# 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 .......................................................................................................... 1 2 3(f) Confidentiality ............................................................................................................... .. 13 3(g) Sensitive Questions ......................................................................................................... 1 3 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 ......................................................................................................... 2 9 6. Estimating the Burden and Cost of the Collection ................................................................. 33 6(a) Respondent Burden.......................................................................................................... 33 6(b) Respondent Costs ............................................................................................................ 3 8 6(c) Agency Burden and Costs ............................................................................................... 40 6(d) Estimating Respondent Universe an d 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 U nderground 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 Oper ator 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 Respond ent 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

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## 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 pur pose of the UIC Program is to establish a federal-state regulatory system to ensure that ac tual or potential undergro und sources of drinking water (USDWs) are not endangered by the underground injection of fluids.

Monitoring and enforcement are primarily ach ieved through initial, quarterly, and annual reporting requirements. Informati on is gathered both at the state 1 

## program level and at the EPA regional level. Each Region ha s 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 met hod by which primacy programs submit reports to EPA is transitioning from paper-based to electro nic reporting (e-reporting). Additional details on this process are located in Appe ndix B: The National UIC Database.

Section 144.6 of 40 CFR describes the six in jection well types (see Exhibit 2-1). EPA collects monitoring data and test results fr om operators of Class I, II, III, and VI 3 

## injection wells and a small percentage of Class V wells. Cla ss IV wells are banned—except for wells used to re-inject treated contaminated gr ound water into the same forma tion from which it was drawn as part of a clean-up authorized by the Resour ce Conservation and Rec overy Act (RCRA) or Comprehensive Environmental Response, Co mpensation, 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 ve hicle waste disposal wells (MVWDWs) in ground

1 

### Throughout this ICR, reference to “States” includ es 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 ag ency may oversee injection wells of various classes.

3 

### Class VI reporting requirements will only be estimated fo r 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.

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## Page 2 water protection areas or other state-defined se nsitive ground water areas to close these wells or apply for a permit to continue injecting. In gene ral, 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 st reamlined electronic dataflow. (Details on ereporting are included in Appendix B.)

EPA estimates that, over the 3 years c overed by this request , the total burden on underground injection well operato rs and Primacy agencies associated with UIC requirements will be 3,888,501 hours (an average of 1,296,167 hours pe r year), and the present value cost will be $584,526,184 (an average of $194,842,061 per ye ar). The public reporting and recordkeeping burden for this collection of info rmation 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 in formation collected pursuant to this ICR and the EPA Regions’ and Headquarters’ use of the colle cted data. Section 2(a) demonstrates both the need and legal authority for information colle ction. Need is demonstrated by describing the potential for contamination of USDWs and the st atutory requirements that justify information collection to prevent contamina tion. Legal authority is demons trated by identifying laws and regulations related to waste di sposal, injection wells, and th e 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 cont amination of current and potential USDWs by keeping in jected 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 summari zes information collection requirements to monitor for or prevent mi gration 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 in itial 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 injec tion. Wells that penetrate the injection area in the zone affected by th is pressure must be properl y constructed or plugged. For this reason, plans for plugging deficient we lls 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 fr actures in the confini ng 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 th at 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 initiate d in the confining bed zone.

Pathway 4: Direct Injection. Class IV wells, which inject into or above USDWs and have a high potential to enda nger human health, are banned. The exception is wells that are used in a RCRA/CERCLA-au thorized ground water remedi ation project. Most Class V wells inject nonhazardous fluids into or a bove formations that contain USDWs. These include, but are not limited to, MVWDWs, cess pools, agricultural dr ainage wells, storm water drainage wells, industrial drainage wells, and untreated se wage 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 larg e-capacity cesspools and requires operators of existing large-capacity cesspools to close their we lls. EPA also banned new MVWDWs and is requiring operators of existing MVWDWs in defined ground water protection areas or other sensitive ground wate r 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 in formation regarding the proximity of injection wells to USDWs is considered by the permitting authority in making a determination of whether the wells are prope rly sited. Well operators are required to control injection pressure and conduct mon itoring and testing to track any lateral migration of fluids.

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## 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 h azardous 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 subj ect to federal or state UIC programs must “establish and maintain such r ecords, make such reports, con duct such monitoring, and provide such information as the Administrator may reas onably require by regulati on to assist him in establishing regulations unde r this title . . .”

The specific requirements for the UIC Program are established in the Code of Federal Regulations (CFR), Title 40, Sections 144 through 148 4 

## as follows:

Section 144 - Underground Injection Control Program . This section describes the general requirements of the Pr ogram, authorizes certain type s of wells, defines permitting procedures, and establishes procedures for ensuring financial responsibility for proper closure of wells.

Section 145 - State UI C 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 standa rds that various classes of underground injection wells must meet. Monitoring and reporting criter ia are outlined for each well class.

Section 147- State UIC Programs . This section describes the provisions of the UIC programs of individual st ates’, territories’, and tribes’ primacy programs.

Section 148 - Hazardous Waste Injection Restrictions . This section identifies hazardous wastes that are restricted from di sposal 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 (CO 2 

### ), captured from an industrial or energy-related source into de ep subsurface rock formati ons for long-term storage.

### Underground Injection Control Program – Information Collection Request 

## Page 5 These CFR Sections contain information colle ction requirements that are applicable to operators of underground injec tion wells and to administrato rs of primacy and direct implementation (DI) programs. Exhibit 2-1 descri bes the six classes of injection wells. A summary of the specific requireme nts for operators is given in Exhibit 4-2, Operator Paperwork Requirements; the paperwork requirements for stat es as respondents are pr esented in Exhibit 4-3, State Reporting Forms.

Exhibit 2-1 Classification of Underground Injection Wells

Class I Wells that inject industrial and m unicipal 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 extr action of minerals including: mining of sulfur by the Frasch process; in si tu 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 operato rs of hazardous waste m anagement 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 whic h 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 v ehicle waste disposal wells, and cesspools.

Class VI Wells that inject carbon dioxide (CO 2 

### ) 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 prog rams 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;

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## Page 6 • Promulgate and enforce UIC programs in those states that choose not to participate in or do not develop a nd operate approved programs; and

• Evaluate state/regional UI C 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 ne w 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, complian ce 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 forms 5 

## or an equivalent form to target inspecti on 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 activitie s, such as the number of mechanical integrity tests (MITs) witnessed, the number of insp ections conducted, and the number of permits reviewed. The electronically submitted well-level da ta is used in a similar manner, but allows for a more effective analysis and be tter understandin g by all users.

Exhibit 2-2 charts the flow of informati on from operators, states, and regions to EPA Headquarters. Operators submit data to states (i n primacy states), or to EPA regional offices (in DI states). Each primacy state, in turn, subm its the data to its respective EPA regional office, which reviews the information and forwards it, al ong with data from its own DI states, to EPA Headquarters. All information in the quarterl y, 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 informa tion to respond to information requests and perform analyses for EPA management, the O ffice of Management and Budget (OMB), the General Accounting Office (GAO), Congress, a nd 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 establis hed by EPA and tracked against Government Performance and Results Act (GPRA) goals. EPA tracks high priority activities that guide the Regions in ca rrying 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.

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## Page 7 Exhibit 2-2 UIC Program Information Flowchart 6

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 ownershi p 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

SemiAnnuall y 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 Re g ional performance

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## Page 8 Additionally, EPA’s 2011-2015 Stra tegic Plan contains a key Strategic Target that, “By 2015, 90 percent of community water systems w ill provide drinking water that meets all applicable health-based dri nking water standards through ap proaches including effective treatment and source water protection.” EPA de veloped associated Program Activity Measures (PAMs) to assess progress toward the strate gic goal, including four related to UIC:

 Percent of Class I, II, and III salt solution we lls that lose mechanical integrity and are returned to compliance within 180 days th ereby reducing the potential to endanger underground sources of drinking water.

 Number of Class V motor ve hicle waste disposal (MVWDW) wells and large capacity cesspools (LCC) [approximately 23,640 in FY 2010] that are closed or permitted (cumulative).

 Volume of CO 2 

## sequestered through injection as defined by the UIC final rule.

 Number of permit decisions during th e reporting period that result in CO 2 

## sequestered through injection as define d by the UIC Final Rule.

As the program meets the objectives of the PAMs, the measures ch ange 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 modificati ons. 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 demonstrat e results from environmental grants.

Additionally, the Class VI rule follows an adaptive approach to data collection. This approach allows EPA to evaluate ongoing resear ch and demonstration projects and gather other relevant information, as needed, to make refine ments to the requirements for Class VI wells. If new information gathered during implementation suggests the requirements need to be revised, EPA will initiate the ap propriate 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, a nd annual reports submitted to the Regions is to help the Regions oversee the pe rformance of the primacy agents. The information is used to track individual state progress against commitment s and to ensure that state programs have the ability to take timely and appropria te action in response to direct threats to the public health due to contamination of USDWs.

Regions also have enforcement responsibilitie s and must use well spec ific information to track state enforcement response actions for all significant non-compliers (SNCs), i.e., operators

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## 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 deve lop regional operating budgets and program plans, allocate res ources, track state-by-st ate performance, and respond to inquiries. The Regions are responsible for reviewing and ve rifying the information on the quarterly reports before sending them to EPA Headquarters.

Direct Implementation of State Programs

In addition to their oversight responsibil ities, EPA regional offices must directly implement the UIC Program in states without prim acy. As administrators of UIC programs in DI states, EPA regional offices use informa tion from operators in several ways.

First, materials submitted with an initia l 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 subm itted prior to construction and during completion to ensure that injected fluids will remain in the selected inject ion 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 determ ine if (l) there is a leak in the casing, tubing, or packer, or (2) there is si gnificant 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 us e information required of operators to focus efforts on injection wells in need of enforcemen t attention. Operators who have been out of compliance for at least two consecutive quarter s are identified on the exceptions list.

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# 3. Nonduplication, Consultations, and Other Collection Criteria

This Section describes how EPA has no othe r means available to gather the requested information. It also describes EPA’ s solicitation of public comments in the Federal Register and Agency consultations in developi ng the burden and cost estimates; describes how less frequent reporting may endanger USDWs; and discusse s Paperwork Reduction Act (PRA) general guidelines and provision s 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 informa tion covered by this ICR. To the best of the Agency’s knowledge, this information is not re quired or collected by any other agency or regulation. The Department of Energy does co llect 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 in formation pertains only to oil production, and is related to, but different from, the info rmation 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 we lls (now banned) involve the injection of hazardous wastes, there is potential overla p between UIC programs under the SDWA and hazardous waste regulations promulgated under RCRA. Historically, the regulations established provisions for RCRA interim status (Part A pe rmit) [40 CFR 270.64] for Class I hazardous wells in states in which no UIC program had been approved or promulga ted. 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 Cl ass I hazardous waste wells are co-regulated under RCRA and the SD WA, 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 Ma ndatory Reporting of Greenhouse Ga ses: Injection and Geologic Sequestration of CO 2 

## Rule (Subpart RR), 40 CFR part 98. In developing the two rules, staff of the Office of Air and Radiation and the UIC progr am coordinated to consider and minimize the potential overlap in reporting a nd recordkeeping requirements on ope rators of wells that may be subject to both rules. Burden and costs associ ated with air monitoring are accounted for under Subpart RR and therefore are not incorporated in to this Programmatic ICR. EPA plans to build an electronic database that wi ll 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 requir ements under the two rules.

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## 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 estima tes. A copy of the Federal Register notice of this information collection is at tached 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 regi onal offices and states in the UIC Program. Collectively, these offices are the permitting author ities for the majority of injection wells in each well class. These staff reviewed the burde n and cost tables and recommended adjustments to some unit burden and non-labor cost s. Their input is reflected in the burden and cost estimates in Section 6. Details on the consul tation related to the burden and co st 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 we lls; 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 demons trate mechanical integrity. Some operators must sample and analyze their injectate and c onduct ambient monitoring. These requirements provide DI and state primacy programs with crucia l 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 en suring protection of USDWs and placing an excessive burden on operators.

The frequency at which operators must c onduct various monitoring and testing activities varies with the potential for a particular we ll class to endanger US DWs. Less frequent monitoring and testing might allow injection wells to operate in a manner that could threaten or cause considerable damage to USDWs if eviden ce of such a situation were undiscovered for a long time. EPA has determined that the specifie d monitoring frequencies for each operators of well class are at the minimum protective frequency for the following reasons:

 State and DI programs use injectate pressu re 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.

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## Page 12  MITs can reduce the amount of damage a well failure can cause to USDWs by detecting those failures. The degree to wh ich 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 operat ors keep timely data on the chemical composition of operators’ inject ate to ensure that potentially incompatible injected substances will not come into contact with each other.

 The Class VI rule requires that some pa rameters be monitored continuously. These monitoring frequencies are based on existing UIC Program regulations for other well classes. EPA believes that the monitoring a nd 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 varyi ng intervals (typically every 5 to 10 years, depending on the well class) . This is necessary to provide permitting authorities an opportunity to review facility opera tions 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 redu ce burden. State officials sugge sted combining, simplifying, or eliminating some of the 7520 forms or reducing th e frequency at which primacy agents report this information to EPA.

Additionally, in 2006, EPA began a Burden Reduc tion Initiative to addr ess state concerns over escalating reporting requirements accomp anied 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 reporti ng, reduce the frequency of reporting, and reduce the data elements requested. EPA is implem enting its plan to streamline and reduce UIC reporting burden through the National UIC data base. 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 UI C database are presented in Appendix B and Appendix D.



# 3(e) General Guidelines

Two provisions of the UIC regulations ex ceed the PRA guideline for response time. Pursuant to 40 CFR 144.51(l),144.28(b) and 146.94(b), operators are re quired to report within 24 hours “any noncompliance which may endanger hea lth or the environment.” This is an

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## 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 a pplication form or its instructions. In the case of other subm issions, respondents may claim confidentiality by stamping the words “confidential business in formation” 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 permitte e; 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 pl ans to routinely release or publish any of the data.



# 3(g) Sensitive Questions

There are no sensitive questi ons pertaining to this ICR.

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## 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 Cl assification (SIC) and North American Industry Classification System (NAICS) codes. Operator respondents for underground injection wells are ca tegorized 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 Reco rdkeeping, Required from Operators

Required data items vary according to we ll class and authorization category (i.e., permitted well vs. rule-authorized well). The in formation 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, alth ough operators of some Class V wells may be required to obtain permits. Operators of Cl ass V MVWDWs in state-designated ground water protection areas or other sensitiv e areas that wish to continue operating must obtain a permit.

### Underground Injection Control Program – Information Collection Request 

## Page 15 Exhibit 4-1 Respondents’ SI C/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 industrie s 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 re sponsibility (this requirement doe s not apply to rule-authorized Class V wells). Authorization te rminates if the operator fails to supply any required information or if the well loses mechanical integrity or c ontaminates a USDW. EPA is working to develop a web-based system that will allow owners or ope rators in DI program states to submit this information over the Internet. Check the status of this effort before finalizing the ICR.

Permitted Wells 7



## 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 characteriza tion 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 we ll) that penetrate the injection zone or the confining zone [Cla sses I, II, III, and VI];

• Corrective Action Plan: a plan for corrective action for wells within the AoR that are not properly plugged [Cla sses 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 regi onal 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 Administra tor determines that it is too burdensome (e.g., if the well is located in a populated area). So me 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 Maxi mum 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, Te sting, Permitting Records      

Closure Closure Report (DI only)     
* Operators of rule-authorized Class V wells will submit in ventory 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 propos ed 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, a nd 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 flui d [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 a nd monitoring devices, and the proposed sampling frequency. Class VI operators must also describe how they will monitor the position of the CO 2 

## plume and pressure front [C lasses 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 mu st 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 we ll must submit a completion report prior to being authorized to inject. Completion repor ts must include the following information:

• The results of deviation checks, other l ogs 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 [Cla sses I, II, III, and VI];

• The results of formation fluid sampling, a nd 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 im properly abandoned wells within the AoR [Classes I, II, III, and VI]; and

• The final delineated area of review an d any updates to the re quired project plans based on computational modeli ng of the AoR [Class VI].

