Information Collection Request

for the Underground Injection 

Control Program

OMB Control No. 2040-0042

EPA ICR Tracking No. 0370.25
Office of Water (4606M)

December, 2014
Underground Injection Control Program – Information Collection Request Page i

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..................................................................................... 3

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

3. Nonduplication, Consultations, and Other Collection Criteria .............................................. 11

3(a) Nonduplication ................................................................................................................ 11

3(b) Public Notice ................................................................................................................... 12

3(c) Consultations................................................................................................................... 12

3(d) Effects of Less Frequent Collection ................................................................................ 12

3(e) General Guidelines.......................................................................................................... 14

3(f) Confidentiality................................................................................................................. 14

3(g) Sensitive Questions.......................................................................................................... 14

4. Respondents and Information Requested............................................................................... 15

4(a) Respondents/NAICS Codes............................................................................................. 15

4(b) Information Requested .................................................................................................... 15

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

Management .......................................................................................................................... 26

5(a) State and Agency Activities ............................................................................................ 26

5(b) Collection Methodology and Management ..................................................................... 27

5(c) Small Entity Flexibility ................................................................................................... 29

5(d) Collection Schedule......................................................................................................... 31

6. Estimating the Burden and Cost of the Collection................................................................. 35

6(a) Respondent Burden.......................................................................................................... 35

6(b) Respondent Costs ............................................................................................................ 40

6(c) Agency Burden and Costs ............................................................................................... 42

6(d) Estimating Respondent Universe and Total Burden and Costs....................................... 43

6(e) Bottom Line Burden Hours and Costs............................................................................. 43

6(f) Reason for Change in Burden.......................................................................................... 44

6(g) Burden Statement ............................................................................................................ 48
Underground Injection Control Program – Information Collection Request Page ii

LIST OF EXHIBITS

2-1 Classification of Underground Injection Control Program 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 State Reporting Frequency

6-1A Annual Burden and Costs Associated with Class I Wells 2015-2017

6-1B Annual Burden and Costs Associated with Class II Wells 2015-2017

6-1C Annual Burden and Costs Associated with Class III Wells 2015-2017

6-1D Annual Burden and Costs Associated with Class IV 2015-2017

6-1E Annual Burden and Costs Associated with Class V Wells 2015-2017

6-1F Annual Burden and Costs Associated with Class VI Wells 2015-2017

6-1G Summary of Annual Operator Burden and Costs (based on above exhibits 2015-2017

6-2 Annual Primacy Agency Burden and Cost 2015-2017

6-3 Annual Agency Burden and Cost 2015-2017

6-4 Bottom Line Annual Burden and Cost 2015-2017

6-5 Reasons for Change in Annual Operator Burden (Hours)

6-6 Reasons for Change in Annual Primacy Agency Burden (Hours)

6-7 Annual Burden and Costs Associated with all Well Classes 2015-2017
Underground Injection Control Program – Information Collection Request Page iii

LIST OF APPENDICES

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

APPENDIX B: The National UIC Database 

APPENDIX C: Federal Register Notice on UIC Program Reporting Requirements

APPENDIX D: UIC Program Burden Reduction Efforts 

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

1. Identification of the Information Collection

1(a) Title and Number of the Information Collection 

Underground Injection Control Program Information

OMB Control Number: 2040-0042

EPA Tracking Number: 0370.25 

1(b) Short Characterization 

The U.S. Environmental Protection Agency (EPA) will use the information collected 

upon extension of the approval of this Information Collection Request (ICR) for the monitoring 

and enforcement of the Underground Injection Control (UIC) Program as authorized by the Safe 

Drinking Water Act (SDWA). The agency developed the UIC Program to establish a federalstate regulatory system to protect actual or potential underground sources of drinking water 

(USDWs) by ensuring that they are not endangered by the underground injection of fluids. The 

purpose of this collection is to help EPA effectively manage the UIC program and ensure 

protection of USDWs. 

Monitoring and enforcement are primarily achieved through initial, quarterly, semiannual, and annual reporting requirements. Information is gathered both at the state1

program 

level and at the EPA regional level. Each EPA Region has the role of implementing UIC 

programs for states that do not have UIC programs.2 In addition, each Region must compile and 

submit information to EPA Headquarters from all respective state UIC programs. This 

information is submitted in summary paper reports to EPA Headquarters or, for programs that 

have transitioned to electronic reporting, via electronic data transfer. Additional details on the 

process by which primacy programs are transitioning from paper-based to electronic reporting

(e-reporting) is presented in Appendix B of this ICR.

Section 144.6 of Title 40 of the Code of Federal Regulations (CFR) describes the six

injection well types (see Exhibit 2-1). EPA collects monitoring data and test results from 

operators of Class I, II, III, and VI injection wells and a small percentage of Class V wells. Class 

IV wells are banned—except for wells used to re-inject treated contaminated ground water into 

the same formation from which it was drawn as part of a clean-up authorized by the Resource 

Conservation and Recovery Act (RCRA) or Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA); operators of these wells must submit plugging and 

 

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

2

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

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

regional offices. In some states, more than one agency may oversee injection wells of various classes.
Underground Injection Control Program – Information Collection Request Page 2

abandonment reports as they are closed. Class II owners or operators must submit permit 

applications, monitor their wells and report the results, and submit plugging and abandonment 

reports when they close their wells. EPA requires operators of existing Class V motor vehicle 

waste disposal wells (MVWDWs) in ground water protection areas or other state-defined 

sensitive ground water areas to close these wells or apply for a permit to continue injecting. In 

general, Class V operators submit only a small subset of the information required of Class I, II, 

III, and VI well operators.

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

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

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

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

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

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

underground injection well operators and primacy agencies associated with UIC requirements 

will be 5,142,137 hours (an average of 1,714,046 hours per year), and the present value cost will 

be $750,997,193 (an average of $250,332,398 per year). The public reporting and recordkeeping 

burden for this collection of information is estimated to average 2.56 hours, or $373.93 per 

response annually. The annual burden per respondent is 37.42 hours; the cost per respondent is 

$5,464.47. During the course of the ICR clearance period, the EPA evaluates all reporting 

information and data collections for burden reduction wherever possible to ensure that all 

information collections are necessary and that they have practical utility for carrying out the 

mandate to protect USDWs. 

Overall, there is a net increase in burden of 410,019 hours between the approved and requested 

amounts. This increase is due to the expected increase in the injection well inventory, primarily 

the number of Class II permit applications expected to be prepared, reviewed and approved, 

increases in the Class I and Class III inventories and the deployment of Class VI (geologic 

sequestration) activities. These increases are offset by burden reductions associated with 

decreases in the number Class V well operators submitting inventory information, continued 

implementation of electronic reporting by states and EPA’s reductions in state reporting 

frequencies.

2. Need For and Use of the Collection

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

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

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

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

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

regulations related to waste disposal, injection wells, and the UIC Program. Section 2(b) 
Underground Injection Control Program – Information Collection Request Page 3

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

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

2(a) Need/Authority for the Collection 

Potential for Contamination

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

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

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

discussion describes each pathway and summarizes information collection requirements to 

monitor for or prevent migration through the pathway.

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

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

well bore. For this reason, the absence of significant leaks and fluid movement in the 

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

thereafter.

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

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

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

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

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

must be submitted if the operator abandons any well.

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

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

address this contamination pathway are tracked using two information collection 

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

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

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

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

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

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

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

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

include motor vehicle waste disposal wells (MVWDWs), cesspools, agricultural drainage 

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

disposal wells. EPA has banned the construction of new large-capacity cesspools and 

requires operators of existing large-capacity cesspools to close their wells, in a regulatory 

effort to address the Class V wells that pose the greatest threat to USDWs. EPA also 

banned new MVWDWs and is requiring operators of existing MVWDWs in defined 
Underground Injection Control Program – Information Collection Request Page 4

ground water protection areas or other sensitive ground water areas to close these wells or 

apply for a permit to continue injecting.

