR; these plans will require one hour to prepare. The remaining 10 percent of applicants will 

submit more complex corrective action plans to address specific problems identified by the AoR study, which 

will take approximately 25 hours to prepare. Thus, the weighted average time to prepare a corrective action 

plan is 3.4 hours. EPA regional or state primacy staff will require 20 percent of applicants to revise their 

complex corrective action plans. Each revised plan will take about 11.3 hours to prepare. 

 Unless exempted by the Director, operators in DI programs are required to submit a list of landowners 

within 1⁄4 mile of the facility boundary. EPA estimates that these applicants will each take 1.2 hours to research 

property ownership records and prepare the list. This unit burden assumes that operators will supply about 30 

percent of the effort, and the remaining 70 percent will be performed by contractors. 

 Prior to obtaining approval to begin injection, operators must submit completion reports for each new 

Class II well. With the completion report, operators must submit results of MITs and any well logs and tests 

required by the Director. Operators will take approximately 2.4 hours to perform and report on logs and tests 

and 4 hours per well to fill out the completion form. The MIT will require an additional 7 hours of operator 

time, given current MIT practices for various completion types. 

 Most operators will submit logs for offset wells in their projects. EPA projects that Directors will 

require some permit applicants to perform and report on new well logs and tests, such as cement bond, 

temperature, or density logs. Directors are more likely to require additional logs and tests for II-D (disposal) 

 

1

 The Cadmus Group, Inc., Technical Issues Paper for Developing Area of Review Guidance (Draft), Contract No. 68-C4-0011, Work 

Assignment No. 1-38 (September 8, 1995). 

2

 EPA estimates that some operators will utilize contract AoR services. The unit burden for operators assumes that operators will 

perform about 67 percent of the AoR burden themselves and contract out for the remaining 33 percent. 
Underground Injection Control Program – Information Collection Request Page A-25 

wells than for II-R (recovery) wells. EPA assumes that operators will perform additional logs and tests for 50 

percent of new II-D wells and 5 percent of new II-R wells. Each of the logs and tests will take approximately 

2.4 hours of operator time, primarily to supervise contractors. 

 Permit Reviews/Modifications

 Class II permits are valid “up to the operating life of the facility” [40 CFR 144.36]. While the 

regulations do not require permit renewals, most permits are reviewed every five years. These reviews may be 

formal compliance reviews or informal reviews, usually conducted in conjunction with reviews of MIT results. 

Operators may be required to respond to any issues raised during the permit review. For purposes of calculating 

operator burden, EPA assumes that each operator will take 3 hours to respond to issues raised during the review. 

 Operators occasionally submit requests for permit modifications in response to changes in well 

ownership or injection practices, to add wells to existing area permits, and for other reasons. EPA expects that 

preparing each request will take an average of 4 hours. 

 Monitoring/Testing

 For purposes of estimating the number of respondents for monitoring and testing, EPA assumes that the 

typical Class II operator has approximately 10 wells. An operator with wells in multiple states is treated as a 

separate operator in each state, since the operator would have to submit separate reports to each state primacy 

agency or EPA regional office. 

 In general, all operators located in DI programs and operators of commercial II-D wells in primacy 

states are required to submit annual injectate analyses. EPA estimates that approximately 40 percent of Class II 

operators submit annual injectate analyses each year. EPA assumes that operators submit samples for 

approximately 20 percent of their wells. Each operator takes 2 hours (1 hour per well) per year to sample and 

analyze its injectate. This includes the time it takes for operators to analyze their injectate or, in some cases, 

send it to a commercial laboratory for analysis. 

 Most operators are required to observe injection pressure, flow rate, and cumulative volume weekly for 

II-D wells and monthly for II-R wells. EPA anticipates that operators, especially operators of II-R wells, 

perform periodic observations of pressure, flow rate, and cumulative volume as a customary business practice. 

Thus, the incremental time needed to perform these observations is about 0.84 hours per operator (0.08 hours, 

or 5 minutes, per well) per month. This represents the time required to record the data on a field report. 

 Based on information reported on the UIC reporting forms, EPA assumes that 27 percent of operators 

will perform MITs on their wells each year. Each operator will spend 3.0 hours (0.3 hours per well) performing 

MITs. The unit burden assumes that contractors perform many of the tasks involved in an MIT. 

 Reporting and Recordkeeping

 Each year, Class II operators spend about 5 hours to prepare annual monitoring reports. These reports 

include summaries of monthly or weekly observations of flow, pressure, and cumulative volume. In addition, 

27 percent of operators will spend 1 hour per operator to prepare reports on MITs performed. 

 From time to time, operators submit other reports or notify UIC staff of various events. These include 

notifications of planned changes to the injection facility, permit transfers, progress in achieving compliance 

milestones, and noncompliance or malfunctions which may endanger a USDW. EPA estimates that 

approximately 6 percent of operators submit one of these occasional reports each year. Operators will spend an 

average of 5 hours to prepare each report. 
Underground Injection Control Program – Information Collection Request Page A-26 

 Operators of rule-authorized wells in DI states may be required to gather and submit groundwater 

monitoring data, analyses of injected fluids, a description of geologic strata, and other items as requested. EPA 

projects that each request will take 30 hours to prepare. In addition, operators of rule-authorized wells will 

spend one hour per operator to notify the Region prior to performing MITs. 

 Each operator will spend about 4 hours annually to maintain records on permitting, monitoring, and 

testing. 

 Closure

 Each operator that closes a well will spend about 3.0 hours (0.3 hours per well) to notify UIC officials 

prior to abandoning the wells. 

 In addition, EPA assumes that operators in DI programs who elect to plug their wells in a manner 

different from the one specified in their plugging and abandonment plans will spend 4 hours to prepare revised 

plugging and abandonment plans. In addition, operators who plug wells in DI programs will spend 6 hours to 

prepare and submit plugging and abandonment reports. 

 Other Activities

 DI programs may require some operators of wells with lifetime permits to submit revised financial 

responsibility demonstrations. EPA estimates that 10 percent of operators in DI programs will each take 2 

hours to prepare and submit revised financial data. 

Burden on Primacy Agencies Associated with Class II Wells 

 Class II primacy agencies review and respond to permit applications and permit reviews/modifications, 

as well as monitoring and testing data submitted by operators within their states. State burden associated with 

each activity involved in the oversight of Class II programs is presented in Column A of Table A-2. 

 EPA estimates that states will spend 23.5 hours per application reviewing Class II injection well permit 

applications. Primacy agency staff spend one hour to determine whether to reissue, modify, or revoke each 

permit during the five-year review process. Primacy agencies spend four hours reviewing each request for a 

permit modification or renewal. 

 State primacy agencies spend from 0.3 to 0.5 hours per report reviewing monitoring and MIT data or 

occasional reports submitted by Class II operators (see details in Table A-2). 

Burden Associated with Class III Wells 

 Table A-3 presents EPA’s estimate of the annual paperwork burden on operators for permitting, 

monitoring and testing, reporting and recordkeeping, and closing their facilities, as well as state burden for 

administering Class III programs. 

Class III Operators 

 Initial Permitting/Start-up

 A Class III operator will spend an average of 132 hours to prepare a new permit application form and 

the required attachments. Reading the directions and filling out the application form account for 11 hours of the 
Underground Injection Control Program – Information Collection Request Page A-27 

total. Table A-3 provides estimates of the operator time, incremental to that considered customary business 

practice, required to prepare each component of the permit application. EPA estimates that permit applicants 

will spend an average of: 

 32 hours to prepare AoR maps and studies; 

 22 hours to prepare maps and cross sections of USDWs within the AoR, and of local and regional 

geology; 

 16 hours to prepare monitoring plans; 

 14 hours to prepare proposed corrective action plans; 

 9 hours to prepare proposed operating data, formation testing and stimulation programs, and injection 

procedures; 

 8 hours to prepare plugging and abandonment plans; 

 5 hours to prepare schematics of the wells; and 

 3.5 hours to demonstrate financial responsibility. 

 In addition, EPA estimates that, when requested by the Director, revised corrective action plans will take 

10 hours each. Applicants in DI programs will spend 1.2 hours each to gather a list of landowners adjacent to 

the facility. 

 

 Operators completing wells must perform a two-part MIT and submit a completion form. The burden 

associated with preparing completion reports is difficult to determine. Operators of Class III facilities, 

especially uranium mining facilities, typically develop their projects in multiple phases under the same area 

permit. Based on conversations with operators and states, EPA estimates that operators of Class III wells will 

spend an average of 4 hours to prepare a completion report, 10 hours to demonstrate mechanical integrity, and 

2.4 hours to perform and submit the results of required logs and tests during construction. 
Table A-3

Annual Paperwork Burden and Costs Associated with Class III Wells: Operato

ABCD

Hours and Costs per Response 

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No of Respons

Initial/Start-up RequirementsRequirements associated with permit applications (Per Permit Application)Read permit application directions. One-time 0.0 0.0 0.5 0.5 1.0 $36 $0 Gather and submit the following information: (1) a description of activities requiring a permit, (2) facility name and address, (3) SIC codes, (4) ownership and facility status, (5) facility location, (6) listing of relevant permits or construction appro

One-time

0.5 2.0 4.7 2.8 10.0 $486 $0 

For DI programs, gather and submit a list of all land owners within one quarter mile of the facility boundary. 

One-time

0.2 0.0 0.0 1.0 1.2 $42 $180 

Prepare and submit plugging and abandonment plan. One-time 0.0 0.0 6.4 1.6 8.0 $335 $0 Show evidence of financial responsibility for closure. One-time 0.0 0.5 1.0 2.0 3.5 $139 $0 Prepare and submit proposed Corrective Action Plan. One-time 0.0 2.0 10.0 2.0 14.0 $669 $0 Prepare and submit revised Corrective Action Plan. One-time 0.0 1.0 8.0 1.0 10.0 $471 $0 Prepare and submit AoR map and study. One-time 0.0 3.2 25.5 3.4 32.0 $1,506 $1,066 Prepare and submit maps and cross-sections of USDWs within AoR, local geology, and regional geology.

One-time

0.0 0.0 18.0 4.0 22.0 $929 $215 

Prepare and submit proposed operating data, formation testing program, stimulation program, and injection procedure.

One-time

0.0 2.0 6.0 1.0 9.0 $460 $0 

Prepare and submit schematic of the well. One-time 0.0 0.0 4.2 0.8 5.0 $213 $0 Prepare and submit monitoring plan. One-time 0.0 0.0 12.0 4.0 16.0 $655 $0 Requirements associated with completion reports (Per Well)Prepare and submit completion form and supporting documentation (7520-9).

One-time

0.0 0.0 1.5 2.5 4.0 $135 $0 

Prepare and submit appropriate logs and tests during construction.

One-time

0.0 0.2 1.9 0.2 2.4 $113 $4,911 

Demonstrate mechanical integrity. One-time 0.0 1.0 8.0 1.0 10.0 $471 $4,292 Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)Respond to issues raised during permit review. Every 5 years 0.0 3.0 1.0 0.0 4.0 $285 $0 Prepare and submit request for permit modification. Occasional 0.0 2.0 22.0 4.0 28.0 $1,270 $0 Monitoring/Testing Requirements (Per Facility)Monitor the nature of injected fluids. As necessary 

to obtain representative data 0.0 0.0 6.0 2.0 8.0 $327 $0 

Monitor injection pressure and flow rate or volume of injected fluids, or meter and record injected and produced fluid volumes.

Semi-monthly/ Continuous

0.0 0.0 3.3 1.3 4.6 $187 $0 3,6

Demonstrate mechanical integrity. Every 5 years 0.0 16.1 128.7 16.1 160.9 $7,585 $69,051 Monitor the fluid level in the injection zone where appropriate and monitor parameters chosen to measure water quality in the monitoring wells.

Semi-monthly/ monthly

0.0 0.0 27.5 3.0 30.5 $1,335 $0 2

Underground Injection Control Program -- Information Collection Request 
Table A-3

Annual Paperwork Burden and Costs Associated with Class III Wells: Operato

ABCD

Hours and Costs per Response 

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No of Respons

Reporting Requirements (Per Facility)Notify Director of (1) planned physical changes to the facility, (2) anticipated noncompliance, (3) permit transfers, (4) progress in meeting compliance schedule in permit, (5) possible endangerment to a USDW.

Occasional

0.0 1.0 3.0 2.0 6.0 $270 $0 

Report to the Director on required monitoring, mechanical integrity tests, and other required tests.

Quarterly

0.0 1.0 10.0 19.0 30.0 $1,045 $0 5

Recordkeeping Requirements (Per Facility)Retain records of permitting data, calibration and maintenance data, and monitoring results.

At least 3 years 0.0 0.0 0.4 3.0 3.4 $99 $0 1

Closure Requirements (Per Facility)Notify the Director before conversion or abandonment of the well or in the case of area permits before closure of the project.

One-time

0.0 1.0 0.5 0.5 2.0 $116 $0 

In DI programs, submit a plugging and abandonment report within 60 days after plugging a well or at the time of the next quarterly report.

One-time

0.0 0.0 0.8 0.3 1.0 $41 $0 

Other Requirements (Per Facility)In DI programs, submit revised demonstration of financial responsibility.

Occasional

0.0 0.5 0.5 1.0 2.0 $89 $0 

TOTALS 5,187 Note: Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-3 (continued)

Annual Paperwork Burden and Costs Associated with Class III Wells: States

ABCDE 

Hours and Costs per Response Total Hours and C

Program Oversight Activities Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Total Hours/Year 

Initial/Start-upPermit applications (Per Permit Application)Consider the permit application, area of review, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and 

t ti d d i ti f

One-time

20.0 $828 $0 13 260 

Consider the permit application, area of review, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and 

t ti d d d ft

One-time

40.0 $1,657 $0 18 720 

Provide public notice of issuance of a draft permit or intent to deny.

One-time

2.0 $83 $0 48 96 

Consider public comments. One-time 8.0 $331 $0 48 384 Issue final permit decision. One-time 10.0 $414 $0 48 480 Respond to comments. One-time

15.0 $621 $0 48 720 

Review completion report. One-time

2.0 $83 $0 21 42 

Underground Injection Control Program -- Information Collection Request 
Table A-3 (continued)

Annual Paperwork Burden and Costs Associated with Class III Wells: States

ABCDE 

Hours and Costs per Response Total Hours and C

Program Oversight Activities Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Total Hours/Year 

Permit reviews/modifications (Per Facility)Review each permit to determine whether it should be modified, revoked and reissued, or terminated.

Every 5 years

4.0 $166 $0 14 55 

Review request for permit modification or reissuance. Occasional 20.0 $828 $0 23 460 

Monitoring/Testing (Per Facility)Review mechanical integrity test data submitted by operators.

Every 5 years

0.5 $21 $0 14 7 

Review monitoring data submitted by operators. Quarterly

0.25 $10 $0 273 68 

Other Reporting (Per Facility)Respond to periodic notifications by owners and operators.

Occasional

4.0 $166 $0 18 72 

Recordkeeping (Per Facility)Maintain administrative record (DI). One-time

4.0 $166 $0 0 0 

Closure (Per Facility)Review plugging and abandonment report (DI only).

One-time

4.0 $166 $0 0 0 

TOTAL 585 3,363 

Note: Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-32 

 Permit Renewals, Reviews, and Modifications

 EPA estimates that 20 percent of operators each year will have a formal or informal review of their 

permits. Each operator will take 4 hours to respond to any issues raised during the review. In addition, Class 

III operators will take an average of 28 hours to prepare requests for permit modifications. 

 Monitoring/Testing

 EPA anticipates that operators of salt solution mining facilities will submit annual analyses of their 

injectate. On average, each operator will take 8 hours per year to sample and analyze its injectate in-house. 

 Operators of Class III facilities will monitor injection pressure, flow rate, or volume of injected fluids 

semi-monthly, or meter injected and produced fluid volumes continuously. EPA expects that operators perform 

this activity periodically as a customary business practice to ensure the efficient operation of their facilities, and 

that the incremental collection burden is approximately 4.6 hours per operator over a two-week period. This 

represents the time needed to fill out field reports. 

 EPA estimates that operators of salt solution mining facilities will perform two-part MITs on all of their 

wells each year.3 The burden is estimated to be 161 hours per operator. 

 All uranium operators monitor water quality at selected monitoring wells completed in the injection 

zone and overlying freshwater aquifers. Some active facilities monitor semi-monthly, while other facilities that 

are performing aquifer restoration monitor monthly. EPA estimates that the typical uranium facility has about 

110 monitoring wells. As with pressure, flow, and volume monitoring, operators will perform about two-thirds 

of this monitoring as a customary business practice to identify potential excursions from the injection zone. 

EPA assumes that UIC requirements increase the monitoring burden to these operators by about 30.5 hours per 

monitoring period. 

 

 Reporting and Recordkeeping

 Operators of Class III facilities will incur a burden of 30 hours per facility per quarter for quarterly 

reporting on monitoring and any MITs performed. About 10 percent of operators will spend 6 hours per year on 

occasional reporting activities. EPA estimates that each Class III operator spends approximately 3.4 hours on 

recordkeeping annually. 

 Closure

 EPA estimates that Class III operators who close their projects will take 2 hours to prepare written 

notifications to the Director. Operators in DI programs will spend one hour to submit a plugging and 

abandonment report. 

Burden on Primacy Agencies Associated with Class III Wells 

 For the Class III Program, primacy agency staff review and respond to permit applications, permit 

reviews/modifications, and monitoring and testing data submitted by operators. State burden associated with 

each activity involved in the oversight of Class III programs is presented in Column A of Table A-3. 

 

3

 Some operators may be allowed to submit cementing records in lieu of performing temperature or noise logs. 
Underground Injection Control Program – Information Collection Request Page A-33 

 Depending on whether the permit is issued or denied, EPA estimates that states will spend between 20 

and 77 hours reviewing each application for a permit to inject waste into a Class III well. Primacy agency staff 

members spend 4 hours determining whether to reissue, modify, or revoke each permit during the five-year 

review process, and 20 hours reviewing each request for a permit modification or re-issuance. Class III primacy 

agencies spend from 0.25 to 4 hours per report reviewing monitoring and MIT data or occasional reports 

submitted by operators (see details in Table A-3). 

Burden Associated with Class IV and Endangering Class V Wells 

 Paperwork burden on operators of Class IV/endangering Class V wells and on states for administering 

these wells is presented Table A-4. 

Class IV and Endangering Class V Well Operators 

 Class IV wells and Class V wells that are found to be endangering USDWs are banned from injection, 

and owners of these wells are required to close them and submit plugging and abandonment reports to states or 

DI programs. The exception to the ban is for those Class IV wells used to inject contaminated ground water 

that has been treated and re-injected into the same formation from which it was drawn. These wells are 

authorized by rule for the life of the well if such subsurface emplacement of fluid is approved by EPA or a State 

pursuant to the provisions for the cleanup of releases under the Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980 or RCRA. EPA estimates that the operator burden associated with this 

one-time requirement to submit a plugging and abandonment report will be 10 hours per well (See Table A-4). 

Because these wells are banned, there are no permitting or monitoring requirements. 

Burden on Primacy Agencies Associated with Class IV and Endangering Class V Wells 

 State burden associated with Class IV and endangering Class V wells involves review by primacy 

agency staff of closure plans submitted by operators. EPA estimates the state burden to be one hour per review. 

Burden Associated with Class V Wells 

 EPA’s estimate of the annual paperwork burden on operators and states associated with Class V wells is 

presented in Column A of Table A-5. 