Operators of Class I hazardous waste wells must adhere to more stringent permit application requirements than thos e required of Class II, III, or V wells. Operators seeking an exemption from the prohibition from injecting a ny 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 constituen ts of wastes will not migrate from the disposal site. In particul ar, the petition must prove th at the waste will not reach the roof of the injection zone or a co nduit within the inject ion zone within 10,000 years. This is known as the Fluid Flow Petition.

• Hydrogeological Compatibility/Compa tibility of Well Material Report. Operators of Class I hazardous waste we lls 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 compatibili ty of well materials (i.e., that the waste stream will be compatible with the well ma terials that come in contact with the waste).

• Waste Analysis Plan. Class I hazardous waste we ll operators must develop and follow an approved written waste analysis plan that describe s 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 se lecting 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 repr esentative 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 str eam; and proof of conformance with AoR requirements.

Class V facilities generally are rule-author ized. However, under the 1999 Class V rule, operators of Class V MVWDWs in ground water pr otection 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 comme nce or to continue in jecting. Typically, the permit application process for Class V operators is less complex than for other well classes— operators are typically required to submit a desc ription of the activiti es requiring a permit, inventory information, topographic maps, and a plugging and abandonment plan which includes a demonstration of financial re sponsibility for closure.

Operators of Class VI wells must submit and ga in approval for a series of project-specific plans, including: an Area of Review and Corr ective Action Plan, a Tes ting and Monitoring Plan, an Injection Well Plugging Plan, a Po st-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 monito ring and testing activities for each well class include:

 

## Monitor injection pressure, flow rate, a nd cumulative volume of injected fluids [continuously for Class I hazardous and Cl ass 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 pressu re 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 [C lasses 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 mechani cal 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 bo ttom-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 pressu re, volume, and rate to demonstrate internal mechanical integrity [Class VI];

 

## Conduct ambient monitoring, including a pre ssure 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 m onitoring plan for Class VI]; and

 

## Monitor the movement of the CO 2 

## 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 f acility; 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 endangermen t of a USDW within 24 hours; or any noncompliance with permit conditions.

Scheduled reporting requirements include the following:

 Class I hazardous well operators report quart erly on monitoring results; and annually on MITs and to update their plugging and abandonment cost estimates.

 Class I nonhazardous well operators are requi red to report quarterly on injectate monitoring, annually on ambient monito ring, and on MITs every 5 years.

9 

### Substitute MIT methods (e.g., review of cemen ting record) may be appr oved 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 repor ting 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 da ta 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 th e permitting authority. Following the reevaluation, operators must update the AoR and Corrective Action Plan, Tes ting 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 gr ound-water monitoring, including periodic reports of such monitoring; periodic repo rts on analysis of injected fl uids; and a description of the geologic strata through and into wh ich injection is taking place.

Operators must maintain monitoring inform ation, calibration and maintenance records, required reports, application data, and monitoring results for 3 year s; 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 mann er 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 re port the results of these tests with their closure reports.

Additionally, Class VI well opera tors 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 th e position of the car bon dioxide plume and pressure front throughout the PISC period; complete a non-e ndangerment demonstrat ion 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 agen cies 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 it ems reported are listed in Exhi bit 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 we lls 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 fl ow 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 agreemen t to submit data electronically through the National UIC database rather than in an altern ate 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 in tegrity. 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 EP A activities with respect to program management. Section 5(b) describes how EPA will manage the information collected; Section 5(c) discusses how this information colle ction addresses the need s of small businesses; and Section 5(d) presents EPA’s justificat ion 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-relate d injection must demonstrate that their program “represent s an effective program to pr event underground injection which endangers drinking water sources” in order to be granted primacy.

In addition to the reporting ac tivities described in Section 4( b)(2), state primacy agencies are responsible for permitting the wells within th eir 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 cons tructed in accordance with construction standards.

State agencies review injectate and ambien t 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 st atus of their programs. The mechanisms by which states report are the paper-based 7520 forms (or equi valent reporting), web-based reporting on UIC program measures and i nventory, 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 activitie s 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. Regiona l staff review reports on MITs and pressure fall-off tests performed in DI states, and in some cases, test s on wells in primacy states. DI programs also review closure reports required of opera tors when they abandon their wells.

### Underground Injection Control Program – Information Collection Request 

## Page 25 EPA Headquarters activities consist of co mpiling 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/D I 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 re porting 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 copi es of all the UIC reporting forms.)

State and DI programs maintain detailed da ta 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. Thes e data are the source of summary information submitted to the Regions and EPA Headquarters fo r 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, th at approximately 100 state and DI UIC program databases are in use.

Electronic reporting involves transmitti ng UIC data in a standard electronic format that can be readily incorporated into Headquarter s’ 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 Nationa l UIC database provides a mechanism to electronically transfer data betw een existing state and DI databa ses and Headquarters’ database, eventually eliminating the n eed for states to complete paper reporting forms.

EPA estimates that, by January 2012 (the be ginning of this information collection), 14 programs will have transitioned to electronic-re porting (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 trans ition in 2014. The time needed for a program to move from initial discussion to e-reporting depends on many variable s, including available funding and FTEs.

Initially states will incur a “s tart 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 inve stment 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 ha s 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 av ailable through the Exchange Network Grant. These funds can be used to upgrade current syst ems, 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 invent ory data through a secure web site.

EPA is also developing a data system to colle ct 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 comp liance 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 activit ies in detail, the sche dule by which states are expected to begin the data transfer, and th e 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 Cla ss II and Class V operators affect ed by this collection are small entities. This collection reduces, to the extent practicable and appropria te, 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 re porting requirements or timetables that take into account the re sources available to those who are to respond;

 Clarification, consolidation, or simp lification of compliance and reporting requirements; or

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

Class I

The size standard the Small Business Admini stration uses to define “small business” varies by SIC code. Class I wells typi cally 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, ga s, and sanitary services

 Major Group 89: Services not elsewhere classified

 Major Group 99: Non-classi fiable 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 ope rate 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 Elect ric, 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.

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## Page 28 Class II

Oil and gas extraction firms fall into three SIC categories:

 SIC code 1311 (crude petr oleum and natural gas);

 SIC code 1321 (natural gas liquids); and

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

All of these categories have small busine ss size standards of 500 employees. According to Dun and Bradstreet Market An alysis Profile, more than 90 pe rcent of the firms in these SIC codes are small businesses, using the 500-employ ee standard. Even though many of the operable Class II injection wells are owne d 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 regula tion of Class II wells must be kept to a minimum, while at the same time ensuring th at USDWs will not be endangered. Recognizing this intent, EPA has minimized reporting requirem ents for Class II wells in the following ways. First, while operators of Class I and Class III well s report injection fluid characteristics quarterly, Class II operators report this information annua lly. Second, Class I monitoring requirements include the installation and use of continuous re cording 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 leas t 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 deta iling geologic structure may be required, whereas Class II well operators must provi de 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 operato rs 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 accommoda te this situation, the regulations specify that cessation of operation does not re quire plugging (and associated info rmation collection) until two years have elapsed.

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## 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 fe wer employees. According to the preamble to the 1980 UIC regulations (45 FR 42472), the opera tors of these wells are large, diversified corporations, well above the size standard of 500 employees. Ther e is no reason to believe that there has been any material change in the si ze of the firms since that analysis was done.

Class V

EPA estimates that the majority of faciliti es 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 administra tive requirements for these operators to a minimum in order to provide regulatory relief to small entities while protecting drinking water supplies. Most Class V facili ties do not have collection requir ements 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 fi nal Class V rule includes a complete, final Regulatory Flexibility Analysis addressing all activities, includi ng 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, an d oil and gas refineries. Because the resources necessary to construct injection wells that meet th e 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 requi rements for Class VI well owners or operators will cause no significant impact on small entities.



# 5(d) Collection Schedule

EPA developed the schedule for informati on 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.

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## Page 30 5(d)(1) Operator Reporting

In determining the reporting schedule fo r 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 re port annually; Class VI operators report semi-annually. Th e regular reporting of these da ta 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 fr equencies at which state prim acy agencies must report UIC data, including the 7520 forms and Program Activ ity 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 cas es 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 st ates submit the grant utilization form (7520-5). As Section 5(b) discusses, upon implementati on of the National UIC database, states UIC flowing data to Headquarters wi ll no longer be required to subm it 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

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## 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' inab ility to meet program objectives and prevent states from meeting schedules. A permitting proce ss that is too lengthy could have a detrimental impact on industry. Conversely, favorable develo pments may occur that enable the states to meet time schedules and goals sooner than antici pated. 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 violati ons to regulations in effect unde r Section 1421 of the SDWA. EPA must remain informed in order to (a) overs ee and encourage states' actions on resolving violations or enforcing against vi olators, and (b) to take direct federal action where appropriate state actions have not occurred in a timel y manner or have not been successful.

EPA would be unable to effec tively 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 Hea dquarters could not direct an effective federal enforcement program using da ta 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 ensu res that inspect ions 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 prot ective 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 qu arters. 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 da ta, as required by 40 CFR 144.8, is necessary for effective oversight of the UI C Program. Primacy states, Regions, and EPA Headquarters need to be routin ely and frequently informed of changes in the number and operating characteristics of in jection wells to monitor and regulate underground injection effectively and to continue prot ecting USDWs from contamination.

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## Page 32 PAMs Data

. EPA Headquarters needs to collect PAM da ta semi-annually to meet the Office of Water's reporting schedules to assess progress to ward 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 en sure public health prot ection 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 th at reporting via the National UIC database is volunt ary. See Appendix B for more information on reporting via the National UIC database.

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## 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 co sts 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 cost s 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 operati ons, ground water and injectate monitoring and well testing during well opera tion, reporting of monitoring results and other events, recordkeeping, and well closure.

EPA estimates that the annual burden on the 53,714 owners or opera tors 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 detail ed 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 to tal, 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 ar e 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 demons tration 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.

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## 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 $33,363,1 03 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 $28,828,8 44 $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 estim ates the total annual burden on the 15,085 operators of Class II wells (a ssociated with the oil and na tural gas industry) to be 872,778 hours. Class II well operators perform ma ny of the same types of activities as Class I wells, including submitting permit applications and completion reports, monitoring and testing, reporting and recordke eping, 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 (particularl y Table A-2) for details on the assumptions used to calculate the owner/operator bur den 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 $37,262,5 81 $84,338,754 $121,601,33 4 388,781.0 2.24 $312.78
Primacy States 127,190 $5,268,725 $0 $5,268,725 84,62 4.8 1.50 $62.26
DI Programs 7,079 $293,231 $0 $293,231 5,010.9 1.41 $58.52
TOTAL 1,007,047 $42,824,5 36 $84,338,754 $127,163,29 0 478,416.7 2.10 $265.80
Note: numbers may not appear to add due to rounding.

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## Page 35 3) Class III Well Operators

The estimated total annual burden on th e 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 pe rmit 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 increas e and that only 6% of these sites are for uranium mining. Before EPA finalizes this ICR, the Agency will investigate whether thes e assumptions are reasonable in light of a current understanding that at least the number of uranium mini ng 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) pres ents details on the assumptions used to calculate the owner/operator bur den and cost associated with the requirements for Class III wells.

Exhibit 6-1C Annual Burden and Cost Asso ciated 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 $2,572,44 2 5,186.7 9.26 $495.97
Primacy States 3,363 $139,33 0 $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 $674,48 6 $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 c ontaminated 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.

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## Page 36 EPA estimates that the burden on the 990 ope rators 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 $23 2,551 $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 $27 3,561 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 Cla ss V wells with reporting requirements under this information collec tion is estimated to be 38,924 hours. See Exhibit 6-1E and Appendix A.

All operators of Class V wells must su bmit inventory information before they may begin operating their wells. In add ition, the 1999 Class V Rule provided additional requirements for owners of MVWDWs and la rge-capacity cesspools. Facilities that wish to continue operating MVWDWs mustapply for permits. MVWDWs and largecapacity cesspools that close are required to submit pre-clos ure notifications.

Although the Class V Rule requir ed that all of these facili ties be closed or apply for a permit by January 2007, EPA understands th at 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 $836,71 9 $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 $6,775,83 7 $8,549,747 83,90 0.4 0.73 $101.90
Note: numbers may not appear to add due to rounding.

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## 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 publis hing 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. Theref ore, 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 $450,13 3 $19,767,163 $20,217,2 96 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 $19,767,1 63 $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 $37,2 62,581 $84,338,754 $121,601, 334 388,781.0 2.24 $312.78
Class III Operators 48,051 $1, 897,957 $674, 486 $2,572,44 2 5,186.7 9. 26 $495.97
Class IV Operators 9,900 $232,55 1 $0 $232,551 990.0 10.00 $234.90
Class V Operators 38,924 $836,719 $6,775, 837 $7,612,555 44,92 1.2 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 $45,214,1 99 $140,385,082 $185,599, 282 445,154.1 2.41 $416.93
Note: numbers may not appear to add due to rounding.

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## 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 injecti on 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 we ll. 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 th rough Class VI UIC programs arise from processing permit applications and completi on reports, reviewing monitoring and testing data, and responding to closure reports s ubmitted 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 measur es reporting process or submission to the National UIC database. By the end of th e clearance period, EPA estimates that all primacy agencies will transfer data to EP A Headquarters to popul ate 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 $72,8 76 $3,006,281 533. 7 132.69 $5,633.26
TOTAL 221,346 $9,169,904 $72,876 $9,242,780 113,3 39.9 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 th e 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-la bor costs and $45.2 million in labor costs.

EPA determined operator labor cost by es timating 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 manage rial staff, $46 for technical staff, and $27 for clerical staff. For Cla sses IV and V, hourly salary a nd 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 thes e 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 ge oscientists. 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 a nd other sources. This ICR assumes there are no capital costs to operator s–large capital expenditures associated with underground injection (e.g., construction co sts and monitoring equipmen t) are considered to be customary business practice. All non-labor costs to operators associated with this collection are operating and main tenance (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 overhea d costs. (This is the inflation factor recommended in EPA’s ICR Handbook .)

The non-labor costs (capital and O&M) to st ates 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 Headqua rters to populate the Na tional UIC database. The remaining non-labor costs to states are th e cost of contractor support for database development.

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## 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-migrati on petitions submitted by Class I hazardous facility operators in both primacy and DI states in their region. In addition, EPA Headquarters spends an estim ated 2 FTEs, or 4,160 hours annually in its oversight responsibilities for the UIC Program activities related to this information collection. Headquarters activit ies include gathering and reviewing 7520 forms, analysis of inventory and measures da ta, and development of the National UIC database. The total annual burden for federal DI programs a ssociated 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 th is collection is $1,23 3,529. 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 $25 9,164 710.1 8.81 $364.95

Class II DI Programs 7,079 $293,231 $0 $29 3,231 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 $16 1,169 24.7 98.55 $6,531.68
Headquarters Management 4,160 $172,324 $0 $17 2,324 1.0 4, 160.00 $172,323.84
TOTAL 28,319 $1,233,529 $0 $1,23 3,529 19,937.6 1.42 $61.87
Note: numbers may not appear to add due to rounding.