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

hydraulically connected USDWs. Permit information regarding the proximity of 

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

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

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

migration of fluids.

Legal Authority 

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

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

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

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

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

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

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

disposal technique.

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

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

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

Administrator in establishing regulations under this title . . . .” 

The specific requirements for the UIC Program are established in Title 40, Sections 144 

through 148 of the CFR as follows:

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

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

procedures, and establishes procedures for ensuring financial responsibility for proper 

closure of wells.

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

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

program approval.

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

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

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

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

programs of individual states’, territories’, and tribes’ primacy programs.
Underground Injection Control Program – Information Collection Request Page 5

Section 148 - Hazardous Waste Injection Restrictions. This section identifies 

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

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

operators may petition to dispose of restricted hazardous wastes.

These CFR Sections contain information collection requirements that are applicable to 

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

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

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

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

State Reporting Forms.

Exhibit 2-1

Classification of Underground Injection Control Program Wells

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

beneath the lowermost formation containing a USDW. 

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

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

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

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

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

such as ore bodies that are not conventionally mined; and solution mining 

of salts or potash. 

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

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

into or above strata that contain a USDW. These wells are banned, unless 

they are used to re-inject treated contaminated ground water into the 

formation from which it was drawn in a RCRA/CERCLA authorized 

cleanup.

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

include, but are not limited to: agricultural drainage wells, storm water 

drainage wells, industrial drainage wells, untreated sewage waste disposal 

wells, motor vehicle waste disposal wells, and cesspools.

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

geologic sequestration (GS) wells, and are not experimental in nature.

Statutory Requirements

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

contain minimum requirements for effective programs to prevent underground injection that

endangers USDWs. Therefore, EPA must:

• Publish minimum national requirements for effective state UIC programs;
Underground Injection Control Program – Information Collection Request Page 6

• List states that need UIC programs;

• Review proposed state programs and approve or disapprove them;

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

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

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

regulatory requirements.

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

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

statutory mandate.

2(b) Practical Utility/Users of the Data 

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

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

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

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

7520 forms3or an equivalent form to target inspection and enforcement activity, to establish 

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

and assess their significance. In addition, the primacy agency can use the summary reports it 

supplies to EPA Headquarters to evaluate its own program activities, such as the number of 

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

number of permits reviewed. The electronically submitted well-level data are used in a similar 

manner, but allows for a more effective analysis and better understanding by all users.

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

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

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

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

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

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

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

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

Headquarters' Management of the National Program 

EPA Headquarters uses reported information to respond to information requests and 

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

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

 

3

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

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

Performance targets and measures for EPA regional programs are established by EPA and 

tracked against Government Performance and Results Act (GPRA) goals. EPA tracks high 

priority activities that guide the Regions in carrying out UIC Program objectives. EPA

Headquarters coordinates with its Regions to obtain commitments for performance based on 

these guidelines.
Underground Injection Control Program – Information Collection Request Page 8

Exhibit 2-2 Flow of Information in the UIC Program4

 

4 Primacy programs utilizing e-reporting submit all data semi-annually.
Underground Injection Control Program – Information Collection Request Page 9

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

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

applicable health-based drinking water standards through approaches including effective 

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

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

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

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

underground sources of drinking water.

 Number of Class V MVWDW wells and large capacity cesspools (LCC) that are 

closed or permitted (cumulative).

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

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

through injection as defined by the UIC Final Rule.

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

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

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

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

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

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

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

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

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

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

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

Regional Oversight of Primacy Programs 

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

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

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

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

to contamination of USDWs.

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

track state enforcement response actions for all significant non-compliers (SNCs), i.e., operators 

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.
Underground Injection Control Program – Information Collection Request Page 10

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

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

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

before sending them to EPA Headquarters.

Direct Implementation of State Programs

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

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

direct implementation (DI) states, EPA regional offices use information from operators in several 

ways.

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

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

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

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

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

areas that could result in contaminated USDWs.

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

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

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

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

can provide early warning of USDW endangerment. 

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

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

compliance for at least two consecutive quarters are identified on the exceptions list. 
Underground Injection Control Program – Information Collection Request Page 11

3. Nonduplication, Consultations, and Other Collection 

Criteria

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

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

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

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

guidelines and provisions for confidentiality.

3(a) Nonduplication 

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

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

knowledge, this information is not required or collected by any other agency or regulation. The 

Department of Energy does collect information relating to production for enhanced oil and gas 

recovery wells in its “Annual Report for Enhanced Oil Recovery (EOR) Incentive” (OMB 

Clearance No. 19054135). This information pertains only to oil production, and is related to, but 

different from, the information EPA uses to evaluate injection well operators. However, on a 

case-by-case basis, permitting authorities may use this information to supplement existing 

information on enhanced recovery wells.

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

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

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

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

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

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

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

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

collection between RCRA and the UIC Program.

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

those associated with the Mandatory Reporting of Greenhouse Gases [GHG]: Injection and 

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

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

minimize the potential overlap in reporting and recordkeeping requirements on operators of wells 

that may be subject to both rules. Burden and costs associated with air monitoring are accounted 

for under Subpart RR and therefore are not incorporated into this Programmatic ICR. EPA plans 

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

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

reporting and recordkeeping requirements under the two rules. Additionally, some Class VI 

owners or operators may inject CO2 that is subject to the Conditional Exemption from RCRA 

Definition of Hazardous Waste for Carbon Dioxide Streams Injected into Class VI UIC Wells at 
Underground Injection Control Program – Information Collection Request Page 12

40 CFR 261.4(h). Owners or operators who claim that a CO2 stream is exempt under 40 CFR 

261.4(h) would have to sign a certification statement that the CO2 is being injected and stored 

pursuant to the requirements of the Class VI rule. None of the information in the certification 

statement duplicates information required by the UIC regulations.

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 August 8, 2014 (79 FR 46437). 

EPA received one comment, which was out of the scope of the ICR burden and cost estimates. A 

copy of the Federal Register notice of this information collection is attached to this ICR as 

Appendix C.

3(c) Consultations 

In March 2014, EPA consulted with several UIC programs on the ICR assumptions, 

focusing on aquifer exemptions and Class V Rule implementation activities. EPA received 

responses from: Kansas Corporation Commission, Kansas Department of Health and 

Environment, Oklahoma Department of Environmental Quality, Oklahoma Corporation 

Commission, Illinois Department of Environmental Protection, Ohio EPA, Ohio Department of 

Natural Resources, and EPA Region 7. The assumptions in this ICR are consistent with the 

information provided by staff for these programs.

3(d) Effects of Less Frequent Collection 

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

(1) operators of injection wells; and (2) primacy agencies. The paragraphs below describe why it 

is necessary to collect the information at the required frequency to ensure the protection of

USDWs, as well as ways that EPA has identified to reduce the burden on states while ensuring 

the continued protection of USDWs. 

Operators

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

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

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

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

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

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

placing an excessive burden on operators. 

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

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

monitoring and testing might allow injection wells to operate in a manner that could threaten or 
Underground Injection Control Program – Information Collection Request Page 13

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

long time. EPA determined that the specified monitoring frequencies for each of well class are 

at the minimum protective frequency for the following reasons:

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

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

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

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

or formation fluids are not displaced into USDWs. 

 Mechanical integrity tests (MITs) can reduce the amount of damage a well failure can 

cause to USDWs by detecting those failures. The degree to which this damage can be 

reduced depends on the frequency of MITs. Less frequent MITs would raise the 

potential for undetected problems that could lead to contamination of USDWs. 

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

composition of the operators’ injectate to ensure that potentially incompatible injected 

substances will not come into contact with each other.

 The Class VI rule requires that some parameters be monitored continuously. These 

monitoring frequencies are based on existing UIC Program regulations for other well 

classes. EPA has determined that the monitoring and reporting frequencies 

established in the Class VI Rule are the minimum necessary to ensure that any 

damage to the injection well would be detected in a timely manner.