Class V Operators 

 Activities for Class V well operators include submitting inventory information and compliance with the 

Class V Rule by owners of motor vehicle waste disposal wells (MVWDWs) and large-capacity cesspools. 

 Inventory Activities 

 Recent efforts by the Regions and state primacy agencies to address the potential threats to USDWs 

posed by Class V wells will likely increase compliance with the inventory requirement. Each Class V well 

operator will take 0.5 hours to prepare and submit inventory information to the appropriate Regional or state 

primacy agency.
Table A-4 

Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: Operators

AB C DE

Total Hours a

Description of Requirement Questions Frequency Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit Nonlabor Cost No. of Responses Tota

Hours/Y

Closure Requirements (Per Well)Submit a plugging and abandonment report within 60 days after plugging a well.

One-time

0 7.5 2.5 10.0 $235 $0 990 9

TOTAL 990 9,Note:Numbers may not add due to rounding.

Underground Injection Control Program - Information Collection Request 
Table A-4 (continued)

Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: 

ABCDE

Hours and Costs per Response Total Hours 

Description of Requirement Frequency

Unit Burden 

(A)

Unit Labor 

Cost

Unit 

Nonlabor 

Cost

Number of 

Responses

Tot

Hours/

ClosureReview closure plan.

One-time 1.0 $41 $0 758 

TOTAL 758 Note:Numbers may not add due to rounding.

Underground Injection Control Program - Information Collection Request 
Table A-5

Annual Paperwork Burden and Costs Associated with Class V Wells: Operators

AB C D 

Hours and Costs per Response

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit Non-labor 

Cost (A)

No. of 

Responses

Inventory RequirementsIn DI programs, submit inventory information prior to commencing injection.

One-time

0.0 0.0 0.0 0.5 0.5 $9 $0 33,86

Class V Rule Requirements for Owners/Operators of Large-Capacity CesspoolsRead regulations. One-time 0.0 0.0 3.0 0.0 3.0 $76 $0 10Prepare and submit pre-closure notification (Form 7520-17).

One-time

0.0 0.5 0.8 0.3 1.5 $53 $0 10

Class V Rule - Startup Requirements for Owners / Operators of Motor Vehicle Waste Disposal Wells Contact state or local agency to determine requirements.

One-time

0.0 0.0 1.0 0.0 1.0 $25 $0 50

Read regulations. One-time 0.0 0.0 3.0 0.0 3.0 $76 $0 50For wells that will close, sample injectate and maintain record.

One-time

0.0 0.0 1.0 0.5 1.5 $34 $661 48

Prepare and submit pre-closure notification (Form 7520-17).

One-time

0.0 0.5 0.8 0.3 1.5 $53 $0 48

For wells obtaining a waiver, conduct initial sampling.One-time

0.0 0.0 1.0 0.5 1.5 $34 $661 2

For wells obtaining a waiver, prepare and submit permit application.

One-time

0.0 8.0 25.0 21.0 54.0 $1,482 $0 2

Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal Wells Conduct quarterly injectate sampling. Quarterly 0.0 0.0 1.0 0.5 1.5 $34 $661 5,89Conduct annual sludge sampling (concurrent with injectate sampling).

Annual

0.0 0.0 1.0 0.5 1.5 $34 $1,728 1,47

Annual reporting and recordkeeping of all monitoring results.

Annual

0.0 0.0 3.0 1.0 4.0 $94 $0 1,47

TOTAL 

44,92

Notes:(A) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-5 (continued)

Annual Paperwork Burden and Costs Associated with Class V Wells: States

A B CD E 

Hours and Costs per Response Total Hours and Cost

Description of Requirement Frequency Unit Burden (A) Unit Labor Cost

Unit Nonlabor 

Cost

Number of 

Responses Total Hours/Year T

Initial/StartupReview inventory information. One-time 0.5 $21 $0 22,038 11,019  Primacy State Activities Associated With the Class V RuleProvide technical assistance to owners/operators (at start-up). One-time 1.0 $41 $0 1,180 1,180 Review and file pre-closure notifications. One-time 1.3 $52 $0 1,141 1,426 Review, approve, and file waivers/permit applications. One-time 8.3 $344 $0 40 329 Review and file annual monitoring reports. Annual 0.8 $33 $0 959 767 TOTAL 25,358 14,722 

$ 

Notes:(A) Unit burdens for initial/start-up activities reported on a per-permit basis. Unit burden for other activities reported on a per-operator basis.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-38 

 Activities Required Under the Class V Rule

 Under the Class V Rule, facilities that wish to continue operating motor vehicle waste disposal wells 

must seek waivers from the ban on existing motor vehicle waste disposal wells and apply for permits. As a 

condition of the permit, facilities must submit all monitoring reports to the UIC Director. Owners of 

MVWDWs and large-capacity cesspools that close are required to submit pre-closure notifications. 

Note: While the Class V Rule required that all closure or permitting activities be completed by January 

2007 (the latest date by which operators with state-granted extensions would be required to have closed or 

applied for a permit), EPA assumes that some of these activities may not be complete or existing wells are still 

being located and addressed. Thus, some permitting/closure burden is included in this ICR. 

 Operators of Large-Capacity Cesspools 

 Operators of facilities with large-capacity cesspools will need to become familiar with the Class V 

requirements and prepare and submit a pre-closure notification to their primacy agencies. EPA assumes that 

each facility will require a total of 4.5 hours to complete these activities. 

 Operators of Motor Vehicle Waste Disposal Wells 

 All operators of facilities with MVWDWs must read the regulations and contact their primacy agencies 

to determine if their wells are located in a source water protection area (SWPA) or other sensitive ground water 

area. These activities will require 4 hours. If a well is located within one of these areas, the owner/operator will 

either close the well or seek a waiver and apply for a permit. 

 If they choose to close their wells, owners of MVWDWs must notify the UIC Program Director at least 

30 days prior to well closure, sample their injectate, and submit a pre-closure notification form (Form 

7520-17 or a state equivalent). These operators would incur a burden of 3 hours. 

 The specific information required in a permit application will be defined by the States or EPA regions. 

For purposes of this analysis, EPA assumes that the permit requirements will be similar to those required 

in existing UIC permit applications (40 CFR 144.31) including: a description of activities requiring a 

permit, inventory information, topographic maps, and a brief description of the business. These 

operators will also sample their injectate. The burden for these activities is estimated to be 55.5 hours, 

the majority of which is for preparing the permit application. Note: In recent years, primacy agencies 

have focused efforts on closing MVWDWs and not issuing permits.4

Operators of MVWDWs that are granted permits will be required to sample their injectate quarterly and 

sludge annually and submit these results once per year. These operators will incur an annual burden of 7 hours. 

Burden on Primacy Agencies Associated with Class V Wells 

 State primacy agencies’ burden associated with Class V wells includes time associated with reviewing 

inventory information, processing permit applications and pre-closure notifications, and reviewing and 

responding to monitoring data submitted by operators within their states. State burden associated with oversight 

of Class V programs is presented in Column A of Table A-5. 

 EPA estimates that states will spend 0.5 hours per Class V facility reviewing inventory information. 

EPA estimates that states will review permit applications and pre-closure notifications submitted by operators of 

 

4

 The source of this information is the annual UIC performance activity measures. 
Underground Injection Control Program – Information Collection Request Page A-39 

facilities with motor vehicle waste disposal wells and large-capacity cesspools. State primacy agencies will also 

review annual monitoring reports submitted by operators (details are presented in Table A-5). 

Burden Associated with Class VI Wells 

 EPA’s estimate of the annual paperwork burden on operators and states associated with Class VI wells is 

presented in Column A of Table A-6. The burden associated with Class VI wells is for 2011 through 2013 is 

estimated in ICR 2309.01; this ICR only includes Class VI Rule burden incurred in 2014 (the last year of this 

clearance). The burden estimates presented for Class VI wells are weighted averages that take into account the 

formation type, injection depth waiver status, and number of facilities that are active during this ICR clearance 

period. As such, these burden estimates are not representative of any one situation under which a GS project 

will operate. 

Class VI Operators 

 Activities for Class VI well operators include permitting and start-up-related reporting, demonstration of 

financial responsibility, monitoring and testing, area of review reevaluations and associated plan revisions, and 

closure and post-injection site care related paperwork activities. 

 EPA anticipates that Class VI facility operators will rely on contractors to assist them for information 

collection activities such as 3D seismic surveys, aerial surveys, and test well drilling. The costs associated with 

contractor labor and other contractor services are included in the operator costs presented in Column C of Table 

A-6. However, as geologic sequestration is a relatively new endeavor, there are still many activities for which 

uncertainty exists as to whether they will customarily be performed by operators or contractors. Those 

activities were classified as operator burden to provide a conservatively large estimate of operator burden. 

 EPA assumes that some activities required of Class VI operators (such as developing maps and crosssections of the receiving formation) are customary business practices that would be performed by operators 

even in the absence of regulation. Unit burden and costs used in Table A-6 represent the costs of performing 

each activity required of Class VI operators that are incremental to customary business practices. 
A B C DE 

Description Of Requirement Frequency

Technical 1 

(Engineer)

Technical 2 

(Geologist)

Unit 

Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Tota

Hours/ 

Initial/Startup Requirements (Per Permit Application)

Requirements Associated with Permit ApplicationsFile Class VI permit application, including attachments 

and the testing and monitoring plan, emergency and remedial response, injection well plugging, and postinjection site care and site closure plan. One-Time 226 56 283 $31,066 $847,124 0.60 

Conduct 3D seismic survey to identify faults and 

fractures; obtain and analyze seismic history. One-Time 0 253 253 $27,090 $18,385,597 0.60 

Obtain geomechanical and geochemical information on injection zone, subsurface aquifers including all USDWs, and the confining zone in the area of review. One-Time 0 909 909 $97,525 $1,840,888 0.60 Develop maps and cross sections of the injection zone, subsurface aquifers including all USDWs, and the confining zone in the area of review. One-Time 0 733 733 $78,562 $0 0.60 Take initial samples to develop a geochemical 

baseline for injection zones and confining zones. One-Time 0 0 0 $0 $4,079 0.60 

Prepare geologic characterization report demonstrating: suitability of receiving zone, storage capacity and injectivity, trapping mechanism free of nonsealing faults, competent confining system, etc. One-Time 0 1036 1036 $111,070 $0 0.60 Demonstrate financial responsibility to ensure funds 

will be available for required future actions. One-Time 4 0 4 $442 $0 0.60 Conduct aerial and database search for artificial penetrations (wells) within the area of review; determine integrity/plugging status of each. One-Time 140 3266 3406 $365,662 $94,057 0.60 Perform complex modeling of CO2 fluid flows and 

migration (reservoir simulations) and prepare Area of Review and corrective action plan. One-Time 308 0 308 $34,072 $0 0.60 Requirements Associated with Injection Well Construction

Install check valve (Director discretion to require down

hole shut-off valve, but expected to be check valves in all but the most exceptional cases). One-Time 0 0 0 $0 $600 0.60 

Design and install equipment for injection wells to measure: injected volumes, pressure, flow rates, and annulus pressure, as well as equipment to add CO2 tracers. One-Time 0 0 0 $0 $86,880 0.60 

Hours and Costs Per Response Total Hour

Table A-6

Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators

Underground Injection Control Program -- Information Collection Request 
A B C DE 

Description Of Requirement Frequency

Technical 1 

(Engineer)

Technical 2 

(Geologist)

Unit 

Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Tota

Hours/ 

Hours and Costs Per Response Total Hour

Table A-6

Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators

Monitoring/Testing Requirements (Per Operator)Analyze injectate stream and perform corrosion 

monitoring. Quarterly 62 0 62 $6,803 $15,068 0 

Develop a corrosion monitoring and prevention 

program. One-Time 24 0 24 $2,655 $0 0.60 

Construct monitoring wells. One-Time 0 0 0 $0 $11,285,190 

0.60 

Design and install equipment for monitoring wells to measure: pressure, temperature, resisitivity, salinity, CO2, tracers, and any other required monitoring equipment. One-Time 0 0 0 $0 $309,595 0.60 Operate and maintain monitoring wells and the 

monitoring equipment within them. Annual 13 0 13 $1,386 $427,167 0 

Conduct periodic monitoring of groundwater quality

and geochemistry. Monthly 21 0 21 $2,323 $10,080 0 Conduct external mechanical integrity tests to detect 

flow adjacent to well using temperature or noise log. Annual 0 0 0 $0 $168,026 0 Conduct a tracer survey of the bottom-hole cement 

using a CO2-soluble isotope. Annual 0 0 0 $0 $39,780 0 

Conduct casing inspection log. 

Every Five 

Years 0 0 0 $0 $154,737 0 

Conduct pressure fall-off testing.

Every Five 

Years 0 0 0 $0 $31,671 0 

Conduct 3D seismic survey to track movement of the 

CO2 plume and pressure front.

Every Five 

Years 0 0 0 $0 $1,104,039 0 

Activities Associated with Area of Review Reevaluations

Conduct complex modeling of fluid flows and migration (reservoir simulations). Based on new results, update AoR and corrective action plan, testing

and monitoring plan, and emergency and remedial response plan.

Every Five Years 1118 0 1118 $123,622 $0 0 

Reporting and Recordkeeping Requirments (Per Operator)

Report to regulators; maintain records of data from all 

data gathering activities.

SemiAnnual 33 0 33 $3,651 $0 0 

Underground Injection Control Program -- Information Collection Request 
A B C DE 

Description Of Requirement Frequency

Technical 1 

(Engineer)

Technical 2 

(Geologist)

Unit 

Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Tota

Hours/ 

Hours and Costs Per Response Total Hour

Table A-6

Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators

Post-Injection Site Care and Site Closure Requirements (Per Operator)Demonstrate financial ability (accounting for inflation) to close site.

PostInjection, One-Time 8 0 8 $885 $0 0 

Perform a mechanical integrity test prior to plugging

injection wells to evaluate integrity of casing and cement to remain in ground.

PostInjection, One-Time 0 0 0 $0 $283,410 0 

Conduct ground water monitoring - operate and 

maintain monitoring wells and the monitoring equipment within them.

PostInjection, Annual 0 0 0 $0 $491,655 0 

Track the CO2 plume and pressure front using 3D seismic surveys.

PostInjection, Every Five Years 0 0 0 $0 $1,104,039 0 

Report post-injection monitoring results to regulators.

PostInjection, Every Five Years 40 0 40 $4,425 $0 0 

TOTAL 8.4 

Notes:

(A) Unit Non-Labor Cost inflated by 20% to account for G&ANumbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
AB C DE 

Description Of Requirement Frequency Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Total 

Hours/ Year

To

Cost

Initial/Startup Requirements (Per Permit Application)Review the permit application and other information submitted by the operator, considering: AoR, relevant maps, geologic characteristics of the site, formation testing results, well schematics and construction procedures, proposed injection procedure, status of corrective action on wells within the AoR, well logging, testing, and mechanical integrity data, and all required project plans. One-time 45.4 $3,010 $0 0.60 27.3 Review financial responsibility demonstration. One-time 4.5 $298 $0 0.60 2.7 

Determine and specify tubing, packing, casing, and cementing requirements based on review of information submitted by operator. One-time 4.5 $298 $0 0.60 2.7 

Witness logging and testing. One-time 1.7 $112 $0 0.60 1.0 

Review applications for waviers to inject above the lowermost underground source of drinking water. One-time 2.4 $157 $0 0.60 1.4 

Monitoring and RecordkeepingReview reports submitted by operators; recordkeeping of data from all data gathering activities. Annual 2.2 $149 $0 0 0 Review mechanical integrity test data. Annual 13.5 $893 $0 0 0 Area of Review ReevaluationReview modeling update of the area of review and updated plans.

Every 5 years 20.0 $1,326 $0 0 0 

Site ClosureReview relevant data prior to granting approval for plugging and abandonment of a well. One-time 2.2 $149 $0 0 0 TOTAL 3.0 35 

$ 

Notes:(A) Unit Non-Labor Cost inflated by 20% to account for G&ANumbers may not add due to rounding.

Annual Paperwork Burden and Costs Associated with Class VI Wells: States

Table A-6 (continued)

Hours and Costs Per Response Total Hours and Costs

Undergound Injection Control Program -- Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-44 

 Initial Permitting/Start-up

 EPA anticipates that all permit applications during the timeframe of this ICR will be submitted by 

owners or operators seeking to inject into deep saline formations. Operators will apply for a Class VI permit for 

each injection well. EPA anticipates that 10 percent of operators will seek a waiver from the requirement that 

Class VI wells inject below the lowermost underground source of drinking water. EPA estimates that 95 percent 

of applications not requesting a waiver will be approved, and 47.5 percent of applications requesting a waiver 

will be approved. EPA or state primacy agencies will deny applications that do not meet Class VI standards, 

and others will be withdrawn by owners. 

 EPA estimates that the operator burden associated with applying for Class VI permits, including 

submitting all required attachments and plans will be 282.6 hours per permit. Submitted plans include an AoR 

and corrective action plan, a testing and monitoring plan, an emergency and remedial response plan, an 

injection well plugging plan, and a post-injection site care and site closure plan. 

 In addition to applying for permits, EPA estimates that operators of Class VI wells will incur burden to 

perform the following start-up activities. Unit burden for these start-up activities is provided below. 

 Conduct a 3D seismic survey to identify faults and fractures and to obtain and analyze the seismic 

history of the site (252.6 hours). 

 Obtain geomechanical and geochemical information on the receiving formation (injection formation), 

other subsurface aquifers (including all underground sources of drinking water), and confining system 

(caprock) in the area of review (909.5 hours). 

 Develop maps and cross-sections of the receiving formation (injection formation), other subsurface 

aquifers (including all USDWs), and confining system (caprock) in the area of review (732.6 hours). 

 Prepare a geologic characterization report demonstrating the suitability of the injection zone, storage 

capacity and injectivity, the presence of a trapping mechanism free of non-sealing faults, and a 

competent confining zone (1,035.8 hours). 

 Post a performance bond or demonstrate financial ability that funds will be available for required future 

actions (4.0 hours). 

 Conduct aerial and database searches for artificial penetrations (wells) within the AoR, and determine 

integrity and plugging status of each (3,405.6 hours). 

 Perform complex modeling of carbon dioxide fluid flows and migration (reservoir simulations) and 

prepare Area of Review and corrective action plan (308.0 hours). 

 Monitoring/Testing

 Class VI well operators will be required to perform quarterly analysis of the injectate stream and 

perform corrosion testing of the injection well , which is estimated to require approximately 61.5 hours per 

operator per quarter. Each operator will incur a one-time burden of 24.0 hours to develop a corrosion 

monitoring program. Additionally, operators will incur an annual burden of approximately12.5 hours to operate 

and maintain monitoring wells and the monitoring equipment within them. Operators must also perform 

groundwater quality and geochemical monitoring which is estimated to occur on a monthly basis and require 

approximately 21.0 hours of burden per month. Owners or operators will also hire contractors to perform annual 

external MITs and to track the extent of the carbon dioxide plume and pressure front. 
Underground Injection Control Program – Information Collection Request Page A-45 

 Area of Review Reevaluations

 Owners or operators of Class VI wells must reevaluate the AoR for the GS project at least every five 

years. Based on the results of the reevaluation, operators will update and resubmit the AoR and corrective 

action plan, the monitoring and testing plan, and the emergency response plan or demonstrate that no updates 

are necessary. They will also update the financial responsibility demonstration as needed to address any changes 

to these plans. (Note that owners or operators will also review their financial responsibility demonstrations 

annually to account for inflation; this is assumed to involve a negligible burden that is accounted for in the AoR 

reevaluation estimate.) 