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## Page 41 

# 6(d) Estimating Respondent Universe and Total Burden and Costs

EPA estimates that 53,714 owners or opera tors 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 assump tions 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 subj ect to monitoring or reporting requirements and the frequency with which they must comp ly 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 re spondent burden over the 3 years covered by this ICR is 3.89 million hours. The tota l 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 res ponses (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 O perator 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 Tota l 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 opera tors and states associated with the UIC Program is 1,000,648 hours. This ICR requ ests total annual re spondent burden of 1,296,167 hours. Thus, there is a net increa se 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 operat ors of injection wells and primacy states between the burden requested in this ICR and th e 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 paragr aphs 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 55,3 87 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 93,9 33 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 t he 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, offs et by adjustment due to inventory increases si nce 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 t he 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 applica tions. Further, the state of Florida has completed its primacy application. Elim ination 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 mon itoring 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 fe wer 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 continue s to populate a national database to streamline reporting from stat es and DI programs to Headquarters. States that are reporting data to the National UIC database no longer complete the paper-based forms. This has resu lted in a reduction of over 20,000 agency burden hours annually. Appendix B de scribes the development and implementation of the National UIC data base, 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 prepari ng 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 bu rden 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. Invent ory data also show that the number of Class III facilities is 15 per cent lower than in the last ICR; this has reduced the Class III ope rator 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 th e 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 operat ors. 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 th e use of electronic reporting methods. EPA’s efforts are briefly desc ribed below and discussed in further detail in Appendix D.

 EPA’s National UIC database allows el ectronic transfer of data between existing state and DI databases and H eadquarters’ database. When fully populated, the National UIC database w ill 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 annua l 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-base d 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 w ould offer many benefits to operators and oversight agencies, including: reduc ing 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; a nd facilitating the no tification process associated with the submissions.



# 6(g) Burden Statement

EPA estimates that, over the 3 years cove red by this request, th e total annual burden on underground injection well owne rs/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 $196,075,59 1 578,431.6 2.29 $338.98
Note: numbers may not appear to add due to rounding.



## The annual public reporting and recordk eeping burden for this collection of information is estimated to average 2.32 hour s 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 instructi ons; develop, acquire, install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosi ng and providing information; adjust the existing ways to comply with any previously applicable instructi ons and requirements; train personnel to be able to respond to a co llection of information; search data sources; complete and review the collection of inform ation; 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 sugge sted methods for minimizing respondent burden, including the use of automated coll ection techniques, EP A 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 Do cket 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 lega l holidays. The telephone num ber 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 cont ents 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 doc ket ID number identified above. Also, you can send comments to the Office of Informa tion and Regulatory Affairs, Office of Management and Budget, 725 17th Str eet, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include th e 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 Explanatio n of Respondent Burden Esti mates and Respondent Universe

Respondents for this information collection include operators of Class I – VI wells and state primacy agencies. The first part of this A ppendix contains EPA’s estimates of re spondent burden associated with UIC paperwork requirements. The second part of this A ppendix provides EPA’s assumpti ons about the number of respondents subject to each in formation collection activity.

A.1 Estimating Respondent Burden

EPA has calculated respondent burden hours fo r each information collection, reporting, and recordkeeping activity required of well operators and stat e 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 collecti on activities are performe d by contractors. The operator unit burdens reported in this appendix represent a composite of the operator time needed to both perform an information collection activ ity and to supervise a contractor when the contractor performs the activity. The mix of operator versus c ontractor 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 admini stering Class I hazardous and Class I nonhazardous programs are presented in Ta bles 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-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearInitial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time0.0 0.25 0.25 0.0 0.5 $31 $0 8 4 $251Gather and submit description of activitiesrequiring a permit, facility name and address,SIC codes, ownership and facility status,facility location, listing of relevant permits orconstruction approvals, description of thebusiness.One-time3.0 2.0 9.0 6.0 20.0 $954 $0 8 160 $7,629In DI programs, gather and submit a list oflandowners within one-quarter mile of thefacility boundary.One-time4.0 0.0 0.0 1.2 5.2 $329 $0 2 12 $766Prepare and submit a map and tabulation ofall wells within the AoR.One-time0.0 1.5 5.5 0.0 7.0 $370 $21,605 8 56 $175,804Prepare and submit AoR protocol. One-time0.0 0.0 1.3 0.0 1.3 $59 $837 8 10 $7,171Prepare and submit maps/cross sections oflocal and regional geology, USDWs.One-time0.0 1.5 16.0 0.0 17.5 $850 $44,856 8 140 $365,641Develop formation testing and stimulationprograms and injection procedures.One-time0.0 2.0 5.0 1.0 8.0 $414 $6,439 8 64 $54,823Prepare and submit contingency plans forshut-ins or well failures.One-time0.0 3.0 10.0 2.0 15.0 $749 $250 8 120 $7,994Prepare and submit ambient monitoring plan. One-time0.0 3.0 0.0 0.0 3.0 $235 $4,221 8 24 $35,647Prepare and submit Corrective Action Plan. One-time0.0 2.0 3.0 2.3 7.3 $358 $10,695 8 58 $88,425Prepare and submit descriptions of logs andtests, construction schematics & operatingdata.One-time0.0 2.0 8.0 5.0 15.0 $658 $5,366 8 120 $48,191Prepare and submit closure plan, includingdemonstration of financial responsibility.One-time0.0 1.0 3.0 2.6 6.6 $286 $1,581 8 53 $14,938Prepare and submit post-closure care plan. One-time0.0 1.4 2.0 1.4 4.8 $239 $1,946 8 38 $17,481Requirements for active hazardous waste facilitiesGather and submit dates of well operationand specific waste information.One-time0.0 0.0 26.6 11.4 38.0 $1,519 $8,156 8 304 $77,400Gather and submit hazardous waste releaseinformation.One-time0.0 1.9 30.4 22.8 55.1 $2,150 $4,078 0 0 $0Underground Injection Control Program -- Information Collection RequestPage A-2Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearDevelop waste analysis plan. One-time0.0 1.9 15.2 1.9 19.0 $896 $2,719 8 152 $28,915Prepare and submit schedule of constructionlogs and tests.One-time0.0 0.0 0.5 0.5 1.0 $36 $0 8 8 $290Requirements associated with completion reportsPrepare and submit completion report. One-time0.0 0.0 1.5 2.5 4.0 $135 $0 8 32 $1,084Submit results of deviation checks, other logsand tests; sample formation fluids; testinjection and confining zones.One-time0.0 0.0 6.0 1.0 7.0 $301 $32,908 8 56 $265,672Demonstrate mechanical integrity (i.e.,casing pressure test, radioactive tracersurvey of bottom-hole cement, andnoise/temperature logs to check formovement along the borehole).One-time0.0 2.0 18.0 0.0 20.0 $981 $21,462 8 160 $179,541Submit information on the anticipatedmaximum pressure and flow rate.One-time0.0 0.0 2.0 0.0 2.0 $91 $143 8 16 $1,875Submit results of the injection zone andconfining zone testing programs.One-time0.0 1.0 4.0 0.0 5.0 $262 $35,770 8 40 $288,257Submit actual injection procedure. One-time0.0 0.0 1.0 0.0 1.0 $46 $143 8 8 $1,510Demonstrate hydrogeologic compatibility/compatability of well materials.One-time0.0 2.0 6.0 0.0 8.0 $433 $7,154 8 64 $60,697Prepare and submit information on thecalculated AoR.One-time0.0 0.0 2.0 0.0 2.0 $91 $2,862 8 16 $23,623No-migration petition requirementsGather and submit waste information andpresent modeling data to demonstrate thatwastes will not migrate from injection zone.One-time0.0 24.0 120.0 30.0 174.0 $8,191 $751,170 8 1,392 $6,074,892Requirements associated with permit renewals/modifications and petition modificationsSubmit updated components of permitapplication attachments.Occasional0.0 9.0 41.5 21.0 71.5 $3,173 $10,588 12 858 $165,137Prepare and submit request for PermitModification.One-time0.0 2.0 6.0 2.0 10.0 $487 $6,152 5 50 $33,196Prepare and submit Petition Modification. One-time0.0 24.0 120.0 30.0 174.0 $8,191 $711,075 6 1,044 $4,315,597Underground Injection Control Program -- Information Collection RequestPage A-3Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearMonitoring/Testing Requirements (Per Facility)Use continuous recording devices to monitorinjection pressure, flow rate, volume, andtemperature.Continuous0.0 0.0 5.7 0.0 5.7 $260 $0 59 339 $15,469Conduct chemical monitoring of injectedwastes as prescribed in waste analysis plan.As specified inWAP0.0 0.0 38.0 0.0 38.0 $1,734 $4,292 238 9,040 $1,433,638Conduct additional chemical monitoring asspecified by the Director.Varies0.0 0.0 7.6 0.0 7.6 $347 $858 24 181 $28,673Conduct casing pressure test and radioactivetracer survey of bottom-hole cement.Annual0.0 3.8 5.2 0.0 9.0 $540 $5,926 48 428 $307,625Conduct casing pressure test, radioactivetracer of bottom-hole cement, andnoise/temperature logs to check formovement along the borehole.Every 5 years0.0 1.0 7.0 0.0 8.0 $399 $40,778 12 95 $489,788Conduct casing inspection log at workover. Occasional0.0 3.8 8.0 0.0 11.8 $668 $7,111 3 35 $23,131Conduct pressure fall-off test. Annual0.0 6.0 18.0 0.0 24.0 $1,299 $16,592 59 1,427 $1,064,042Conduct ambient monitoring. Annual0.0 0.4 1.9 0.0 2.3 $117 $5,723 59 136 $347,336Reporting Requirements (Per Facility)Prepare and submit report on maximuminjection pressure, total injectate volume, andmonitoring and testing results.Quarterly0.0 4.0 15.0 6.0 25.0 $1,492 $0 238 5,947 $354,878Prepare and submit report on mechanicalintegrity testing.Annual0.0 1.0 2.0 1.0 4.0 $234 $1,288 59 238 $90,476Notify Director within 24 hours of: plannedphysical changes to facility, changes thatmay result in noncompliance, compliance ornoncompliance with a compliance schedule,any indication of possible endangerment of aUSDW, or all other noncompliance.Occasional0.0 1.0 2.0 3.0 6.0 $234 $0 1 4 $139Prepare and submit revised plugging andabandonment cost estimate.Annual0.0 1.0 0.0 0.0 1.0 $74 $0 59 59 $4,416Prepare and submit report on: eventsexceeding operating parameters or triggeringalarms; changes in annular fluid volume;workovers or other testing.Occasional0.0 1.0 1.0 1.0 3.0 $152 $0 3 9 $452Underground Injection Control Program -- Information Collection RequestPage A-4Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearRecordkeeping Requirements (Per Facility)Maintain monitoring information, calibrationand maintenance records, required reports,application data, monitoring results, andmost recent plugging and abandonment costestimate.3 years0.0 0.0 0.0 5.0 5.0 $134 $0 59 297 $7,972Closure Requirements (Per Well)Prepare and submit notice of intent to close. One-time0.0 0.5 0.0 1.0 1.5 $67 $0 1 2 $67Prepare and submit closure report. One-time0.0 2.0 8.0 0.0 10.0 $524 $2,862 1 10 $3,386Conduct pressure fall-off test prior to wellclosure.One-time0.0 1.0 5.0 0.0 6.0 $308 $16,592 1 6 $16,900Demonstrate mechanical integrity (i.e.,casing pressure test, radioactive tracer ofbottom-hole cement, and noise/temperaturelogs to check for movement along theborehole) prior to closure.One-time0.0 2.0 18.0 0.0 20.0 $981 $26,784 1 20 $27,764Notify state or local zoning or drillingauthorities and Regional Administratorfollowing closure.One-time0.0 0.5 1.0 3.0 4.5 $166 $0 1 5 $166TOTAL1,153 23,337 16,558,758$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 RequestPage A-5Table A-1A (continued)Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: StatesABCDEFHours and Costs per Response Total Hours and CostsDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonlaborCostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearInitial/Start-upPermit ApplicationsConsider the permit application, AoR, relevant maps andcross sections, fluid injection rate and volume, proposedcontingency plans, monitoring plans, and constructionprocedures as required at 146.70 and prepare draft permit.One-time40.0 $1,657 $0 6227$9,401Provide public notice of issuance of a draft permit or intent todeny.One-time1.0 $41 $0 66$235Consider public comments. One-time6.0 $249 $0 634$1,410Issue final permit decision. One-time2.0 $83 $0 611$470Respond to comments. One-time7.0 $290 $0 640$1,645Review notice of completion of construction. One-time2.0 $83 $0 611$470No-Migration PetitionsReview and respond to petition request. One-time18.0 $746 $0 6102$4,231Public notice/public comment. One-time10.0 $414 $0 657$2,350Review and respond to petition modification request. One-time10.0 $414 $0 443$1,763Permit renewals/modificationsReview and respond to requests for permit modifications or reissuance.Occasional30.0 $1,243 $0 9255$10,577Underground Injection Control Program -- Information Collection RequestPage A-6Table A-1A (continued)Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: StatesABCDEFHours and Costs per Response Total Hours and CostsDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonlaborCostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearMonitoring/TestingReview quarterly monitoring and testing results. Quarterly1.5 $62 $0 169253$10,484Review casing pressure test and radioactive tracer survey ofbottom-hole cement.Annual4.0 $166 $0 34135$5,591Review casing pressure test, radioactive tracer survey ofbottom-hole cement, and logs.Every 5 years4.0 $166 $0 8 34$1,398Review pressure fall-off test. Annual2.0 $83 $0 3265$2,691Other ReportingRespond to periodic notifications by owners and operators. Occasional2.0 $83 $0 4 9$353ClosureReview closure and post-closure plans prior to approvingplugging and abandonment.One-time2.0 $83 $0 12$83Witness and review pressure fall-off test prior to authorizingclosure.One-time24.0 $994 $0 124$994TOTAL3531,308$54,187Notes:(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 RequestPage A-7Table A-1BAnnual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: OperatorsAB C D E FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Non-LaborCost (B)No. ofResponsesTotalHours/Year Total Cost/YearInitial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time0.0 0.25 0.25 0.0 0.5 $31 $0 14 7 $438Gather and submit description of activitiesrequiring a permit, facility name and address,SIC codes, ownership and facility status,facility location, listing of relevant permits orconstruction approvals, relevant maps andcross sections, construction specifics,description of the business, proposedinjection,formation testing,and stimulationOne-time3.0 2.0 9.0 6.0 20.0 $954 $0 14 280 $13,350In DI programs, gather and submit a list oflandowners within one-quarter mile of thefacility boundary.One-time4.0 0.0 0.0 1.2 5.2 $329 $0 4 21 $1,340Prepare and submit a map and tabulation ofall wells within the AoR.One-time0.0 1.5 5.5 0.0 7.0 $370 $17,284 14 98 $247,163Prepare and submit maps/cross sections oflocal and regional geology, USDWs.One-time0.0 1.5 16.0 0.0 17.5 $850 $44,856 14 245 $639,872Prepare and submit descriptions of logs andtests, construction schematics and operatingdata.One-time0.0 2.0 8.0 2.5 12.5 $591 $5,366 14 175 $83,396Develop formation testing and stimulationprograms and injection procedures.One-time0.0 2.0 7.0 1.0 10.0 $506 $6,439 14 140 $97,218Prepare and submit contingency plans forshut-ins or well failures.One-time0.0 3.0 10.0 2.0 15.0 $749 $250 14 210 $13,990Prepare and submit ambient monitoring plan. One-time0.0 3.0 3.0 3.0 9.0 $456 $4,221 14 126 $65,480Prepare and submit Corrective Action Plan. One-time0.0 2.0 3.0 2.3 7.3 $358 $8,227 14 102 $120,189Prepare and submit closure plan, includingdemonstration of financial responsibility.One-time0.0 1.0 3.0 2.6 6.6 $286 $1,581 14 92 $26,142Requirements associated with completion reportsPrepare and submit completion report. One-time0.0 0.0 1.5 2.5 4.0 $135 $0 14 56 $1,897Prepare and submit a report of deviationchecks and other logs and tests duringOne-time0.0 0.0 6.0 1.0 7.0 $301 $32,908 14 98 $464,926Demonstrate mechanical integrity (i.e., casingpressure test and noise/temperature logs toOne-time0.0 2.0 3.5 0.0 5.5 $319 $9,300 14 77 $134,669Submit information on the anticipatedmaximum pressure and flow rate.One-time0.0 0.0 2.0 0.0 2.0 $91 $143 14 28 $3,281Underground Injection Control Program -- Information Collection RequestPage A-8Table A-1BAnnual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: OperatorsAB C D E FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Non-LaborCost (B)No. ofResponsesTotalHours/Year Total Cost/YearSubmit results of the formation testingprogram.One-time0.0 1.0 4.0 0.0 5.0 $262 $35,770 14 70 $504,450Submit actual injection procedure. One-time0.0 0.0 1.0 0.0 1.0 $46 $143 14 14 $2,642Demonstrate hydrogeologic compatibility/compatibility of well materials.One-time0.0 2.0 6.0 0.0 8.0 $433 $7,154 14 112 $106,219Requirements associated with permit renewals/modificationsSubmit updated components of permitapplication attachments.Occasional0.0 8.0 11.0 2.0 21.0 $1,193 $5,008 20 420 $124,011Prepare and submit request for permitmodification.Occasional0.0 2.0 6.0 0.0 8.0 $433 $3,577 9 72 $36,091Monitoring/Testing Requirements (Per Facility)Analyze injected fluids. Per permit0.0 0.0 38.0 0.0 38.0 $1,734 $2,862 1,131 42,960 $5,195,396Monitor injection pressure, flow rate andvolume, and annulus pressure.Continuous0.0 0.0 5.7 0.0 5.7 $260 $0 283 1,611 $73,511Demonstrate mechanical integrity (i.e., casingpressure test and noise/temperature logs tocheck for movement along the borehole).Every 5 years0.0 1.0 8.0 0.0 9.0 $445 $17,670 57 509 $1,023,978Conduct pressure fall-off test. Annual0.0 8.0 16.0 0.0 24.0 $1,367 $16,592 283 6,783 $5,075,782Conduct ambient monitoring. Annual0.0 0.4 1.5 0.0 1.9 $100 $5,723 283 537 $1,645,714Reporting Requirements (Per Facility)Report on: physical, chemical, and othercharacteristics of injected fluids; injectionpressure, flow rate, and volume; andmonitoring of USDWs.Quarterly0.0 0.0 4.0 12.0 16.0 $504 $0 1,131 18,088 $570,031Report results of ambient monitoring andpressure fall-off test.Annual0.0 2.0 6.0 4.0 12.0 $540 $1,185 283 3,392 $487,543Notify Director within 24 hours of: plannedphysical changes to facility, changes that mayresult in noncompliance, compliance ornoncompliance with a compliance schedule,any indication of possible endangerment of aOccasional0.0 1.0 2.0 3.0 6.0 $251 $0 14 85 $3,552Underground Injection Control Program -- Information Collection RequestPage A-9Table A-1BAnnual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: OperatorsAB C D E FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Non-LaborCost (B)No. ofResponsesTotalHours/Year Total Cost/YearSubmit periodic updates of financialresponsibility for closure that account forinflation.Occasional0.0 1.0 0.0 0.0 1.0 $80 $0 94 94 $7,504Report results of: any required mechanicalintegrity tests, other required tests, and wellworkovers.Occasional0.0 1.0 2.0 1.0 4.0 $198 $1,288 3 11 $4,198Recordkeeping Requirements (Per Facility)Maintain monitoring information, calibrationand maintenance records, required reports,application data, and monitoring results.At least 3 years0.0 0.0 0.0 4.0 4.0 $107 $0 283 1,131 $30,307Closure Requirements (Per Well)Notify the Director before conversion orabandonment of the well or, in the case ofarea permits, before closure of the project.One-time0.0 0.5 0.0 1.0 1.5 $67 $0 1 2 $67TOTAL4,11477,64616,804,345$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 RequestPage A-10Table A-1B (continued)Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: StatesABCDEHours and Costs per Response Total Hours and CostDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonLabor CostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearInitial/Start-upPermit applicationsConsider the permit application, AoR,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andconstruction procedures as required at146.14 and issue notice of intent to deny.One-time20.0 $828 $0 1 20 $823Consider the permit application, AoR,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andconstruction procedures as required at146.14 and prepare draft permit.One-time40.0 $1,657 $0 9 357 $14,807Provide public notice of issuance of a draftpermit or intent to deny.One-time1.0 $41 $0 10 10 $411Consider public comments. One-time6.0 $249 $0 10 60 $2,468Issue final permit decision. One-time2.0 $83 $0 10 20 $823Respond to comments. One-time7.0 $290 $0 10 70 $2,879Review notice of completion of construction. One-time2.0 $83 $0 10 20 $823Permit renewals/modificationsReview and respond to requests for permitmodifications or re-issuance.Occasional30.0 $1,243 $0 14 426 $17,628Monitoring/TestingReview casing pressure test and logs. Every 5 years4.0 $166 $0 40 160 $6,643Underground Injection Control Program -- Information Collection Request Page A-11Table A-1B (continued)Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: StatesABCDEHours and Costs per Response Total Hours and CostDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonLabor CostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearReview pressure fall-off test. Annual2.0 $83 $0 200 401 $16,607Review monitoring data submitted byoperators.Quarterly2.0 $83 $0 802 1,604 $66,428Other ReportingRespond to periodic notifications by ownersand operators.Occasional1.0 $41 $0 7 7 $294ClosureReview plugging and abandonment report. One-time1.0 $41 $0 1 1 $41TOTAL1,124 3,155 $130,674Notes:(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 Page A-12