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

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

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

endanger USDWs.

Primacy Agencies

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

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

simplifying, or eliminating some of the 7520 forms or reducing the frequency at which primacy 

agencies report this information to EPA.

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

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

was identified as one of the agency’s 16 priority areas for burden reduction. States asked EPA to 

eliminate duplicative UIC reporting, reduce the frequency of reporting, and reduce the data 

elements requested. In evaluating the state and operator input, EPA determined that very little, if 

any data elements could be removed from the 7520 forms and still maintain a robust UIC 
Underground Injection Control Program – Information Collection Request Page 14

program that tracks information crucial to the protection of USDWs. However, in 2013, EPA 

was able to reduce reporting frequency in response to the states’ requests. 

3(e) General Guidelines 

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

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

24 hours “any noncompliance which may endanger health or the environment.” This is an 

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

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

3(f) Confidentiality 

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

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

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

must be made at the time of submission in the manner prescribed by the application form or its 

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

stamping the words “confidential business information” on each page containing such 

information. Claims of confidentiality for the following information will be denied: the name 

and address of any permit applicant or permittee; and information regarding the existence, 

absence, or level of contaminants in drinking water.

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

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

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

3(g) Sensitive Questions 

There are no sensitive questions pertaining to this ICR.
Underground Injection Control Program – Information Collection Request Page 15

4. Respondents and Information Requested

This Section identifies respondents affected by this information collection and describes 

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

4(a) Respondents/NAICS Codes 

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

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

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

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

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

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

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

(Administration of Public Health Programs). 

4(b) Information Requested 

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

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

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

Exhibit 4-2.

Initial Reporting Requirements

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

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

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

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

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

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

protection areas or other sensitive areas that wish to continue operating must obtain a permit. 
Underground Injection Control Program – Information Collection Request Page 16

Exhibit 4-1

Respondents’ SIC/NAICS Codes*

UIC 

Class SIC Code NAICS Code (2002) Description

I  Major Group 13

 Major Group 28

 Major Group 26

 Major Group 29

 Major Group 32

 Major Group 33 

 Major Group 36

 Major Group 37 

 Major Group 45

 Major Group 49

 Major Group 89

 Major Group 99

 211

 325

 322

 324

 327

 331

 335

 336

 481

 221

 54162

 54169

 Oil and Gas Extraction

 Chemical Manufacturing

 Paper Manufacturing

 Petroleum and Coal Products Manufacturing

 Nonmetallic Mineral Product Manufacturing

 Primary Metal Manufacturing

 Electrical Equipment, Appliance, & Component Mfg.

 Transportation Equipment Manufacturing

 Air Transportation

 Utilities

 Environmental Consulting Services

 Other Scientific and Technical Consulting Services

II  1311

 1321

 1381 

 211111

 211112

 213111

 Crude Petroleum and Natural Gas Extraction

 Natural Gas Liquid Extraction

 Drilling Oil and Gas Wells

III  Major Group 10

 Major Group 14

 212  Mining (except Oil and Gas)

IV  4953  562  Waste Management and Remediation Services

V  01, 02, 074, 075

 4789, 4953, 9511

 7542

 7033, 9111

 4142, 4212, 4213, 

4581, 5015, 5511, 

5521, 5531, 5541, 

7514, 7515, 7532, 

7533, 7537, 7538, 

7539, 7549, 9111

 111, 112, 54194, 

11521

 488999, 562213, 

562219, 92411

 811192

 7212, 92111

 441, 484, 485, 

488, 562, 811, 

44711, 44719, 

45299, 48841, 

92111, 532111, 

532112

 Agricultural or storm drainage wells

 Domestic wastewater disposal wells

 Car washes

 Recreational vehicle parks and campsites, executive 

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

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

and airport terminal services; motor vehicle parts; 

motor vehicle dealers; auto and home supply stores; 

gasoline service stations; passenger car rental or 

leasing; automotive repair and services; executive 

offices (e.g., town garages)

VI  4911

 4911

 2911

 221112

 211111

 324110

 Fossil fuel electric power generation

 Crude petroleum and natural gas extraction

 Petroleum refining

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

Rule-Authorized Wells 

Wells in existence before the promulgation of specific permitting regulations are 

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

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

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

operating status of the injection well) to the permitting authority using Form 7520-16 (or a statedeveloped equivalent form). Operators must also submit a plugging and abandonment plan and 
Underground Injection Control Program – Information Collection Request Page 17

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

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

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

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

information over the Internet. 

Permitted Wells5

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

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

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

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

Operators must include the following information with their permit applications:

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

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

requiring a permit [all well Classes];

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

(in DI programs) [all well Classes];6

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

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

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

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

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

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

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

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

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

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

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

 

5

 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.

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

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

to construct the well.
Underground Injection Control Program – Information Collection Request Page 18

Exhibit 4-2

Operator Paperwork Requirements

Information Submitted Class

I-H I-N II III V * VI

Inventory Information X

Permit Application

List of Landowners X X X X X X

Area of Review Methods X X X X X

Maps of Wells/Area of Review X X X X X

Corrective Action Plan X X X X X

Maps and Cross Sections of USDWs X X X X

Names and Depths of USDWs X

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

Geological Data on Injection and Confining Zones X X

Operating Data X X X X X

Formation Testing Program X X X X

Stimulation Program X X X X

Injection Procedures X X X X

Construction Details X X X X

Changes in Injected Fluid X X

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

Ambient Monitoring Program X X X X

Plugging and Abandonment Plan X X X X X

Financial Assurance X X X X X

Post Injection Site Care Plan X

Aquifer Exemption Request X X X X X

Injection Depth Waiver Application X

Completion Report

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

MIT Results X X X X X

Anticipated Maximum Injection Pressure & Flow Rate X X X X X

Formation Testing Results X X X X X

Actual Injection Procedure X X X X X

Hydrogeological Compatibility/ Compatibility of Well Materials X X X X

Status of Corrective Action X X X X X

Monitoring and Reporting

Chemical Composition of Injectate X X X X X X

Injection Pressure, Volume, & Flow Rate X X X X X

MIT X X X X X

Ambient Monitoring X X X X

Pressure Fall-Off Test X X X

Recordkeeping

Retain Monitoring, Testing, Permitting Records X X X X X X

Closure

Closure Report X X X X X

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

permits will be subject to the other paperwork requirements listed.
Underground Injection Control Program – Information Collection Request Page 19

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

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

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

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

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

• Stimulation Program: a description of the proposed stimulation program 

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

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

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

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

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

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

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

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

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

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

• Ambient Monitoring Program: planned ambient monitoring program, including 

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

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

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

for Class II];

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

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

care plan (PISC) for Class VI; and

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

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

financial responsibility demonstrations must also address corrective action, PISC, 

and emergency and remedial response.

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

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

being authorized to inject. Completion reports must include the following information:
Underground Injection Control Program – Information Collection Request Page 20

• The results of deviation checks, other logs and tests [Classes I, II, III, and VI];

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

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

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

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

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

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

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

• Report on hydrogeological compatibility and the compatibility of well materials 

[Classes I, and III, and VI]; 

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

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

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

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

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

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

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

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

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

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

endanger USDWs. The operator must provide sufficient information to 

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

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

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

years. This is known as the Fluid Flow Petition.

• Hydrogeological Compatibility/Compatibility of Well Material Report. 

Operators of Class I hazardous waste wells must demonstrate hydrogeological 

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

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

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

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

waste).
Underground Injection Control Program – Information Collection Request Page 21

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

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

detailed chemical and physical analysis of a representative sample of their waste. 

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

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

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

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

analyzed.

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

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

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

requirements.

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

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

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

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

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

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

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

a demonstration of financial responsibility for closure. 

