Underground Injection Control Program – Information Collection Request Page A-1 

### Appendix A: Detailed Explanatio n of Respondent Burden Esti mates and Respondent Universe

Respondents for this information collection include operators of Class I – VI wells and state primacy

agencies. The first part of this A ppendix contains EPA’s estimates of re spondent burden associated with UIC

paperwork requirements. The second part of this A ppendix provides EPA’s assumpti ons about the number of

respondents subject to each in formation collection activity.

A.1 Estimating Respondent Burden

EPA has calculated respondent burden hours fo r each information collection, reporting, and

recordkeeping activity required of well operators and stat e primacy agencies. Because required data items vary

by well class, separate operator and state burden estimates have been prepared for each class. Tables A-1

through A-7 contain detailed estimates of the number of respondents and unit burden hours for required

paperwork-related activities.

EPA recognizes that many UIC information collecti on activities are performe d by contractors. The

operator unit burdens reported in this appendix represent a composite of the operator time needed to both

perform an information collection activ ity and to supervise a contractor when the contractor performs the

activity. The mix of operator versus c ontractor labor varies by activity and by well class. Contractor costs are

included in the estimates of operator unit costs.

Burden Associated with Class I Wells

EPA’s estimate of the annual paperwork burden on operators for permitting, monitoring and testing,

reporting and recordkeeping, and closing their facilities and state burden for admini stering Class I hazardous

and Class I nonhazardous programs are presented in Ta bles A-1A and Table A-1B , respectively. Legal,

managerial, technical, and clerical staff hours are shown; Column A presents the total unit burden for each

activity.

Class I facility operators rely on co ntractors to assist them with most information collection activities,

including initial/start -up activities (e.g., permit app lications, completion reports, and no-migration petitions);

monitoring and testing (e.g., ambient monitoring, pressure fall-off tests, and MITs); closure-related reporting;

and other paperwork activities (e.g., permit and no-migration petition modi fications). The operator burdens

presented in Column A of Tables A- 1A and A-1B largely reflect the tim e it takes to oversee and furnish

information to contractors. The costs associated with contractor labor and othe r contractor services are

presented in Column C of Tables A-1A and A-1B.

EPA estimates that 70 percent of the new Class I perm its issued will be for newly constructed wells at

existing facilities, and that mu ch of the information these applicants are required to submit is li kely to have been

developed in connection with permitting other wells and, ther efore, already exists for the facility. EPA assumes

the remaining 30 percent of permits will be issued for we lls at new facilities, and the burden associated with

applying for a permit will be greater. Thus, the unit burdens presented in this ICR are a composite of the