 EPA estimates that, each year, 20 percent of operators will reevaluate the AoR and update the 

aforementioned plans and submit them to the primacy agency for review and approval. Each operator is 

estimated to incur 1,117.5 hours of burden once every five years for Area of Review reevaluations, which is 

assumed to include burden incurred by operators to respond to issues raised during a review of the Class VI 

permit, which is required every five years, per 40 CFR 144.36. 

 Reporting and Recordkeeping

 Operators of Class VI wells will incur 33.0 hours of burden per well every six months to report the 

results of required monitoring and testing and keep records of all data-gathering activities. This results in an 

annual burden of 66 hours per year for each operator of a Class VI well. 

 Closure and Post-Injection Site Care

 There are two closure and post-injection site care activities for which operators incur burden. It is 

estimated that operators will require 8.0 hours to prepare and submit a performance bond or demonstrate 

financial ability (accounting for inflation) to properly close the site. This occurs once at the beginning of the 

post-injection period. Subsequently, operators are assumed to report monitoring results to regulators every five 

years during the post-injection site care period, which is estimated to require 40.0 hours per operator, every five 

years. Due to the potentially long life spans of injection operations, no operators are anticipated to conduct 

closure or post-injection site care activities during the ICR clearance period. 

 Burden on Primacy Agencies Associated with Class VI Wells 

 State primacy agencies’ burden associated with Class VI wells includes reviewing and responding to 

permit applications, monitoring and testing data, AoR reevaluations, and closure and post-injection site care 

information submitted by operators. Due to the potentially long life spans of injection operations, no closure 

and post-injection site care activities are anticipated to occur during the ICR clearance period. State burden 

associated with each activity involved in the oversight of Class VI programs is presented in Column A of Table 

A-6. 

 EPA estimates that states will incur 58.5 hours of burden per permit application to review applications 

for Class VI wells, and the following materials submitted with the permit application. 

 Review the financial assurance of capacity to properly close, plug, and to provide post-injection care for 

wells. 

 Determine and specify tubing, packing, casing, and cementing requirements based on project 

information submitted by owners and operators. 
Underground Injection Control Program – Information Collection Request Page A-46 

 Witness logging and testing. 

 Review applications for waivers to inject above the lowermost underground source of drinking water 

(EPA estimates that about 10 percent of permit applicants will also apply for injection depth waivers). 

 State primacy agencies will incur an estimated 2.2 hours of burden annually per operator reviewing 

reports and data records submitted by operators. Every year, they will also incur approximately 13.5 hours of 

burden per operator reviewing mechanical integrity test data. State primacy agencies will review modeling 

updates to the AoR and other revised plans submitted by operators every five years, requiring approximately 20 

hours per review. 

States as Respondents 

 State burden associated with program oversight and compiling and reporting data using the 7520 forms 

and the UIC measures reporting process is presented in Column A of Table A-7. The burden on states 

associated with completing the 7520 forms ranges from 2 to 6 hours per form. States will also report semiannually to EPA on the UIC program measures via an online reporting system. EPA estimates the annual 

burden associated with this effort will be 120 hours per state primacy agency, or 60 hours semi-annually. States 

will also report inventory information annually to EPA. The burden associated with the oversight activities for 

the Class V inventory includes compiling the number of each Class of well, and reporting to an EPA online 

inventory. EPA estimates the annual burden associated with this effort will be 60 hours per primacy agency. 

 EPA estimates that the annual recordkeeping burden on state primacy agencies associated with the 7520 

forms and the inventory form will be 40 hours per agency. EPA estimates that maintenance of inventory data 

will account for the bulk of the recordkeeping burden. 

 EPA estimates that, in each primacy program, one-half of an FTE (1,040 hours) is devoted to 

implementing the state UIC Program. Implementation activities states may perform include updating state 

regulations as needed to reflect new federal rules or providing guidance, training, or other information to well 

operators. 
Table A-7

Annual State Burden and Cost for Program Oversight and Reporting

A BC D E 

Hours and Costs per Response Total Hours and Cost

Description of Requirement Frequency Unit Burden

Unit Labor 

Cost

Unit Nonlabor 

Cost

Number of 

Responses

Total 

Hours/Year Total Co

Program OversightOversee and implement UIC program in the State, for example, update regulations or guidances as needed. 

Ongoing

1,040 $43,081 $0 58 60,320 $2,

7520 Forms ReportingPermit Review and Issuance Form (7520-1) Annual

4.5 $186 $0 18 81 

Compliance Evaluation Form (7520-2A) Semi-annual

6.0 $249 $0 36 216 

Compliance Evaluation for Significant Non-Compliance Form (7520-2B)

Semi-annual

5.5 $228 $0 36 198 

Mechanical Integrity Tests/Remedial Action Form (7520-3) Annual

5.0 $207 $0 18 90 

Quarterly Exceptions List Form (7520-4) Quarterly

2.0 $83 $0 72 144 

Inventory and Measures ReportingConduct inventory-related activities, e.g., review operator data and report to EPA's online inventory data system.

Annual

60 $2,485 $0 18 1,080 

Report on UIC Measures to Headquarters Semi-annual

60 $2,485 $0 36 2,160 

Activities related to populating the National UIC Database Start-up activities (per program)Develop data to meet UIC database needs (programs with UIC databases)

One-time

10 $428 3,540 $ 9 93 

Build data flow through data node (programs with UIC databases)

One-time

25 $1,036 2,024 $ 9 225 

Build data flow through data node (programs without databases)

One-time

8 $345 4,024 $ 6 47 

Ongoing activities (per program)Enter UIC data into state database Ongoing 40 $1,657 $0 40 1,600 Data flow and QA checks Quarterly 24 $994 $0 160 3,840 $

RecordkeepingMaintain records of 7520 forms Ongoing 40 $1,657 $0 18 720 

534 70,814 $3,

Notes:There may be more than one agency per state with Primacy authority.

EPA assumes that once states transition to electronic reporting, they will no longer complete 7520 forms or submit inventory and measures data to EPA. See Appendix B.Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-48 

State Activities Associated with the National UIC Database 

EPA Headquarters deployed the National UIC database in December 2007. States are able to transfer 

the data needed to generate the information they currently report via the 7520 forms, the inventory, and the 

measures data to Headquarters. (Once they set up this data transfer process, States will no longer be required to 

complete the 7520 forms, report UIC inventory or measures data, or retain records.) Appendix B describes the 

data transfer activities in detail, EPA’s burden and cost estimates, and the burden and cost savings to states 

associated with the national UIC database. 

Start-up costs for states that have UIC databases include the costs associated with developing the data to 

transfer to the National UIC Database and setting up the data flow process. EPA estimates that, on average, the 

total “data development” cost to these programs is about 310 hours. Annualizing the effort over the estimated 6-

year phase-in schedule, this equals 51.6 hours per program annually, of which 10 hours will be conducted by 

state staff (the remaining work will be performed by contractors). 

States with existing data bases will also need to set up a data flow (i.e., data mapping, conversion to 

Extensible Markup Language, and setting up the data transfer through EPA’s Central Data Exchange). The total 

data flow burden is estimated to be 210 hours per program. Annualized over 6 years, this equates to 35 hours 

per year per program, of which 25 hours are state burden. 

To assist states without a UIC data base, EPA Headquarters developed an Access database. Because the 

database would be designed to the needs of the National UIC Database and Headquarters would perform the 

basic programming, the start-up effort for states without a UIC data base is assumed to be less intensive than for 

those states that already have a database. EPA estimates the start-up burden to these state programs is 250 

hours/ program (state and contractor labor), or 41.6 hours per year, annualized over 6 years. Of this, 8 hours will 

be state burden. 

Following establishment of a data flow, states will need to enter UIC data into their data bases; EPA 

estimated that states will spend 40 hours annually on this ongoing effort. States will also submit their data to the 

National UIC Database and respond to QA and data validation issues. EPA estimates that these tasks will 

require 24 hours, and be incurred 4 times per year (96 hours total). 

A.2 Estimating the Respondent Universe 

 In this section, EPA describes the number of respondents subject to each paperwork activity in this ICR. 

The number of responses for each activity is shown in Column D of Tables A-1 through A-7. This number, 

known as 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 or well closures 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 also presented in Tables A-1 

through A-7, along with EPA’s description of each activity. Specific assumptions about the respondent 

universe for each well class are described below. 

Class I 

 EPA inventory data indicate that there are 650 Class I wells, of which 113 inject hazardous waste, and 

537 inject nonhazardous waste. 
Underground Injection Control Program – Information Collection Request Page A-49 

 Class I Hazardous 

 According to EPA’s inventory, there are 113 Class I hazardous waste wells, with an average of 1.9 wells 

at each facility. EPA estimates that 8 new Class I hazardous waste facility operating permits will be issued each 

year (6 for one new well at an existing facility, and the remaining two for newly constructed facilities). EPA 

further anticipates that 12 Class I hazardous facility operators will renew their permits each year; 5 will modify 

their permits each year, and 6 operators will modify their petitions each year. All operators of Class I hazardous 

waste facilities must monitor and report at various frequencies (see Table A-1A). EPA expects that one Class I 

hazardous well will close during each year of the life of this ICR. 

 Class I Nonhazardous 

 EPA estimates that there are 537 Class I nonhazardous waste wells at 283 facilities, an average of 1.9 

wells per facility. The Agency estimates that 14 new nonhazardous waste injection permits will be issued each 

year, of which 10 will be for one new well at an existing facility. EPA anticipates that 20 Class I nonhazardous 

facility operators will renew their permits each year, and 9 Class I nonhazardous facility operators will modify 

their permits each year. Every operator of a Class I nonhazardous waste facility must monitor and report at 

various frequencies, as shown in Table A-1B. Based on past data, EPA anticipates that one Class I 

nonhazardous well in a primacy state will close each year. 

Class II 

 The 2006 UIC inventory includes 150,851 Class II wells. EPA assumes that the typical Class II facility 

has approximately 10 wells, thus there are approximately 15,085 Class II facilities. 

 EPA anticipates that, collectively, EPA regional offices and primacy states will receive approximately 

6,038 permit applications for Class II wells each year during the life of this ICR. Details of the numbers of 

Class II operators subject to each paperwork requirement are presented in Column D of Table A-2. 

 Based on previous studies of state AoR practices and requirements, EPA projects that state primacy 

agencies and EPA Regions will determine that a complete AoR is not necessary for approximately 4,899 of the 

6,038 permit applicants. Of the remaining applicants, EPA projects that approximately 1,139 applicants will 

submit an AoR map and an AoR study as part of the permit application. Another 1,342 applicants will submit 

an AoR map and a listing of the wells in the AoR, and the state primacy agency will perform most or all of the 

tasks involved in the AoR study. 

 EPA estimates that 604 applicants will submit corrective action plans to address specific problems 

identified by the AoR study. EPA regional or state primacy staff will require 121 operators (20 percent) to 

revise their corrective action plans. 

 Prior to obtaining approval to begin injection, operators must demonstrate mechanical integrity and 

submit completion reports for an estimated 1,725 new Class II wells each year. 

 EPA estimates that approximately 75,426 Class II wells (50 percent of the inventory) are permitted, and 

that 20 percent of operators will undergo permit reviews each year, and half of these (1,509) will need to 

respond to issues raised during the reviews. In addition, EPA expects that 2,263 operators will submit requests 

for permit modifications. 

 From time to time, operators submit reports or notify UIC staff of various events such as planned 

changes to the injection facility, permit transfers, progress in achieving compliance milestones, and 
Underground Injection Control Program – Information Collection Request Page A-50 

noncompliance or malfunctions which may endanger a USDW. EPA estimates that approximately 905 

operators submit one of these occasional reports each year. 

 EPA projects that approximately three operators of rule-authorized wells in DI states may be required to 

gather and submit groundwater monitoring data, analyses of injected fluids, a description of geologic strata, and 

other items as requested. 

 EPA projects that, each year, approximately 1,044 operators will plug and abandon all of their wells. In 

addition, EPA assumes that approximately one operator in a DI program will elect to plug its wells in a manner 

different from the one specified in its plugging and abandonment plan, triggering a revision to the plugging and 

abandonment plan. 

Class III 

 EPA estimates that there are approximately 141 facilities with Class III wells (9 uranium mining, 39 salt 

solution mining, and 94 brine mining/other sites). A typical uranium facility has approximately 2,360 Class III 

wells, a typical salt mining facility has 22 wells, and a typical brine mining/other facility has 2 wells. 

 EPA regional offices and state primacy agencies expect to receive 32 permit applications from Class III 

operators each year. EPA estimates that approximately 2 Class III operators will close their projects annually. 

 Operators of all 141 Class III facilities will monitor injection pressure, flow rate, or volume of injected 

fluids semi-monthly, or meter injected and produced fluid volumes continuously. EPA anticipates that 

operators of salt solution mining facilities will submit analyses of their injectate once each year, and operators 

of salt solution mining facilities will perform two-part MITs on all of their wells every five years. All uranium 

well operators monitor water quality in the injection zone and overlying freshwater aquifers either semimonthly or monthly. 

Class IV/Endangering Class V 

 Based on UIC measures data reported by the states in 2003, EPA anticipates that 990 Class IV wells and 

endangering Class V wells will close each year. EPA estimates 23 percent of Class IV and endangering Class V 

wells are in DI states. 

Class V 

 The current EPA inventory of Class V wells includes 511,184 wells. This number is imprecise, and it is 

estimated that perhaps 3 to 5 times as many Class V wells actually exist. EPA anticipates that approximately 

33,867 operators of Class V facilities will submit inventory information each year over the life of this ICR, 

based on trends in the UIC program inventory. 

Facilities Subject to the Class V Rule 

The Class V rule required that all large-capacity cesspools be closed and that all motor vehicle waste 

disposal wells (MVWDWs) either close their well or obtain a permit by 2007 (the burden associated with these 

activities was estimated in the 2004 UIC Program ICR). However, based on consultations with regional and 

state staff, there is reason to believe that these activities are incomplete. Thus, this ICR assumes that some 

permitting and closure activities associated with Class V Rule requirements will continue into this clearance 

period. 
Underground Injection Control Program – Information Collection Request Page A-51 

EPA estimates, based on data from the states, that operators of 1,313 large-capacity cesspools need to 

close their facilities during the clearance period. This number includes 1,000 large-capacity cesspools that were 

estimated to be closed in the 2007 ICR, but that did not close (i.e., due to a lack of resources) and therefore the 

burden associated with closure of those large-capacity cesspools is already accounted for. Thus, EPA assumes 

that an additional burden for closing 313 large-capacity cesspools (an average of 104 per year) will be incurred 

in this clearance period. 

In addition, EPA estimates that operators of 1,440 MVWDWs (480/year) will close and 61 MVWDW 

operators (20/year) will apply for a permit during the clearance period. Furthermore, operators of 1,474 

MVWDWs that have opted to obtain a permit will conduct quarterly injectate sampling and annual sludge 

sampling, as required under the Class V rule. 

Class VI 

 EPA assumes that GS technology will be implemented at a slow pace over the next few years, and that, 

during the clearance period, 1.8 Class VI facilities injecting into deep saline groundwater formations will be 

subject to reporting burden associated with Class VI rule requirements. On average, EPA anticipates that, 

collectively, EPA regional offices and primacy states will receive approximately 0.6 applications for Class VI 

facilities each year during the ICR clearance period. 

 No Class VI operators are expected to conduct external mechanical integrity tests, a casing inspection 

log, a pressure falloff test, complex fluid modeling, or a 3D seismic survey during the life of this ICR. No 

operators are expected to conduct post-injection site care and site closure activities during the ICR clearance 

period, as no facilities are expected to have reached the end of their injection periods during the ICR clearance 

period. 

States as Respondents 

 EPA assumes that 58 primacy agencies in 40 states and two tribes (Navajo and Fort Peck) will report 

UIC data to EPA, either electronically or on paper forms. This number reflects the fact that, in some states, 

more than one agency oversees UIC activities (e.g., states typically regulate Class II wells through agencies 

other than those overseeing other classes of wells for which they have primacy). 

Because of the effort involved in initiating data transfer to the National UIC database EPA assumes that 

states will accomplish this at varying paces, depending on many variables including available funding and staff. 

This results in a phased-in schedule for populating the National UIC Database. EPA estimates that, by January 

2012 (the beginning of this information collection), 14 programs will have transitioned to electronic-reporting 

(e-reporting). Nine additional programs are expected to transition to e-reporting in 2012, 16 programs are 

expected to do so in 2013, and the remaining 19 programs are expected to transition in 2014. On average over 

the clearance period, 15 states will perform activities associated with start-up of the data transfer—of these, nine 

are estimated to be programs with existing data bases and six programs have no existing electronic UIC data. 

On average, EPA estimates that 40 primacy programs will report UIC data electronically each year, and 

18 will report using paper-based methods. The frequency at which primacy agencies complete each 7520 form 

is presented in Table A-7. Measures reporting will take place semi-annually (mid-year and end of year). 

Underground Injection Control Program – Information Collection Request Page B-1 

Appendix B: The National UIC Database 

 

EPA Headquarters developed the National UIC Database, a well-specific database that collects 

and stores state1

 and regional direct implementation (DI) program data to support UIC 

programmatic data needs. The UIC system contains approximately 120 data elements related to 

various aspects of the UIC Program (e.g., permit information and enforcement and compliance 

data). The database includes a tool to electronically transfer data between existing state 

databases and the National UIC Database, a tool to generate standard reports, and a tool to 

support data quality assurance/quality control (QA/QC) reviews. 

Headquarters deployed the National UIC Database in December 2007. After deployment, EPA 

developed a strategy to transition all state and DI programs to electronic reporting (e-reporting). 

The goal of the Strategy, known as the 2012 Strategy, is to engage all UIC primacy programs by 

2012. As of January 2011, four programs have transitioned to e-reporting. Ten programs are 

expected to transition in 2011, nine programs are expected to transition to e-reporting in 2012, 

sixteen programs are expected in 2013, and the remaining nineteen program are expected to 

transition in 2014. To assist with funding challenges, EPA’s Exchange Network Grants can be 

used to establish a data flow. Grant funds can also be used to complete other related activities, 

such as building a state database or establish an electronic data flow from owners or operators. 

Several programs have already received funds to support the National UIC Database efforts. 

While the UIC regulations do not mandate the format in which the data must be submitted, 

historically, programs have provided information in paper format. States that transfer to ereporting are no longer required to submit the 7520 paper forms or do inventory and measures 

reporting; this eliminates the current burden associated with gathering and compiling data, 

completing the reporting forms, and maintaining records. EPA is encouraging programs to 

voluntarily transition to e-reporting to help reduce the overall reporting burden on primacy 

programs. Although there is still burden associated with e-reporting, after establishing the data 

flow the burden is less than current paper based reporting. EPA developed tools to generate the 

same data as the paper reports to ensure consistency in program management after the transition. 

A list of the tools and supporting documents developed to reduce burden associated with the data 

flow process can be found in the last section of this Appendix. In addition to the reduction in 

burden, programs have reported data quality improvements as a result of the data flow process. 

The improvement in data quality may result in more efficient program management by both the 

states and EPA. 

This Appendix describes the status of UIC data management by primacy states and DI programs, 

the burden and cost associated with data transfer, and the eventual cost savings to states 

associated with the National UIC Database. It also describes tools and other support available 

from EPA to support states in e-reporting. 

 

1

 The term state includes states, tribes, and territories. 
Underground Injection Control Program – Information Collection Request Page B-2 

B1. Status of State Data Management Activities 

As a prelude to the National UIC Database development effort, EPA Headquarters conducted a 

cataloging effort to assess the status of data management by state UIC programs. EPA’s findings 

are presented in the UIC Program Databases Cataloging Report (December 2, 2005). This 

report provided EPA with a better understanding of the type of support and tools states may 

require. 