### 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 app lications, 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 modi fications). The operator burdens presented in Column A of Tables A- 1A and A-1B largely reflect the tim e it takes to oversee and furnish information to contractors. The costs associated with contractor labor and othe r contractor services are presented in Column C of Tables A-1A and A-1B.

EPA estimates that 70 percent of the new Class I pe rmits issued will be for newly constructed wells at existing facilities, and that mu ch of the information these applicants are required to submit is li kely to have been developed in connection with permitting other wells and, ther efore, already exists for the facility. EPA assumes the remaining 30 percent of permits will be issued for we lls 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 tim e 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 locat e a subsurface zone suitable for injection. EPA assumes that 50 perc ent of the geological characterizat ion required of permit applicants is customary business practice. Most of the incremen tal ICR burden is attributab le to the requirement to submit detailed maps of local geology.

 Operators would customarily develop and conduct fo rmation 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 conti ngency plans to reduce poten tial liability should a well failure occur and develop closure plans to reduce potential liability wh en they close their facilities. EPA assumes that 25 percent of the burden of deve loping these plans is cust omary business practice.

 Facility engineers would normally prepare cons truction schematics and operating data during the planning and design of an injection f acility; EPA estimates that 75 percent of the burden associated with compiling this data is customary business practice.

 As part of their overall industria l 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 pl an and conducting waste co mpatibility testing is customary business practice.

 During construction, operators would probably conduct de viation checks and other logs to verify that drilling is progressing within expected parameters. EP A estimates that 50 percent of the requirement to conduct deviation checks and other logs a nd tests is customary business practice.

 Operators would routinely observe in jection pressure, flow rate, volum e, and temperature, and analyze the chemical composition of their wastes to verify the proper operation of thei r wells; EPA assumes that nearly all the burden for continuous monitoring and 75 percent of th e 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 haza rdous facilities include: permitting and start-up-related reporting; permit renewals and modifications of permits or petitions; monitoring; re porting and recordkeeping; and closure-related paperwork.

Initial Permitting/Start-up

EPA estimates that, of the new Cl ass I hazardous waste facility opera ting 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 fo r 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 estim ates 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 en compass 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 corr ective 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 Re source Conservation and Recovery Act (RCRA) requirements and is not included in this burden estimate. Other ac tivities that operators of active hazardous waste facilities must perform (e.g., developi ng a waste analysis plan) are included in this estimate.

EPA estimates that the burden on Class I hazardous facility operators associ ated with preparing and submitting completion reports will be 49 hours per facility. The burden to perf orm 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, opera tors of newly constructed hazardous Class I wells will submit no-migration petitions to the EPA Regional Ad ministrator. 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 pe tition in the process of permitting and preparing petitions for existing wells at thei r 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 year s, after which operators mu st apply to renew their permits. Additionally, from time to time, operators of Cl ass 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 asso ciated with renewing permits for a Class I hazardous facility will be 71.5 hours per renewal. Requirements for permit renewa ls vary among states and regions, ranging from submitting a letter of intent to continue operating the facil ity 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 informati on and those attachments that have changed or been updated since their last application, su ch as the AoR, corrective action pla n, 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 cont ractor activities associat ed with preparing and submitting a request for a permit modification is 10 hours pe r 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 facilitie s 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 com position 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 ope rators would perform some chemical monitoring during the course of business. EPA estimates the additiona l 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 au thorities 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 casi ng 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 temper ature, noise, or other logs to check for movement along the borehole, is estimated to be 8 hours per facility.

Operators must conduct casing insp ection 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 te st every year; EPA estimates that the annual burden associated with this requirement will be 24 hours per faci lity. EPA estimates that the total burden associated with required annu al ambient monitoring at Class I ha zardous 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 include s 25 hours per report (100 hours annually) for quarterly monitoring reports, and 4 hours to repor t on the results of MITs. In addi tion, EPA assumes that 5 percent of operators will spend 3 to 6 hours annually submitting vari ous occasional reports (e.g., on changes to the facility;

### Underground Injection Control Program – Information Collection Request Page A-16 

## planned workovers; noncompliance or anticipated noncomp liance; or events triggering alarms or shutdown devices). Operators will also spend one hour submitti ng 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, ca libration and maintenance records, required reports, application data, and monitoring results for three years; and keep their most rece nt plugging and abandonment cost estimate for one year.

Closure

EPA estimates that the total annual burden associat ed with closure of a Cla ss I hazardous well is 42 hours. This includes 1.5 hours to notify the Regional Administrator pr ior 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 pos t-closure care plan. The operator wi ll also spend 4.5 hours on third-party notification activities, such as not ifying state or local zoning or dril ling authorities and the Regional Administrator following closure.

Class I Nonhazardous Facilities

Paperwork requirements for operators of Class I nonh azardous facilities include permitting and start-uprelated reporting, permit rene wals and modifications, monitoring and te sting, reporting and recordkeeping, and closure-related pape rwork activities.

Initial Permitting/Start-up

As is the case for Class I hazardous facilities, EP A estimates that the majority of the new nonhazardous waste injection permits issued each year will be for ne w 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 nonh azardous 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 sma ller AoR. Consequently, the burden for the AoR study and for developing a corrective action plan for we lls 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 inject ate; nor are they required to gath er 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 burde n varies from that for Class I hazardous facilities, as Class I nonhazardous facility operators are not re quired 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 assume s that applicants for nonhazardous injection permit renewals will submit only those attachments to the appli cation form that have change d since the original permit application. Preparing and submitting the updated materials needed for a pe rmit renewal appli cation 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 injectat e periodically as normal business activities. However, to comply with UIC requirements, operators spend more time on these activit ies than they otherwise w ould. Class I nonhazardous facility operators will spend 38 hours to monitor their injectat e; 5.7 hours to monitor injection pressure, flow rate, and volume; 1.9 hours to conduct ambient monitori ng; and 24 hours to conduct an annual pressure fall-off test. In addition, approximately 20 pe rcent 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 re porting 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 ambien t monitoring and the pressure fall-off test.

EPA assumes that Class I nonhazard ous 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 ma intenance 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 Cl ass I nonhazardous facilities a ssociated 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 imp lementing 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 applicati on 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 modi fications or renewals. EPA regiona l offices review all no-migration petitions and petition modification requests submitted by operators of Class I hazardous waste injection facilities; however, state primacy ag encies assist the regions with this review. States spend 28 hours per nomigration petition application and 10 hours per pe tition modification reques t on this assistance.

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## State primacy agencies spend from 1 to 4 hours per report reviewing mon itoring and MIT data or occasional reports submitted by operators (details are pres ented in Tables A-1A and A-1B). States spend one hour reviewing plugging and abandonment reports s ubmitted by operators of Class I nonhazardous waste facilities, and 26 hours revi ewing reports and testing results associ ated 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 st ate 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 standa rds, and others will be withdrawn by owners.

The average burden for preparing permit applic ation 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 indi vidual or an area permit, the use of co ntractors, 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 di rections and fill out the permit application form. With respect to the suppor ting documentation, EPA assu mes 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 operato r generally submits supporting data for a representative well. Ta ble A-2 provides estimates of the time required, beyond what is considered customary business practice, to prepar e the attachments to a Class II perm it 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 propo sed operating data; and