burdens for permitting new wells at both new and existing facilities.Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearInitial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time0.0 0.25 0.25 0.0 0.5 $33 $0 8 4 $266Gather and submit description of activitiesrequiring a permit, facility name and address,SIC codes, ownership and facility status,facility location, listing of relevant permits orconstruction approvals, description of thebusiness.One-time3.0 2.0 9.0 6.0 20.0 $1,051 $0 8 160 $8,408In DI programs, gather and submit a list oflandowners within one-quarter mile of thefacility boundary.One-time4.0 0.0 0.0 1.2 5.2 $399 $0 3 13 $1,016Prepare and submit a map and tabulation ofall wells within the AoR.One-time0.0 1.5 5.5 0.0 7.0 $394 $23,082 8 56 $187,810Prepare and submit AoR protocol. One-time0.0 0.0 1.3 0.0 1.3 $63 $894 8 10 $7,661Prepare and submit maps/cross sections oflocal and regional geology, USDWs.One-time0.0 1.5 16.0 0.0 17.5 $906 $47,922 8 140 $390,623Develop formation testing and stimulationprograms and injection procedures.One-time0.0 2.0 5.0 1.0 8.0 $440 $6,879 8 64 $58,553Prepare and submit contingency plans forshut-ins or well failures.One-time0.0 3.0 10.0 2.0 15.0 $797 $268 8 120 $8,514Prepare and submit ambient monitoring plan. One-time0.0 3.0 0.0 0.0 3.0 $248 $4,509 8 24 $38,061Prepare and submit Corrective Action Plan. One-time0.0 2.0 3.0 2.3 7.3 $380 $11,426 8 58 $94,449Prepare and submit descriptions of logs andtests, construction schematics & operatingdata.One-time0.0 2.0 8.0 5.0 15.0 $700 $5,732 8 120 $51,460Prepare and submit closure plan, includingdemonstration of financial responsibility.One-time0.0 1.0 3.0 2.6 6.6 $304 $1,689 8 53 $15,947Prepare and submit post-closure care plan. One-time0.0 1.4 2.0 1.4 4.8 $254 $2,079 8 38 $18,663Prepare and submit information to support anaquifer exemption request.One-time0.0 2.5 17.0 0.5 20.0 $1,053 $2,079 1.4 27 $4,260Underground Injection Control Program -- Information Collection RequestPage A-2Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearRequirements for active hazardous waste facilitiesGather and submit dates of well operationand specific waste information.One-time0.0 0.0 26.6 11.4 38.0 $1,620 $8,713 8 304 $82,667Gather and submit hazardous waste releaseinformation.One-time0.0 1.9 30.4 22.8 55.1 $2,289 $4,357 0 0 $0Develop waste analysis plan. One-time0.0 1.9 15.2 1.9 19.0 $955 $2,904 8 152 $30,873Prepare and submit schedule of constructionlogs and tests.One-time0.0 0.0 0.5 0.5 1.0 $39 $0 8 8 $309Requirements associated with completion reportsPrepare and submit completion report. One-time0.0 0.0 1.5 2.5 4.0 $144 $0 8 32 $1,153Submit results of deviation checks, other logsand tests; sample formation fluids; testinjection and confining zones.One-time0.0 0.0 6.0 1.0 7.0 $321 $35,158 8 56 $283,829Demonstrate mechanical integrity (i.e., casingpressure test, radioactive tracer survey ofbottom-hole cement, and noise/temperaturelogs to check for movement along theborehole).One-time0.0 2.0 18.0 0.0 20.0 $1,046 $22,929 8 160 $191,798Submit information on the anticipatedmaximum pressure and flow rate.One-time0.0 0.0 2.0 0.0 2.0 $97 $153 8 16 $2,003Submit results of the injection zone andconfining zone testing programs.One-time0.0 1.0 4.0 0.0 5.0 $279 $38,215 8 40 $307,953Submit actual injection procedure. One-time0.0 0.0 1.0 0.0 1.0 $49 $153 8 8 $1,613Demonstrate hydrogeologic compatibility/compatability of well materials.One-time0.0 2.0 6.0 0.0 8.0 $461 $7,643 8 64 $64,830Prepare and submit information on thecalculated AoR.One-time0.0 0.0 2.0 0.0 2.0 $97 $3,057 8 16 $25,238No-migration petition requirementsGather and submit waste information andpresent modeling data to demonstrate thatwastes will not migrate from injection zone.One-time0.0 24.0 120.0 30.0 174.0 $8,721 $802,515 8 1,392 $6,489,891Requirements associated with permit renewals/modifications and petition modificationsSubmit updated components of permitapplication attachments.Occasional0.0 9.0 41.5 21.0 71.5 $3,377 $11,312 12 858 $176,261Prepare and submit request for PermitModification.One-time0.0 2.0 6.0 2.0 10.0 $518 $6,573 5 50 $35,453Prepare and submit Petition Modification. One-time0.0 24.0 120.0 30.0 174.0 $8,721 $759,679 6 1,044 $4,610,403Underground Injection Control Program -- Information Collection RequestPage A-3Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearMonitoring/Testing Requirements (Per Facility)Use continuous recording devices to monitorinjection pressure, flow rate, volume, andtemperature.Continuous0.0 0.0 5.7 0.0 5.7 $278 $0 74 420 $20,474Conduct chemical