Based on the cataloging effort, 36 state programs had existing data bases with high or medium 

quality data coverage and nine programs had little or no data in electronic data. The remaining 

programs did not respond to the request for information (EPA conservatively assumes these 

programs do not have UIC databases). 

B2. Burden and Cost Associated With Data Transfer 

State UIC programs will incur burden and cost associated with the necessary start-up activities to 

prepare their databases and data for transfer to Headquarters and ongoing activities associated 

with data entry and quarterly data transfers to Headquarters. 

Burden associated with start-up activities

Prior to initiating data transfer, states will need to prepare their databases to flow data to the 

National UIC Database and initially populate the database. The effort (and associated cost) will 

vary depending on the status of the state’s database. 

States with Existing UIC Databases 

Start-up costs include the costs associated with developing the data to transfer to the National 

UIC Database and setting up the data flow process. The following activities are included: 

Data Development: these activities include adding new data fields and new data tables (if 

needed) to align the state’s UIC data to the national data model. 

Inputting Historic Data: in addition, EPA assumes some programs have at least partial 

data in hard copy only and would need to input some data from paper files. 

On average, the total “data development” cost to these programs is about 310 hours. Annualizing 

the effort over the estimated 6-year phase-in schedule, this equals 51.6 hours per program, 

annually. Note that much of this is contractor labor, which is presented as non-labor costs in the 

UIC Programmatic ICR. 

Setting up a Data Flow includes the following activities: 

 Data mapping and data set generation, including mapping data from the state database to 

Headquarters and generating data sets with valid records, 
Underground Injection Control Program – Information Collection Request Page B-3 

 Convert to Extensible Markup Language (XML),2 and 

 Data flow via a Network Node involves setting up/testing automatic data submission and 

transfer to EPA’s Central Data Exchange (CDX). 

The total data flow burden is estimated to be 210 hours per program. Annualized over 6 years, 

this equates to 35 hours (in state and contractor labor) per year per program. 

States with Little or no Electronic Data

EPA Headquarters funded the development of an Access database for use by states with no 

existing UIC database, or those that do not currently maintain most of the national data elements. 

EPA assumes that the states with little or no data coverage would use this primacy program 

database template. Because the database would be designed to the needs of the National UIC 

Database and Headquarters would perform the basic programming, this effort is assumed to be 

less intensive than for those states that already have a database, as described above. EPA 

estimates the start-up burden to these state programs is 250 hours/ program (state and contractor 

labor), or 20.8 hours per year, annualized over 6 years. 

Cost associated with start-up activities

Start-up non-labor costs include contractor support and one-time hardware costs to set up a state 

“data node.” EPA developed a Node Client that states without a data node can use to submit UIC 

data. States may choose to develop a data node to serve all state programs but it is no longer a 

cost they must incur to submit data to the National UIC Database. See additional information in 

B.4 below. 

EPA assumes that most start-up activities (estimated at 80 percent of the burden cited above), 

will be performed by contractors at an estimated labor rate of $86 hour. In addition, programs 

will incur $7,000/program ($1,167/year, annualized over 6 years) for hardware costs associated 

with setting up a data flow via the network node. 

Ongoing activities

Annual activities include the incremental data entry burden for those states that currently do not 

enter UIC data into a state database. (States that already have a database are already incurring a 

data entry burden; thus, the ICR assumes no additional paperwork burden for these states as a 

result of the new database.) The annual data entry burden is estimated to be 40 hours. Note that 

some states have developed software that allows inspection data gathered in the field to be 

directly uploaded into their state database, further reducing data entry burden. Other states have 

also established web-based permitting and inventory system that flow data to their state database 

further reducing burden. 

All programs will submit their data to the National UIC Database through CDX and respond to 

QA and data validation issues. EPA estimates these tasks will require 24 hours per quarter, or 96 

 

2

 Extensible Markup Language (XML) is a set of rules for encoding documents in machine-readable form. 
Underground Injection Control Program – Information Collection Request Page B-4 

hours per year. 

B3. Burden Reduction and Cost Savings 

Over the long run, the National UIC Database will reduce the states’ reporting burden. Following 

transfer to e-reporting, states will no longer need to complete the 7520 forms and report on the 

measures and inventory. This eliminates the current burden associated with gathering and 

compiling UIC data, completing the reporting forms, and maintaining records. 

As described above, states will need to make a time and hardware investment to develop the 

automated data transfer process. However, when the data transfer is complete, the current annual 

burden associated with completing the 7520 forms and reporting inventory and PAMs data will 

be replaced with a lower burden associated with placing data on a network node to transfer it to 

Headquarters and providing QA to assure data accuracy, as described below: 

 Under a paper-based system, states would collectively incur over $625,000 annually in 

reporting and recordkeeping costs; this equals about $10,800 annually per state. (Note 

that the 2011 ICR estimates a lower annual cost, as 14 programs are assumed to have 

transferred to electronic reporting by the start of the clearance period. 

 Between 2010 and 2014, states will collectively incur $2,313,786 in start-up costs to 

convert from paper-based to electronic reporting. This equates to an average of $47,062 

in labor and hardware costs for each program that currently has a database, and $26,271 

per program without a database. 

 When their initial data transfer is complete, states will incur lower annual costs: an 

estimated annual cost of about $ $230,627 for all states collectively (or $3,976 per state) 

to enter data and transfer it to Headquarters quarterly. 

Table B-1 presents the annual and cumulative costs to states under paper based and electronic 

reporting systems. When the initial data population and transfer are complete, states will 

collectively save nearly $400,000 annually. 
Underground Injection Control Program – Information Collection Request Page B-5 

Table B-1: Comparison of Costs –

Paper-Based Reporting vs. Electronic Reporting 

Paper-Based Reporting Electronic Reporting 

Year Annual cost Cumulative cost Annual cost* Cumulative cost 

2007 $625,815 $625,815 $51,039 $51,039 

2008 $625,815 $1,251,630 $55,015 $106,053 

2009 $625,815 $1,877,444 $58,991 $165,045 

2010 $625,815 $2,503,259 $62,968 $228,012 

2011 $625,815 $3,129,074 $382,631 $610,644 

2012 $625,815 $3,754,889 $516,519 $1,127,163 

2013 $625,815 $4,380,703 $779,349 $1,906,512 

2014 $625,815 $5,006,518 $963,959 $2,870,471 

2015 $625,815 $5,632,333 $230,627 $3,101,098 

2016 $625,815 $6,258,148 $230,627 $3,331,724 

2017 $625,815 $6,883,963 $230,627 $3,562,351 

2018 $625,815 $7,509,777 $230,627 $3,792,977 

2019 $625,815 $8,135,592 $230,627 $4,023,604 

2020 $625,815 $8,761,407 $230,627 $4,254,230 

2021 $625,815 $9,387,222 $230,627 $4,484,857 

2022 $625,815 $10,013,036 $230,627 $4,715,483 

2023 $625,815 $10,638,851 $230,627 $4,946,110 

2024 $625,815 $11,264,666 $230,627 $5,176,737 

2025 $625,815 $11,890,481 $230,627 $5,407,363 

2026 $625,815 $12,516,296 $230,627 $5,637,990 

* Includes the cost for new programs transitioning to e-reporting plus ongoing costs 

(e.g., for data entry and QA/QA) following transfer. 

B4. Process for Transitioning to Electronic Reporting 

The data flow process starts with a discussion between the state/DI program and EPA. These 

discussions are documented in a Trading Partnership Agreement (TPA), which describes the data 

that will be submitted, the timetable for data submission, and any roadblocks with which the 

program may need assistance. The next step is to perform logical mapping; this is a process of 

matching the data elements in a primacy program’s database to the National UIC Database. Next, 

an electronic connection is established based on the logical mapping called the physical 

mapping. This step will allow states to submit the correct information each time they submit to 

the National UIC Database and results in an XML document. The final step is for a program to 

submit data to the National UIC Database using CDX. After the data flow is established the 

quality of the data must be reviewed to ensure data integrity. 

Before transiting to e-reporting, a program must complete a comprehensive QA/QC review, 

which allows programs to correct any errors that may have occurred in the logical or physical 

mapping. This review, which may occur over several submissions, allows programs to improve 

their overall data quality. Once the quality of the submission is sufficient, the state and EPA will 
Underground Injection Control Program – Information Collection Request Page B-6 

start finalizing the transition process, which concludes with a signed memorandum stating that 

the state is no longer required to submit the paper 7520 report or the web-based PAMs and 

inventory reports. During the transition period, programs will continue to submit paper reports. 

This practice has been adopted to give programs control over the numbers reported. At this point 

in the transition process, programs will have a populated state database that can be used to 

generate the necessary reports. However, since the data quality may still be questionable, 

submitting the paper report ensures that the official data has integrity by allowing the state to 

correct numbers that may not be accurate. 

Recognizing that states needed a wide range of support, EPA developed a primacy program 

database template. The template can support the needs of an implementation program and 

facilitate data transfer to the National UIC Database. EPA also developed a web-based tool to 

convert data to XML format to allow data sharing between databases of different structure and 

content and to perform QA/QC of the data. States are not required to use the XML conversion 

tool. 

To provide technical support, EPA established an Integrated Project Team (IPT). The initial IPT 

consisted of EPA Regions and select state programs. These members tested the data flow process 

and provided feedback to streamline and improve the process. As a result of the IPT’s efforts 

EPA developed a customizable process with instructional documents, supporting tools, and a 

peer-to-peer assistance network. After the database was deployed and programs began 

consistently submitting data to the National UIC Database, EPA reorganized the IPT creating 

two IPTs. The IPT 1 allows programs to share lessons learned and provide peer-to-peer support 

for programs that have an established data flow. The IPT 2 consists of programs that are 

beginning the logical mapping process, completing the physical mapping process, and testing the 

initial data flow. 

EPA also developed a Node Client that states without a data node can use to submit UIC data. 

States may choose to develop a data node to serve all state programs but it is no longer a cost 

they must incur to submit data to the National UIC Database. In practice most programs choose 

to use the Node Client. To use the Node Client, states submit a request for a username and 

password, and download the software on to a desktop. 

EPA developed several supporting documents and tools to facilitate and reduce the burden 

associated with the transition to e-reporting and with the quarterly submissions. Tables B-2 and 

B-3 provide a brief description of each document or tool. 
Underground Injection Control Program – Information Collection Request Page B-7 

Table B-2: UIC Database Support Documents 

Document Description 

Mapping Instructions This document provides step-by-step instructions on how to complete the logical 

mapping and information about the physical mapping. This document also 

includes a Q&A on common issues that arise in the logical mapping process. 

Logical Mapping Form A form that will document how the program’s database relates to the National 

UIC Database. This is a living document and should be updated if the physical 

mapping differs from the original logical mapping. 

Questions and Answers on 

the Mapping Process 

Provides questions and answers about common issues related to the mapping 

process. 

UIC Trading Partner 

Agreement Template 

A template that can be used to document the discussions between the program and 

EPA Headquarters. The agreement will be used to ensure mutual understanding of 

the data flow process. 

How to Guide This includes instructions on how to obtain a Network Authentication 

Authorization Service (NAAS) account, use the conversion tool, download UIC 

supporting materials, complete pre-submission validation, read a validation report, 

submit using the Node Client, submit using a Node, check the status of your 

submission, and download CDX reports. 

UIC National Database Ad 

Hoc Query Tool User 

Guide 

A user guide for the Ad Hoc Query Tool. This document includes instructions on 

how to use the tool, the query logical used in the tool, and details about the reports 

included in the tool. 

Standard Operating 

Procedures 

Provides the standard operating procedures (SOP) for the National UIC database 

and establishes a reporting schedule. The SOP is updated annually. 

Transition from Existing 

Reporting Mechanisms to 

Electronic Submittal into 

the New National UIC 

Database 

Establishes a process for programs to transition to electronic reporting. The memo 

outlines a three step process to bring programs from existing reporting to 

electronic reporting. 
Underground Injection Control Program – Information Collection Request Page B-8 

Table B-3: UIC Database Support Tools 

Tool Description

National Database Access 

file 

A file structured like the National UIC Database that incorporates the UIC 

Business Rules that programs can use to house their data or to modify to manage 

their program. 

Primacy Template database 

and User Interface 

A direct implementation database and user interface that was developed for 

Region 7’s direct implementation program. This database can be used by other 

programs. 

Conversion Tool This is a tool that can be used to convert an Access file in the format of the 

National database to an XML file. 

Pre-submission Validation 

Tool 

The pre-submission tool allows data submitters to validate their data before it is 

submitted to the database through CDX. After submitting data to the presubmission validation submitters will receive a validation report identifying 

Required 1 and 2 errors. Using the pre-submission validation can reduce the time 

it takes to complete data submission. 

Oracle Client Software The Oracle Client allows state and regional users to connect to the National UIC 

Database. 

Node Client Software This is software that can be used to submit data through CDX without having to 

develop a Node. 

UIC Reporting Services The UIC Reporting Tool is a software system used by the EPA to generate 

standard and ad hoc reports. It is also used for QA/QC purposes. 

Ad Hoc Query Tool This is an Access tool that can be used by the Regions or States to run queries and 

reports. 
APPENDIX C 

Federal Register Notice on UIC Program Reporting Requirements 

To be included in final ICR 

Underground Injection Control Program – Information Collection Request Page D-1

Appendix D: Burden Reduction Efforts in the UIC Program 

In 2006, EPA’s Underground Injection Control (UIC) Program completed an in-depth 

evaluation of options to reduce reporting burden on injection well owners and operators. 

Electronic reporting was identified as the option most likely to offer significant burden 

reduction opportunities for owners or operators and state primacy agencies. 

To increase the use of electronic reporting in the UIC Program, EPA began a number of 

initiatives related to reporting by injection well owners or operators and by permitting 

authorities. This includes developing Agency data systems, supporting state efforts to 

implement electronic reporting by owners or operators, and providing technical and 

financial support to encourage electronic data reporting via the National UIC Database. 

This appendix describes these efforts. 

Summary of the 2008 Burden Reduction Report 

In 2008, the UIC Program discussed the ongoing efforts to reduce reporting burden on 

injection well owners and operators in the paper, “Evaluation of Burden Reduction 

Opportunities Related to Some UIC Program Operator Reporting Forms.” The program 

evaluated the reporting forms that operators are required to submit to determine whether 

opportunities exist to reduce burden. EPA undertook the following activities: 

 Created an ad hoc workgroup of regional and state staff to review the necessity of the 

data collected on several of the forms, including forms 7520-6 through 7520-12, 

7520-14, 7520-15, and 7520-16.1

 

 Reviewed each element on the owner or operator reporting forms to determine 

whether any elements on the reporting forms could be combined or eliminated while 

still ensuring the protection of underground sources of drinking water (USDWs). 

 Explored options for electronic reporting of data, including web interfaces that would 

replace the paper forms currently submitted by well owners and operators. 

 Investigated whether any of the needed information could be obtained from other 

sources, e.g., the U.S. Bureau of Land Management (BLM). It was determined that 

BLM forms could not replace any of the UIC Program’s owner or operator 7520 

forms and provide the level of detail needed to meet UIC Program goals. 

 

1

 These forms include: Permit Application (7520-6), Application to Transfer Permit (7520-7); Injection 

Well Monitoring Report (7520-8); Completion Form for Injection Wells (7520-9); Completion Report for 

Brine Disposal, Hydrocarbon Storage, or Enhanced Recovery (7520-10); Annual Disposal/Injection Well 

Monitoring Report (7520-11); Well Rework Record (7520-12); Plugging and Abandonment Plan (7520-

14); Inventory of Injection Wells (7520-16); and Pre-Closure Notification Form (7520-17). 
Underground Injection Control Program – Information Collection Request Page D-2

Based on the research conducted for the paper, EPA concluded that eliminating forms or 

reducing reporting frequency was not an option due to the following: 

 Most of the reported information is required by regulation and is necessary to ensure 

that injection wells will be sited, constructed, and operated in a manner that protects 

USDWs. 

 Reducing reporting frequency could endanger USDWs by eliminating crucial early 

warnings that wells are not operating within protective parameters. 

 Combining or eliminating any of the UIC reporting forms is not practical since the 

forms collect information generated at various milestones in the life of an injection 

well or are already submitted infrequently. 

Electronic reporting was identified as an option that might offer significant burden 

reduction opportunities. 

Ongoing Burden Reduction Efforts: Owner or Operator Reporting

EPA is encouraging and implementing electronic reporting by injection well owners or 

operators by developing Agency databases and encouraging states to develop their own 

data systems. 

EPA Initiatives 

In 2007, EPA began the development of a web-based system that will allow owners or 

operators to submit their inventory information and pre-closure notifications, normally 

submitted on forms 7520-16 and 7520-17, via a secure website. To date, a test site has 

been developed that allows the submission of inventory information and to later retrieve 

relevant information for the pre-closure notification. EPA Headquarters and regional staff 

have conducted limited testing of the website. Due to budget and FTE constraints, the 

web-based system is not complete. EPA is investigating options to finish the 

development of the web-based system and deploy the system for use by well operators. 

The recently promulgated Federal Requirements Under the Underground Injection 

Control (UIC) Program for Carbon Dioxide (CO2) Geologic Sequestration (GS) Wells

(GS Rule) requires electronic submission of all data related to Class VI (GS) wells. The 

GS Rule requires permit applications and all reports, submittals, and notifications 

required by the rule to be submitted electronically. (The rule allows for alternative 

methods for submission if necessary.) EPA took the opportunity to require electronic 

reporting from owners or operators for Class VI wells because the facilities that contain 

Class VI wells currently employ technologies that easily support electronic reporting. 

The relatively small universe of Class VI wells also makes requiring electronic reporting 

practical. EPA is developing a data system to collect and store Class VI well owner or 

operator data. 
Underground Injection Control Program – Information Collection Request Page D-3

State Initiatives 

EPA has encouraged states to create electronic data flows from owners or operators as 

part of the National UIC Database effort, and has encouraged state primacy programs to 

apply for Exchange Network Grants to establish an electronic data flows from owners or 

operators to states. Some programs are taking advantage of the incentive offered by EPA 

to begin electronic reporting for owners or operators while other programs have taken 

their own initiative to reduce reporting burden on owners or operators through electronic 

reporting. For example: 

 The Massachusetts Department of Environmental Quality, a 2007 Exchange 

Network Grantee, is beta testing a system for the electronic permitting of Class V 

wells. The system will include electronic versions of the following forms: 

registration and pre-closure, well modification or conversion, well closure, well 

monitoring report, well completion and construction notifications, and well postclosure notification. Access to the system will be controlled with a username and 

password. 

 The Wyoming Department of Environmental Quality used a 2005 Exchange 

Network Grant to establish a data flow to EPA, to enhance their UIC database, and 

to create the Graduated Environmental Management (GEM) tool. The GEM tool 

allows registered users to apply for a new permit, modify an existing permit, 

manually enter or upload monitoring data, and upload electronic data deliverables. 

GEM collects information related to permits, financial assurance, well construction, 

facility inspections, monitoring, violation, and lab analyses. The tool allows 

reviewers to track the steps in the permitting process, including the method and 

dates of public notice, and whether public comments were received. 

 The Washington Department of Ecology employs the Online UIC Well Registration 

System for owners or operators to register their injection wells. The system, 

SecureAccess Washington, is a single sign-on application gateway created to 

simplify access to the Washington’s government services accessible via the 

Internet. 