 20 hours to prepare financial responsibility information.Table A-2Annual Paperwork Burden and Costs Associated with Class II Wells: OperatorsABCDE FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo. ofResponsesTotalHours/Year Total Cost/YearInitial/Start-up RequirementsRequirements associated with permit applications (Per Permit Application)Read permit application directions. One-time0.0 0.0 0.5 0.5 1.0 $36 $0 6,038 6,038 $218,673Gather and submit: a description of activitiesrequiring a permit, facility name and address,SIC codes, ownership and facility status,facility location, listing of relevant permits orconstruction approvals, topographic maps,description of the business.One-time0.1 0.0 1.0 0.4 1.5 $64 $0 6,038 9,056 $385,067For DI programs, gather and submit a list ofall land owners within one quarter mile of thefacility boundary.One-time0.2 0.0 0.0 1.0 1.2 $42 $180 294 353 $65,252Prepare and submit plugging andabandonment plan.One-time0.0 0.6 4.8 0.6 6.0 $283 $0 6,038 36,225 $1,708,006Show evidence of financial responsibility forclosure.One-time0.0 5.0 5.0 10.0 20.0 $894 $0 6,038 120,750 $5,400,375Prepare and submit proposed CorrectiveAction Plan.One-time0.0 0.3 2.9 0.2 3.4 $162 $0 604 2,053 $97,556Prepare and submit revised Corrective ActionPlan.One-time0.0 1.0 9.6 0.7 11.3 $536 $0 121 1,364 $64,778Prepare and submit Area of Review map.(State/DI Program performs study)One-time0.0 0.0 1.0 0.0 1.0 $46 $36 1,342 1,342 $109,257Prepare and submit Area of Review map andstudy.One-time0.0 0.1 2.9 2.0 5.0 $194 $195 1,139 5,721 $442,742Prepare and submit proposed operating data. One-time0.0 0.1 1.8 0.1 2.0 $93 $0 6,038 12,075 $560,161Prepare and submit geological data on theinjection and confining zone.One-time0.0 0.5 8.0 1.0 9.5 $432 $0 6,038 57,356 $2,606,239Prepare and submit name and depth tobottom of USDWs.One-time0.0 0.1 2.3 0.1 2.5 $116 $215 6,038 15,094 $1,993,676Prepare and submit schematic of the well. One-time0.0 0.0 2.8 0.2 3.0 $133 $0 6,038 18,113 $803,753Underground Injection Control Program -- Information Collection RequestPage A-19Table A-2Annual Paperwork Burden and Costs Associated with Class II Wells: OperatorsABCDE FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo. ofResponsesTotalHours/Year Total Cost/YearRequirements associated with completion reports (Per Well)Prepare and submit completion report. One-time0.0 0.0 1.5 2.5 4.0 $135 $0 1,725 6,900 $233,678Perform and report on appropriate logs andother tests during construction.One-time0.0 0.2 1.9 0.2 2.4 $113 $4,292 259 621 $1,139,939Demonstrate mechanical integrity. One-time0.0 0.0 7.0 0.0 7.0 $319 $193 1,725 12,075 $884,185Requirements associated with permit reviews/modifications (Per Permit/Per Operator)Respond to issues raised during permitreview.Every 5 years0.0 0.5 2.0 0.5 3.0 $144 $0 1,509 4,526 $217,963Prepare and submit request for permitmodification.Occasional0.0 0.4 2.8 0.8 4.0 $181 $0 2,263 9,051 $409,720Monitoring/Testing Requirements (Per Operator)Monitor the nature of injected fluids. As necessaryto obtainrepresentative0.0 0.0 2.0 0.0 2.0 $91 $43 60,340 120,681 $8,096,765Record injection pressure, flow rate, andcumulative volume.At least every30 days.0.0 0.0 0.6 0.3 0.8 $33 $0 181,021 152,058 $5,984,428Demonstrate mechanical integrity. Every 5 years0.0 0.0 3.0 0.0 3.0 $137 $1,932 40,730 122,189 $84,248,356Reporting Requirements (Per Operator)In DI programs, gather and submitgroundwater monitoring data, analyses ofinjected fluids, a description of geologicstrata, and other items as requested.Occasional0.0 3.0 22.0 5.0 30.0 $1,377 $0 3 98 $4,475In DI programs, notify Regional Administrator30 days prior to MIT.Every 5 years0.0 0.0 0.5 0.5 1.0 $36 $0 78 78 $2,820Notify Director of (1) any planned physicalchanges to facility; (2) changes that mayresult in noncompliance, (3) permit transfers,(4) compliance or noncompliance withcompliance schedules, (5) possibleendangerment to a USDW.Occasional0.0 1.0 1.5 2.5 5.0 $215 $0 905 4,526 $194,701Report monitoring data, including monthlyrecords of injected fluids, any changes incharacteristics or sources of injected fluids.Annual0.0 0.0 3.3 1.7 5.0 $197 $0 15,085 75,426 $2,967,520Report MIT results. Annual0.0 0.0 1.0 0.0 1.0 $46 $0 15,085 15,085 $688,339Underground Injection Control Program -- Information Collection RequestPage A-20Table A-2Annual Paperwork Burden and Costs Associated with Class II Wells: OperatorsABCDE FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo. ofResponsesTotalHours/Year Total Cost/YearRecordkeeping Requirements (Per Operator)Retain records of permitting data, nature andcomposition of injected fluids, and allmonitoring results.At least 3years0.0 0.0 1.0 3.0 4.0 $126 $0 15,085 60,340 $1,901,543Closure Requirements (Per Operator)In DI programs, notify director of revisions toplugging and abandonment plan.One-time0.0 0.5 2.5 1.0 4.0 $181 $0 1 2 $92Notify the Director before conversion orabandonment of the well, or in the case ofarea permits, before closure of the project.One-time0.0 1.0 0.0 2.0 3.0 $133 $0 1,044 3,132 $139,128In DI programs, submit a plugging andabandonment report within 60 days afterplugging a well.One-time0.0 0.0 4.5 1.5 6.0 $246 $258 51 305 $25,577Other Requirements (Per Operator)In DI programs, submit reviseddemonstration of financial responsibility.Occasional0.0 0.5 0.5 1.0 2.0 $89 $0 73 147 $6,571TOTALS388,781 872,778 121,601,334$Note: Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-21Table A-2 (continued)Annual Paperwork Burden and Costs Associated with Class II Wells: StatesABCD E FHours and Costs per Response Total Hours and CostDescription of Requirement Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearInitial/Start-upPermit applications (Per Permit Application)Review permit application and supportingdocumentation and prepare draft permit.One-time6.0 $249 $0 5,743 34,461 $1,427,510Consider public comments. One-time2.0 $83 $0 5,743 11,487 $475,837Issue final permit decision. One-time2.0 $83 $0 5,743 11,487 $475,837Respond to comments. One-time4.0 $166 $0 5,743 22,974 $951,674Review operator's AoR map and study. One-time5.0 $207 $0 1,083 5,416 $224,333Review operator's AoR map and performAoR study.One-time2.5 $104 $0 1,342 3,356 $139,000Review completion report. One-time2.0 $83 $0 1,641 3,282 $135,953Permit reviews/modifications (Per Operator)Review each permit to determine whether itshould be modified, revoked and reissued, orterminated.Every 5 years1.0 $41 $0 1,435 1,435 $59,446Review request for permit modification or reissuance.Occasional4.0 $166 $0 2,153 8,610 $356,673Monitoring/Testing (Per Operator)Review mechanical integrity test datasubmitted by operators.Every 5 years0.5 $21 $0 38,746 19,373 $802,514Review monitoring data submitted byoperators.Annual0.3 $10 $0 14,351 3,588 $148,614RecordkeepingMaintain administrative record in DIprograms.One-time1.0 $41 $0 0 0 $0Underground Injection Control Program - Information Collection Request Page A-22Table A-2 (continued)Annual Paperwork Burden and Costs Associated with Class II Wells: StatesABCD E FHours and Costs per Response Total Hours and CostDescription of Requirement Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearOther Reporting (Per Operator)Respond to periodic notifications by ownersand operators.Occasional2.0 $83 $0 861 1,722 $71,335Closure (Per Operator)For DI programs, review plugging andabandonment report.One-time1.0 $41 $0 0 0 $0TOTAL84,625 127,190 $5,268,725Note: Numbers may not add due to roundingUnderground Injection Control Program - Information Collection Request Page A-23

### Underground Injection Control Program – Information Collection Request Page A-24 

## Based on previous studies of state AoR practices and requirements, EPA proj ects 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-referen ced AoR studies, ensuring AoR coverage.

 Operator has been granted a state variance based on factors relating to geol ogic setting and/or well conditions.

 Well is located in a unitized proj ect, and many of the elements of AoR studies were previously performed during unitization.

Previous EPA studies also have shown that many stat e primacy agencies perform all or most of the tasks involved in the AoR study. In these ca ses, 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 Ao R 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 listin g 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 acti on 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, th e weighted average time to prepare a corrective action plan is 3.4 hours. EPA regional or state primacy staff will require 20 percent of a pplicants to revise their complex corrective action plans. Each revise d plan will take about 11.3 hours to prepare.

Unless exempted by the Director, operators in DI programs are requi red to submit a list of landowners within 1⁄4 mile of the facility boundary. EPA estimates th at these applicants will each take 1.2 hours to research property ownership records and prepare the list. This un it 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, op erators must submit comple tion reports for each new Class II well. With the completion report, operators mu st submit results of MITs and any well logs and tests required by the Director. Operators will take approximately 2.4 hours to pe rform and report on logs and tests and 4 hours per well to fill out the co mpletion form. The MIT will requir e 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 repor t on new well logs and test s, 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 serv ices. The unit burden for operators assumes that operators wi ll 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 ar e 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 rais ed 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 a dd wells to existing area permits, and for other reasons. EPA expects that preparing each request will ta ke an average of 4 hours.

Monitoring/Testing

For purposes of estimating the number of respondent s for monitoring and testing, EPA assumes that the typical Class II operator has approximately 10 wells. An ope rator with wells in multiple states is treated as a separate operator in ea ch state, since the operator w ould 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 inje ctate 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 analy ze their injectate or, in some cases, send it to a commercial laboratory for analysis.

Most operators are required to obs erve 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 pressu re, flow rate, and cumulative volume as a customary business practice. Thus, the incremental time needed to perform these observations is about 0.84 hour s per operator (0.08 hours, or 5 minutes, per well) per month. This represents th e time required to record the data on a field report.

Based on information reported on the UIC reporting fo rms, EPA assumes that 27 percent of operators will perform MITs on their wells each year. Each ope rator 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 sp end about 5 hours to prepare annual monitoring reports. These reports include summaries of monthly or week ly observations of flow, pressure, and cumulative volume. In addition, 27 percent of operators will spend 1 hour per op erator 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 transfer s, 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 we lls in DI states may be require d 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, oper ators 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 op erators 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 pe rcent 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 pe rmit 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 oversig ht of Class II programs is presen ted in Column A of Table A-2.

EPA estimates that states will spend 23.5 hours per a pplication reviewing Class II injection well permit applications. Primacy agency staff spend one hour to de termine whether to reissue, modify, or revoke each permit during the five-year review process. Primacy ag encies spend four hours reviewing each request for a permit modification or renewal.

State primacy agencies spend from 0.3 to 0.5 hour s per report reviewing mon itoring 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 r ecordkeeping, and closing their facili ties, 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 th e directions and filling out the applic ation 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 stim ulation 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 fi nancial responsibility.

In addition, EPA estimates that, when requested by th e Director, revised corrective action plans will take 10 hours each. Applicants in DI programs will spend 1.2 hour s each to gather a list of landowners adjacent to the facility.

Operators completing wells must perform a two-pa rt 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 prep are a completion report, 10 hours to de monstrate mechanical integrity, and 2.4 hours to perform and submit the results of required logs and tests during construction.Table A-3Annual Paperwork Burden and Costs Associated with Class III Wells: OperatorsABCDE FHours and Costs per ResponseTotal HoursDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo ofResponsesTotalHours/Year Total Cost/YearInitial/Start-up RequirementsRequirements associated with permit applications (Per Permit Application)Read permit application directions. One-time0.0 0.0 0.5 0.5 1.0 $36 $0 32 32 $1,159Gather and submit the following information: (1) a descriptionof activities requiring a permit, (2) facility name and address,(3) SIC codes, (4) ownership and facility status, (5) facilitylocation, (6) listing of relevant permits or construction approOne-time0.52.0 4.7 2.8 10.0 $486 $0 32 320 $15,550For DI programs, gather and submit a list of all land ownerswithin one quarter mile of the facility boundary.One-time0.20.0 0.0 1.0 1.2 $42 $180 24 29 $5,389Prepare and submit plugging and abandonment plan. One-time0.00.0 6.4 1.6 8.0 $335 $0 32 256 $10,718Show evidence of financial responsibility for closure. One-time0.00.5 1.0 2.0 3.5 $139 $0 32 112 $4,450Prepare and submit proposed Corrective Action Plan. One-time0.02.0 10.0 2.0 14.0 $669 $0 32 448 $21,415Prepare and submit revised Corrective Action Plan. One-time0.01.0 8.0 1.0 10.0 $471 $0 6 64 $3,018Prepare and submit AoR map and study. One-time0.03.2 25.5 3.4 32.0 $1,506 $1,066 32 1,024 $82,316Prepare and submit maps and cross-sections of USDWs withinAoR, local geology, and regional geology.One-time0.00.0 18.0 4.0 22.0 $929 $215 32 704 $36,582Prepare and submit proposed operating data, formation testingprogram, stimulation program, and injection procedure.One-time0.02.0 6.0 1.0 9.0 $460 $0 32 288 $14,716Prepare and submit schematic of the well. One-time0.00.0 4.2 0.8 5.0 $213 $0 32 160 $6,819Prepare and submit monitoring plan. One-time0.00.0 12.0 4.0 16.0 $655 $0 32 512 $20,953Requirements associated with completion reports (Per Well)Prepare and submit completion form and supportingdocumentation (7520-9).One-time0.00.0 1.5 2.5 4.0 $135 $0 21 84 $2,845Prepare and submit appropriate logs and tests duringconstruction.One-time0.00.2 1.9 0.2 2.4 $113 $4,911 1 2 $4,776Demonstrate mechanical integrity. One-time0.01.0 8.0 1.0 10.0 $471 $4,292 21 210 $100,042Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)Respond to issues raised during permit review. Every 5 years0.03.0 1.0 0.0 4.0 $285 $0 28 113 $8,025Prepare and submit request for permit modification. Occasional0.02.0 22.0 4.0 28.0 $1,270 $0 24 672 $30,490Monitoring/Testing Requirements (Per Facility)Monitor the nature of injected fluids. As necessaryto obtainrepresentativedata0.00.0 6.0 2.0 8.0 $327 $0 39 310 $12,667Monitor injection pressure and flow rate or volume of injectedfluids, or meter and record injected and produced fluidvolumes.Semi-monthly/Continuous0.00.0 3.3 1.3 4.6 $187 $0 3,666 16,992 $683,957Demonstrate mechanical integrity. Every 5 years0.016.1 128.7 16.1 160.9 $7,585 $69,051 8 1,245 $593,015Monitor the fluid level in the injection zone where appropriateand monitor parameters chosen to measure water quality in themonitoring wells.Semi-monthly/monthly0.00.0 27.5 3.0 30.5 $1,335 $0 224 6,821 $298,599Underground Injection Control Program -- Information Collection RequestPage A-28Table A-3Annual Paperwork Burden and Costs Associated with Class III Wells: OperatorsABCDE FHours and Costs per ResponseTotal HoursDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo ofResponsesTotalHours/Year Total Cost/YearReporting 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.Occasional0.01.0 3.0 2.0 6.0 $270 $0 14 85 $3,809Report to the Director on required monitoring, mechanicalintegrity tests, and other required tests.Quarterly0.01.0 10.0 19.0 30.0 $1,045 $0 564 16,920 $589,551Recordkeeping Requirements (Per Facility)Retain records of permitting data, calibration and maintenancedata, and monitoring results.At least 3years0.00.0 0.4 3.0 3.4 $99 $0 141 479 $13,913Closure Requirements (Per Facility)Notify the Director before conversion or abandonment of thewell or in the case of area permits before closure of the project.One-time0.01.0 0.5 0.5 2.0 $116 $0 2 4 $232In DI programs, submit a plugging and abandonment reportwithin 60 days after plugging a well or at the time of the nextquarterly report.One-time0.00.0 0.8 0.3 1.0 $41 $0 1 1 $42Other Requirements (Per Facility)In DI programs, submit revised demonstration of financialresponsibility.Occasional0.00.5 0.5 1.0 2.0 $89 $0 83 165 $7,394TOTALS5,18748,051 2,572,442$Note: Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-29Table A-3 (continued)Annual Paperwork Burden and Costs Associated with Class III Wells: StatesABCDE FHours and Costs per Response Total Hours and CostProgram Oversight Activities Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearInitial/Start-upPermit applications (Per Permit Application)Consider the permit application, area of review,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andt ti d d i ti fOne-time20.0 $828 $0 13 260 $10,770Consider the permit application, area of review,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andt ti d d d ftOne-time40.0 $1,657 $0 18 720 $29,825Provide public notice of issuance of a draftpermit or intent to deny.One-time2.0 $83 $0 48 96 $3,977Consider public comments. One-time8.0 $331 $0 48 384 $15,907Issue final permit decision. One-time10.0 $414 $0 48 480 $19,884Respond to comments. One-time15.0 $621 $0 48 720 $29,825Review completion report. One-time2.0 $83 $0 21 42 $1,740Underground Injection Control Program -- Information Collection RequestPage A-30Table A-3 (continued)Annual Paperwork Burden and Costs Associated with Class III Wells: StatesABCDE FHours and Costs per Response Total Hours and CostProgram Oversight Activities Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearPermit reviews/modifications (Per Facility)Review each permit to determine whether itshould be modified, revoked and reissued, orterminated.Every 5 years4.0 $166 $0 14 55 $2,259Review request for permit modification or reissuance.Occasional20.0 $828 $0 23 460 $19,055Monitoring/Testing (Per Facility)Review mechanical integrity test data submittedby operators.Every 5 years0.5 $21 $0 14 7 $282Review monitoring data submitted by operators. Quarterly0.25 $10 $0 273 68 $2,823Other Reporting (Per Facility)Respond to periodic notifications by ownersand operators.Occasional4.0 $166 $0 18 72 $2,983Recordkeeping (Per Facility)Maintain administrative record (DI). One-time4.0 $166 $0 0 0 $0Closure (Per Facility)Review plugging and abandonment report (DIonly).One-time4.0 $166 $0 0 0 $0TOTAL585 3,363139,330$Note: Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-31

### 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 a ny issues raised during the review. In addition, Class III operators will take an averag e of 28 hours to prepare reques ts for permit modifications.