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

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

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

Response Plan. 

Operators of Class I, Class II, or Class III wells seeking to inject into an aquifer that 

meets the definition of a USDW and is not exempted must request and receive an aquifer 

exemption. This request includes a delineation of the exempted area and a demonstration that the 

request meets the criteria at 40 CFR 146.4. (Owners or operators of Class VI wells transitioning 

from Class II EOR wells may apply to expand the areal extent of existing Class II aquifer 

exemptions; new aquifer exemptions for Class VI wells are prohibited, however.)

Monitoring and Testing Requirements

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

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

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

include:

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

[continuously for Class I hazardous and Class VI, weekly for Class II disposal 
Underground Injection Control Program – Information Collection Request Page 22

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

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

casing [Class I];

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

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

MVWDWs];

 Conduct annual sludge monitoring [permitted Class V MVWDWs];

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

— casing pressure test [annually for Class I hazardous and Class VI, every five 

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

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

hazardous];

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

borehole [annually for Class VI, every five years for Class I and Class III (salt 

solution mining)];7

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

internal mechanical integrity [Class VI];

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

I and VI]; 

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

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

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

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

feasible [Class VI].

Reporting and Recordkeeping Requirements 

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

of required monitoring and testing.8 In addition, operators must notify the permitting authority 

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

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

 

7 Alternative MIT methods (e.g., review of cementing record) may be approved by the Director.

8

 In accordance with the Paperwork Reduction Act of 1995, the reporting requirements covered by this information 

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

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

is compatible with their facility practices.
Underground Injection Control Program – Information Collection Request Page 23

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

permit conditions. 

Scheduled reporting requirements include the following:

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

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

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

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

 Class II operators must report monitoring data annually, and on MITs every five

years.

 Class III operators report quarterly on monitoring and on MITs every five 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 Area of Review (AoR) at 

least every five years and submit a report to the permitting authority. Following the reevaluation, 

operators must update the AoR and Corrective Action Plan, Testing and Monitoring Plan, and 

Emergency and Remedial Response Plan based on the results of the revised AoR or submit 

information that no updates to the plans are necessary.

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

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

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

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

geologic strata through and into which injection is taking place.

Operators must maintain monitoring information, calibration and maintenance records, 

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

recent plugging and abandonment cost estimate for one year.

Closure Requirements

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

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

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

wells). Operators who choose to plug in a manner different from the one specified in their 
Underground Injection Control Program – Information Collection Request Page 24

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

abandonment plan.

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

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

with their closure reports.

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

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

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

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

dioxide plume has stabilized and there is no threat to USDWs following the PISC period; and 

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

regarding the fact that injection occurred to complete well closure.

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

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

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

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

the 7520 forms.) The National UIC database allows states to report the information 

electronically, if they prefer. Each of the forms that agencies must submit as respondents, the 

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

are provided in Appendix E.
Underground Injection Control Program – Information Collection Request Page 25

Exhibit 4-3

State Reporting Forms

Form Frequency Information Collected

Permit Review and Issuance 

(7520-1)

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

permits issued and not issued, and permit modifications), 

permit file reviews, the number of rule-authorized wells 

reviewed, AoR reviews, and corrective action performed.

Compliance Evaluation

(7520-2A)

Semi-annual Enforcement actions, including administrative actions and 

civil and criminal actions. 

Compliance Evaluation -

Significant Noncompliance 

(7520-2B)

Semi-annual Operators of injection wells identified as being in 

significant noncompliance (SNC) with statutory 

requirements and enforcement actions against SNCs and 

returns of wells to compliance; contamination of USDWs; 

and closures.

Mechanical Integrity 

Test/Remedial Actions

(7520-3)

Annual Results of inspections and MITs and remedial actions 

conducted for any test failures.

Quarterly Exceptions List 

(7520-4)

Quarterly Wells that have remained in SNC for two or more 

consecutive quarters and have not been returned to 

compliance or been subject to a formal enforcement 

action.

States have two options for reporting, 7520 Federal Reporting forms (paper submission) 

and the National UIC database (electronic data flow). States and Regional DI programs that 

have chosen to transition to electronic reporting must report the agreed upon UIC data elements

semi-annually to the database. As part of the data flow process, the primacy program and EPA 

agree to specific timelines and data elements to be submitted in a Trading Partner Agreement 

(TPA). The TPA also documents the primacy program’s agreement to submit data electronically 

through the National UIC database rather than in an alternate format. The frequency of data 

submission to the database (as well as via paper 7520s) is now established as semi-annually. 
Underground Injection Control Program – Information Collection Request Page 26

5. Information Collected: EPA Activities, Collection 

Methodology, and Information Management

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

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

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

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

5(a) State and Agency Activities 

5(a)(1) State Activities

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5(a)(2) Agency Activities

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

programs. The Regions perform the same activities as state primacy agencies. In addition, 

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

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

performed in DI states, and in some cases, tests on wells in primacy states; they also review 

requests for aquifer exemptions. DI program staff also review closure reports required of 

operators when they abandon their wells.
Underground Injection Control Program – Information Collection Request Page 27

EPA Headquarters activities consist of compiling the regional summary information on 

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

and inventory and measures data. 

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

submitted to the National UIC database. 

5(b) Collection Methodology and Management 

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

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

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

OGWDW’s website (http://water.epa.gov/type/groundwater/uic/reportingforms.cfm), as well as

on GSA’s website. (Appendix E of this ICR contains copies of all the UIC reporting forms.)

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

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

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

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

use some type of electronic data management system to maintain this data. States manage their

own databases independently to meet their specific programmatic needs. However, EPA is 

working with a number of states to map their UIC data to the UIC National database with the 

expectation they will eventually transition to regular electronic reporting. EPA is also 

participating in an effort with the Ground Water Protection Council and the US Department of 

Energy to collect data from state oil and gas agencies nationally (production as well as disposal 

data) and consolidate it into a regularly updated “National Gateway”. In many states, these 

agencies also house the Class II primacy programs and EPA anticipates that we will be able to 

use this data flow to gather a substantial amount of the required information on class II wells at 

no extra burden to the states. 

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

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

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

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

EPA initiated deployment of the UIC database to collect and store data to support UIC 

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

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

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

EPA’s database is voluntary.
Underground Injection Control Program – Information Collection Request Page 28

To date, 15 programs have transitioned to electronic reporting (e-reporting). EPA 

estimates that more programs will transition to electronic reporting between 2015 and 2017. The 

time needed for a program to move from initial discussion to e-reporting depends on many 

variables, including available funding and full time employees. As states complete the transition, 

EPA expects a reduced reporting burden for some well classes as a result of electronic data flow.

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

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

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

states associated with gathering data and completing the reporting forms. Along with the 

reduced cost, e-reporting has resulted in data quality improvement.

Taking into account the costs of the initial phase-in, EPA estimates that the cumulative 

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

would have been to report by paper during the same time frame. To support states’ start-up 

efforts, EPA has made grant funds available through the Exchange Network Grant. These funds 

can be used to upgrade current systems, to establish electronic data flow from operators, or to 

establish the data flow to EPA. 

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

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

UIC Program Activity Measures and inventory data through a secure website. 