 The State of Utah supports electronic permitting and monitoring reporting for well 

owners or operators. Utah employs eReport, a secure system that uses an Extensible 

Markup Language (XML) data schema to transfer data over the Internet. The 

system allows for submission through: 

o Web forms for small operators with a few wells, 

o eReportRemote for small and mid-size operators using a spreadsheet-style 

format, and 

o Batch submittal for large operators. 
Underground Injection Control Program – Information Collection Request Page D-4

Ongoing Burden Reduction Efforts: Electronic Reporting by Permitting Authorities 

EPA is also encouraging state primacy agencies to report the data they must provide to 

EPA using electronic data flows as part of the National UIC Database effort by providing 

technical and financial assistance. 

EPA has provided technical support to the states through the development of tools to 

support the transition to electronic reporting. For example, EPA developed a primacy 

program database template and a web-based tool to convert data to XML format to allow 

sharing of data between databases of different structure and content. EPA also developed 

a Node Client that states without a data node can use to submit UIC data to the National 

UIC Database without making the investment in a state data node. 

EPA also established an Integrated Project Team to provide peer-to-peer support for 

programs that are either beginning to map their data to the National UIC Database or 

have an established data flow. Additional information about this technical support is 

presented in Appendix B of the 2011 UIC Programmatic Information Collection Request. 

EPA is also encouraging the shift to electronic reporting by offering Exchange Network 

Grants to support state’s efforts to establish an electronic data flow from owners or 

operators to states (as described above) and then to EPA. To date, 14 states have initiated 

the data transfer process, and all state and regional direct implementation programs plan 

to convert to electronic reporting by 2014. 

Conclusion 

EPA continues efforts to encourage primacy programs to develop end-to-end electronic 

data flows starting with operators and ending with EPA. EPA has made grant money 

available to assist state programs in establishing electronic data flows through the 

Exchange Network Grant. To date, over 20 programs have received assistance through 

the Grant. 

The support network established for the National UIC Database has provided 

opportunities for peer-to-peer sharing of success stories and lessons learned for electronic 

data flows from owners or operators. EPA has highlighted the efforts of programs with 

end-to-end electronic data flows at national meetings such as the Ground Water 

Protection Council’s annual UIC Conference. 

Without mandating a change in reporting formats, EPA has worked to support the 

implementation of voluntary changes in reporting by owners or operators. Primacy 

programs have also seen the advantages of electronic reporting and have unilaterally

made changes in their reporting practices. 
APPENDIX E
APPENDIX E

Underground Injection Control Program Reporting Forms

Number Form

7520-1 Permit Review and Issuance/Wells in Area of Review

7520-2A Compliance Evaluation

7520-2B Compliance Evaluation - Significant Noncompliance

7520-3 Mechanical Integrity Test/Remedial Actions

7520-4 Quarterly Exceptions List

7520-6 UIC Permit Application

7520-7 Application to Transfer Permit

7520-8 Injection Well Monitoring report

7520-9 Completion Form for Injection Wells

7520-10 Completion Report for Brine Disposal, Hydrocarbon Storage, or Enhanced

Recovery Well

7520-11 Annual Disposal/Injection Well Monitoring Report

7520-12 Well Rework Record

7520-14 Plugging and Abandonment Plan

7520-16 Inventory of Injection Wells

7520-17 Pre-Closure Notification Form
Please type or print all information. Please read instructions. OMB No. 2040-0042 Form Expires 1/31/05 

United States Environmental Protection Agency 

Office of Ground Water and Drinking Water 

Washington, DC 20460 

(This information is solicited under the 

authority of the Safe Drinking Water Act) 

UIC Federal Reporting System 

Part I: Permit Review and Issuance/ 

Wells in Area of Review 

I. Name and Address of Reporting Agency 

United States Environmental Protection Agency 

II. Date Prepared (month, day, year) III. State Contact (name, telephone no.) IV. Reporting Period (month, year) 

From 

October 1, 20 

To 

Item 

Class and Type of Injection Wells 

I 

II 

III IV V 

SWD 

2D 

ER 

2R 

HC 

2H 

V. Permit 

Application Number of Permit Applications Received 

VI. 

Permit 

Determination 

Permit 

Issued 

A 

Number of Individual 

Permits Issued 

(One Well) 

New 

Wells 

Existing 

Wells 

B 

Number of area Permits* Issued 

(Multiple Wells) 

(*See instructions on back) 

New 

Well Field 

Existing 

Well Field 

C 

Number of Wells in Area Permits 

(See B above) 

New 

Wells 

Existing 

Wells 

Permit 

Not Issued 

D 

Number of Permits Denied/Withdrawn 

(after complete technical review) 

Modification 

Issued 

E Number of Major Permit 

Modifications Approved 

VII. 

Permit 

File 

Review 

Number of Rule-Authorized 

Class II Wells Reviewed 

Wells 

Reviewed 

Wells 

Deficient 

VIII. 

Area 

of 

Review 

(AOR) 

Wells 

Reviewed A 

Number of Wells 

in Area of Review 

Abandoned 

Wells 

Other 

Wells 

Wells 

Identified 

for C/A 

B 

Number of Wells Identified 

for Corrective Action 

Abandoned 

Wells 

Other 

Wells 

Wells 

with 

C/A 

C 

1. Number of Wells in AOR with 

Casing Repaired/Recemented C/A 

2. Number of Active Wells in AOR 

Plugged/Abandoned 

3. Number of Abandoned Wells 

in AOR Replugged 

4. Number of Wells in AOR with 

"Other" Corrective Action 

IX. Remarks/Ad Hoc Report (Attach additional sheets if necessary) 

I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. 

Certification 

Signature and Typed or Printed Name and Title of Person Completing Form Date Telephone No. 

EPA Form 7520-1 (Rev. 8-01) Previous edition is obsolete. 
Instructions and Definitions 

All reporting is cumulative, year to date, and begins with October 1. 

Section V. Permit Application 

Enter under each well class the total number of permit applications that have 

been received this year to date. Include all applications: complete and 

incomplete; individual and municipal well (Area Permit); and applications for 

“New” and “Existing” wells. 

A “New Well” is any well other than an existing well or a plugged/abandoned 

well that became operable after the effective dateof the State(or EPA) Underground Injection Control Program. 

An “Existing Well” is any operable (i.e., active, under construction, shut in, 

or temporarily abandoned) injection well or a properly plugged and abandoned 

injection well that was in existence on the effective dateof the State(or EPA) 

UIC Program. 

Section VI. Permit Determination 

Permit Determinations include the approval or denial of UIC permit 

request/actions such as: applications for permits, major modifications to 

issued permits, revocation andreissuanceof permits, or termination of permits 

for cause. A complete permit determination includes a thorough technical 

evaluation of the request,public notification or review before issuance, and a 

final decision document signed by the regulating authority. 

Item A: Enter under each well class the number of individual permits issued 

for “New” or “Existing” wells this year to date. 

ItemB: Enter under each well class the number of area permits that have been 

issued for “New” or “Existing” well fields this year to date. (“New” in this 

case, describes a nonhazardous injection well field having only new wells or 

a mixture of new and existingwells. “Existing” describes a nonhazardous well 

field having only existing wells.) 

Item C: Enter under each well class the number of “New” and “Existing” 

wells covered by the Area Permits entered in Item B. 

Item D: Enter under each well class the number of permits or major modifications denied by the State(or EPA) UIC program and/or permits withdrawn by 

applicants this year to date. The denial of a permit or major modification 

should be included as a permit determination only after there has been a 

complete technical review. 

Item E: Enter under each well class the number of major modifications 

approved this year to date. An approved major modification requires a 

complete technical review, public notification or review, and a final decision 

document signed by the regulating authority. 

Section VII. Permit File Review 

A complete technical review of an existing (rule authorized) Class II well
 

record may be conducted by the authorized regulating 
 

authority in lieu of a permit determination in accordance with the 
 

UIC 1425 Guidance to determine whether the well is in compliance with UIC
 

regulatory requirements. The well record (or file) review may include an
 

evaluation of siting reports, wells in the area of review, construction, operat-
 

ing, monitoring or other State reports. Existing Class II wells should be
 

routinely reviewed at least once every five years during the life of the well.
 

Well Reviewed: Enter under the appropriate category of injection wells the 

number of rule authorized (existing) Class II wells with permit files reviewed 

and compliance status determined this year to date. 

Well Deficient: Enter under the Class II well class the number of reviewed 

rule authorized Class II wells found deficient (not in compliance) that received 

corrective or enforcement action as appropriate followup response. 

Section VIII. Area of Review (AOR) 

All wells that penetrate the injection zone in the AOR of an injection well/field 

are reviewed duringpermit determination or duringany AOR analysis of a rule 

authorized well file. 

Item A: Enter under the well class of each permit application or file that has 

been reviewed this year to date, the number of “Abandoned” and “Other” 

wells reviewed in the AOR. 

“Abandoned” includes any well penetratingthe injection zone in theAOR that 

has been properly or improperly plugged and/or abandoned. “Other” includes 

any producing well, operable injection well, dry hole, exploratory well, etc., 

that penetrates the injection zone in the AOR. 

Corrective Action is required for thosewells that penetrate the injection zone 

in the AOR that are improperly sealed, completed, or abandoned. 

Item B: Enter under the well class of each permit applications or file reviewed 

this year to date, all “Abandoned” and “Other” wells in the AOR that have 

required corrective action. 

ItemC: Enter under the well class of all permit applications or files that have 

been reviewed, the number of wells in the AOR which have received corrective 

action (be specific) this year to date. 

Paperwork Reduction Act Notice 

The public reporting and record keeping burden for this collection of 

information is estimated to average 4.5 hours per year. Burden meansthe total 

time, effort, or financial resource 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, processingand maintaininginformation, and disclosing 

and providing information; adjust the existing ways to comply with any 

previously applicable instructions and requirements;trainpersonnel to be able 

to respond to the 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. Send comments 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 to Director, Collection Strategies Division, 

U.S.EnvironmentalProtectionAgency (2822), 1200 Pennsylvania Ave., NW., 

Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed forms to this address. 

EPA Form 7520-1 (8-01) Revised 
Please type or print all information. Please read instructions on reverse. OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

(This information is solicited under the 

authority of the Safe Drinking Water Act) 

UIC Federal Reporting System 

Part II: Compliance Evaluation 

Office of Ground Water and Drinking Water 

I. Name and Address of Reporting Agency 

United States Environmental Protection Agency 

II. Date Prepared (month, day, year) III. State Contact (name, telephone no.) IV. Reporting Period (month, year) 

From 

October 1, 20 

To 

Item 

Class and Type of Injection Wells 

I 

II 

III IV V 

SWD 

2D 

ER 

2R 

HC 

2H 

V. 

Summary 

of 

Violations 

Total 

Wells 

A Number of Wells with Violations 

Total 

Violations 

B 

1. Number of Unauthorized 

Injection Violations 

2. Number of Mechanical Integrity Violations 

3. Number of Operation and 

Maintenance Violations 

4. Number of Plugging 

and Abandonment Violations 

5. Number of Monitoring and 

Reporting Violations 

(Specify) 

6. Number of Other Violations 

VI. 

Summary 

of 

Enforcement 

Total 

Wells 

A Number of Wells with 

Enforcement Actions 

Total 

Enforcement 

Actions 

B 

1. Number of Notices of Violation 

2. Number of Consent Agreements 

3. Number of Administrative Orders 

4. Number of Civil Referrals 

5. Number of Criminal Referrals 

6. Number of Well Shut-ins 

7. Number of Pipeline Severances 

8. Number of Other Enforcement Actions 

(Specify) 

VII. 

Summary 

of 

Compliance 

Number of Wells 

Returned to Compliance 

A. This Quarter 

B. This Year 

VIII. 

Contamination Number of Cases of Alleged Contamination of a USDW 

IX. 

MIT Resolved Percent of MIT Violations Resolved in 90 Days 

X. Remarks/Ad Hoc Report (Attach additional sheets) 

I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. 

Certification 

Signature and Typed or Printed Name and Title of Person Completing Form Date Telephone No. 

EPA Form 7520-2A (1-88) Replaces EPA Form 7520-2 which is obsolete 
Definitions and Instructions 

Allreportingis cumulative, year to date, and begins with October 1. 

A Class II, III, or V injection well with a violation of a permit or rule 

requirement is said to be in noncompliance. A Class I or IV well with 

any violation is said to be in significant noncompliance (SNC). Note: 

A ClassII, III, or Vwell withcertain types of violations may also be 

in significant noncompliance. (See Form 7520-2B (Reverse) for 

definitions of SNC violations.) 

Section V. Summary of Violations 

(Includes all noncompliance, significant and non-significant) 

Note: Also Report Significant Noncompliance Information on Form 

7520-2B. 

A. Total Wells: Enter under each well class the number of wells with 

a violation(s) identified this yearto date, whether or not the well has 

been returned to compliance. These totals track the percentage of the 

injection well universein noncompliance each year. Enter a well only 

once each year. 

B. Total Violations: 

Item 1-6: Enter under each well class the number of times each 

violation (be specific) has been identified this year to date. 

Section VI. Summary of Enforcement 

A. Total Wells: Enter under each well class the number of wells with 

violations that have received an enforcement action(s) this year to 

date. These totals track the percentage of the injection well universe 

that receives an enforcement action each year. Enter a well only once 

each year. 

B. Total Enforcement Actions: 

Item 1-8: Enter under each well class the number of times wells with 

violations have received an enforcement action(s) (be specific) this 

year to date. 

Section VII. Number of Wells Returned to Compliance 

A “Well Returned to Compliance” is a well in violation of UIC 

program requirements that has had the violation(s) corrected and the 

resolution of the violation(s) has been verified by the regulating 

authority.Note: An enforcement action alone (e.g., wellshut-in) does 

not constitute a “return to compliance.” 

A. Enter under each well class the number of wells returned to 

compliance in the current quarter only. 

B. Enter under each well class the number of wells returned to 

compliance (as a result of an enforcement action against a violation) 

this year to date. These totals track the percentage of the injection 

well universe that returned to compliance through an enforcement 

action(s) each year. Enter a well only once each year. 

Section VIII. USDW Contaminations 

Enter under each well class the number of times a well in noncompliance has allegedly contaminated an underground source of drinking 

water (USDW) this year to date. 

Section IX. % MIT Violations Resolved in 90 Days 

Enter under each well class the percentage of MIT violations 

(identified in Section V., under “Mechanical Integrity”) resolved 

within 90 days. 

In order to calculate the percentage: 

1. Add up the total number of MIT violations to date 

whether of not they were identified in this reporting 

period, e.g., 10. 

2. Add up the number of these violations to date that were 

resolved in 90 days or less, e.g., 5. 

3.Calculatethe percentage of total MIT violations todate 

that have been resolved in 90 days or less, e.g., 50%. 

Paperwork Reduction Act 

The public reportingand record keeping burden for this collection 

of information is estimated to average 6 hours per response. 

Burden meansthetotal time, effort,or financialresource 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 disclosingand providinginformation; adjust the existing 

ways to comply withany previously applicable instructions and 

requirements; train personnel to be able to respond to the 

collection of information; search data sources; complete and 

review the collection of information; and, transmit or otherwise 

disclosethe information. An agency may not conduct orsponsor, 

and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control 

number. Send comments 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 to Director, Collection 

Strategies Division, U.S. Environmental Protection Agency 

(2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. 

Include the OMBcontrol number in any correspondence. Do not 

send the completed forms to this address. 

EPA Form 7520-2A Revised 
Please type or print all information. Please read instructions on reverse. OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

(This information is solicited under the 

authority of the Safe Drinking Water Act) 

UIC Federal Reporting System 

Part II: Compliance Evaluation 

Significant Noncompliance 

Office of Ground Water and Drinking Water 

I. Name and Address of Reporting Agency 

United States Environmental Protection Agency 

II. Date Prepared (month, day, year) III. State Contact (name, telephone no.) IV. Reporting Period (month, year) 

From 

October 1, 20 

To 

Item 

Class and Type of Injection Wells 

I 

II 

III IV V 

SWD 

2D 

ER 

2R 

HC 

2H 

V. 

Summary 

of 

Significant 

NonCompliance 

(SNC) 

Total 

Wells 

A Number of Wells with SNC Violations 

Total 

Violations 

B 

1. Number of Unauthorized 

Injection SNC Violations 

2. Number of Mechanical Integrity 

SNC Violations 

3. Number of Injection Pressure 

SNC Violations 

4. Number of Plugging 

and Abandonment SNC Violations 

5. Number of SNC Violations 

of Formal Orders 

6. Number of Falsification 

SNC Violations 

(Specify) 

Number of Other SNC Violations 7. 

VI. 

Summary 

of 

Enforcement 

Against 

SNC 

Total 

Wells 

A Number of Wells with 

Enforcement Actions Against SNC 

Total 

Enforcement 

Actions 

B 

1. Number of Notices of Violation 

2. Number of Consent Agreements/Orders 

3. Number of Administrative Orders 

4. Number of Civil Referrals 

5. Number of Criminal Referrals 

6. Number of Well Shut-ins 

7. Number of Pipeline Severances 

8. Number of Other Enforcement Actions 

Against SNC Violations (Specify)

VII. 

Summary 

of 

Compliance 

Number of Wells in SNC 

Returned to Compliance 

A. This Quarter 

B. This Year 

VIII. 

Contamination Number of Cases of Alleged Contamination of a USDW 

IX. 

Well 

Closure 

Class IV/Endangering Class V 

Well Closures 

Involuntary Well Closure 

Voluntary Well Closure 

I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. 

Certification 

Signature and Typed or Printed Name and Title of Person Completing Form Date Telephone No. 

EPA Form 7520-2B (8-01) Replaces EPA Form 7520-2 which is obsolete. 
Instructions and Definitions 

EPA Form 7520-2B 

Section IV. Reporting Period: All reporting is cumulative, year to date, 

beginning with October 1. 

Definitions of SNC Violations: 

1. Violations of any kind pertaining to a Class I or IV well. 

2. The followingviolations by the owner/operator of a Class II, III, or V well: 

a. Unauthorized Injection – Any unauthorized emplacement of fluids (where 

formal authorization is required); 

b. Mechanical Integrity – Well operation without mechanical integrity which 

causes the movement of fluid outside the authorized zone – if injection of such 

fluid may have the potential for endangering a USDW; 

c. Injection Pressure – Well operation at an injection pressure that exceeds the 

permitted or authorized injection pressure and causes the movement of fluid 

outside the authorized zone of injection – if such movement may have the 

potential for endangering a USDW; 

d. Pluggingand Abandonment – The pluggingand abandonment of an injection 

well in an unauthorized manner. This definition includes the “walking away 

from” a responsibility to plug and abandon a well. These wells are in SNC 

only when there is endangerment of USDW and there is an identifiable 

owner/operator; 

e. Violation of a Formal Order – Any violation of a formal enforcement action, 

includingan administrative or judicial order, consent agreement,judgement,or 

equivalent State action; 

f. Falsification – The knowing submission or use of any false information in 

a permit application, periodic report or special request for information about 

a well. 

Section V. Total No. of Wells with SNC Violations: 

Significant Noncompliance information is also to be reported on EPA From 

7520-2A. Under each well class and type, enter the total number of SNC 

violations which have been identified in the year to date, whether or not the 

violations(s)havebeen corrected and the well(s)returned to compliance. These 

totals track the percentage of the injection well universe in SNC each year. 

Enter a well only once each year. 

For subsections 1 through 7 enter under each well class the total number of 

times, by specific violation, an SNC has been identified this year to date. 