monitoring of injectedwastes as prescribed in waste analysis plan.As specified inWAP0.0 0.0 38.0 0.0 38.0 $1,852 $4,586 295 11,200 $1,897,589Conduct additional chemical monitoring asspecified by the Director.Varies0.0 0.0 7.6 0.0 7.6 $370 $917 29 224 $37,952Conduct casing pressure test and radioactivetracer survey of bottom-hole cement.Annual0.0 3.8 5.2 0.0 9.0 $573 $6,331 59 531 $406,969Conduct casing pressure test, radioactivetracer of bottom-hole cement, andnoise/temperature logs to check formovement along the borehole.Every 5 years0.0 1.0 7.0 0.0 8.0 $425 $43,565 15 118 $648,281Conduct casing inspection log at workover. Occasional0.0 3.8 8.0 0.0 11.8 $710 $7,597 4 43 $30,603Conduct pressure fall-off test. Annual0.0 6.0 18.0 0.0 24.0 $1,382 $17,726 74 1,768 $1,407,975Conduct ambient monitoring. Annual0.0 0.4 1.9 0.0 2.3 $125 $6,114 74 168 $459,716Reporting Requirements (Per Facility)Prepare and submit report on maximuminjection pressure, total injectate volume, andmonitoring and testing results.Quarterly0.0 4.0 15.0 6.0 25.0 $1,627 $0 295 7,368 $479,572Prepare and submit report on mechanicalintegrity testing.Annual0.0 1.0 2.0 1.0 4.0 $260 $1,376 74 295 $120,492Notify Director within 24 hours of: plannedphysical changes to facility, changes that mayresult in noncompliance, compliance ornoncompliance with a compliance schedule,any indication of possible endangerment of aUSDW, or all other noncompliance.Occasional0.0 1.0 2.0 3.0 6.0 $260 $0 1 4 $191Prepare and submit revised plugging andabandonment cost estimate.Annual0.0 1.0 0.0 0.0 1.0 $91 $0 74 74 $6,720Prepare and submit report on: eventsexceeding operating parameters or triggeringalarms; changes in annular fluid volume;workovers or other testing.Occasional0.0 1.0 1.0 1.0 3.0 $161 $0 4 11 $594Underground Injection Control Program -- Information Collection RequestPage A-4Table A-1AAnnual Paperwork Burden and Costs Associated with Class I Hazardous Wells: OperatorsAB C D E FHours and Costs per Response Total Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Nonlabor Cost (B)No. ofResponsesTotalHours/Year Total Cost/YearRecordkeeping Requirements (Per Facility)Maintain monitoring information, calibrationand maintenance records, required reports,application data, monitoring results, and mostrecent plugging and abandonment costestimate.3 years0.0 0.0 0.0 5.0 5.0 $142 $0 74 368 $10,461Closure Requirements (Per Well)Prepare and submit notice of intent to close. One-time0.0 0.5 0.0 1.0 1.5 $70 $0 1 2 $70Prepare and submit closure report. One-time0.0 2.0 8.0 0.0 10.0 $558 $3,057 1 10 $3,615Conduct pressure fall-off test prior to wellclosure.One-time0.0 1.0 5.0 0.0 6.0 $328 $17,726 1 6 $18,054Demonstrate mechanical integrity (i.e., casingpressure test, radioactive tracer of bottomhole cement, and noise/temperature logs tocheck for movement along the borehole) priorto closure.One-time0.0 2.0 18.0 0.0 20.0 $1,046 $28,615 1 20 $29,660Notify state or local zoning or drillingauthorities and Regional Administratorfollowing closure.One-time0.0 0.5 1.0 3.0 4.5 $176 $0 1 5 $176TOTAL1,375 27,723 18,769,130$Notes:(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-5Table A-1A (continued)Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: StatesABCDEFHours and Costs per Response Total Hours and CostsDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonlaborCostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearInitial/Start-upPermit ApplicationsConsider the permit application, AoR, relevant maps andcross sections, fluid injection rate and volume, proposedcontingency plans, monitoring plans, and constructionprocedures as required at 146.70 and prepare draft permit.One-time40.0 $1,657 $0 5218$9,036Provide public notice of issuance of a draft permit or intent todeny.One-time1.0 $41 $0 55$226Consider public comments. One-time6.0 $249 $0 533$1,355Issue final permit decision. One-time2.0 $83 $0 511$452Respond to comments. One-time7.0 $290 $0 538$1,581Review notice of completion of construction. One-time2.0 $83 $0 511$452Review information related to aquifer exemption requests andforward to EPA region.One-time1.0 $41 $0 11$38No-Migration PetitionsReview and respond to petition request. One-time18.0 $746 $0 598$4,066Public notice/public comment. One-time10.0 $414 $0 555$2,259Review and respond to petition modification request. One-time10.0 $414 $0 441$1,694Permit renewals/modificationsReview and respond to requests for permit modifications or reissuance.Occasional30.0 $1,243 $0 8245$10,165Underground Injection Control Program -- Information Collection RequestPage A-6Table A-1A (continued)Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: StatesABCDEFHours and Costs per Response Total Hours and CostsDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonlaborCostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearMonitoring/TestingReview quarterly monitoring and testing results. Quarterly1.5 $62 $0 201301$12,484Review casing pressure test and radioactive tracer survey ofbottom-hole cement.Annual4.0 $166 $0 40161$6,658Review casing pressure test, radioactive tracer survey ofbottom-hole cement, and logs.Every 5 years4.0 $166 $0 10 40$1,664Review pressure fall-off test. Annual2.0 $83 $0 3977$3,204Other ReportingRespond to periodic notifications by owners and operators. Occasional2.0 $83 $0 4 8$339ClosureReview closure and post-closure plans prior to approvingplugging and abandonment.One-time2.0 $83 $0 12$83Witness and review pressure fall-off test prior to authorizingclosure.One-time24.0 $994 $0 124$994TOTAL3981,371$56,793Notes:(A) For quarterly activities, the number of responses = number of facilities X 4.(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-7Table A-1BAnnual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: OperatorsAB C D E FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Non-LaborCost (B)No. ofResponsesTotalHours/Year Total Cost/YearInitial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time0.0 0.25 0.25 0.0 0.5 $33 $0 14 7 $465Gather and submit description of activitiesrequiring a permit, facility name and address,SIC codes, ownership and facility status,facility location, listing of relevant permits orconstruction approvals, relevant maps andcross sections, construction specifics,description of the business, proposedinjection,formation testing,and stimulationOne-time3.0 2.0 9.0 6.0 20.0 $1,051 $0 14 280 $14,714In DI programs, gather and submit a list oflandowners within one-quarter mile of thefacility boundary.One-time4.0 0.0 0.0 1.2 5.2 $399 $0 4 23 $1,778Prepare and submit a map and tabulation ofall wells within the AoR.One-time0.0 1.5 5.5 0.0 7.0 $394 $18,465 14 98 $264,038Prepare and submit maps/cross sections oflocal and regional geology, USDWs.One-time0.0 1.5 16.0 0.0 17.5 $906 $47,922 14 245 $683,589Prepare and submit descriptions of logs andtests, construction schematics and operatingdata.One-time0.0 2.0 8.0 2.5 12.5 $629 $5,732 14 175 $89,061Develop formation testing and stimulationprograms and injection procedures.One-time0.0 2.0 7.0 1.0 10.0 $538 $6,879 14 140 $103,833Prepare and submit contingency plans forshut-ins or well failures.One-time0.0 3.0 10.0 2.0 15.0 $797 $268 14 210 $14,899Prepare and submit ambient monitoring plan. One-time0.0 3.0 3.0 3.0 9.0 $484 $4,509 14 126 $69,906Prepare and submit Corrective Action Plan. One-time0.0 2.0 3.0 2.3 7.3 $380 $8,789 14 102 $128,370Prepare and submit closure plan, includingdemonstration of financial responsibility.One-time0.0 1.0 3.0 2.6 6.6 $304 $1,689 14 92 $27,907Prepare and submit information to support anaquifer exemption request.One-time0.0 2.5 17.0 0.5 20.0 $0 $0 2.4 48 $0Requirements associated with completion reportsPrepare and submit completion report. One-time0.0 0.0 1.5 2.5 4.0 $144 $0 14 56 $2,018Prepare and submit a report of deviationchecks and other logs and tests duringOne-time0.0 0.0 6.0 1.0 7.0 $321 $35,158 14 98 $496,702Demonstrate mechanical integrity (i.e., casingpressure test and noise/temperature logs toOne-time0.0 2.0 3.5 0.0 5.5 $339 $9,936 14 77 $143,848Underground Injection Control Program -- Information Collection RequestPage A-8Table A-1BAnnual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: OperatorsAB C D E FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Non-LaborCost (B)No. ofResponsesTotalHours/Year Total Cost/YearSubmit information on the anticipatedmaximum pressure and flow rate.One-time0.0 0.0 2.0 0.0 2.0 $97 $153 14 28 $3,505Submit results of the formation testingprogram.One-time0.0 1.0 4.0 0.0 5.0 $279 $38,215 14 70 $538,918Submit actual injection procedure. One-time0.0 0.0 1.0 0.0 1.0 $49 $153 14 14 $2,823Demonstrate hydrogeologic compatibility/compatibility of well materials.One-time0.0 2.0 6.0 0.0 8.0 $461 $7,643 14 112 $113,453Requirements associated with permit renewals/modificationsSubmit updated components of permitapplication attachments.Occasional0.0 8.0 11.0 2.0 21.0 $1,266 $5,350 20 420 $132,327Prepare and submit request for permitmodification.Occasional0.0 2.0 6.0 0.0 8.0 $461 $3,822 9 72 $38,541Monitoring/Testing Requirements (Per Facility)Analyze injected fluids. Per permit0.0 0.0 38.0 0.0 38.0 $1,852 $3,057 1,484 56,400 $7,286,951Monitor