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

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

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

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

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

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

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

associated with the National UIC database. 
Underground Injection Control Program – Information Collection Request Page 29

5(c) Small Entity Flexibility

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

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

entities. The EPA reduces, to the extent practicable and appropriate, the burden of this collection 

on persons that provide information to or for the agency, including with respect to small entities, 

as defined by the Regulatory Flexibility Act [5 USC 601(6)], using techniques such as:

 Establishing differing compliance or reporting requirements or timetables that 

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

 Clarification, consolidation, or simplification of compliance and reporting 

requirements; or

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

Class I

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

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

 Major Group 13: Oil and gas extraction

 Major Group 28: Chemicals and allied products

 Major Group 26: Paper and allied products

 Major Group 29: Petroleum and coal products

 Major Group 32: Stone, clay and glass products

 Major Group 33: Primary metal industries

 Major Group 36: Electrical and electronic machinery

 Major Group 37: Transportation equipment

 Major Group 45: Transportation by air

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

 Major Group 89: Services not elsewhere classified

 Major Group 99: Non-classifiable establishments

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

1,500 employees, except for SIC code 4953, hazardous waste disposal firms that own and 

operate Class I wells, for which the size standard is $3.5 million or less in revenues. Most of the 

firms that own or operate Class I injection wells exceed both the 500-employee and the 1,500-

employee standard. Examples include Allied Chemical, Bethlehem Steel, Dow Chemical, 

DuPont, Exxon, General Electric, Monsanto, and Shell. The hazardous waste disposal firms that 

own and operate Class I wells are believed to exceed the $3.5 million revenue standard.
Underground Injection Control Program – Information Collection Request Page 30

Class II

Oil and gas extraction firms fall into three SIC categories:

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

 SIC code 1321 (natural gas liquids); and

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

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

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

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

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

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

500-employee size standard.

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

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

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

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

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

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

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

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

measurements at least monthly [40 CFR 146.23].

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

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

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

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

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

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

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

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

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

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

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

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

years have elapsed.
Underground Injection Control Program – Information Collection Request Page 31

Class III

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

 SIC Major Group 10 (metal mining) and

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

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

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

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

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

Class V

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

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

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

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

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

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

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

options for minimizing economic impacts on small entities.

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

Regulatory Flexibility Analysis addressing all activities, including reporting and recordkeeping 

activities, required of small entities.

Class VI

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

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

necessary to construct injection wells that meet the standards of the Class VI Rule are significant, 

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

Therefore, EPA assumes that the reporting requirements for Class VI well owners or operators 

will cause no significant impact on small entities.

5(d) Collection Schedule 

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

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

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

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

collection requirements.
Underground Injection Control Program – Information Collection Request Page 32

5(d)(1)Operator Reporting 

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

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

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

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

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

through A-6 of Appendix A. 

5(d)(2)State Reporting 

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

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

following the Exhibit present the justification for the reporting frequencies. 

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

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

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

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

in 2013, EPA reduced the reporting frequency for PAMs data. As Section 5(b) discusses, upon 

implementation of the National UIC database, states UIC flowing data to Headquarters will no 

longer be required to submit the 7520 forms and inventory and PAM data.

Exhibit 5-1

State Reporting Frequencies

Reporting Activity Frequency

Form 7520-1: Permit Review and Issuance Annual

Form 7520-2A: Compliance Evaluation Semi-annual

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

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

Form 7520-4: Quarterly Exceptions List Quarterly

Inventory Reporting Annual

Program Activity Measures Annual
Underground Injection Control Program – Information Collection Request Page 33

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

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

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

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

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

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

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

shifts in workload and resource distribution.

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

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

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

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

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

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

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

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

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

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

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

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

compliance information.

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

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

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

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

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

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

to evaluate the MIT program. 

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

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

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

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

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

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

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

operating characteristics of injection wells to monitor and regulate underground injection 

effectively and to continue protecting USDWs from contamination.
Underground Injection Control Program – Information Collection Request Page 34

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

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

achieving minimized risk to public health. This 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 semi-annually; this frequency allows EPA to ensure public health protection and to meet 

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

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

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

National UIC database.
Underground Injection Control Program – Information Collection Request Page 35

6. Estimating the Burden and Cost of the Collection

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

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

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

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

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

costs as users of respondent data. Section 6(d) describes the respondent universe and the total 

burden and cost of this collection to respondents. Section 6(e) covers aggregate burden hours 

and costs for all respondents, and Section 6(f) explains the reasons for the change in estimated 

respondent burden hours and costs from the approved ICR burden. Section 6(g) presents the 

burden statement for this information collection.

6(a) Respondent Burden

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

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

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

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

and well closure. Non-labor costs include capital and operation and maintenance costs; for 

example, to purchase well components or analyze samples to meet the UIC requirements. These 

are primarily operators’ costs; states and EPA regulators would typically not incur such costs.

EPA estimates that the annual burden on the 45,753 owners or operators of injection 

wells will be 1,434,967 hours over the three years covered by this ICR. This is summarized in 

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

owner/operator burden and detailed burden and cost calculations.

1) Class I Well Operators

The total annual burden on the 445 operators of Class I wells nation-wide is estimated to 

be 128,945 hours. See Exhibit 6-1A. Of this total, EPA estimates the annual burden for the 74 

operators of Class I hazardous wells to be 27,723 hours, and the burden for 371 operators of 

Class I non-hazardous wells to be 101,222 hours annually.

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

Operator activities associated with Class I facilities include permitting and start-up related 

reporting, permit renewals and modifications, monitoring, reporting and recordkeeping, and 

closure-related paperwork. Operators of Class I hazardous wells must also perform an extensive 

no-migration demonstration to ensure that their wastes will not endanger USDWs. 

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

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

burden estimates specific to Class I wells.
Underground Injection Control Program – Information Collection Request Page 36

Exhibit 6-1A

Annual Burden and Cost Associated with Class I Wells

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 128,945 $6,168,089 $35,263,853 $41,431,942 6,693.4 19.26 $6,189.94 

Primacy States 5,056 $209,419 $0 $209,419 1,793.2 2.82 $116.79 

DI Programs 6,856 $283,995 $0 $283,995 963.4 7.12 $294.78 

TOTAL 140,856 $6,661,503 $35,263,853 $41,925,356 9,450.1 14.91 $4,436.52 

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

2) Class II Well Operators

As shown in Exhibit 6-1B, EPA estimates the total annual burden on the 17,682 operators 

of Class II wells (associated with the oil and natural gas industry) to be 1,195,002 hours. Class II 

well operators perform many of the same types of activities as Class I well owners or operators, 

including submitting permit applications and completion reports, monitoring and testing, 

reporting and recordkeeping, and closure-related paperwork, although with significantly less 

information and paperwork required for each of these activities. 

Hydraulic fracturing operations using diesel fuels are subject to the Class II UIC 

requirements at Subpart C of 40 CFR 146. In February 2014 EPA issued its Permitting Guidance 

for Oil and Gas Hydraulic Fracturing Activities Using Diesel Fuels: UIC Program Guidance #84 

(EPA 816-R-14-001), which recommends that operators of production wells in DI states 

performing HF using diesel fuels obtain a UIC permit for the HF activity and submit the same 

types of information required of Class II well operators, along with additional information to 

afford an evaluation of the proposed HF operation. This ICR includes the burden on owners or 

operators in DI states to apply for Class II permits and perform the monitoring and other 

activities recommended in the Guidance. See Section 6(f) for additional information on how 

these additional permits affect the UIC Program ICR estimates.

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

the owner/operator burden and cost associated with the requirements for Class II wells.
Underground Injection Control Program – Information Collection Request Page 37

Exhibit 6-1B

Annual Burden and Cost Associated with Class II Wells

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 1,195,002 $54,561,313 $111,993,437 $166,554,749 485,966.7 2.46 $342.73 

Primacy States 191,778 $7,944,220 $0 $7,944,220 114,709.7 1.67 $69.25 

DI Programs 12,566 $520,515 $0 $520,515 7,118.7 1.77 $73.12 

TOTAL 1,399,346 $63,026,047 $111,993,437 $175,019,484 607,795.2 2.30 $287.96 

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

3) Class III Well Operators

The estimated total annual burden on the 171 operators of Class III facilities is 57,184

hours. See Exhibit 6-1C. Operators of these wells associated with mining operations incur 

burden associated with permit applications and completion reports, monitoring, reporting and 

recordkeeping, and closure-related paperwork. 

Appendix A (particularly Table A-3) presents details on the assumptions used to calculate 

the owner/operator burden and cost associated with the requirements for Class III wells.