Section VI. Total SNC Enforcement Actions: Significant Noncompliance 

information is also to be reported on EPA Form 7520-2A. Under each well 

class and type, enter the total number of wells with SNC violations that have 

received an enforcement action(s) this year to date, whether or not the wells 

have been returned to compliance. These totals track the percentage of the 

injection well universe that receives an SCN enforcement action each year. 

Enter a well only once each year. 

For subsections 1 through 8 enter under each well class the total number of 

times wells with SNC violations have received the specified enforcement 

action this year to date. 

Section VII. No. of Wells Returned to Compliance: A “Well Returned to 

Compliance” is a well in violation of UIC program requirements which has had 

the violation(s) corrected and has had the resolution of the violation(s) verified 

by the regulating authority. An enforcement action alone (e.g., well shut-in) does 

not constitute a “Return to Compliance.” 

Under subsection A, enter under each well class the total number of wells 

returned to compliance (as a result of an enforcement action against an SNC 

violation) in the current quarter only. Undersubsection B, enter under each well 

class the total number of wells returned to compliance (as a result of an 

enforcement action against an SNC violation) this year to date. These totals 

track the percentage of the injection well universe that returned to compliance 

through an SNC enforcement action(s) each year. Enter a well only once each 

year. 

Section VIII. USDW Contaminations 

Enter under each well class the number of times a well in SNC has allegedly 

contaminated an underground source of drinking water (USDW) this year to 

date. 

Section IX. Number of Class IV/V Endangering Class V Well Closures: 

Enter the number of Class IV and Class V well closures either as a voluntary or 

involuntary action. Involuntary well closure means wells closed as a result of 

enforcement actions or permit call-ins. Voluntary well closure means well 

closed as a direct result of outreach activities. Well closure describes a process 

to permanently discontinue injection of an unauthorized and en-dangeringfluid 

contaminant which is in violation of RCRA or SDWA or applicable regulations. 

At the time, closure must include immediate cessation of injection of unauthorized waste stream to satisfy SDWA requirements. To satisfy bothSDWA and 

RCRA, well closure may require additional actions: remove injection fluids 

deposited in well,sludge and any visibly contaminated soil;segregatehazardous 

waste streams from sanitary waste streams (septic system) and redirect HW 

to holding tank; restrict injection to authorized waste stream; seal floor drain; 

obtain authorized sewer hook-up; remove well, injectate and contaminated soil 

and dispose in authorized facility. Imminent threat to USDW may require 

monitoring and ground-water remediation. 

Paperwork Reduction Act 

The public reporting and record keeping burden for this collection of information is estimated to average 5.5 hours per response. Burden means the total 

time, effort, or financial resource 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 the collection of information; search datasources;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. Send comments 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 to Director, Collection Strategies Division, U.S. 

Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., 

Washington, DC 20460. Include the OMB control number in any correspondence. Do not send the completed forms to this address. 
Please type or print all information. Please read instructions on reverse. OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

(This information is solicited under the 

authority of the Safe Drinking Water Act) 

UIC Federal Reporting System 

Part III: Inspections 

Mechanical Integrity Testing 

Office of Ground Water and Drinking Water 

I. Name and Address of Reporting Agency 

United States Environmental Protection Agency 

II. Date Prepared (month, day, year) III. State Contact (name, telephone no.) IV. Reporting Period (month, year) 

From 

October 1, 20 

To 

Item 

Class and Type of Injection Wells 

I 

II 

III IV V 

SWD 

2D 

ER 

2R 

HC 

2H 

V. 

Summary 

of 

Inspections 

Total 

Wells 

A Number of Wells Inspected 

Total 

Inspections 

B 

1. Number of Mechanical Integrity Tests 

(MIT) Witnessed 

2. Number of Emergency Response or 

Complaint Response Inspections 

3. Number of Well 

Constructions Witnessed 

4. Number of Well 

Pluggings Witnessed 

5. Number of Routine/Periodic 

Inspections 

VI. 

Summary 

of 

Mechanical 

Integrity 

(MI) 

Total 

Wells 

A Number of Wells Tested or Evaluated 

for Mechanical Integrity (MI) 

B No. of Rule-Authorized Wells 

Tested/Evaluated for MI 

Passed 2-part test 

Failed 2-part test 

For 

Significant 

Leak 

C 

1. Number of Annulus Pressure 

Monitoring Record Evaluations 

Well Passed 

Well Failed 

2. No. of Casing/ 

Tubing Pressure Tests 

Well Passed 

Well Failed 

3. Number of Monitoring 

Record Evaluations 

Well Passed 

Well Failed 

4. 

(Specify) 

No. of Other Significant Leak 

Tests/Evaluations 

Well Passed 

Well Failed 

For 

Fluid 

Migration 

D 

1. Number of Cement 

Record Evaluations 

Well Passed 

Well Failed 

2. Number of Temperature/ 

Noise Log Tests 

Well Passed 

Well Failed 

3. No. of Radioactive Tracer/ 

Cement Bond Tests 

Well Passed 

Well Failed 

4. 

(Specify) 

No. of Other Fluid Migration 

Tests/Evaluations 

Well Passed 

Well Failed 

VII. 

Summary 

of 

Remedial 

Action 

Total 

Wells 

A Number of Wells with 

Remedial Action 

Total 

Remedial 

Actions 

B 

1. Number of Casing Repaired/ 

Squeeze Cement Remedial Actions 

2. Number of Tubing/Packer 

Remedial Actions 

3. Number of Plugging/Abandonment 

Remedial Actions 

4. Number of Other Remedial Actions 

(Specify) 

VIII. Remarks/Ad Hoc Report (Attach additional sheets) 

I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any 

knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law. 

Certification 

Signature and Typed or Printed Name and Title of Person Completing Form Date Telephone No. 

EPA Form 7520-3 (Rev. 8-01) Previous edition is obsolete. 
Instructions and Definitions 

(Allreporting is cumulative, year to date, and begins withOctober 1.) 

Section V. Summary of Inspections 

A complete inspection should include an assessment of: the well 

head, pressure and flow meters, pipeline connections, and any other 

equipment associated with the injection system; an inspection is 

complete only when a report has been filed with the regulating 

authority. 

Item A: Enter under each well class the number of wells that have 

been inspected this year to date. Thesetotals track the percentage of 

the injection well universe inspected each year. Enter a well only 

once each year. 

Total Inspections: (This year to date) 

Item 1: Enter under each well class the number of inspections to 

witness field Mechanical Integrity Tests. (At least 25% of MITs 

performed by operators each year should be witnessed.) 

Item 2: Enter under each well class the number of inspections that 

have been in response to a problem reported to the regulating 

authority. 

Item 3: Enter under each well class the number of inspections of well 

constructions or any preoperational activities. 

Item 4: Enter under each well class the number of inspections of well 

pluggings or pluggings and abandonment. 

Item 5: Enter under each well class the number of inspections that 

have been routine/periodic. 

Section VI. Summary of Mechanical Integrity 

A complete MIT is composed of a test for significant leaks in the 

casing, tubing or packer and a test for significant fluid migration into 

aUSDWthrough vertical channels adjacent to the well bore. An MIT 

consists of a field test on a well or an evaluation of a well’s monitoring records (i.e., annulus pressure, etc.) or cement records. At a 

minimum, the mechanical integrity of a Class I, II, or III (solution 

mining of salt) well should be demonstrated at least once every five 

years during the life of the well. 

Item A:Enter under each well classthe number of wells that have had 

a complete MIT this year to date. These totals track the percentage 

of the injection well universe tested for MI each year. Enter a well 

only once each year. 

Item B: Enter under the appropriate well class the number of rule 

authorized wells that have passed a complete MIT and the number 

that have failed a complete MIT this year to date. 

Item C: Significant Leak Tests: (This year to date) 

Item 1-4: Enter under each well class the number of times wells have 

passed or failed a field test/record evaluation for significant leaks (be 

specific). 

Item D. Fluid Migration Tests: (This year to date) 

Items 1-4: Enter under each well class the number of times wells have 

passed or failed a field test/record evaluation for fluid migration (be 

specific). 

Section VII. Summary of Remedial Action 

A failure of mechanical integrity (MI) may occur at any time during the 

life of an injection well until it is plugged and abandoned in accordance 

witha preapproved plan. Failure may be identified duringan inspection, 

a field test, an evaluation of well records, or during routine operation of 

a well. Remedial actions include additional permit conditions, monitoring 

or testing, or one of the actions specified below. 

Item A: Enter under each well class the number of wells that have 

received remedial actions this yearto date. This total tracks the percentage of the injection well universe that have received remedial action each 

year. Enter a well only once each year. 

Total Remedial Actions: (This year to date) 

Item 1-4: Enter under each well class the number of times that wells have 

received remedial action (be specific). 

Paperwork Reduction Act 

The public reporting and record keeping burden for this collection of 

information is estimated to average 5 hours per response. Burden 

meansthe total time, effort,or financialresource expended by persons 

to generate, maintain, retain, or discloseor 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 the 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. Send comments 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 to Director, Collection 

Strategies Division, U.S. Environmental Protection Agency (2822), 

1200 Pennsylvania Ave., NW., Washington, DC 20460. Include the 

OMB control number in any correspondence. Do not send the 

completed forms to this address. 

EPA Form 7520-3 Reverse 
United States Environmental Protection Agency 

Washington, DC 20460 

(This information is collected under the authority of the Safe Drinking Water Act) 

UIC Federal Reporting System 

Part IV: Quarterly Exceptions List 

Office of Ground Water and Drinking Water 

OMB No. 2040-0042 

Approval expires 1/31/05 

I. Reporting Period 

From To 

II. 

Well 

Class 

and 

Type 

III. 

Name and Address 

of Owner/Operator 

IV. 

Well 

ID No. 

(Permit 

No.) 

V. Summary of Violations VI. Summary of Enforcement VII. 

Date 

Compliance 

Achieved 

Date of 

Violation 

Mark ('X') Violation Type Date of 

Enforcement 

Mark ('X') Enforcement Type 

Unauthorized Injection Well Mechanical Integrity Injection Pressure Plugging and Abandonment Formal Order Falsification Other (Specify) Notice of Violation Consent Agreement Administrative Order Civil Referral Criminal Referral Well Shut-in Pipeline Severance Other (Specify) 

I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any knowingly false or misleading statement may be 

punishable by fine or imprisonment or both under applicable law. 

Certification 

Signature of Person Completing Form Typed or Printed Name and Title Date Telephone No. 

EPA Form 7520-4 (Rev. 8-01) Previous edition is obsolete. 
Instructions and Definitions 

The quarterly Exceptions list is used to track wells reported 

in significant noncompliance (SNC) on EPA Form 7520-2B 

for two or more consecutive quarters without being addressed with a formal enforcement action or returned to 

compliance. Any SNC reported on Form 7520-4 shall be 

reported until the SNC is resolved. Once a SNC is reported 

as resolved, it need not appear in subsequent reports. 

Section I - Reporting Period 

All reporting is cumulative, year to date, beginning with 

October 1. 

Section II - Well Class and Type 

Enter the well class and type of each well in SNC for two or 

more consecutive quarters. For Class I wells, specify IH for 

hazardous waste, IM of municipal waste, Ii for industrial 

waste. For Class II wells, specify IID for saltwater disposal, 

IIR for enhanced recovery, IIH for liquid hydrocarbon 

storage. 

Section III - Name and Address of Owner/Operator 

Enter the name and address of the owner/operator of the 

injection well. Use multiple lines of the form if needed. (You 

may use one form for each owner/operator.) 

Section IV - Well ID No. (Permit No.) 

Enter the I.D. number of the injection well in SNC. If the well 

has a UIC permit number, enter this as the I.D. number. 

Section V - Summary of Violations 

Enter the date the SNC violation was first identified and 

place an “X” in the appropriate column. In the event that 

there were multiple SNC violations for a single well, enter 

each violation and the date it was identified on a separate 

line. 

Section VI - Summary of Enforcement 

Enter the date an enforcement action was taken against the 

SNC violation and place an “X” in the appropriate column. 

In the event that there were multiple enforcement actions, 

enter each enforcement action and the date it was taken on 

a separate line. 

Paperwork Reduction Act 

The public reporting and record keeping burden for this 

collection of information is estimated to average 2 hours 

per response. Burden means the total time, effort, or 

financial resource 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 the 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 informat ion unless it displays a currently 

valid OMB control number. Send comments 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 to Director, Collection 

Strategies Division, U.S. Environmental Protection 

Agency (2822), 1200 Pennsylvania Ave., NW., Washington, DC 20460. Include the OMB control number in any 

correspondence. Do not send the completed forms to this 

address. 

EPA Form 7520-4 (8-01) Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

(Collected under the authority of the Safe Drinking 

Water Act. 

I. EPA ID Number 

Underground Injection Control 

Permit Application 

Application approved Date received 

Owner Name 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments 

and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true, 

accurate, and complete. 

imprisonment. 

XIV. Certification 

A. Name and Title B. Phone No. 

A. 

U 

T/A C 

Read Attached Instructions Before Starting 

For Official Use Only 

Permit Number Well ID FINDS Number mo day year mo day year 

Street Address 

City State ZIP CODE 

Phone Number 

II. Owner Name and Address III. Operator Name and Address 

Owner Name 

Street Address 

City State ZIP CODE 

Phone Number 

IV. Commercial Facility V. Ownership VI. Legal Contact VII. SIC Codes 

Yes 

No 

Private 

Federal 

Other 

Owner 

Operator 

VIII. Well Status (Mark "x") 

Date Started 

mo day year 

Operating 

B. Modification/Conversion C. Proposed 

IX. Type of Permit Requested (Mark "x" and specify if required) 

A. Class(es) B. Type(s) 

(enter code(s)) (enter code(s)) 

A. Individual B. Area Number of Existing Wells Number of Proposed Wells Name(s) of field(s) or project(s) 

X. Class and Type of Well (see reverse) 

C. If class is "other" or type is code 'x,' explain D. Number of wells per type (if area permit) 

XI. Location of Well(s) or Approximate Center of Field or Project XII. Indian Lands (Mark 'x') 

Latitude Longitude 

Deg Min Sec Deg Min Sec 

Township and Range 

Sec Twp Range 1/4 Sec Feet From Line Feet From Line 

Yes 

No 

XIII. Attachments 

(Complete the following questions on a separate sheet(s) and number accordingly; see instructions) 

For Classes I, II, III, (and other classes) complete and submit on a separate sheet(s) Attachments A--U (pp 2-6) as appropriate. 

required. 

(Type or Print) (Area Code and No.) 

C. Signature D. Date Signed 

Sections 1421, 1422, 40 CFR 144) 

I am aware that there are significant penalties for submitting false information, including the possibliity of fine and 

(Ref. 40 CFR 144.32) 

Attach maps where 

List attachments by letter which are applicable and are included with your application. 

EPA Form 7520-6 (Rev. 8-01) 
Well Class and Type Codes 

Class I Wells used to inject waste below the deepest underground source of drinking 

water. 

Type “I” Nonhazardous industrial disposal well 

“M” Nonhazardous municipal disposal well 

“W” Hazardous waste disposal well injecting below USDWs 

“X” Other Class I wells (not included in Type “I,” “

M,” or “W”) 

Class II Oil and gas production and storage related injection wells. 

Type “D” Produced fluid disposal well 

“R” Enhanced recovery well 

“H” Hydrocarbon storage well (excluding natural gas) 

“X” Other Class II wells (not included in Type “D,” “R,” or “H”) 

Class III Special process injection wells. 

Type “G” Solution mining well 

“S” Sulfur mining well by Frasch process 

“U” Uranium mining well (excluding solution mining of conventional mines) 

“X” Other Class III wells (not included in Type “G,” “S,” or “U”) 

Other Classes Wells not included in classes above. 

Class V wells which may be permitted under §144.12. 

Wells not currently classified as Class I, II, III, or V. 

Attachments to Permit Application 

Class Attachments 

I new well A, B, C, D, F, H – S, U 

existing A, B, C, D, F, H – U 

II new well A, B, C, E, G, H, M, Q, R; optional – I, J, K, O, P, U 

existing A, E, G, H, M, Q, R, – U; optional – J, K, O, P, Q 

III new well A, B, C, D, F, H, I, J, K, M – S, U 

existing A, B, C, D, F, H, J, K, M – U 

Other Classes To be specified by the permitting authority 

EPA Form 7520-6 (8-01) page 2 of 6 
INSTRUCTIONS - Underground Injection Control (UIC) Permit Application 

Paperwork Reduction Act: The public reporting and record keeping burden for this collection of information is estimated to average 

394 hours for a Class I hazardous well application, 252 hours for a Class I non-hazardous well application, 32 hours for a Class II well 

application, and 119 hours for a Class III well application. Burden means the total time, effort, or financial resource 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;adjustthe existing ways to complywith 

any previously applicable instructions and requirements;train personnel to be able to respond to the 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 ofinformation unless it displays a currently valid OMB 

control number. Send comments 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 to Director, Collection 

Strategies Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, DC 20460. Include the 

OMB control number in any correspondence. Do not send the completed forms to this address. 

This form must be completed by all owners or operators of Class I, II, and III injection wells and others who may be directed to 

apply for permit by the Director. 

I. EPA I.D. NUMBER - Fill in your EPA Identification Number. If you do not have a number, leave blank. 

II. OWNER NAME AND ADDRESS - Name of well, well field or company and address. 

III. OPERATOR NAME AND ADDRESS - Name and address of operator of well or well field. 

IV. COMMERCIAL FACILITY - Mark the appropriate box to indicate the type of facility. 

V. OWNERSHIP - Mark the appropriate box to indicate the type of ownership. 

VI. LEGAL CONTACT - Mark the appropriate box. 

VII. SIC CODES - List at least one and no more than four Standard Industrial Classification (SIC) Codes that best describe the 

nature of the business in order of priority. 

VIII. WELL STATUS - Mark Box A if the well(s) were operating as injection wells on the effective date of the UIC Program for the 

State. Mark Box B if wells(s) existed on the effective date of the UIC Program for the State but were not utilized for injection. 

Box C should be marked if the application is for an underground injection project not constructed or not completed by the 

effective date of the UIC Program for the State. 

IX. TYPE OF PERMIT - Mark “Individual” or “Area” to indicate the type of permit desired. Note that area permits are at the 

discretion of the Director and that wells covered by an area permit must be at one site, under the control of one person and 

do not inject hazardous waste. If an area permit is requested the number of wells to be included in the permit must be 

specified and the wells described and identified by location. If the area has a commonly used name, such as the “Jay 

Field,” submit the name in the space provided. In the case of a project or field which crosses State lines, it may be 

possible to consider an area permit if EPA has jurisdiction in both States. Each such case will be considered individually, if 

the owner/operator elects to seek an area permit. 

X. CLASS AND TYPE OF WELL - Enter in these two positions the Class and type of injection well for which a permit is 

requested. Use the most pertinent code selected from the list on the reverse side of the application. When selecting type X 

please explain in the space provided. 

XI. LOCATION OF WELL - Enter the latitude and longitude of the existing or proposed well expressed in degrees, minutes, and 

seconds or the location by township, and range, and section, as required by 40 CFR Part 146. If an area permit is being 

requested, give the latitude and longitude of the approximate center of the area. 

XII. INDIAN LANDS - Place an “X” in the box if any part of the facility is located on Indian lands. 

XIII. ATTACHMENTS - Note that information requirements vary depending on the injection well class and status. Attachments 

for Class I, II, III are described on pages 4 and 5 of this document and listed by Class on page 2. Place EPA ID number in 

the upper right hand corner of each page of the Attachments. 