injection pressure, flow rate andvolume, and annulus pressure.Continuous0.0 0.0 5.7 0.0 5.7 $278 $0 371 2,115 $103,103Demonstrate mechanical integrity (i.e., casingpressure test and noise/temperature logs tocheck for movement along the borehole).Every 5 years0.0 1.0 8.0 0.0 9.0 $474 $18,878 74 668 $1,436,148Conduct pressure fall-off test. Annual0.0 8.0 16.0 0.0 24.0 $1,453 $17,726 371 8,905 $7,116,437Conduct ambient monitoring. Annual0.0 0.4 1.5 0.0 1.9 $106 $6,114 371 705 $2,308,124Reporting Requirements (Per Facility)Report on: physical, chemical, and othercharacteristics of injected fluids; injectionpressure, flow rate, and volume; andmonitoring of USDWs.Quarterly0.0 0.0 4.0 12.0 16.0 $536 $0 1,484 23,747 $795,137Report results of ambient monitoring andpressure fall-off test.Annual0.0 2.0 6.0 4.0 12.0 $574 $1,266 371 4,453 $682,759Underground Injection Control Program -- Information Collection RequestPage A-9Table A-1BAnnual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: OperatorsAB C D E FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency (A) Legal Managerial Technical ClericalUnitBurdenUnit LaborCostUnit Non-LaborCost (B)No. ofResponsesTotalHours/Year Total Cost/YearNotify Director within 24 hours of: plannedphysical changes to facility, changes that mayresult in noncompliance, compliance ornoncompliance with a compliance schedule,any indication of possible endangerment of aOccasional0.0 1.0 2.0 3.0 6.0 $267 $0 19 111 $4,951Submit periodic updates of financialresponsibility for closure that account forinflation.Occasional0.0 1.0 0.0 0.0 1.0 $84 $0 124 124 $10,409Report results of: any required mechanicalintegrity tests, other required tests, and wellworkovers.Occasional0.0 1.0 2.0 1.0 4.0 $210 $1,376 4 15 $5,884Recordkeeping Requirements (Per Facility)Maintain monitoring information, calibrationand maintenance records, required reports,application data, and monitoring results.At least 3 years0.0 0.0 0.0 4.0 4.0 $114 $0 371 1,484 $42,144Closure Requirements (Per Well)Notify the Director before conversion orabandonment of the well or, in the case ofarea permits, before closure of the project.One-time0.0 0.5 0.0 1.0 1.5 $70 $0 1 2 $70TOTAL5,319101,22222,662,812$Notes:(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-10Table A-1B (continued)Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: StatesABCDEHours and Costs per Response Total Hours and CostDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonLabor CostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearInitial/Start-upPermit applicationsConsider the permit application, AoR,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andconstruction procedures as required at146.14 and issue notice of intent to deny.One-time20.0 $828 $0 1 19 $791Consider the permit application, AoR,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andconstruction procedures as required at146.14 and prepare draft permit.One-time40.0 $1,657 $0 9 344 $14,231Provide public notice of issuance of a draftpermit or intent to deny.One-time1.0 $41 $0 10 10 $395Consider public comments. One-time6.0 $249 $0 10 57 $2,372Issue final permit decision. One-time2.0 $83 $0 10 19 $791Respond to comments. One-time7.0 $290 $0 10 67 $2,767Review notice of completion of construction. One-time2.0 $83 $0 10 19 $791Review information related to aquiferexemption requests and forward to EPAregion.One-time1.0 $41 $0 2 2 $67Permit renewals/modificationsReview and respond to requests for permitmodifications or re-issuance.Occasional30.0 $1,243 $0 14 409 $16,942Underground Injection Control Program -- Information Collection Request Page A-11Table A-1B (continued)Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: StatesABCDEHours and Costs per Response Total Hours and CostDescription of RequirementFrequency (A)Unit Burden(B)Unit LaborCostUnit NonLabor CostNumber ofStateResponsesTotal StateHours/YearTotal StateCost/YearMonitoring/TestingReview casing pressure test and logs. Every 5 years4.0 $166 $0 51 202 $8,382Review pressure fall-off test. Annual2.0 $83 $0 253 506 $20,955Review monitoring data submitted byoperators.Quarterly2.0 $83 $0 1,012 2,023 $83,819Other ReportingRespond to periodic notifications by ownersand operators.Occasional1.0 $41 $0 7 7 $282ClosureReview plugging and abandonment report. One-time1.0 $41 $0 1 1 $41TOTAL1,396 3,685 $152,627Notes:(A) For quarterly activities, the number of responses = number of facilities X 4.(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection Request Page A-12Underground Injection Control Program – Information Collection Request Page A-13 

