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STATE OF TE NNESSEE DEPA RTME NT OF ENVI RO NMEN T A ND CO NSER VATION WATER SUP P LY 9th Floor, 4 01 C hurch Street Nashville, Tennessee 37243-154 9

CLASS I PE RMIT APP L ICA T I O N ATTA CHM E NT GUI D ANCE

Minim u m in formation to be included in attach m e nts that m u st be subm itted with per m it applications for individua l or area authoriza tion of Class I wel l operation or plugging and

abandonm ent allowed und er Rule 1200- 4-6.

I. Individual Well Permits

A. Produced W a ter Disposa l Operational Permit s

1. Area of Revi ew De scripti on – Subm it a detailed description of the area of

Review for each Class I well that m e ets the requirem e nts of Rule 1200- 4-6

- .09(3) an d th at provides i n form ation equivalent t o Rules 1200-4

- 6-.10(3)( b ) and .10(4)(a)2. In the c a se of a well alre ady drilled, this desc ription m u st include appro p riate logs of the well with the proposed injection zone m a rked. For wells to be drilled, the description mu st include a statement of t h e proposed injection zon e and the app r oxim a te depth and elevation of this zone. The area of review description for each Cla s s I well m u s t provide and justify the method(s) used to determ ine the size of the area of review.

2. Construction Feasibility – Provide suffi cient information to assure that the subject Class I well will m e et the requirements set in 1 200- 4

- 6-.10(3)(a).

Subm ission of inform atio n on construction feasibility is necessary to assure that ground water within the injection zone is classified a cco rding to Rule

1200- 4-6-.1 0 (2)(c).2 o f 4

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 cla ssified 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.3 o f 4

10. Financial Responsibility – Submit a sure ty bond or other evidence of financial responsibility as required by Rule 120 0-4-6-.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 subs tances are injected into the proposed injection zone and that provisions have been made for adequate protection of formation(s) containing USDW’s pursu ant to Rule 1200-4-6-.05(1) and any

other zone of commercial value. Th is 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 Ab andonment 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.4 o f 4

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 completi on. 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 Repor t 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.