XIV. CERTIFICATION - All permit applications (except Class II) must be signed by a responsible corporate officer for a 

corporation, by a general partner for a partnership, by the proprietor of a sole proprietorship, and by a principal executive or 

ranking elected official for a public agency. For Class II, the person described above should sign, or a representative duly 

authorized in writing. 

EPA Form 7520-6 Page 3 of 6 
INSTRUCTIONS - Attachments 

Attachments to be submitted with permit application for Class I, II, III and other wells. 

A. AREA OF REVIEW METHODS - Give the methods 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 well bore 

unless the use of an equation is approved in advance by the Director. 

B. MAPS OF WELL/AREA AND AREA OF REVIEW - Submit a topographic map, extending one mile beyond the property 

boundaries, showing the injection well(s) or project area for which a permit is sought and the applicable area of 

review. The map must show all intake and discharge structures and all hazardous waste treatment, storage, or 

disposal facilities.If the application is for an area permit, the map should show the distribution manifold (ifapplicable) 

applying injection fluid to all wells in the area, including all system monitoring points. Within the area of review, the 

map must show the following: 

Class I 

The number, or name,and location ofall producing wells,injection wells, abandoned wells,dryholes,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.In addition,the map must identify thosewells,springs,other 

surface water bodies, and drinking water wells located within one quarter mile of the facility property boundary. Only 

information of public record is required to be included in this map; 

Class II 

In addition to requirements for Class I, include pertinent information known to the applicant. This requirement 

does not apply to existing Class II wells; 

Class III 

In addition to requirements for Class I, include public water systems and pertinent information known to the 

applicant. 

C. CORRECTIVE ACTION PLANANDWELL DATA - Submita tabulation of data reasonably available from public records 

or otherwise known to the applicant on all wells within the area of review, including those on the map required in B, 

which penetrate the proposed injection zone. Such data shall include the following: 

Class I 

Adescription ofeach well's types,construction,date drilled,location,depth,record ofplugging and/or completion,and 

any additional information the Director may require. In the case of new injection wells, include the corrective action 

proposed to be taken by the applicant under 40 CFR 144.55. 

Class II 

In addition to requirement for Class I, in the case of Class II wells operating overthe fracture pressure ofthe injection 

formation, all known wells within the area ofreview which penetrate formations affected by the increase in pressure. 

This requirement does not apply to existing Class II wells. 

Class III 

In addition to requirements for Class I, the corrective action proposed under 40 CFR 144.55 for all Class III wells. 

D. MAPS AND CROSS SECTION OF USDWs - Submit maps and cross sections indicating the vertical limits of all 

underground sources of drinking water within the area of review (both vertical and lateral limits for Class I), their 

position relative to the injection formation and the direction of water movement, where known, in every underground 

source of drinking water which may be affected by the proposed injection. (Does not apply to Class II wells.) 

EPA Form 7520-6 Page 4 of 6 
E. NAME AND DEPTH OF USDWs (CLASS II) - For Class II wells, submit geologic name, and depth to bottom of all 

underground sources of drinking water which may be affected by the injection. 

F. MAPS ANDCROSSSECTIONS OFGEOLOGICSTRUCTUREOF AREA - Submit maps and cross sections detailing the 

geologic structure ofthe local area (including the lithology of injection and confining intervals) and generalized maps 

and cross sections illustrating the regional geologic setting. (Does not apply to Class II wells.) 

G. GEOLOGICAL DATA ON INJECTION AND CONFINING ZONES (Class II) - For Class II wells, submit appropriate 

geological data ontheinjectionzone and confining zones including lithologic description,geological name,thickness, 

depth and fracture pressure. 

H. OPERATING DATA - Submit the following proposed operating data for each well (including all those to be covered by 

area permits): (1) average and maximum dailyrate and volumeofthe fluids to be injected; (2) average and maximum 

injection pressure; (3) nature of annulus fluid; (4) for Class I wells, source and analysis of the chemical, physical, 

radiological and biological characteristics, including density and corrosiveness, of injection fluids; (5) for Class II 

wells, source and analysis of the physical and chemical characteristics of the injection fluid; (6) for Class III wells, a 

qualitative analysis and ranges in concentrations ofall constituents ofinjected fluids. If the information is proprietary, 

maximum concentrations only may be submitted, but all records must be retained. 

I. FORMATION TESTING PROGRAM - Describe the proposed formation testing program.For Class Iwells the program 

must be designed to obtain data on fluid pressure, temperature, fracture pressure, other physical, chemical, and 

radiological characteristics of the injection matrix and physical and chemical characteristics of the formation fluids. 

For Class II wells the testing program must be designed to obtain data on fluid pressure, estimated fracture 

pressure, physical and chemical characteristics of the injection zone. (Does not apply to existing Class II wells or 

projects.) 

For Class III wells the testing must be designed to obtain data on fluid pressure,fracture pressure, and physical and 

chemical characteristics of the formation fluids if the formation is naturally water bearing. Only fracture pressure is 

required if the program formation is not water bearing. (Does not apply to existing Class III wells or projects.) 

J. STIMULATION PROGRAM - Outline any proposed stimulation program. 

K. INJECTION PROCEDURES - Describe the proposed injection procedures including pump, surge, tank, etc. 

L. CONSTRUCTIONPROCEDURES - Discuss the construction procedures (according to §146.12 for Class I, §146.22 for 

Class II, and §146.32 for Class III) to be utilized. This should include details of the casing and cementing program, 

logging procedures, deviation checks, and the drilling, testing and coring program, and proposed annulus fluid. 

(Request and submission of justifying data must be made to use an alternative to packer for Class I.) 

M. CONSTRUCTION DETAILS - Submit schematic or other appropriate drawings of the surface and subsurface 

construction details of the well. 

N. CHANGES IN INJECTED FLUID - Discuss expected changes in pressure, native fluid displacement, and direction of 

movement of injection fluid. (Class III wells only.) 

O. PLANS FOR WELL FAILURES - Outline contingency plans (proposed plans, if any, for Class II) to cope with all 

shut-ins or wells failures, so as to prevent migration of fluids into any USDW. 

P. MONITORING PROGRAM - Discuss the planned monitoring program. This should be thorough, including maps 

showing the number and location ofmonitoring wells as appropriate and discussion ofmonitoring devices,sampling 

frequency, and parameters measured. If a manifold monitoring program is utilized, pursuant to §146.23(b)(5), 

describe the program and compare it to individual well monitoring. 

Q. PLUGGING AND ABANDONMENT PLAN - Submit a plan for plugging and abandonment of the well including: (1) 

describe the type, number, and placement (including the elevation of the top and bottom) of plugs to be used; (2) 

describe the type, grade, and quantity of cement to be used; and (3) describe the method to be used to place plugs, 

including the method used to place the well in a state of static equilibrium prior to placement of the plugs. Also for a 

Class III well that underlies or is in an exempted aquifer, demonstrate adequate protection of USDWs. Submit this 

information on EPA Form 7520-14, Plugging and Abandonment Plan. 

EPA Form 7520-6 Page 5 of 6 
R. NECESSARY RESOURCES - Submit evidence such as a surety bond or financial statement to verify that the 

resources necessary to close, plug or abandon the well are available. 

S. AQUIFEREXEMPTIONS - Ifan aquifer exemption is requested,submit data necessary to demonstrate that the aquifer 

meets the following criteria:(1) does notserve 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 reasonablyexpected to supply a public water system. Data to demonstrate that the aquifer is 

expected to be mineral or hydrocarbon production, such as general description of the mining zone, analysis of the 

amenability of the mining zone to the proposed method, and time table for proposed development must also be 

included. For additional information on aquifer exemptions, see 40 CFR Sections 144.7 and 146.04. 

T. EXISTING EPA PERMITS - List program and permit number of any existing EPA permits, for example, NPDES, 

PSD, RCRA, etc. 

U. DESCRIPTION OF BUSINESS - Give a brief description of the nature of the business. 

EPA Form 7520-6 Page 6 of 6 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Name and Address of Existing Permittee 

Application To Transfer Permit 

Locate Well and Outline Unit on 

Section Plat - 640 Acres 

Attach to this application a written agreement between the existing and new permittee containing a 

specific date for transfer of permit responsibility, coverage, and liability betweend them. 

Certification 

Name and Official Title Date Signed 

Name and Address of Surface Owner 

State County Permit Number 

N 

W E 

S 

Surface Location Description 

____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of 

Locate well in two directions from nearest lines of quarter section and drilling unit 

Surface 

Location ____ ft. frm (N/S) ____ Line of quarter section 

and ____ ft. from (E/W) ____ Line of quarter section. 

Well Activity Well Status Type of Permit 

____ Class I 

____ Class II 

____ Class III 

____ Other 

____ Brine Disposal 

____ Enhanced Recovery 

____ Hydrocarbon Storage 

Lease Number Well Number 

____ Operating 

____ Modification/Conversion 

____ Proposed 

____ Individual 

____ Area 

Number of Wells ____ 

Name(s) and Address(es) of New Owner(s) Name and Address of New Operator 

The new permittee must show evidence of financial responsibility by the submission of a surety bond, or 

other adequate assurance, such as financial statements or other materials acceptable to the Director. 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in 

this document and all attachments and that, based on my inquiry of those individuals immediately responsible for 

obtaining the information, I believe that the information is true, accurate, and complete. 

(Please type or print) Signature 

significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32) 

Section ____ Township ____ Range ____

I am aware that there are 

EPA Form 7520-7 (Rev. 8-01) 
PAPERWORK REDUCTION ACT 

The public reporting and record keeping burden for this collection ofinformation is estimated to average 5 hours per response. 

Burden means the total time, effort, or financial resource 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 the collection of information; search data 

sources;complete and review the collection ofinformation;and,transmitor otherwisedisclosethe information.An agencymay 

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. Send comments 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 to Director, Collection Strategies Division,U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., 

NW., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed forms to 

this address. 

Well Class and Type Code 

Class I Wells used to inject waste below the deepest underground source of drinking water. 

Type “I” Nonhazardous industrial disposal well 

“M” Nonhazardous municipal disposal well 

“W” Hazardous waste disposal well injecting below USDWs 

“X” Other Class I wells (not included in Type “I,” “M,” or “W”) 

Class II Oil and gas production and storage related injection wells. 

Type “D” Produced fluid disposal well 

“R” Enhanced recovery well 

“H” Hydrocarbon storage well (excluding natural gas) 

“X” Other Class II wells (not included in Type “D,” “R,” or “H”) 

Class III Special process injection wells. 

Type “G” Solution mining well 

“S” Sulfur mining well by Frasch process 

“U” Uranium mining well 

“X” Other Class III wells (not included in Type “G,” “S,” or “U”) 

Other Classes Wells not included in classes above. 

Class V wells which may be permitted under § 144.12 

Wells not currently classified as Class I, II, III, or V 

EPA Form 7520-7 (8-01) Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Injection Well Monitoring Report 

Year Month Month Month 

Injection Pressure (PSI) 

1. Minimum 

2. Average 

3. Maximum 

Injection Rate (Gal/Min) 

1. Minimum 

2. Average 

3. Maximum 

Annular Pressure (PSI) 

1. Minimum 

2. Average 

3. Maximum 

Injection Volume (Gal) 

1. Monthly Total 

2. Yearly Cumulative 

Temperature (F °) 

1. Minimum 

2. Average 

3. Maximum 

pH 

1. Minimum 

2. Average 

3. Maximum 

Other 

Name and Address of Permittee Permit Number 

Name and Official Title (Please type or print) Signature Date Signed 

EPA Form 7520-8 (Rev. 8-01) 
Paperwork Reduction Act 

The public reporting and record keeping burden for this collection of information is estimated to average 5.7 

hours per year for operators of Class I wells and 30 hours per quarter for operators of Class III wells. Burden 

means the total time, effort, or financial resource 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 the 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. Send comments 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 to Director, Collection Strategies Division, U.S. 

Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include 

the OMB control number in any correspondence. Do not send the completed forms to this address. 

EPA Form 7520-8 Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Completion Form For Injection Wells 

Administrative Information 

1. Permittee 

Address (Permanent Mailing Address) (Street, City, and ZIP Code) 

2. Operator 

Address (Street, City, State and ZIP Code) 

3. Facility Name Telephone Number 

Address (Street, City, State and ZIP Code) 

4. Surface Location Description of Injection Well(s) 

State County 

Surface Location Description 

____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of Section ____ Township ____ Range ____ 

Locate well in two directions from nearest lines of quarter section and drilling unit 

Surface 

Location ____ ft. frm (N/S) ____ Line of quarter section 

and ____ ft. from (E/W) ____ Line of quarter section. 

Well Activity Well Status Type of Permit 

____ Class I 

____ Class II 

____ Class III 

____ Other 

____ Brine Disposal 

____ Enhanced Recovery 

____ Hydrocarbon Storage 

Lease Number _______________ Well Number _______________ 

____ Operating 

____ Modification/Conversion 

____ Proposed 

____ Individual 

____ Area : Number of Wells ____ 

Submit with this Completion Form the attachments listed in Attachments for Completion Form. 

Certification 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in 

this document and all attachments and that, based on my inquiry of those individuals immediately responsible for 

obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are 

significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32) 

Name and Official Title (Please type or print) Signature Date Signed 

EPA Form 7520-9 (Rev. 8-01) 
PAPERWORK REDUCTION ACT 

The public reporting and record keeping burden for this collection of information is estimated to average 49 hours per response for a Class I 

hazardous facility, and 47 hours per response for a Class I non-hazardous facility. Burden means the total time, effort, or financial resource 

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 the 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. Send comments 

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 to Director, Collection StrategiesDivision, U.S. Environmental Protection 

Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send 

the completed forms to this address. 

Attachments to be submitted with the Completion report: 

I. Geologic Information 

1. Lithology and Stratigraphy 

A. Provide a geologic description of the rock units penetrated by name, age, depth, thickness, and lithology of

each rock unit penetrated.

B. Provide a description of the injection unit.

(1) Name

(2) Depth (drilled)

(3) Thickness

(4) Formation fluid pressure

(5) Age of unit

(6) Porosity (avg.)

(7) Permeability

(8) Bottom hole temperature

(9) Lithology

(10) Bottom hold pressure

(11) Fracture pressure

C. Provide chemical characteristics of formation fluid 

(attach chemical analysis). 

D. Provide a description of freshwater aquifers.

(1) Depth to base of fresh water (less than 10,000 mg/l

TDS).

(2) Provide a geologic description of aquifer units with

name, age, depth, thickness, lithology, and average total

dissolved solids.

II. Well Design and Construction 

1. Provide data on surface, intermediate, and long string 

casing and tubing. Data must include material, size, 

weight, grade, and depth set. 

2. Provide data on the well cement, such as type/class, 

additives, amount, and method of emplacement. 

3. Provide packer data on the packer (if used) such as 

type, name and model, setting depth, and type of annular 

fluid used. 

4. Provide data on centralizers to include number, type 

and depth. 

5. Provide data on bottom hole completions. 

6. Provide data on well stimulation used. 

III. Description of Surface Equipment 

1. Provide data and a sketch of holding tanks, flow lines, 

filters, and injection pump. 

IV. Monitoring Systems 

1. Provide data on recording and nonrecording injection 

pressure gauges, casing-tubing annulus pressure 

gauges, injection rate meters, temperature meters, and 

other meters or gauges. 

2. Provide data on constructed monitor wells such as 

location, depth, casing diameter, method of cementing, 

etc. 

V. Logging and Testing Results 

Provide a descriptive report interpreting the results of 

geophysical logs and other tests. Include a description 

and data on deviation checks run during drilling. 

VI. Provide an as-built diagrammatic sketch of the injection well(s) showing casing, cement, tubing, packer, etc., 

with proper setting depths. The sketch should include 

well head and gauges. 

VII. Provide data demonstrating mechanical integrity 

pursuant to 40 CFR 146.08. 

VIII. Report on the compatibility of injected wastes with 

fluids and minerals in both the injection zone and the 

confining zone. 

IX. Report the status of corrective action on defective 

wells in the area of review. 

X. Include the anticipated maximum pressure and flow 

rate at which injection will operate. 

EPA Form 7520-9 Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Name and Address of Existing Permittee 

COMPLETION REPORT FOR BRINE DISPOSAL, 

HYDROCARBON STORAGE, OR ENHANCED RECOVERY 

Locate Well and Outline Unit on 

Section Plat - 640 Acres 

Certification 

Name and Official Title Date Signed 

Name and Address of Surface Owner 

State County Permit Number 

N 

W E 

S 

Surface Location Description 

____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of 

Locate well in two directions from nearest lines of quarter section and drilling unit 

Surface 

Location ____ ft. frm (N/S) ____ Line of quarter section 

and ____ ft. from (E/W) ____ Line of quarter section. 

WELL ACTIVITY TYPE OF PERMIT 

Brine Disposal 

Enhanced Recovery 

Hydrocarbon Storage 

Individual 

Area 

Number of Wells ____ 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all 

attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the 

information is true, accurate, and complete. 

possibliity of fine and imprisonment. 

(Please type or print) Signature 

Estimated Fracture Pressure 

of Injection Zone 

Anticipated Daily Injection Volume (Bbls) Injection Interval 

Average Maximum Feet to Feet 

Anticipated Daily Injection Pressure (PSI) 

Average Maximum 

Depth to Bottom of Lowermost Freshwater 

Formation (Feet) 

Type of Injection Fluid (Check the appropriate block(s)) Lease Name Well Number 

Salt Water Brackish Water Fresh Water 

Liquid Hydrocarbon Other 

Name of Injection Zone 

Permeability of Injection Zone 

Porosity of Injection Zone 

Date Drilling Began Date Well Completed 

Date Drilling Completed 

CASING AND TUBING CEMENT HOLE 

OD Size Wt/Ft - Grade - New or Used Depth Sacks Class Depth Bit Diameter 

INJECTION ZONE STIMULATION WIRE LINE LOGS, LIST EACH TYPE 

Interval Treated Materials and Amount Used Log Types Logged Intervals 

Complete Attachments A -- E listed on the reverse. 

Section ____ Township ____ Range ____

I am aware that there are significant penalties for submitting false information, including the 

(Ref. 40 CFR 144.32) 

EPA Form 7520-10 (Rev. 8-01) 
ATTACHMENTS

A. Present a schematic or other appropriate drawing of the surface and subsurface 

construction details of the well as built. 

B. Describe the method and results of mechanical integrity testing. 

C. Present the results of that portion of those logs, test, and cores which specifically 

relate to (1) underground sources of drinking water and the confining zone(s) and 

(2) the injection and adjacent formations. 

D. Present the status of corrective action on defective wells in the area of review. 

E. Provide to EPA, with the completion report, one final print of all geophysical logs 

run. 

PAPERWORK REDUCTION ACT 

The public reporting and record keeping burden for this collection of information is estimated to average 4 hours 

per well. Burden means the total time, effort, or financial resource 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 the 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. Send comments 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 to Director, Collection Strategies Division, U.S. Environmental Protection 

Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the OMB control number in 

any correspondence. Do not send the completed forms to this address. 

EPA Form 7520-10 Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Name and Address of Existing Permittee 

ANNUAL DISPOSAL/INJECTION WELL MONITORING REPORT 

Locate Well and Outline Unit on 

Section Plat - 640 Acres 

Certification 

Name and Official Title Date Signed 

Name and Address of Surface Owner 

State County Permit Number 

N 

W E 

S 

Surface Location Description 

____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of 

Locate well in two directions from nearest lines of quarter section and drilling unit 

Surface 

Location ____ ft. frm (N/S) ____ Line of quarter section 

and ____ ft. from (E/W) ____ Line of quarter section. 