Exhibit 6-1C

Annual Burden and Cost Associated with Class III Wells

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 57,184 $2,400,410 $842,432 $3,242,842 6,176.4 9.26 $525.04 

Primacy States 3,402 $140,934 $0 $140,934 674.3 5.05 $209.01 

DI Programs 271 $11,243 $0 $11,243 379.1 0.72 $29.66 

TOTAL 60,858 $2,552,586 $842,432 $3,395,019 7,229.8 8.42 $469.58 

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

4) Class IV/Endangering Class V Well Operators

Class IV wells and Class V wells that are found to be endangering USDWs are banned 

from injection, and owners of these wells are required to close them and submit plugging and 

abandonment reports to states or DI programs. The exception to the ban is for those Class IV 

wells used to inject contaminated ground water that has been treated and re-injected into the 

same formation from which it was drawn. These wells are authorized by rule for the life of the 

well if such subsurface emplacement of fluid is approved by EPA or a state pursuant to the 

provisions for the cleanup of releases under CERCLA or RCRA. 
Underground Injection Control Program – Information Collection Request Page 38

EPA estimates that the burden on the 990 operators of these wells that are subject to this 

information collection will be 9,900 hours annually. See Exhibit 6-1D and Appendix A.

Exhibit 6-1D

Annual Burden and Cost Associated with Class IV Wells

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 9,900 $235,165 $0 $235,165 990.0 10.00 $237.54 

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 $276,174 $0 $276,174 1,980.0 5.50 $139.48 

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

5) Class V Well Operators

The total annual burden on the 26,459 operators of Class V wells with reporting 

requirements under this information collection is estimated to be 29,789 hours. See Exhibit 6-1E 

and Appendix A. 

All operators of Class V wells must submit inventory information before they may begin 

operating their wells. In addition, the 1999 Class V Rule requires owners or operators that wish 

to continue operating MVWDWs to apply for permits and operators of MVWDWs and largecapacity cesspools that close, to submit pre-closure notifications. While most of these activities 

are complete, EPA assumes that a handful of these facilities will be identified via inspections and 

either close or apply for a permit.

Exhibit 6-1E

Annual Burden and Cost Associated with Class V Wells

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 29,789 $645,361 $6,932,543 $7,577,905 33,880.6 0.88 $223.67 

Primacy States 9,044 $374,637 $0 $374,637 17,270.5 0.52 $21.69 

DI Programs 4,874 $201,919 $0 $201,919 9,318.4 0.52 $21.67 

TOTAL 43,708 $1,221,917 $6,932,543 $8,154,461 60,469.5 0.72 $134.85 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 39

6) Class VI Well Operators

EPA estimates that the burden on the Class VI well operators subject to this information 

collection during the clearance period will be 14,146 hours annually for activities associated with 

a permit application and the early years of injection operations. 

EPA finalized requirements for owners or operators of Class VI wells (for GS) in 2010 

(75 FR 77230). Concurrent with publishing the Class VI Rule, EPA obtained OMB clearance 

for paperwork burden associated with the requirements for Class VI wells (ICR No. 2309.01, 

OMB control number 2040-0278). The clearance period of that ICR ended in 2013. This UIC 

Programmatic ICR estimates the burden and cost to owners or operators and primacy agencies 

associated with implementing the Class VI Rule over all three years of this proposed information 

collection. See Exhibit 6-1F and Appendix A.

Exhibit 6-1F

Annual Burden and Cost Associated with Class VI Wells

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 14,146 $1,531,257 $18,133,892 $19,665,149 112.3 125.93 $175,060.67 

Primacy States 2,840 $117,644 $0 $117,644 4.0 710.00 $29,411.04 

DI Programs 3,775 $156,376 $0 $156,376 25.0 151.00 $6,255.02 

TOTAL 20,761 $1,805,277 $18,133,892 $19,939,168 141.3 146.90 $141,079.02 

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)

2015-2017

Respondent Type Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Class I Operators 128,945 $6,168,089 $35,263,853 $41,431,942 6,693.4 19.26 $6,189.94 

Class II Operators 1,195,002 $54,561,313 $111,993,437 $166,554,749 485,966.7 2.46 $342.73 

Class III Operators 57,184 $2,400,410 $842,432 $3,242,842 6,176.4 9.26 $525.04 

Class IV Operators 9,900 $235,165 $0 $235,165 990.0 10.00 $237.54 

Class V Operators 29,789 $645,361 $6,932,543 $7,577,905 33,880.6 0.88 $223.67 

Class VI Operators 14,146 $1,531,257 $18,133,892 $19,665,149 112.3 125.93 $175,060.67 

TOTAL 1,434,967 $65,541,594 $173,166,157 $238,707,751 533,819.5 2.69 $447.17 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 40

6(a)(ii) Burden to Primacy Agencies

EPA estimates that the annual oversight burden on the 58 state primacy agencies that 

oversee the various classes of injection wells is 212,878 hours. This burden is for processing 

permit applications and completion reports, reviewing monitoring and testing data, and 

responding to closure reports submitted by operators in their states. 

The burden to states as respondents associated with compiling and reporting data using 

the 7520 forms and the UIC measures reporting process or submission to the National UIC 

database totals 66,201 hours annually. 

Exhibit 6-2 shows the annual Primacy agency burden hours associated with oversight of 

each class of injection well and providing data. Appendix A describes the basis for the burden 

estimates.

Exhibit 6-2

Annual Primacy Agency Burden and Cost

2015-2017

Respondent Type Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Class I Programs 5,056 $209,419 $0 $209,419 1,793.2 2.82 $116.79 

Class II Programs 191,778 $7,944,220 $0 $7,944,220 114,709.7 1.67 $69.25 

Class III Programs 3,402 $140,934 $0 $140,934 674.3 5.05 $209.01 

Class IV Programs 758 $31,399 $0 $31,399 758.0 1.00 $41.42 

Class V Programs 9,044 $374,637 $0 $374,637 17,270.5 0.52 $21.69 

Class VI Programs 2,840 $117,644 $0 $117,644 4.0 710.00 $29,411.04 

Subtotal-Operator 

Oversight 212,878 $8,818,254 $0 $8,818,254 135,209.8 1.57 $65.22 

States as 

Respondents 66,201 $2,742,291 $64,101 $2,806,393 435.0 152.19 $6,451.48 

TOTAL 279,078 $11,560,545 $64,101 $11,624,646 135,644.8 2.06 $85.70 

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

6(b) Respondent Costs

6(b)(i) Cost to Operators

Exhibits 6-1A through F and 6-1G show the total costs for owners and operators of 

various classes of injection wells over the three-year ICR clearance period. Annual costs to 

injection well operators are estimated at approximately $238.7 million, which consists of $173.2

million in non-labor costs and $65.5 million in labor costs. 

EPA determined operator labor cost by estimating the mix of legal, managerial, technical, 

and clerical time needed to perform each collection activity. For Classes I, II, and III, the labor 
Underground Injection Control Program – Information Collection Request Page 41

cost estimate is based on average hourly estimates for salary and overhead of $91 for legal staff, 

$84 for managerial staff, $49 for technical staff, and $28 for clerical staff. For Classes IV and V, 

hourly salary and overhead rates are estimated to be slightly less: $59 for managerial staff, $25 

for technical staff, and $19 for clerical staff (no legal staff labor is assumed for these operators). 

For Class VI, the labor cost estimate is based on average hourly estimates for salary and 

overhead of $111 for mining and geological engineers and $106 for geoscientists. 

EPA estimated non-labor costs from data provided by staff in EPA Regions and state 

primacy agencies, and from operators and other sources. This ICR assumes there are no capital 

costs to operators–large capital expenditures associated with underground injection (e.g., 

construction costs and monitoring equipment) are considered to be customary business practice. 