Monitoring/Testing

EPA anticipates that operators of salt solution mi ning facilities will submit annual analyses of their injectate. On average, each operato r will take 8 hours per year to sample and analyze its injectate in-house.

Operators of Class III facilities wi ll monitor injection pre ssure, 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 burd en is approximately 4.6 hours per opera tor 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 se lected monitoring wells completed in the injection zone and overlying freshwater aquifers. Some active f acilities monitor semi-monthly, while other facilities that are performing aquifer restoration mon itor monthly. EPA estimates that th e typical uranium facility has about 110 monitoring wells. As with pressure, flow, and volum e monitoring, operators will perform about two-thirds of this monitoring as a customary bus iness practice to identify potential excursions from the injection zone. EPA assumes that UIC requirements in crease the monitoring burden to th ese operators by about 30.5 hours per monitoring period.

Reporting and Recordkeeping

Operators of Class III facilities will incur a bur den 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 oversig ht of Class III programs is pres ented 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 denie d, EPA estimates that states will spend between 20 and 77 hours reviewing each application fo r a permit to inject waste into a Cl ass 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 revi ewing 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/endange ring 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 require d to close them and submit plugging and abandonment reports to states or DI programs. The exception to the ban is for those Cl ass 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 th e 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 Compre hensive Environmental Response, Compensation, and Liability Act of 1980 or RCRA. EPA estimat es that the operator burde n associated with this one-time requirement to submit a plugging and abandonmen t 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 e ndangering Class V wells involves review by primacy agency staff of closure plans submitted by operators. EP A estimates the state burden to be one hour per review.

Burden Associated with Class V Wells

EPA’s estimate of the annual paperw ork 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 subm itting inventory information and compliance with the Class V Rule by owners of motor vehicle waste disposal wells (MVW DWs) and large-capacity cesspools.

Inventory Activities

Recent efforts by the Regions and state primacy agen cies 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 invent ory information to the appr opriate Regional or state primacy agency.Table A-4Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: OperatorsAB C DEFTotal Hours and CostsDescription of Requirement Questions Frequency Managerial Technical Clerical Unit BurdenUnit LaborCostUnit Nonlabor CostNo. ofResponsesTotalHours/YearTotalCost/YearClosure Requirements (Per Well)Submit a plugging and abandonment reportwithin 60 days after plugging a well.One-time0 7.5 2.5 10.0 $235 $0 990 9,900 $232,551TOTAL990 9,900 $232,551Note:Numbers may not add due to rounding.Underground Injection Control Program - Information Collection RequestPage A-34Table A-4 (continued)Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: StatesABCDEFHours and Costs per Response Total Hours and CostDescription of RequirementFrequencyUnit Burden(A)Unit LaborCostUnitNonlaborCostNumber ofResponsesTotalHours/YearTotalCost/YearClosureReview closure plan.One-time 1.0 $41 $0 758 758 $31,399TOTAL758 758 $31,399Note:Numbers may not add due to rounding.Underground Injection Control Program - Information Collection Request Page A-35Table A-5Annual Paperwork Burden and Costs Associated with Class V Wells: OperatorsAB C D E FHours and Costs per ResponseDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit Non-laborCost (A)No. ofResponsesTotalHours/YearTotalCost/YearInventory RequirementsIn DI programs, submit inventory information prior tocommencing injection.One-time0.0 0.0 0.0 0.5 0.5 $9 $0 33,867 16,934 $308,463Class V Rule Requirements for Owners/Operators of Large-Capacity CesspoolsRead regulations. One-time0.0 0.0 3.0 0.0 3.0 $76 $0 104 313 $7,903Prepare and submit pre-closure notification (Form7520-17).One-time0.0 0.5 0.8 0.3 1.5 $53 $0 104 157 $5,501Class V Rule - Startup Requirements for Owners / Operators of Motor Vehicle Waste Disposal WellsContact state or local agency to determinerequirements.One-time0.0 0.0 1.0 0.0 1.0 $25 $0 500 500 $12,632Read regulations. One-time0.0 0.0 3.0 0.0 3.0 $76 $0 500 1,501 $37,897For wells that will close, sample injectate andmaintain record.One-time0.0 0.0 1.0 0.5 1.5 $34 $661 480 720 $333,785Prepare and submit pre-closure notification (Form7520-17).One-time0.0 0.5 0.8 0.3 1.5 $53 $0 480 720 $25,308For wells obtaining a waiver, conduct initial sampling.One-time0.0 0.0 1.0 0.5 1.5 $34 $661 20 31 $14,140For wells obtaining a waiver, prepare and submitpermit application.One-time0.0 8.0 25.0 21.0 54.0 $1,482 $0 20 1,098 $30,124Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal WellsConduct quarterly injectate sampling. Quarterly0.0 0.0 1.0 0.5 1.5 $34 $661 5,896 8,844 $4,099,993Conduct annual sludge sampling (concurrent withinjectate sampling).Annual0.0 0.0 1.0 0.5 1.5 $34 $1,728 1,474 2,211 $2,598,312Annual reporting and recordkeeping of all monitoringresults.Annual0.0 0.0 3.0 1.0 4.0 $94 $0 1,474 5,896 $138,497TOTAL44,92138,924$7,612,555Notes:(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 RequestPage A-36Table A-5 (continued)Annual Paperwork Burden and Costs Associated with Class V Wells: StatesA B CD E FHours and Costs per Response Total Hours and CostDescription of RequirementFrequency Unit Burden (A) Unit Labor CostUnit NonlaborCostNumber ofResponses Total Hours/Year Total Cost/YearInitial/StartupReview inventory information.One-time 0.5 $21 $0 22,038 11,019 $456,456Primacy 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 $48,897Review and file pre-closure notifications.One-time 1.3 $52 $0 1,141 1,426 $59,066Review, approve, and file waivers/permit applications.One-time 8.3 $344 $0 40 329 $13,648Review and file annual monitoring reports.Annual 0.8 $33 $0 959 767 $31,786TOTAL25,358 14,722 609,854$Notes:(A) Unit burdens for initial/start-up activities reported on a per-permit basis. Unit burden for other activities reported ona per-operator basis.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-37

### 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 co ntinue operating motor vehicle waste disposal wells must seek waivers from the ban on existing motor vehicl e 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 pr e-closure notifications.

Note: While the Class V Rule require d that all closure or permitting activities be completed by January 2007 (the latest date by which operators with state-granted extensions woul d 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 in cluded in this ICR.

Operators of Large-Capacity Cesspools

Operators of facilities with large-capacity cesspoo ls will need to become familiar with the Class V requirements and prepare and submit a pre-closure notific ation to their primacy agencies. EPA assumes that each facility will require a total of 4.5 hours to comp lete 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 wa ter protection area (SWPA) or other sensitive ground water area. These activities will re quire 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 MV WDWs must notify the UIC Pr ogram Director at least 30 days prior to well closure, sample their inject ate, and submit a pre-closure notification form (Form 7520-17 or a state equivalent). These opera tors would incur a burden of 3 hours.

 The specific information required in a permit applicati on 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 desc ription of activities requiring a permit, inventory information, topographic maps, a nd a brief description of the business. These operators will also sample their in jectate. The burden for these activ ities 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 Cla ss V wells includes time associated with reviewing inventory information, processing permit applications and pre-closure notifica tions, and reviewing and responding to monitoring data submitted by operators within their states. State burden associated with oversight of Class V programs is presente d in Column A of Table A-5.

EPA estimates that states will spend 0.5 hours per Cl ass 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 an nual UIC performance activity measures.

### Underground Injection Control Program – Information Collection Request Page A-39 

## facilities with motor vehicle waste dis posal wells and large-cap acity cesspools. State pr imacy agencies will also review annual monitoring reports submitted by oper ators (details are presented in Table A-5).

Burden Associated with Class VI Wells

EPA’s estimate of the annua l paperwork burden on operators and states associated with Class VI wells is presented in Column A of Table A- 6. The burden associated with Cla ss VI wells is for 2011 through 2013 is estimated in ICR 2309.01; this ICR only in cludes Class VI Rule burden incurred in 2014 (the last year of this clearance). The burden estimates presente d for Class VI wells are weighted av erages that take into account the formation type, injection depth waiver status, and number of f acilities that are active during this ICR clearance period. As such, these burden estimate s 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 r eevaluations and associat ed plan revisions, and closure and post-injection site car e related paperwork activities.

EPA anticipates that Class VI facility operators w ill rely on contractors to assist them for information collection activities such as 3D seismic surveys, aerial surveys, and te st well drilling. The costs associated with contractor labor and other c ontractor services are included in the opera tor costs presented in Column C of Table A-6. However, as geologic sequestra tion is a relatively new endeavor, ther e 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 operato r burden to provide a conservatively large estimate of operator burden.

EPA assumes that some activities required of Class VI operators (s uch as developing maps and crosssections of the receiving formation) are customary bus iness practices that would be performed by operators even in the absence of regulation. Un it burden and costs used in Table A- 6 represent the co sts of performing each activity required of Class VI operators that are incremental to customary business practices.AB C DE FDescription Of Requirement FrequencyTechnical 1(Engineer)Technical 2(Geologist)UnitBurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ YearTotalCost/YearInitial/Startup Requirements (Per Permit Application)Requirements Associated with Permit ApplicationsFile Class VI permit application, includingattachmentsand the testing and monitoring plan, emergency andremedial response, injection well plugging, and postinjection site care and site closure plan. One-Time226 56 283 $31,066 $847,124 0.60170 $528,377Conduct 3D seismic surveyto identifyfaults andfractures; obtain and analyze seismic history. One-Time0 253 253 $27,090 $18,385,597 0.60152 $11,078,300Obtain geomechanical and geochemical informationon injection zone, subsurface aquifers including allUSDWs, and the confining zone in the area of review. One-Time0 909 909 $97,525 $1,840,888 0.60547 $1,166,279Develop maps and cross sections of the injectionzone, subsurface aquifers including all USDWs, andthe confining zone in the area of review. One-Time0 733 733 $78,562 $0 0.60441 $47,268Take initial samples to develop ageochemicalbaseline for injection zones and confining zones. One-Time0 0 0 $0 $4,079 0.600 $2,454Prepare geologic characterization reportdemonstrating: suitability of receiving zone, storagecapacity and injectivity, trapping mechanism free ofnonsealing faults, competent confining system, etc. One-Time0 1036 1036 $111,070 $0 0.60623 $66,827Demonstrate financial responsibilityto ensure fundswill be available for required future actions. One-Time4 0 4 $442 $0 0.602 $266Conduct aerial and database search for artificialpenetrations (wells) within the area of review;determine integrity/plugging status of each. One-Time140 3266 3406 $365,662 $94,057 0.602049 $276,597Perform complex modelingof CO2 fluid flows andmigration (reservoir simulations) and prepare Area ofReview and corrective action plan. One-Time308 0 308 $34,072 $0 0.60185 $20,500Requirements Associated with Injection Well ConstructionInstall check valve(Director discretion to require downhole shut-off valve, but expected to be check valves inall but the most exceptional cases). One-Time0 0 0 $0 $600 0.600 $361Design and install equipment for injection wells tomeasure: injected volumes, pressure, flow rates, andannulus pressure, as well as equipment to add CO2tracers. One-Time0 0 0 $0 $86,880 0.600 $52,273Total Hours andCostsHours and Costs Per ResponseTable A-6Annual Paperwork Burden and Costs Associated with Class VI Wells: OperatorsUnderground Injection Control Program -- Information Collection RequestPage A-40AB C DE FDescription Of Requirement FrequencyTechnical 1(Engineer)Technical 2(Geologist)UnitBurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ YearTotalCost/YearTotal Hours andCostsHours and Costs Per ResponseTable A-6Annual Paperwork Burden and Costs Associated with Class VI Wells: OperatorsMonitoring/Testing Requirements (Per Operator)Analyze injectate stream and perform corrosionmonitoring. Quarterly62 0 62 $6,803 $15,068 0 0 $0Develop a corrosion monitoringand preventionprogram. One-Time24 0 24 $2,655 $0 0.6014 $1,597Construct monitoringwells. One-Time0 0 0 $0 $11,285,1900.600 $6,789,923Design and install equipment for monitoring wells tomeasure: pressure, temperature, resisitivity, salinity,CO2, tracers, and any other required monitoringequipment. One-Time0 0 0 $0 $309,595 0.600 $186,273Operate and maintain monitoringwells and themonitoring equipment within them. Annual13 0 13 $1,386 $427,167 0 0 $0Conduct periodic monitoringofgroundwater qualityand geochemistry. Monthly21 0 21 $2,323 $10,080 0 0 $0Conduct external mechanical integritytests to detectflow adjacent to well using temperature or noise log. Annual0 0 0 $0 $168,026 0 0 $0Conduct a tracer surveyof the bottom-hole cementusing a CO2-soluble isotope. Annual0 0 0 $0 $39,780 0 0 $0Conduct casing inspection log.EveryFiveYears0 0 0 $0 $154,737 0 0 $0Conduct pressure fall-off testing.EveryFiveYears0 0 0 $0 $31,671 0 0 $0Conduct 3D seismic surveyto track movement of theCO2 plume and pressure front.EveryFiveYears0 0 0 $0 $1,104,039 0 0 $0Activities Associated with Area of Review ReevaluationsConduct complex modeling of fluid flows andmigration (reservoir simulations). Based on newresults, update AoR and corrective action plan, testingand monitoring plan, and emergency and remedialresponse plan.Every FiveYears1118 0 1118 $123,622 $0 0 0 $0Reporting and Recordkeeping Requirments (Per Operator)Report to regulators; maintain records of data from alldata gathering activities.SemiAnnual33 0 33 $3,651 $0 0 0 $0Underground Injection Control Program -- Information Collection RequestPage A-41AB C DE FDescription Of Requirement FrequencyTechnical 1(Engineer)Technical 2(Geologist)UnitBurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ YearTotalCost/YearTotal Hours andCostsHours and Costs Per ResponseTable A-6Annual Paperwork Burden and Costs Associated with Class VI Wells: OperatorsPost-Injection Site Care and Site Closure Requirements (Per Operator)Demonstrate financial ability (accounting for inflation)to close site.PostInjection,One-Time8 0 8 $885 $0 0 0 $0Perform a mechanical integritytest prior to plugginginjection wells to evaluate integrity of casing andcement to remain in ground.PostInjection,One-Time0 0 0 $0 $283,410 0 0 $0Conductground water monitoring- operate andmaintain monitoring wells and the monitoringequipment within them.PostInjection,Annual0 0 0 $0 $491,655 0 0 $0Track the CO2 plume and pressure front using 3Dseismic surveys.PostInjection,Every FiveYears0 0 0 $0 $1,104,039 0 0 $0Report post-injection monitoring results to regulators.PostInjection,Every FiveYears40 0 40 $4,425 $0 0 0 $0TOTAL8.4 418420,217,296$Notes:(A)Unit Non-Labor Cost inflated by20% to account for G&ANumbers maynot add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-42AB C DE FDescription Of Requirement Frequency Unit BurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ YearTotalCost/YearInitial/Startup Requirements (Per Permit Application)Review the permit application and other informationsubmitted by the operator, considering: AoR, relevant maps,geologic characteristics of the site, formation testing results,well schematics and construction procedures, proposedinjection procedure, status of corrective action on wellswithin the AoR, well logging, testing, and mechanicalintegrity data, and all required project plans. One-time45.4 $3,010 $0 0.6027.3 $1,811Review financial responsibility demonstration. One-time4.5 $298 $0 0.602.7 $179Determine and specify tubing, packing, casing, andcementing requirements based on review of informationsubmitted by operator. One-time4.5 $298 $0 0.602.7 $179Witness logging and testing. One-time1.7 $112 $0 0.601.0 $67Review applications for waviers to inject above thelowermost underground source of drinking water. One-time2.4 $157 $0 0.601.4 $94Monitoring and RecordkeepingReview reports submitted by operators; recordkeeping ofdata from all data gathering activities. Annual2.2 $149 $0 0 0 $0Review mechanical integrity test data. Annual13.5 $893 $0 0 0 $0Area of Review ReevaluationReview modeling update of the area of review and updatedplans.Every 5years20.0 $1,326 $0 0 0 $0Site ClosureReview relevant data prior to granting approval for pluggingand abandonment of a well. One-time2.2 $149 $0 0 0 $0TOTAL3.0 352,331$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: StatesTable A-6 (continued)Hours and Costs Per Response Total Hours and CostsUndergound Injection Control Program -- Information Collection RequestPage A-43

### Underground Injection Control Program – Information Collection Request Page A-44 

## Initial Permitting/Start-up

EPA anticipates that all permit applications dur ing the timeframe of this ICR will be submitted by owners or operators seeking to inject into deep saline fo rmations. 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 sour ce of drinking water. EPA estimates that 95 percent of applications not requesting a waiv er will be approved, and 47.5 percent of applications requesting a waiver will be approved. EPA or state primacy agencies will de ny applications that do not meet Class VI standards, and others will be withdrawn by owners.