### EPA assumes that some activities required of Class I permit applicants are customary business practices.

The burden presented in this ICR is the incremental tim e and cost of presenting the information in a format

acceptable to permitting authorities and for using EPA-approved tests.

 Knowledge of subsurface geology is necessary to site a well and locat e a subsurface zone suitable for

injection. EPA assumes that 50 perc ent of the geological characterizat ion required of permit applicants

is customary business practice. Most of the incremen tal ICR burden is attributab le to the requirement to

submit detailed maps of local geology.

 Operators would customarily develop and conduct fo rmation testing and stimulation programs for the

same reasons they would develop geological data. EPA estimates that 50 percent of the required

program development and testing is customary business practice.

 Operators would probably develop and retain conti ngency plans to reduce poten tial liability should a

well failure occur and develop closure plans to reduce potential liability wh en they close their facilities.

EPA assumes that 25 percent of the burden of deve loping these plans is cust omary business practice.

 Facility engineers would normally prepare cons truction schematics and operating data during the

planning and design of an injection f acility; EPA estimates that 75 percent of the burden associated with

compiling this data is customary business practice.

 As part of their overall industria l process, operators would normally develop injectate composition data

and test the compatibility of the waste stream with well materials. EPA assumes that 50 percent of the

time and cost of developing a waste analysis pl an and conducting waste co mpatibility testing is

customary business practice.

 During construction, operators would probably conduct de viation checks and other logs to verify that

drilling is progressing within expected parameters. EP A estimates that 50 percent of the requirement to

conduct deviation checks and other logs a nd tests is customary business practice.

 Operators would routinely observe in jection pressure, flow rate, volum e, and temperature, and analyze

the chemical composition of their wastes to verify the proper operation of thei r wells; EPA assumes that

nearly all the burden for continuous monitoring and 75 percent of th e burden of performing chemical

analyses of injectate is customary business practice.