All non-labor costs to operators associated with this collection are operating and maintenance 

(O&M) costs, such as the cost of contractor services or laboratory fees associated with injectate, 

sludge, or ground water monitoring. Contractor time was estimated to be approximately $80 per 

hour. 

6(b)(ii) Cost to Primacy Agencies

Exhibit 6-2 shows that the annual cost to primacy agencies is estimated at approximately 

$11.62 million, of which most ($11.56 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 2013 federal pay scale, increased by 60 percent to account for 

overhead costs. (This is the inflation factor recommended in EPA’s ICR Handbook.) 

The non-labor costs (capital and O&M) to states in this ICR are estimated to be $64,101. 

These include capital/start-up costs associated with purchasing computer hardware to allow data 

transfer to Headquarters to populate the National UIC database. The remaining non-labor costs 

to states are the cost of contractor support for database development. 
Underground Injection Control Program – Information Collection Request Page 42

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 six states. Additionally, EPA 

assumes that, at the beginning of the clearance period, the agency will directly implement the 

Class VI program in all states. EPA estimates that only a handful of Class VI permits will be 

issued during the clearance period, and the Agency will review these permit applications for 

states that have not yet been granted primacy. The paperwork requirements for DI programs are 

roughly the same as those for the state primacy programs. In addition, EPA regions review all 

no-migration petitions submitted by Class I hazardous facility operators and Class VI injection 

depth waivers in both primacy and DI states in their Region. 

EPA Headquarters’ activities associated with oversight of the national UIC Program 

include gathering and reviewing 7520 forms, analyzing inventory and measures data, and 

developing the National UIC database. 

The total annual burden for federal DI programs associated with the above activities is 

32,734 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 2013

federal pay scale, increased by 60 percent to account for overhead costs. The annual federal cost 

associated with this collection is $1,355,981. The breakdown of agency cost associated with 

each well class is presented in Exhibit 6-3.

Exhibit 6-3

Annual Agency Burden and Cost

2015-2017

Respondent Type Burden 

(hours)

Labor Cost Non-Labor 

Cost

Total Cost Responses Burden/ 

Response

Cost/ 

Response

Class I DI Programs 6,856 $283,995 $0 $283,995 963.4 7.12 $294.78 

Class II DI Programs 12,566 $520,515 $0 $520,515 7,118.7 1.77 $73.12 

Class III DI Programs 271 $11,243 $0 $11,243 379.1 0.72 $29.66 

Class IV DI Programs 232 $9,610 $0 $9,610 232.0 1.00 $41.42 

Class V DI Programs 4,874 $201,919 $0 $201,919 9,318.4 0.52 $21.67 

Class VI DI Programs 3,775 $156,376 $0 $156,376 25.0 151.00 $6,255.02 

Headquarters 

Management 4,160

$ 

172,323.84 $0 $172,324 1.0 4,160.00 $172,323.84 

TOTAL 32,734 $1,355,981 $0 $1,355,981 18,037.6 1.81 $75.18 

Note: numbers may not appear to add due to rounding.
Underground Injection Control Program – Information Collection Request Page 43

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

EPA estimates that 45,753 owners or operators of injection wells and 58 primacy

agencies are subject to the UIC Program’s information collection requirements outlined in 

Section 6(a). The number of responses for each well class and activity are shown in Exhibits 6-

1A though 6-1F, and summarized in Exhibit 6-1G. The estimates of the number of state 

responses are shown in Exhibit 6-2. This number, known as the respondent universe, is based on 

EPA’s assumptions of the number of permittees subject to each paperwork requirement, e.g., the 

number of permit applications or well closures expected, or the percent of permittees subject to 

monitoring or reporting requirements and the frequency with which they must comply with those 

requirements. Part 2 of Appendix A provides more detail on EPA’s assumptions about the 

number of respondents that perform each collection activity.

EPA estimates that the total non-federal respondent burden over the three years covered 

by this ICR is 5.1 million hours (or 1.71 million hours per year). The total cost to respondents is 

$750.99 million (or $250.3 million per year).

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

2015-2017

Number of Respondents 45,811 = 45,753 Operators (from EPA inventory) +

58 Primacy agencies

Total Annual Responses 669,464 = 533,819 Operator responses (from Exhibit 6-1G) +

135,645 Primacy agency responses (from Exhibit 6-2)

Number of Responses per 

Respondent

14.6 = 669,464 Total annual responses from above ÷

45,811 Total respondents from above

Total Respondent Hours 1,714,046 = 1,434,967 Operator burden hours (from Exhibit 6-1G) +

279,078 Primacy agency burden hours (from Exhibit 6-2)

Hours per Response 2.6 = 1,714,046 Total annual hours from above/

669,464 Total responses from above

Annual O&M + Capital Cost $173,230,258 = $173,166,157 Operator non-labor cost (from Exhibit 6-1G) +

$64,101 Primacy agency non-labor cost (from Exhibit 6-2)

Total Respondent Cost $250,332,398 = $238,707,751 Operator cost (from Exhibit 6-1G) +

$11,624,646 Primacy agency cost (from Exhibit 6-2)

Total Hours (Respondents) 1,746,780 = 1,714,046 Total respondent hours from above +

32,734 Total EPA hours (from Exhibit 6-3)

Total Cost (Respondents 

plus Agency) $251,688,379 = $250,332,398 Total respondent cost from above +

$1,355,981 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 44

6(f) Reason for Change in Burden 

The current total annual approved burden on operators and states associated with the UIC 

Program is 1,304,027 hours. This ICR renewal request estimates a total annual respondent 

burden of 1,714,046 hours. Thus, there is a net increase in burden of 410,019 hours between the 

approved and requested amounts. Of this, 358,597 hours is increased operator burden and 

51,422 is increased primacy agency burden.

This increase is due to adjustments associated with an increase in the injection well 

inventory, primarily the number of Class II permit applications expected to be approved, as well 

as increases in the Class I and Class III inventories and the deployment of Class VI (geologic 

sequestration) activities. These increases are offset by burden reductions associated with 

decreases in the number Class V well operators submitting inventory information, continued 

implementation of electronic reporting by states and reduced state reporting frequencies.

Note that the approved burden cited above differs from the burden reported in the 

previous UIC Program ICR (ICR No. 0370.21); that ICR estimated a total annual burden on 

operators and states of 1,296,167 hours. The current approved burden reflects the addition of 

activities associated with the Class VI Rule, estimated in EPA ICR No. 2309.01. That ICR added 

7,860 hours to the approved UIC Program burden for the total presented above, which is the 

basis of the analysis in this section.

9

 

This section discusses the change in burden to operators of injection wells and primacy 

states between the burden requested in this ICR and the approved burden. The burden changes 

are the result of program and inventory changes that affect well operators and the agencies that 

oversee them. 

Exhibits 6-5 and 6-6 summarize the burden impacts of these changes to operators and 

primacy agencies, respectively. The paragraphs following the exhibits describe these changes. 

 

9

 Note: In 2011, OMB jointly approved the UIC programmatic ICR and the Class VI Rule ICR; the burden hours 

approved in that action (1,013,399 hours) were different than the sum of the burden estimated two ICRs. For 

consistency with previous analyses and to allow an in-depth discussion of the change in burden, the UIC-developed 

burden estimates are used as the basis for this discussion.
Underground Injection Control Program – Information Collection Request Page 45

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 100,983 128,945 27,962

Adjustment due to inventory increases and addition of 

small burden associated with applying for aquifer 

exemptions.

Class II Operators 872,778 1,195,002 322,224

Adjustments to the inventory and the number of permit 

applications submitted; also small change due to the 

addition of burden associated with applying for aquifer 

exemptions. Program change associated with a small 

number of facilities following the recommendations of 

the DFHF Guidance.

Class III 

Operators 48,051 57,184 9,133

Adjustment due to increase in the number of Class III 

facilities; small change due to the addition of burden 

associated with applying for aquifer exemptions.