EPA estimates that the operator burden associat ed 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 testi ng and monitoring plan, an emergenc y and remedial response plan, an injection well plugging plan, and a post-inj ection site care and site closure plan.

In addition to applying for permits, EPA estimates th at operators of Class VI wells will incur burden to perform the following start-up activi ties. Unit burden for these star t-up activities is provided below.

 Conduct a 3D seismic survey to identify faults an d 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 s ources 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 syst em (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 pres ence of a trapping m echanism 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 pe netrations (wells) within the AoR, and determine integrity and plugging status of each (3,405.6 hours).

 Perform complex modeling of carbo n dioxide fluid flows and migra tion (reservoir simulations) and prepare Area of Review and co rrective action plan (308.0 hours).

Monitoring/Testing

Class VI well operators will be required to perfor m 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 on e-time burden of 24.0 hours to develop a corrosion monitoring program. Additionally, operators will incur an annual burden of approxima tely12.5 hours to operate and maintain monitoring wells and the monitoring e quipment within them. Operators must also perform groundwater quality and geochemical m onitoring which is estimated to o ccur on a monthly basis and require approximately 21.0 hours of burden per month. Owners or opera tors will also hire contra ctors 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 reevalua te the AoR for the GS project at least every five years. Based on the results of th e reevaluation, operators will update and resubmit the AoR and corrective action plan, the monitoring and testing plan, and the em ergency response plan or demonstrate that no updates are necessary. They will also update th e financial responsibility demonstrati on as needed to address any changes to these plans. (Note that owners or operators will al so 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 ope rators will reevaluate the AoR and update the aforementioned plans and submit them to the primacy ag ency 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 res pond to issues raised during a review of the Class VI permit, which is required ever y 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 testi ng and keep records of all data-gatheri ng activities. This results in an annual burden of 66 hours per year for each operator of a Class VI well.

Closure and Post-In jection 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 pr epare 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. Subseque ntly, operators are assumed to report mon itoring results to regulators every five years during the post-injection site ca re period, which is estimated to requi re 40.0 hours per operator, every five years. Due to the potentially long life spans of inj ection operations, no operator s are anticipated to conduct closure or post-injection s ite care activities during th e ICR clearance period.

Burden on Primacy Agencies Associated with Class VI Wells

State primacy agencies’ burden associated with Cl ass VI wells includes reviewing and responding to permit applications, monitoring and te sting data, AoR reevalua tions, and closure and po st-injection site care information submitted by operators. Due to the potential ly long life spans of injection operations, no closure and post-injection site care activit ies 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 bur den 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 proper ly close, plug, and to provi de 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 unde rground source of drinking water (EPA estimates that about 10 percen t of permit applicants will also ap ply 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 agen cies will review modeling updates to the AoR and other revised plans submitted by ope rators 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 proc ess 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 pe r 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 w ith 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, tr aining, or other information to well operators.Table A-7Annual State Burden and Cost for Program Oversight and ReportingA BC D E FHours and Costs per Response Total Hours and CostDescription of Requirement FrequencyUnit BurdenUnit LaborCostUnit NonlaborCostNumber ofResponsesTotalHours/Year Total Cost/YearProgram OversightOversee and implement UIC program in the State, forexample, update regulations or guidances as needed.Ongoing1,040 $43,081 $0 5860,320 $2,498,6967520 Forms ReportingPermit Review and Issuance Form (7520-1) Annual4.5 $186 $0 1881 $3,355Compliance Evaluation Form (7520-2A) Semi-annual6.0 $249 $0 36216 $8,948Compliance Evaluation for Significant Non-ComplianceForm (7520-2B)Semi-annual5.5 $228 $0 36198 $8,202Mechanical Integrity Tests/Remedial Action Form (7520-3) Annual5.0 $207 $0 1890 $3,728Quarterly Exceptions List Form (7520-4) Quarterly2.0 $83 $0 72144 $5,965Inventory and Measures ReportingConduct inventory-related activities, e.g., review operatordata and report to EPA's online inventory data system.Annual60 $2,485 $0 181,080 $44,738Report on UIC Measures to Headquarters Semi-annual60 $2,485 $0 362,160 $89,476Activities related to populating the National UIC DatabaseStart-up activities (per program)Develop data to meet UIC database needs (programs withUIC databases)One-time10 $428 3,540$ 993 $35,708Build data flow through data node (programs with UICdatabases)One-time25 $1,036 2,024$ 9225 $27,535Build data flow through data node (programs withoutdatabases)One-time8 $345 4,024$ 6 47 $24,759Ongoing activities (per program)Enter UIC data into state database Ongoing40 $1,657 $0 40 1,600 $66,278Data flow and QA checks Quarterly24 $994 $0 1603,840 $159,068RecordkeepingMaintain records of 7520 forms Ongoing40 $1,657 $0 18720 $29,825534 70,814 $3,006,281Notes: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 RequestPage A-47

### Underground Injection Control Program – Information Collection Request Page A-48 

## State Activities Associated w ith 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 cu rrently report via the 7520 form s, the inventory, and the measures data to Headquarters. (Once th ey 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 th e burden and cost sa vings to states associated with the national UIC database.

Start-up costs for states that have UIC databases include the costs associ ated 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 a bout 310 hours. Annualizing the e ffort over the estimated 6- year phase-in schedule, this equals 51.6 hours per pr ogram 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 setti ng 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 wh ich 25 hours are state burden.

To assist states without a UIC da ta base, EPA Headquarters developed an Access database. Because the database would be designed to the needs of the Na tional UIC Database and Hea dquarters 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 da tabase. 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 n eed 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 valid ation issues. EPA estimat es 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 responde nts subject to each paperwor k 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 assump tions of the number of permittees subject to each paperwork requirement, e.g., the number of permit applica tions or well closures expe cted, 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 ac tivity is performed is also presented in Tables A-1 through A-7, along with EPA’s description of each ac tivity. 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 whic h 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 h azardous 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 th e remaining two for newly constructed facilities). EPA further anticipates that 12 Class I hazardous facility op erators 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 repo rt at various frequencie s (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 facili ties, 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 existi ng facility. EPA anticipates that 20 Class I nonhazardous facility operators will renew their pe rmits each year, and 9 Class I nonhazar dous facility operators will modify their permits each year. Every operato r of a Class I nonhazardous waste faci lity 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 ar e approximately 15,085 Class II facilities.

EPA anticipates that, collectively, EPA regional offi ces and primacy states will receive approximately 6,038 permit applications for Class II wells each year during the lif e of this ICR. Details of the numbers of Class II operators subject to each paperwork requir ement are presented in Column D of Table A-2.

Based on previous studies of state AoR practices and requirements, EPA proj ects that state primacy agencies and EPA Regions will determine that a comple te 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 th e state primacy agency will perform most or all of the tasks involved in the AoR study.

EPA estimates that 604 applicants will submit corr ective action plans to ad dress specific problems identified by the AoR study. EPA regional or state pr imacy staff will require 121 operators (20 percent) to revise their corrective action plans.

Prior to obtaining approval to begin injection, op erators must demonstrate mechanical integrity and submit completion reports for an estima ted 1,725 new Class II wells each year.

EPA estimates that approximately 75,426 Class II wells (50 percent of the inve ntory) are permitted, and that 20 percent of operators will und ergo permit reviews each year, and ha lf of these (1,509) will need to respond to issues raised during the reviews. In add ition, EPA expects that 2,263 ope rators 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 transfer s, progress in achieving co mpliance 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 thr ee operators of rule-authorized wells in DI states may be required to gather and submit groundwater monitoring data, analyses of injected fluids, a descrip tion of geologic strata, and other items as requested.

EPA projects that, each year, approximately 1,044 opera tors will plug and abandon al l 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 abandonmen t plan, triggering a revi sion to the plugging and abandonment plan.

Class III

EPA estimates that there are approximately 141 facili ties with Class III wells (9 uranium mining, 39 salt solution mining, and 94 brine mining/other sites). A t ypical uranium facility has approximately 2,360 Class III wells, a typical salt mining facility has 22 wells, and a typical brine mini ng/other facility has 2 wells.

EPA regional offices and state primacy agencies exp ect to receive 32 permit applications from Class III operators each year. EPA estimates that approximately 2 Class III operators will cl ose their projects annually.

Operators of all 141 Class III facilities will monitor in jection 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 anal yses of their injectate once each year, and operators of salt solution mining faci lities will perform two-part MITs on all of their wells ev ery five years. All uranium well operators monitor water quality in the injection zone and overlying freshwateraquifers 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 Cl ass 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 ob tain a permit by 2007 (the burde n associated with these activities was estimated in the 2004 UI C Program ICR). However, based on consultations with regional and state staff, there is reason to beli eve that these activities ar e 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-cap acity cesspools need to close their facilities during the cl earance 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 res ources) and therefore the burden associated with closure of th ose large-capacity cesspools is alr eady accounted for. Thus, EPA assumes that an additional burden for closi ng 313 large-capacity cesspool s (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 obta in 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 in to 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 exte rnal 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 activit ies during the ICR clearance period, as no facilities are expected to have reached th e end of their injection peri ods 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 refl ects the fact that, in some states, more than one agency oversees UIC activities (e.g., stat es typically regulate Clas s 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 tr ansfer 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 schedul e for populating the National UIC Database. EPA estimates that, by January 2012 (the beginning of this information collection), 14 pr ograms will have transitione d 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 program s are expected to transition in 2014. On average over the clearance period, 15 states will perf orm activities associated with start-up of the data transfer—of these, nine are estimated to be programs with existing data base s and six programs have no ex isting 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 frequenc y at which primacy agencies complete each 7520 form is presented in Table A-7. Measur es reporting will take place semi-annua lly (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 Data base, a well-specific database that collects and stores state 1 

## and regional direct implementati on (DI) program data to support UIC programmatic data needs. The UIC system contai ns 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 elec tronically 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/qua lity control (QA/QC) reviews.

Headquarters deployed the Nati onal UIC Database in December 2007. After deployment, EPA developed a strategy to transiti on all state and DI programs to electronic reporting (e-reporting). The goal of the Strategy, known as the 2012 Strate gy, is to engage all UIC primacy programs by 2012. As of January 2011, four programs have tr ansitioned to e-reporting. Ten programs are expected to transition in 2011, ni ne programs are expected to tr ansition 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 challe nges, EPA’s Exchange Network Grants can be used to establish a data flow. Gr ant funds can also be used to co mplete other related activities, such as building a state database or establish an electronic data flow fr om 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 provi ded information in paper format. States that transfer to ereporting are no longer required to submit the 75 20 paper forms or do inventory and measures reporting; this eliminates the current burden associated with gathering and compiling data, completing the reporting forms, and maintaini ng records. EPA is encouraging programs to voluntarily transition to e-repo rting to help reduce the overall reporting burden on primacy programs. Although there is still burden associated with e-reporti ng, after establishing the data flow the burden is less than current paper base d reporting. EPA developed tools to generate the same data as the paper reports to ensure consis tency in program manageme nt after the transition. A list of the tools and supporting documents developed to reduce bur den associated with the data flow process can be found in the last section of this Appendix. In addi tion to the reduction in burden, programs have reported data quality improve ments 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 w ith data transfer, and the even tual cost savings to states associated with the National UIC Database. It also describes tools and other support available from EPA to support stat es in e-reporting.

1 

### The term state includes st ates, 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 st atus of data management by st ate 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 in formation (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 da ta 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 effo rt (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 proc ess. The following activities are included:

Data Development: these activities include adding new da ta 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 pr ograms have at least partial data in hard copy only and would need to input some data from paper files.

On average, the total “data de velopment” cost to these progr ams 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, includi ng 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 set ting 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 c ontractor labor) per year per program.

States with Little or no Electronic Data

EPA Headquarters funded the de velopment of an Access databa se 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 w ith 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 alr eady 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 c ontractor support and one-time ha rdware 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 devel op 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 ac tivities (estimated at 80 percen t 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 ove r 6 years) for hardware costs associated with setting up a data flow via the network node.

Ongoing activities

Annual activities include the increm ental data entry burden for those states that currently do not enter UIC data into a state database. (States th at already have a databa se are already incurring a data entry burden; thus, the ICR assumes no add itional paperwork burden for these states as a result of the new database.) The annual data en try burden is estimated to be 40 hours. Note that some states have developed soft ware that allows inspection data gathered in the field to be directly uploaded into their state database, furt her reducing data entry bur den. 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 Natio nal UIC Database through CDX and respond to QA and data validation issues. EPA estimates thes e 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 wi ll reduce the states’ repo rting 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 a ssociated with gathering and compiling UIC data, completing the reporti ng 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 co mplete, the current annual burden associated with completing the 7520 form s 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 woul d collectively incur over $625,000 annually in reporting and recordkeeping costs; this e quals 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 collectiv ely incur $2,313,786 in start-up costs to convert from paper-based to electronic repo rting. This equates to an average of $47,062 in labor and hardware costs for each progr am that currently has a database, and $26,271 per program without a database.

 When their initial data transfer is comple te, states will incur lower annual costs: an estimated annual cost of about $ $230,627 for al l states collectively (or $3,976 per state) to enter data and transfer it to Headquarters quarterly.

Table B-1 presents the annual and cumulative cost s to states under paper based and electronic reporting systems. When the initial data popul ation 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 $3,129,07 4 $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 $5,632,33 3 $230,627 $3,101,098 2016 $625,815 $6,258,14 8 $230,627 $3,331,724 2017 $625,815 $6,883,96 3 $230,627 $3,562,351 2018 $625,815 $7,509,77 7 $230,627 $3,792,977 2019 $625,815 $8,135,59 2 $230,627 $4,023,604 2020 $625,815 $8,761,40 7 $230,627 $4,254,230 2021 $625,815 $9,387,22 2 $230,627 $4,484,857 2022 $625,815 $10,013,0 36 $230,627 $4,715,483 2023 $625,815 $10,638,8 51 $230,627 $4,946,110 2024 $625,815 $11,264,6 66 $230,627 $5,176,737 2025 $625,815 $11,890,4 81 $230,627 $5,407,363 2026 $625,815 $12,516,2 96 $230,627 $5,637,990 * Includes the cost for new programs trans itioning 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 discussi on between the state/DI program and EPA. These discussions are documented in a Trading Partners hip 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 Natio nal UIC Database. Next, an electronic connection is established ba sed on the logical mapping called the physical mapping. This step will allow stat es to submit the correct inform ation 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-reporti ng, a program must complete a comprehensive QA/QC review, which allows programs to correct any errors that may have occurred in th e logical or physical mapping. This review, which may occur over seve ral 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 pr ocess, 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, pr ograms 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 po pulated 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 offici al 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 Da tabase. EPA also developed a web-based tool to convert data to XML format to allow data shar ing between databases of different structure and content and to perform QA/QC of the data. States are not requi red 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 sele ct state programs. These members tested the data flow process and provided feedback to streamline and improve th e process. As a result of the IPT’s efforts EPA developed a customizable process with in structional documents, supporting tools, and a peer-to-peer assistance network. After the da tabase was deployed and programs began consistently submitting data to the National UI C Database, EPA reorganized the IPT creating two IPTs. The IPT 1 allows programs to share le ssons learned and provide peer-to-peer support for programs that have an established data fl ow. 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 se rve all state programs but it is no longer a cost they must incur to submit data to the Nationa l UIC Database. In practice most programs choose to use the Node Client. To us e the Node Client, states subm it 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 a nd with the quarterly submissions. Tables B-2 and B-3 provide a brief descripti on 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 documen t the discussions between the program and EPA Headquarters. The agreement will be us ed 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 schedu le. 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 Data base 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 issubmitted to the database through CDX. After submitting data to the presubmission validation submitters will r eceive 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 stat e 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 burde n on injection well owners and operators. Electronic reporting was identified as the optio n most likely to offe r significant burden reduction opportunities for owners or ope rators and state primacy agencies.