EPA estimates that owners or operators of Class I wells that apply for an aquifer exemption will submit

geologic and water use-related inform ation to demonstrate that the cr iteria at 40 CFR 144.7 and 40 CFR 146.4

are met. EPA estimates that much of this information wi ll be gathered as part of the Class I permit application

process, and that applying for an aquifer exemption will require an additional 20 hours for each applicant.Underground Injection Control Program – Information Collection Request Page A-14 

### Class I Hazardous Facilities

Operator activities associated with Class I haza rdous facilities include: permitting and start-up-related

reporting; permit renewals and modifications of permits or petitions; monitoring; re porting and recordkeeping;

and closure-related paperwork.

Initial Permitting/Start-up

EPA estimates that, of the new Cl ass I hazardous waste facility opera ting permits that are issued each

year, most will be for new wells at existing facilities. Thus, in some cases, operators will adapt existing

materials for their permit applications. Note that fo r permitting activities, the unit burdens are expressed on a

per-application basis.

EPA estimates that the operator burden associated with applying for Class I hazardous waste injection

permits will be 224 hours per permit. (This unit burden incorporates the above assumptions about customary

business practices.) Table A-1A contains burden estim ates for specific components of the permit application.

EPA’s calculation of operator burden and contractor labor costs above customary business practices is based on

the following assumptions:

 Operators, rather than contractors, will gather the facility description and location information necessary

to complete the permit application form;

 Area of review (AoR) studies in support of the a pplication will encompass portions of previous AoR

studies at the facility;

 The burden for developing a corrective action plan is based on the assumption that 10 percent of

operators will be required by the permitting authority to revise their corr ective action plans; and

 The requirement that operators of active hazardous waste facilities gather and submit site investigation

information [40 CFR 144.31(g)(3)] duplicates Re source Conservation and Recovery Act (RCRA)

requirements and is not included in this burden estimate. Other ac tivities that operators of active

hazardous waste facilities must perform (e.g., developi ng a waste analysis plan) are included in this

estimate.

EPA estimates that the burden on Class I hazardous facility operators associ ated with preparing and

submitting completion reports will be 49 hours per facility. The burden to perf orm specific activities related to

completion reports is presented in Table A-1A. As with permitting activities, EPA anticipates that much of the

testing reported in the completion report would normally be performed in the course of business.

In addition to submitting permit applications, opera tors of newly constructed hazardous Class I wells

will submit no-migration petitions to the EPA Regional Ad ministrator. EPA assumes that no-migration petition

requirements impose an additional 174 burden hours on each operator. EPA anticipates that operators already

have compiled much of the extensive data required to support a no-migration pe tition in the process of

permitting and preparing petitions for existing wells at thei r facilities, during the permit application process, or

as a customary business practice.

Permit Renewals and Modifications

Class I operating permits are valid for up to ten year s, after which operators mu st apply to renew their

permits. Additionally, from time to time, operators of Cl ass I hazardous facilities may need to modify theirUnderground Injection Control Program – Information Collection Request Page A-15 

### permits or their no-migration petitions. Paperwork submittals include: permit renewals, permit modifications,

and petition modifications.

EPA anticipates that the burden asso ciated with renewing permits for a Class I hazardous facility will be

71.5 hours per renewal. Requirements for permit renewa ls vary among states and regions, ranging from

submitting a letter of intent to continue operating the facil ity to submitting an application that is similar in scope

to one for a new permit. EPA assumes that, for renewal applications, Class I hazardous facility operators will

be required to submit facility identification informati on and those attachments that have changed or been

updated since their last application, su ch as the AoR, corrective action pla n, closure plan, waste identification

information, and financial responsibility information. EPA assumes that Class I hazardous facility operators

will not be required to submit no-migration petitions in support of permit renewal applications.

EPA estimates the operator burden for overseeing cont ractor activities associat ed with preparing and

submitting a request for a permit modification is 10 hours pe r facility, and the burden associated with modifying

a no-migration petition is 174 hours.

Monitoring/Testing

As indicated above, EPA assumes that operators of Class I hazardous facilitie s would routinely observe

injection pressure, flow rate, volume, and temperature in the normal course of business. EPA estimates an

incremental annual burden of 5.7 hours per facility beyond customary business practice to meet UIC reporting

requirements.

