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STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

WATER SUPPLY 

9th Floor, 401 Church Street 

Nashville, Tennessee 37243-1549 

CLASS I PERMIT APPLICATION ATTACHMENT GUIDANCE 

Minimum information to be included in attachments that must be submitted with permit

applications for individual or area authorization of Class I well operation or plugging and 

abandonment allowed under Rule 1200-4-6. 

I. Individual Well Permits 

A. Produced Water Disposal Operational Permits 

1. Area of Review Description – Submit a detailed description of the area of 

Review for each Class I well that meets the requirements of Rule 1200-4-6-

.09(3) and that provides information equivalent to Rules 1200-4-6-.10(3)(b)

and .10(4)(a)2. In the case of a well already drilled, this description must 

include appropriate logs of the well with the proposed injection zone marked. 

For wells to be drilled, the description must include a statement of the proposed 

injection zone and the approximate depth and elevation of this zone. The area 

of review description for each Class I well must provide and justify the

method(s) used to determine the size of the area of review. 

2. Construction Feasibility – Provide sufficient information to assure that the 

subject Class I well will meet the requirements set in 1200-4-6-.10(3)(a). 

Submission of information on construction feasibility is necessary to assure 

that ground water within the injection zone is classified according to Rule 

1200-4-6-.10 (2)(c). 
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3. Corrective Action – Provide a map and a tabulation of data as described in Rule 

1200-4-6-.10(3)(b)1. Also, submit a Corrective Action Plan, if necessary. 

Corrective Action Plans shall comply with Rule 1200-4-6-.09 (5). 

4. Construction Data – Submit sufficient information to assure that well 

Construction will comply with Rule 1200-4-6-.10(3)(d)(e)(f). Include a 

detailed description of the proposed injection system including the type and 

construction of the injection well and a schematic diagram of the well showing 

the casing and cementing program with an appropriate explanation. 

5. Class I Testing – Submit logs, plans, and information as described in Rule 

1200-4-6-.10(3)(g)(h) for injection well and formation testing. 

6. Operational Data – Provide information regarding the maximum and average 

daily rate and volume of injected fluid, the maximum and average injection 

pressures, the nature and pressure of the annulus fluid, and the physical and 

chemical nature (including corrosiveness and density) of the injected fluid. 

Also submit proposed methodology for collecting and reporting representative 

values for the above operational data. 

7. Monitoring Program – Submit a plan for a proposed monitoring program to 

fulfill the requirements of Rule 1200-4-6-.10(4)(e)(f)(g)(h)(i). 

8. Contingency Plans – Submit detailed contingency plans to prevent pollution of 

surface water or any ground water classified pursuant to Rule 1200-4-6-.05(1) 

resulting from any failure of the well or associated equipment. 

9. Plugging and Abandonment Plan – Submit Plugging and Abandonment Plan 

that meets the Standards and Requirements of Rule 1200-4-6-.09(6), (7), (8) 

and (9) and 1200-4-6-.10(5). This plan shall also contain a detailed cost 

estimate for plugging and abandonment. 
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10. Financial Responsibility – Submit a surety bond or other evidence of financial 

responsibility as required by Rule 1200-4-6-.09(10) and 1200-4-6-.19. 

11. Provide a statement that the proposed Class I well will be completed in such a 

manner to insure that the injected substances are injected into the proposed 

injection zone and that provisions have been made for adequate protection of 

formation(s) containing USDW’s pursuant to Rule 1200-4-6-.05(1) and any 

other zone of commercial value. This statement should contain a brief 

summary of the information contained in the application attachments that 

verify that injection only occurs in the injection zone and that adequate 

protection for ground water classified pursuant to Rule 1200-4-6-.05(1) is 

provided. 

II. Plugging and Abandonment Permits

Attachments to all Class I Plugging and Abandonment permit applications, whether for 

an individual well or for an area, must contain the following: 

A. A summary of the reasons for abandonment. 

B. An updated copy of the previously approved plugging and abandonment plan(s) 

with any plan modifications deemed necessary. 

C. Current evidence of financial responsibility. 
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CLASS I REPORTING REQUIREMENTS

Reports associated with operation or plugging and abandonment of Class I wells. 

I. Testing Requirements 

At least once every five years after construction, injection wells shall be tested to 

assure their continued mechanical integrity. The results of these tests shall be 

reported to the Department upon completion. Refer to Rule 1200-4-6-.10(3)(h) 

for tests that shall be conducted to demonstrate mechanical integrity. 

II. Reporting Requirements 

A. Annual Report – Submit an annual report to the Department summarizing 

the results of monitoring required under Rule 1200-4-6-.10(6)(h). It shall 

include monthly records of injected fluid and any major changes in 

characteristics or sources of injected fluid. 

B. Notification – The following events shall be reported to the Department: 

1) The date and time of initial, three-year, or special tests will commence 

in order that such tests may be witnessed by a representative of the 

Department. 

2) The date of commencement of injection operations in any well. 

3) Within 30 days after the date of permanent cessation of hydrocarbon 

storage operations or discontinuance of injection operations into any 

other well, the operator shall notify the Department of the date of 

discontinuance and the reasons therefor. 

III. Plugging and Abandonment Permits

A. Final Report – Submit a Final Report upon completion and abandonment of 

a well or wellfield. It shall include at least daily construction reports, 

certification of completion in accordance with approved plans and 

specifications by a person knowledgeable and experienced in the field, and 

evidence that a surveyor’s plot of the location of the abandoned wells has 

been recorded in the county courthouse property records.