To increase the use of electronic reporti ng in the UIC Program, EPA began a number of initiatives related to reporting by injecti on 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 pr oviding 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 ope rators in the paper, “Eva luation of Burden Reduction Opportunities Related to Some UIC Program Operator Repo rting Forms.” The program evaluated the reporting forms th at 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 st ate staff to review the necessity of the data collected on several of the form s, 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 in terfaces 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 Mana gement (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 require d by regulation and is necessary to ensure that injection wells will be sited, construc ted, and operated in a manner that protects USDWs.

 Reducing reporting frequency could endange r USDWs by eliminating crucial early warnings that wells are not operatin g within protective parameters.

 Combining or eliminating any of the UIC reporting forms is not practical since the forms collect information generated at vari ous milestones in the life of an injection well or are already submitted infrequently.

Electronic reporting was identi fied as an option that mi ght offer significant burden reduction opportunities.

Ongoing Burden Reduction E fforts: Owner or Operator Reporting

EPA is encouraging and implementing electr onic reporting by injection well owners or operators by developing Agency databases a nd encouraging states to develop their own data systems.

EPA Initiatives

In 2007, EPA began the development of a web- based system that wi ll allow owners or operators to submit their inventory informa tion and pre-closure notifications, normally submitted on forms 7520-16 and 7520-17, via a secu re website. To date, a test site has been developed that allows th e submission of inventory inform ation and to later retrieve relevant information for the pre-closure not ification. EPA Headquart ers and regional staff have conducted limited testing of the webs ite. 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 de ploy the system for use by well operators.

The recently promulgated Federal Requirements Under the Underground Injection Control (UIC) Program for Carbon Dioxide (CO 2 

## ) 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 electronica lly. (The rule allows for alternative methods for submission if necessary.) EP A 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 requiri ng 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 fr om owners or operators as part of the National UIC Database effort, a nd has encouraged state primacy programs to apply for Exchange Network Grants to establis h an electronic data flows from owners or operators to states. Some programs are taki ng 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 E nvironmental 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 modifi cation 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, a nd upload electronic data deliverables. GEM collects information related to permits , financial assuran ce, well construction, facility inspections, monitoring, violati on, and lab analyses. The tool allows reviewers to track the steps in the permitting process, including the method and dates of public notice, and whethe r public comments were received.

 The Washington Department of Ecology em ploys the Online UIC Well Registration System for owners or operators to regi ster their injection wells. The system, SecureAccess Washington, is a single si gn-on application ga teway created to simplify access to the Washington’s gove rnment 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: Electro nic 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 st ates through the development of tools to support the transition to elec tronic 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 i nvestment in a state data node.

EPA also established an Integrated Project Team to provide peer-to-peer support for programs that are either begi nning 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 Progr ammatic Information Collection Request.

EPA is also encouraging the shift to elec tronic reporting by offering Exchange Network Grants to support state’s efforts to establis h an electronic data flow from owners or operators to states (as describe d above) and then to EPA. To date, 14 states have initiated the data transfer process, a nd 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 endi ng with EPA. EPA has made grant money available to assist state programs in establishing elect ronic data flows through the Exchange Network Grant. To date, over 20 programs have receive d assistance through the Grant.

The support network established for the National UIC Database has provided opportunities for peer-to-peer sharing of succe ss 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 nati onal 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 re porting by owners or operators. Primacy programs have also seen the advantages of electronic reporting and have unilaterally made changes in thei r 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 Dispos al, 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 FormPlease type or print all information. Please read instructions

. OMB No. 2040-0042 Form Expires 1/31/05

United States Environmental Protection Agency

Office of Grou n d Wate r a n d 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. PermitDetermination 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 d ate. 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 date of 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 date of the State (or EPA) UIC Program.

Section VI. Permit Determination

Permit Determin ations include the approval or denial of UIC permit request/actions such as: applications for permits, major modif ications to
issued permits, revocation and reissuance of permits, or termination of permits
for cause. A complete permi t 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.

Item B: 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 existing wells. “Existing” describes a nonhazardous well field having only existing wells.)

Item C: Enter under each well class th e 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 applicant s 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 majo r modifications

a pproved 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 exis ting (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) rev iew 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 during permit determination or during any AOR analysis of a rule
authorized well file.

Item A: Enter under the well class of each permit application or file that has
been revi ewed this year to date, the number of “Abandoned” and “Other”
wells reviewed in the AOR.

“Abandoned” includes any well penetrating the injection zone in the AOR 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 those wells 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.

Item C: 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 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 e x isting 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 co nduct or sponsor, and a person is not required to res pond 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 th e 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 7520-1 (8-01) RevisedPlease type or print all information. Please read instructions on rever s e

. OMB No. 2040-0042 Approval Expires 1/31/05

United States Environmental Protection Agenc y

Washington, DC 20460

(This information is solicited under the authority of the Safe Drinking Water Act) 

### UIC Federal Reporting System 

## Part II: Compliance Evaluation Offic e of G round 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

All reporting is 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 Class II, III, or V well with certain 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 year to date, whether or not the well has
been returned to compliance. These totals track the percentage of the injection well universe in 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 Comp l iance” 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., well shut-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 throu gh 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

Ent er under each well class the percentage of MIT violations (identified in Section V., un der “Mechanical Integrity”) resolved within 90 days.

In order to calculate the percentage:

1. Add up the total number of MI T violations to date
whether of not they were iden tified 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. Calculate the percentage of total MIT violations to date that have been resolved in 90 days or less, e.g., 50%.

Paperwork Reduction Act
The public reporting and record keeping burden for this collection
of information is estimat ed to average 6 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. T h is 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 personne l 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 i s not required to respond to, a collection of
informatio n 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 7520-2A RevisedPlease type or print all information. Please read instructions on revers e. OMB No. 2040-0042 Ap p roval 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

O ffic e 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 Perio d (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 (Specify) Against SNC Violations

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 For m Date Telephone No.

EPA Form 7520-2B ( 8

- 01 ) Replaces EPA Form 7520

- 2 which is o b solete

.

## Instructions and Definitions EPA Form 7520-2B

Section IV. Reporting Period: All reporti ng 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 following violations 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. Plugging and Abandonment

– The plugging and abandonment of an injection
well in an un authorized 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 end angerment of USDW and there is an identifiable owner/operator;

e. Violation of a Formal Order – Any violation of a formal enforcement action, including an 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) have been corrected and the well(s) returned to compliance. These
totals track the percentage of the injection well universe in SNC each y e ar. 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 complia nce. T hese 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 sub section 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

. Under subsection B, enter under each well
class the total number of wells returned to compliance (a s 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
enforc ement 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-dangering fluid
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 both SDWA and RCRA, well closur e may require additional actions: remove injection fluids deposited in well, sludge and any visibly contaminated soil; segregate hazardous

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 ActThe 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 o r 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 numb er. 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 Directo r, 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 rev erse

. 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

Ite m 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 F or m Date Telephone No.

EPA Form 7520-3 (Rev. 8-01 ) Previous edition is obsolete.

## Instructions and Definitions

(All reporting is cumulative, year to date, and begins with October 1.)

Section V. Summary of Inspections

A complete inspectio n should include an assessment of: the well head, pressure and flow meters, pipeline connections, and any other equipment associated with the injection system; a n 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. These totals track the percentage of
the inje ction well universe inspected each year. Enter a well only once each year.

Total Inspections: (This year to date)

Item 1: Enter under each well clas s 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

a USDW through 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 class the 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
with a preapproved plan. Failure may be identified during an 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 num ber of wells that have received remedial actions this year to 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 estimate d 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, a nd utilize technology and systems for the purpose s of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with

a ny previously applicable instructions and requirements; t rain 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 ReverseUnited 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 TypeUnauthorized InjectionWell Mechanical IntegrityInjection PressurePlugging and AbandonmentFormal OrderFalsificationOther (Specify)Notice of ViolationConsent AgreementAdministrative OrderCivil ReferralCriminal ReferralWell Shut-inPipeline SeveranceOther (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 en forcement action or returned to compliance. Any SNC reported on Form 7520-4 shall be reported until the SNC is resolved. Once a S NC 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 cl ass and type of each well in SNC for two or

more consecutive quarters. For Cl ass I wells, specify IH for
hazardous was te, IM of municipal waste, Ii for industrial

waste. For Class II wells, specify IID for saltwate r disposal,
IIR for enhanced recover y, IIH for liquid hydrocarbon storage.

Section III - Name and Address of Owner/Operator

Enter the name and address of th e owner/operator of the injection well. Use multiple lines of th e 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 S NC. If the well has a UIC permit number, enter this as the I.D. number.

Section V - Summary of Violations

Enter the date th e SNC violation was first identified and place an “X” in the appropriate co lumn. In the event that
there were multiple SNC violations for a single well, enter
each violation and the date it was ident ified 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 appropriat e column.
In the event that there were multiple enforcement actions,

enter e ach enforcement action and the date it was taken on a separate line. Paperwork Reduction Act
The public reporting and record keepin g burden for this
collection of information is estim ated to average 2 hours

per response. Burden means the total time, effort, or
financial resource expen ded by persons to generate, maintain, reta in, or disclose or provide information to or
for a Federal Agency . This includes the time needed to
review instructions; develop, acqui re, 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 t he existing ways to comply with any previously applicable instructions an d requirements;
train personnel to be able to respond to the collection of
in f ormation; search data sources; complete and review
the collection of information; and, transmit or otherwise
disclose the inform ation. An agency may not conduct or

sponsor, and a person is not requir ed to respond to, a
collection of informa t ion unless it displays a currently
val id 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 min imizing respondent burden, including the use of

automat ed collection techniques to Director, Collection Strategi es Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washingto n, 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) ReverseOMB No. 2040-0042 Approval Expires 1 / 31/0 5

United States Environmental Protection Agenc y

(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 h ours 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; 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.

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 6INSTRUCTIONS - 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 (if applicable) 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 of all producing wells, injection wells, abandoned wells, dry holes, 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 those wells, 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 PLAN AND WELL DATA

- Submit a 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

A description of each well's types, construction, date drilled, location, depth, record of plugging 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 over the fracture pressure of the injection formation, all known wells within the area of review 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 6E. 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 AND CROSS SECTIONS OF GEOLOGIC STRUCTURE OF AREA - Submit maps and cross sections detailing the geologic structure of the 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 on the injection zone 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 daily rate and volume of the 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 of all constituents of injected 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 I wells 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. CONSTRUCTION PROCEDURES

- 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 drilli ng, 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 monitorin g program. This should be thorough, including maps showing the number and location of monitoring wells as appropriate and discussion of monitoring devices, sampling frequency, and parameters measured. If a manifold monitoring prog ram is utilized, pursuant to §146.23(b)(5), describe the program and compare it to individual well monitoring.

Q. PLUGGING AND ABAN DONMENT 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 6R. 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. AQUIFER EXEMPTIONS

- If an aquifer exemption is requested, submit data necessary to demonstrate that the aquifer meets the following criteria: (1) does not serve as a source of drinking water; (2) cannot now and will not in the future

serve as a source of drinking water; and (3) the TDS content of the ground water is more than 3,000 and less than 10,000 mg/l and is not reasonably expected to supply a public water system. 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 tabl e 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 6OMB 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 ) Range ____ Township ____ Section ____

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 of information 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 maintainin g 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 c ollection 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) ReverseOMB 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 pers ons 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 colle ction 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 techniqu es to Director, Collection Strategies Division, U.S.
Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washing ton, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed forms to this address.

EPA Form 7520-8 ReverseO MB 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 i nformation, 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 suggest ed 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.



## 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 ReverseOMB 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 Depth Wt/Ft - Grade - New or Used Sacks Depth Class 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. Range ____ Township ____ Section ____

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 t o 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 r equirements; train personnel to be able to respond to the collection of information; search data sources; complete and review
the collection of in formation; and, transmit or otherwise disclose the information. An agency may not conduct

or spo nsor, 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 accurac y 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., Was hington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed forms to this address.

EPA Form 7520-10 ReverseOMB No. 2040-0042 A pproval 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 Range ____ Township ____ Section ____

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 e stimated 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

r esource expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Age ncy. This
include s the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes
of collecting, validating, and ve rifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to co mply 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 min imizing respondent
bu rden, including the use of automated collection techniques to Director, Collection Strategies Division, U.S. Environmental
Protection Agency (2822), 1200 Pennsylvania A ve., 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 ReverseOMB No. 2040-0042 A pproval 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 Treatment Record Size Depth Sacks Type From To

WELL CASING RECORD -- AFTER REWORK (Indicate Additions and Changes Only)
Casing Cement Perforations Acid or Fracture Treatment Record Size Depth Sacks Type From To Range ____ Township ____ Section ____

I am aware that there are significant penalties for submitting false information, including the (Ref. 40 CFR 144.32)

EPA Form 7520-12 (R ev . 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 annu ally. 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 disc losing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; t rain 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 accur acy 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 Pennsylva nia 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 ReverseOMB No. 2040-0042 A pproval E xpires 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.

WELL ACTIVITY TYPE OF AUTHORIZATION

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)

From To To

Estimated Cost to Plug Wells Range ____ Township ____ Section ____

I am aware that there are significant penalties for submitting false information, including the (Ref. 40 CFR 144.32)

EPA Form 7520-14 (R ev. 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 ReverseType or print all information. See reverse for instructions. OMB No. 2040-0042 A pproval 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 2. FACILITY ID NUMBER (Year, Month, Day)

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 D. LONGITUDE B. STREET ADDRESS/ROUTE NUMBER

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

20503. 20460, and to the Office of Management and Budget, Paperwork Reduction Project, Washington, DC

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 Agenc y
UIC Federal Reporting Syste m 

# Class V Well Pre-Closure Notification For m

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) :

Drywel l Septic tan k Cesspoo l

Improved sinkhol e Drainfield/leachfiel d Othe r

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/sediment s Clean out wel l

Appropiate disposal of remaining fluids/sediment s Install permanent plu g

Remove well & any contaminated soi l Conversion to other well typ e

Other (describe) :

9

. Proposed date of well closure :

10

. Name of preparer : Date :

Certificatio n I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this doc u

ment and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the info r

mation, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for su b

mitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32)

. Name and Official Title ( Please type or prin t ) Signatur e Date Signe d Type or print all information. See reverse for instruction s Form Approved 12/99 OMB No. 2040-021 4

EPA Form 7520-1 7INSTRUCTIONS 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, V I, 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 ce mentplug 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 respond ent. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provid einformation 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, a nd disclosing and providing information, adjust the existing ways to comply with any previously applicable instructions and require

ments; 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 requir ed 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, Regulatoryinformation 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