WELL ACTIVITY TYPE OF PERMIT 

Brine Disposal 

Enhanced Recovery 

Hydrocarbon Storage 

Individual 

Area 

Number of Wells ____ 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all 

attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the 

information is true, accurate, and complete. 

possibliity of fine and imprisonment. 

(Please type or print) Signature 

INJECTION PRESSURE 

Lease Name Well Number 

TOTAL VOLUME INJECTED 

TUBING -- CASING ANNULUS PRESSURE 

(OPTIONAL MONITORING) 

MONTH YEAR AVERAGE PSIG MAXIMUM PSIG BBL MCF MINIMUM PSIG MAXIMUM PSIG 

Section ____ Township ____ Range ____

I am aware that there are significant penalties for submitting false information, including the 

(Ref. 40 CFR 144.32) 

EPA Form 7520-11 (Rev. 8-01) 
PAPERWORK REDUCTION ACT 

The public reporting and record keeping burden for this collection of information is estimated to average 25 hours annually for 

operators of Class I wells and 5 hours annually for operators of Class II wells. Burden means the total time, effort, or financial 

resource 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 the 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. Send comments 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 to Director, Collection Strategies Division, U.S. Environmental 

Protection Agency (2822), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any 

correspondence. Do not send the completed forms to this address. 

EPA Form 7520-11 Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Name and Address of Permittee 

WELL REWORK RECORD 

Locate Well and Outline Unit on 

Section Plat - 640 Acres 

Certification 

Name and Official Title Date Signed 

Name and Address of Contractor 

State County Permit Number 

N 

W E 

S 

Surface Location Description 

____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of 

Locate well in two directions from nearest lines of quarter section and drilling unit 

Surface 

Location ____ ft. frm (N/S) ____ Line of quarter section 

and ____ ft. from (E/W) ____ Line of quarter section. 

WELL ACTIVITY TYPE OF PERMIT 

Brine Disposal 

Enhanced Recovery 

Hydrocarbon Storage 

Individual 

Area 

Number of Wells ____ 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all 

attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the 

information is true, accurate, and complete. 

possibliity of fine and imprisonment. 

(Please type or print) Signature 

WELL CASING RECORD -- BEFORE REWORK 

Lease Name Well Number 

Casing 

DESCRIBE REWORK OPERATIONS IN DETAIL 

USE ADDITIONAL SHEETS IF NECESSARY 

WIRE LINE LOGS, LIST EACH TYPE 

Log Types Logged Intervals 

Total Depth Before Rework 

Total Depth After Rework 

Date Rework Commenced 

Date Rework Completed 

Cement Perforations Acid or Fracture 

Size Depth Sacks Type From To Treatment Record

WELL CASING RECORD -- AFTER REWORK (Indicate Additions and Changes Only) 

Casing Cement Perforations Acid or Fracture 

Size Depth Sacks Type From To Treatment Record

Section ____ Township ____ Range ____

I am aware that there are significant penalties for submitting false information, including the 

(Ref. 40 CFR 144.32) 

EPA Form 7520-12 (Rev. 8-01) 
PAPERWORK REDUCTION ACT 

The public reporting and record keeping burden for this collection of information is estimated to average 4 hours per 

response annually. Burden means the total time, effort, or financial resource 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 the 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. Send comments 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 to Director, Collection Strategies 

Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include 

the OMB control number in any correspondence. Do not send the completed forms to this address. 

EPA Form 7520-12 Reverse 
OMB No. 2040-0042 Approval Expires 1/31/05 

United States Environmental Protection Agency 

Washington, DC 20460 

Name and Address of Facility 

PLUGGING AND ABANDONMENT PLAN 

Locate Well and Outline Unit on 

Section Plat - 640 Acres 

Certification 

Name and Official Title Date Signed 

Name and Address of Owner/Operator 

State County Permit Number 

N 

W E 

S 

Surface Location Description 

____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of 

Locate well in two directions from nearest lines of quarter section and drilling unit 

Surface 

Location ____ ft. frm (N/S) ____ Line of quarter section 

and ____ ft. from (E/W) ____ Line of quarter section. 

TYPE OF AUTHORIZATION WELL ACTIVITY

Brine Disposal 

Enhanced Recovery 

Hydrocarbon Storage 

Individual Permit 

Area Permit 

Number of Wells ____ 

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all 

attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the 

information is true, accurate, and complete. 

possibliity of fine and imprisonment. 

(Please type or print) Signature 

CASING AND TUBING RECORD AFTER PLUGGING 

Lease Name Well Number 

LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED (if any) 

From 

SIZE WT (LB/FT) TO BE PUT IN WELL (FT) TO BE LEFT IN WELL (FT) HOLE SIZE 

CEMENTING TO PLUG AND ABANDON DATA: PLUG #1 

Rule 

CLASS I 

CLASS II 

CLASS III 

METHOD OF EMPLACEMENT OF CEMENT PLUGS 

The Balance Method 

The Dump Bailer Method 

The Two-Plug Method 

Other 

PLUG #2 PLUG #3 PLUG #4 PLUG #5 PLUG #6 PLUG #7 

Size of Hole or Pipe in which Plug Will Be Placed (inches) 

Depth to Bottom of Tubing or Drill Pipe (ft.) 

Sacks of Cement To Be Used (each plug) 

Slurry Volume To Be Pumped (cu. ft.) 

Calculated Top of Plug (ft.) 

Measured Top of Plug (if tagged ft.) 

Slurry Wt. (Lb./Gal.) 

Type Cement or Other Material (Class III) 

To From To 

Estimated Cost to Plug Wells 

Section ____ Township ____ Range ____

I am aware that there are significant penalties for submitting false information, including the 

(Ref. 40 CFR 144.32) 

EPA Form 7520-14 (Rev. 8-01) 
Paperwork Reduction Act Notice 

The public reporting and record keeping burden for this collection of information is 

estimated to average 19.5 hours annually for operators of Class I wells, 6 hours 

annually for operators of Class II wells, and 8 hours annually for operators of Class III 

wells. 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; adjust the 

existing ways to comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to the 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. 

Please send comments 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 to Director, Office of 

Environmental Information, Collection Strategies Division, U.S. Environmental 

Protection Agency (2822), Ariel Rios Building, 1200 Pennsylvania Ave., NW., 

Washington, DC 20460; and to the Office of Information and Regulatory Affairs, Office 

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

Desk Officer for EPA. Please include the EPA ICR number and OMB control number 

in any correspondence. 

EPA Form 7520-14 Reverse 
Type or print all information. See reverse for instructions. OMB No. 2040-0042 Approval Expires 1/31/05 

(This information is collected under the authority of the Safe Drinking Water Act) 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

INVENTORY OF INJECTION WELLS 

Deletion 

YR 

PAPERWORK REDUCTION ACT NOTICE 

OFFICE OF GROUND WATER AND DRINKING WATER 

1. DATE PREPARED (Year, Month, Day) 2. FACILITY ID NUMBER

MO DY 

The public reporting burden for this collection of information is estimated at about 0.5 hour per response, including time for reviewing 

instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection 

of information. 

suggestions for reducing this burden, to Chief, Information Policy Branch, 2136, U.S. Environmental Protection Agency, 401 M Street, 

SW, Washington, DC 

3. TRANSACTION TYPE (Please mark one of the following) 

Entry Change 

First Time Entry 

Replacement 

4. FACILITY NAME AND LOCATION 

A. NAME (last, first, and middle initial) C. LATITUDE 

. TOWNSHIP RANGE SECT

DEG MIN SEC E. TOWNSHIP/RANGE 

1/4 SECT 

. 

DEG MIN SEC B. STREET ADDRESS/ROUTE NUMBER D. LONGITUDE

F. CITY/TOWN G. STATE H. ZIP CODE I. NUMERIC 

COUNTY CODE 

J. INDIAN LAND 

(mark "x") Yes No 

5. LEGAL CONTACT: 

A. TYPE (mark "x") 

Owner Operator 

C. PHONE 

(area code 

and number) 

B. NAME (last, first, and middle initial) 

D. ORGANIZATION E. STREET/P.O. BOX 

F. CITY/TOWN G. STATE H. ZIP CODE 

I. OWNERSHIP (mark "x") 

PRIVATE 

STATE 

PUBLIC 

FEDERAL 

SPECIFY OTHER 

6. WELL INFORMATION: 

A. CLASS 

AND 

TYPE 

C. TOTAL 

NUMBER 

OF WELLS 

B. NUMBER OF WELLS D. WELL OPERATION STATUS 

COMM NON-COMM UC AC TA PA AN 

COMMENTS (Optional): 

KEY: DEG = Degree 

MIN = Minute 

SEC = Second 

SECT = Section 

1/4 SECT = Quarter Section 

COMM = Commercial 

NON-COMM = Non-Commercial 

AC = Active 

UC = Under Construction 

TA = Temporarily Abandoned 

PA = Permanently Abandoned and Approved by State 

AN = Permanently Abandoned and not Approved by State 

Send comments regarding the burden estimate or any other aspect of this collection of information, including 

20460, and to the Office of Management and Budget, Paperwork Reduction Project, Washington, DC 20503.

EPA Form 7520-16 (Rev. 8-01) 
INSTRUCTIONS AND DEFINITIONS 

SECTION 1. DATE PREPARED: Enter date in order of year, month, 

and day. 

SECTION 2. FACILITY ID NUMBER: In the first two spaces, insert 

the appropriate U.S. Postal Service State Code. In the third space, insert 

one of the following one letter alphabetic identifiers: 

D - DUNS Number, 

G - GSA Number, or 

S - State Facility Number. 

In the remaining spaces, insert the appropriate nine digit DUNS, GSA, or 

State Facility Number. For example, A Federal facility (GSA -

123456789) located in Virginia would be entered as : VAG123456789. 

SECTION 3. TRANSACTION TYPE: Place an “x” in the applicable 

box. See below for further instructions. 

Deletion. Fill in the Facility ID Number. 

First Time Entry. Fill in all the appropriate information. 

Entry Change. Fill in the Facility ID Number and the information 

that has changed. 

Replacement. 

SECTION 4. FACILITY NAME AND LOCATION: 

A. Name. Fill in the facility’s official or legal name. 

B. Street Address. Self Explanatory. 

C. Latitude. Enter the facility’s latitude (all latitudes assume 

North Except for American Samoa). 

D. Longitude. Enter the facility’s longitude (all longitudes assume 

West except Guam). 

E. Township/Range. Fill in the complete township and range. 

The first 3 spaces are numerical and the fourth is a letter 

(N,S,E,W) specifying a compass direction. A township is North 

or South of the baseline, and a range is East or West of the 

principal meridian (e.g., 132N, 343W). 

F. City/Town. Self Explanatory. 

G. State. Insert the U.S. Postal Service State abbreviation. 

H. Zip Code. Insert the five digit zip code plus any extension. 

SECTION 4. FACILITY NAME & LOCATION (CONT’D.): 

I. Numeric County Code. Insert the numeric county code from 

the Federal Information Processing Standards Publication (FIPS 

Pub 6-1) June 15, 1970, U.S. Department of Commerce, 

National Bureau of Standards. For Alaska, use the Census Division 

Code developed by the U.S. Census Bureau. 

J. Indian Land. Mark an “x” in the appropriate box (Yes or No) 

to indicate if the facility is located on Indian land. 

SECTION 5. LEGAL CONTACT: 

A. Type. Mark an “x” in the appropriate box to indicate the type 

of legal contact (Owner or Operator). For wells operated by lease, 

the operator is the legal contact. 

B. Name. Self Explanatory. 

C. Phone. Self Explanatory. 

D. Organization. If the legal contact is an individual, give the 

name of the business organization to expedite mail distribution. 

E. Street/P.O. Box. Self Explanatory. 

F. City/Town. Self Explanatory. 

G. State. Insert the U.S. Postal Service State abbreviation. 

H. Zip Code. Insert the five digit zip code plus any extension. 

I. Ownership. Place an “x” in the appropriate box to indicate 

ownership status. 

SECTION 6. WELL INFORMATION: 

A. Class and Type. Fill in the Class and Type of injection wells 

located at the listed facility. Use the most pertinent code 

(specified below) to accurately describe each type of injection 

well. For example, 2R for a Class II Enhanced Recovery Well, or 

3M for a Class III Solution Mining Well, etc. 

B. Number of Commercial and Non-Commercial Wells. 

Enter the total number of commercial and non-commercial wells 

for each Class/Type, as applicable. 

C. Total Number of Wells. Enter the total number of injection 

wells for each specified Class/Type. 

D. Well Operation Status. Enter the number of wells for each 

Class/Type under each operation status (see key on other side). 

INJECTION WELL CLASS AND TYPE CODES 

CLASS I Industrial, Municipal, and Radioactive Waste Disposal Wells 

used to inject waste below the lowermost Underground Source of Drinking 

Water (USDW). 

TYPE 1I Non-Hazardous Industrial Disposal Well. 

1M Non-Hazardous Municipal Disposal Well. 

1H Hazardous Waste Disposal Well injecting below the 

lowermost USDW. 

1R Radioactive Waste Disposal Well. 

1X Other Class I Wells. 

CLASS II Oil and Gas Production and Storage Related Injection Wells. 

TYPE 2A Annular Disposal Well. 

2D Produced Fluid Disposal Well. 

2H Hydrocarbon Storage Well. 

2R Enhanced Recovery Well. 

2X Other Class II Wells. 

CLASS III Special Process Injection Wells. 

TYPE 3G In Situ Gassification Well 

3M Solution Mining Well. 

CLASS III (CONT’D.) 

TYPE 3S Sulfur Mining Well by Frasch Process. 

3T Geothermal Well. 

3U Uranium Mining Well. 

3X Other Class III Wells. 

CLASS IV Wells that inject hazardous waste into/above USDWs. 

TYPE 4H Hazardous Facility Injection Well. 

4R Remediation Well at RCRA or CERCLA site. 

CLASS V Any Underground Injection Well not included in Classes I 

through IV. 

TYPE 5A Industrial Well. 

5B Beneficial Use Well. 

5C Fluid Return Well. 

5D Sewage Treatment Effluent Well. 

5E Cesspools (non-domestic). 

5F Septic Systems. 

5G Experimental Technology Well. 

5H Drainage Well. 

5I Mine Backfill Well. 

5J Waste Discharge Well. 

EPA Form 7520-16 (Revised 8-01) 
PAPERWORK REDUCTION ACT The public reporting and record keeping burden for this collection of information is

estimated to average 0.5 hours per response. Burden means the total time, effort, or financial resource 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 the 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. Send comments 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 to Director, Collection Strategies

Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the

OMB control number in any correspondence. Do not send the completed forms to this address. 

EPA Form 7520-16 (Revised 8-01) 
United States Environmental Protection Agency

UIC Federal Reporting System

Class V Well Pre-Closure Notification Form

1. Name of facility:

Address of facility:

City/Town: State: Zip Code:

County: Location: Lat./Long.:

2. Name of Owner/Operator:

Address of Owner/Operator:

City/Town: State: Zip Code:

Legal contact: Phone number:

3. Type of well(s): Number of well(s):

4. Well construction (check all that apply):

Drywell Septic tank Cesspool

Improved sinkhole Drainfield/leachfield Other

5. Type of discharge:

6. Average flow (gallons/day): 7. Year of well construction:

8. Type of well closure (check all that apply):

Sample fluids/sediments Clean out well

Appropiate disposal of remaining fluids/sediments Install permanent plug

Remove well & any contaminated soil Conversion to other well type

Other (describe):

9. Proposed date of well closure:

10.Name of preparer: Date:

Certification

I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32).

Name and Official Title (Please type or print) Signature Date Signed

Type or print all information. See reverse for instructions Form Approved 12/99 OMB No. 2040-0214

EPA Form 7520-17
INSTRUCTIONS FOR EPA FORM 7520-17

This form contains the minimum information that you must provide your UIC Program Director if you intend to close your Class V well. This form

will be used exclusively where the EPA administers the UIC Program: AK, AS, AZ, CA, CO, DC, DE, HI, IA, IN, KY, MI, MN, MT, NY, PA, SD, TN, VA, VI,

and on all Tribal Lands. If you are located in a different State or jurisdiction, ask the agency that administers the UIC Program in your State for

the appropriate form.

If you are closing two or more Class V wells that are of similar construction at your facility (two dry wells, for example) you may use one form. If

you are closing Class V wells of different construction (a septic system and a dry well, for example) use one form per construction type.

The numbers below correspond to the numbers on the form.

1. Supply the name and street address of the facility where the Class V well(s) is located. Include the City/Town, State (U.S. Postal Service

abbreviation) and Zip Code. If there is no street address for the Class V well, provide the route number or locate the well(s) on a map and

attach it to this form. Under "Location," provide the Latitude/Longitude of the well, if available.

2. Provide the name and mailing address of the owner of the facility, or if the facility is operated by lease, the operator of the facility. Include

the name and phone number of the legal contact for any questions regarding the information provided on this form.

3. Indicate the type of Class V well that you intend to close (for example, motor vehicle waste disposal well or cesspool). Provide the number

of wells of this well type at your location that will be closed.

4. Mark an "X" in the appropriate box to indicate the type of well construction. Mark all that apply to your situation. For example, for a septic tank that drains into a drywell, mark both the "septic tank" and "drywell" boxes. Please provide a generalized sketch or schematic of

the well construction if available.

5. List or describe the types of fluids that enter the Class V well. If available, attach a copy of the chemical analysis results and/or the

Material Safety Data Sheets for the fluids that enter the well.

6. Estimate the average daily flow into the well in gallons per day.

7. Provide the year that the Class V well was constructed. If unknown, provide the length of time that your business has been at this location

and used this well.

8. Mark an "X" in the appropriate box(s) to indicate briefly how the well closure is expected to proceed. Mark all that apply to your situation.

For example, all boxes except the "Remove well & any contaminated soil" and "Other" would be marked if: the connection of an automotive service bay drain leading to a septic tank and drainfield will be closed, but the septic system will continue to be used for washroom

waste disposal only, and the fluids and sludge throughout the system will be removed for proper disposal, the system cleaned, a cement

plug placed in the service bay drain and the pipe leading to the washroom connection, and the septic tank/drainfield remains open for septic use only. In this example, the motor vehicle waste disposal well is being converted to another well type (a large capacity septic system).

9. Self explanatory.

10. Self explanatory.

PLEASE READ . . .

The purpose of this form is to serve as the means for the Class V well owner or operator’s notice to the UIC Director of his/her intent to close the

well in accordance with Title 40 of the Code of Federal Regulations (40 CFR) Section 144.12(a). According to 40 CFR §144.86, you must notify the

UIC Program Director at least 30 days prior to well closure of your intent to close and abandon your well. Upon receipt of this form, if the

Director determines that more specific information is required to be submitted to ensure that the well closure will be conducted in a manner that

will protect underground sources of drinking water (as defined in 40 CFR §144.3), the Director can require the owner/operator to prepare, submit

and comply with a closure plan acceptable to, and approved by the Director.

Please be advised that this form is intended to satisfy Federal UIC requirements regarding pre-closure notification only. Other State, Tribal or

Local requirements may also apply.

Paper Work Reduction Act Notice

The public reporting and record keeping burden for this collection of information is estimated to average 1.5 hours per respondent.

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.

Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including thorough the use of automated collection techniques to the Director, Regulatory

information Division, U.S. Environmental Protection Agency (2137), 401 M. Street, S.W., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.

EPA Form 7520-17