Class IV 

Operators 9,900 9,900 0 None.

Class V 

Operators 38,924 29,789 -9,135

Adjustment due to a reduction in the number of largecapacity cesspools and MVWDWs permitted/closed; 

also a general decreasing trend in the Class V 

inventory.

Class VI 

Operators 5,734 14,146 8,413

Program change and adjustment. Reflects complete 

incorporation of Class VI burden into this ICR. Also, 

increase in the number of Class VI permit applications 

expected and adjustment to unit burden estimates 

based on early implementation experience. 

Total 1,076,371 1,434,967 358,597

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 4,463 5,056 593

Adjustment due to inventory increases since the last 

ICR.

Class II Primacy 127,190 191,778 64,588

Adjustments due to inventory changes and the number 

of permit applications reviewed.

Class III Primacy 3,363 3,402 39

Adjustment due to increase in the number of Class III 

facilities.

Class IV Primacy 758 758 0 None.

Class V Primacy 14,722 9,044 -5,678

Adjustment due to a reduction in the number of largecapacity cesspools and MVWDWs identified and 

permitted/closed; also a general decreasing trend in the 

Class V inventory.

Class VI Primacy 6,346 2,840 -3,506

Program change and adjustment associated with 

complete incorporation of the Class VI burden into the 

UIC programmatic ICR. Adjustment reflecting more 

Class VI permit applications expected in this ICR period 

and adjustment to unit burden estimates based on early 

implementation experience.

States as 

respondents 70,814 66,201 -4,614

Program changes reflect change in frequency of PAMs 

reporting and electronic reporting to the National UIC 

database.

Total 227,657 279,078 51,422

Note: Detail may not appear to add exactly due to independent rounding.
Underground Injection Control Program – Information Collection Request Page 46

Program Changes

This section describes the program changes that affect the UIC reporting burden in this 

ICR. (EPA assumes that ongoing activities associated with implementation of the Florida Class I 

rule and the Class V rule—previously considered to be program changes—are now “ongoing” 

activities. Therefore, any burden changes associated with these rules are associated with the 

number of operators performing these activities and are included under “adjustments,” below).

 Diesel Fuels Hydraulic Fracturing (DFHF) Guidance. EPA published a guidance 

recommending that owners or operators of production wells in DI states performing HF 

using diesel fuels obtain a UIC permit for the HF activity. EPA estimates that only a 

small number of owners or operators (30) will be subject to the recommendations in the 

DFHF Guidance (based on the fact that most Class II wells are in primacy states and most 

HF operations do not involve the use of diesel fuels), and that this change will add 2,400

hours to the total owner or operator burden. See Table A-2 in Appendix A.

 Class VI Rule. Activities associated with obtaining Class VI permits and operating GS 

facilities are now fully accounted for in this clearance period. Many unit burdens 

associated with permit applications were adjusted upward based on EPA’s experiences 

during early implementation activities; this ICR also assumes that by the end of the 

clearance period, three owners or operators will be operating Class VI wells. As a result, 

EPA estimates that the burden on owners or operators will increase by 8,413 hours. Also, 

while EPA assumed that all states would have received Class VI primacy during the 

clearance period for the Class VI rule ICR, this was not the case; EPA currently assumes 

that states will continue to apply for Class VI primacy under this clearance period. As a 

result, EPA estimates a net decrease of 3,506 hours for Class VI primacy agencies.

 PAMs reporting. EPA reduced the frequency at which states must submit PAMs data 

from semi-annually to annually. This results in a modest burden reduction of 1,040 hours 

annually. 

 National UIC database. EPA has reduced the frequency at which e-reporters must upload 

information to the National UIC database from quarterly to semi-annually, resulting in a 

reduction of 3,600 state burden hours annually. Appendix B describes the development 

and implementation of the National UIC database, and compares the reporting costs for 

states with and without a national database. 
Underground Injection Control Program – Information Collection Request Page 47

Adjustments

Adjustments that affect the UIC reporting burden in this ICR include the following: 

 Inventory changes. Between 2011 and 2013, the national injection well inventory 

decreased by approximately 4,100 wells. In particular, a decrease in the Class V 

inventory (of 31,346 wells) was offset by an increase in the Class II inventory (of 25,665 

wells); other well inventories also changed. In general, the burden on Class II owners or 

operators is higher than on Class V owners or operators, who only submit inventory data; 

therefore the Class II inventory changes have a larger impact on the total ICR burden. 

Changes in the Class II inventory add 623,159 hours to the ICR burden; much of this 

increase is associated with an increase in the number of permit applications expected to 

be processed over the next three years. The Class V inventory decrease had a much more 

modest impact on the ICR burden, reducing the owner or operator burden by 1,425 hours. 

Inventory changes affected the total burden on all well classes, increasing the ICR burden 

by 658,749 hours.

 Other adjustments relate to assumptions about the number of Class I, Class II, and Class 

III aquifer exemptions and the associated burden and other adjustments to unit burdens 

based on UIC Program experience. These adjustments collectively reduced the ICR 

estimate by 259,257 hours. 

UIC Program Burden Reduction Efforts

EPA continues to explore options to reduce the reporting burden and cost to respondents, 

while maintaining the protective components of the UIC Program. This is primarily being 

accomplished by increasing the use of electronic reporting methods. EPA’s efforts are briefly 

described below and discussed in further detail in Appendix D.

 EPA’s National UIC database allows electronic transfer of data between existing state 

and DI databases and Headquarters’ database. When fully populated, the National UIC 

database will eliminate the need for state UIC Program Directors to complete paper 

reporting forms because Headquarters would be able to collect data for and prepare 

national annual reports using the information in the database. As part of this effort, EPA 

encourages primacy programs to develop electronic reporting from operators to primacy 

programs. Also, as noted above, EPA has reduced the frequency at which e-reporters 

must upload information to the national data base from quarterly to semi-annually. See 

additional discussion of the National UIC database in Section 5(b) of this ICR and in 

Appendix B.

 As noted above, EPA reduced the frequency at which states must submit PAMs data 

from semi-annually to annually. This results in a modest burden reduction of 1,040

hours annually. 
Underground Injection Control Program – Information Collection Request Page 48

6(g) Burden Statement

EPA estimates that, over the three years covered by this request, the total annual burden 

on injection well owners or operators and primacy agencies associated with UIC requirements 

will be 1,714,046 hours and the present value cost will be $250.3 million per year. See Exhibit 6-

7.

Exhibit 6-7

Annual Burden and Cost Associated with All Well Classes

2015-2017

Respondent 

Type

Burden 

(hours)

Labor Cost Non-Labor Cost Total Cost Responses Burden/ 

Response

Cost/ 

Response

Operators 1,434,967 $65,541,594 173,166,157 238,707,751 533,819.5 2.69 $447.17 

Primacy States 279,078 $11,560,545 $64,101 $11,624,646 135,644.8 2.06 $85.70 

Respondent 

total 1,714,046 $77,102,139 $173,230,258 $250,332,398 669,464.3 2.56 $373.93 

EPA 32,734 $1,355,981 $0 $1,355,981 18,037.6 1.81 $75.18 

TOTAL 1,746,780 $78,458,121 $173,230,258 $251,688,379 687,501.9 2.54 $366.09 

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

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 2.56 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information. An agency may not conduct or sponsor, and a person is not required to 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.
Underground Injection Control Program – Information Collection Request Page 49

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

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

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OW-2014-0359, which is available for public viewing at the Water 

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

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

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

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

2426. An electronic version of the public docket is available through 

http://www.regulations.gov. Use www.regulations.gov to submit or view public comments, 

access the index listing of the contents of the public docket, and to access those documents in the 

public docket that are available electronically. Once in the system, select “search,” then key in 

the docket ID number identified above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

No. EPA-HQ-OW-2014-0359 and OMB control number 2040-0042 in any correspondence.