Class I hazardous facility operators must also monitor the chemical com position of their wastes

according to the waste analysis plans submitted with their permit applications. As with monitoring of injection

pressure, flow rate, and volume, EPA assumes that ope rators would perform some chemical monitoring during

the course of business. EPA estimates the additiona l annual burden for chemical monitoring is 38 hours per

facility per quarter for operators to collect samples and send them to commercial laboratories for analysis. In

addition, EPA assumes that, for various reasons, permitting au thorities will require 10 percent of facilities to

conduct additional monitoring under 40 CFR 146.68(a)(3), and that the total burden will be 7.6 hours per

facility per quarter. EPA assumes that all monitoring will be conducted quarterly.

The burden associated with conducting annual MITs (i.e., conducting a casi ng pressure test and

radioactive tracer survey) is estimated to be 9 hours per facility, and the burden associated with conducting fiveyear MITs, which also include temper ature, noise, or other logs to check for movement along the borehole, is

estimated to be 8 hours per facility.

Operators must conduct casing insp ection logs when their wells are worked over. EPA estimates the

total annual burden will be 11.8 hours per log.

Class I hazardous facility operators must conduct a pressure fall-off te st every year; EPA estimates that

the annual burden associated with this requirement will be 24 hours per faci lity. EPA estimates that the total

burden associated with required annu al ambient monitoring at Class I ha zardous facilities will be 2.3 hours per

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

### Reporting and Recordkeeping

Operators of each Class I hazardous facility will spend 104 hours per facility reporting the results of

required monitoring and testing each year: this include s 25 hours per report (100 hours annually) for quarterly

monitoring reports, and 4 hours to repor t on the results of MITs. In addi tion, EPA assumes that 5 percent of

operators will spend 3 to 6 hours annually submitting vari ous occasional reports (e.g., on changes to the facility;

planned workovers; noncompliance or anticipated noncomp liance; or events triggering alarms or shutdown

devices). Operators will also spend one hour submitti ng revised plugging and abandonment cost estimates.

EPA estimates the annual recordkeeping burden for Class I hazardous facilities to be 5 hours.

Operators must maintain monitoring information, ca libration and maintenance records, required reports,

application data, and monitoring results for three years; and keep their most rece nt plugging and abandonment

cost estimate for one year.

Closure

EPA estimates that the total annual burden associat ed with closure of a Cla ss I hazardous well is 42

hours. This includes 1.5 hours to not ify the permitting authority prior to closing, 6 hour s to perform pressure

fall-off tests, 20 hours for MITs, and 10 hours for a clos ure report. EPA assumes that the operator will not

revise the closure plan or the post-closure care pl an. The operator will also spend 4.5 hours on third-party

notification activities, such as notifyi ng state or local zoning or drilling authorities and the permitting authority

following closure.

Class I Nonhazardous Facilities

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

closure-related pape rwork activities.

Initial Permitting/Start-up

As is the case for Class I hazardous facilities, EP A estimates that the majority of the new nonhazardous

waste injection permits issued each year will be for ne w wells at existing facilities. Unit burdens are reported

on a per-application basis.

Requirements associated with permit applications add 110.6 hours to the customary business activities

of Class I nonhazardous facility operators. Column A of Table A-1B presents EPA’s estimates of burdens for

specific components of a permit application. Class I nonh azardous waste injection well permit applicants must

submit much of the same information as operators of hazardous facilities. EPA assumes that the burden on

nonhazardous facilities is the same as that for Class I hazardous waste facilities, with the exception of the

following:

 Class I nonhazardous facility operators will study a sma ller AoR. Consequently, the burden for the AoR

study and for developing a corrective action plan for we lls in the AoR will be lower for these operators.

 Nonhazardous facility operators are not required to develop waste analysis plans or plans to reduce the

quantity or toxicity of their inject ate; nor are they required to gath er and submit hazardous waste release

information.

EPA estimates that the unit burden on Class I nonhazardous facility operators for preparing and

submitting completion reports is 32.5 hours. This unit burde n varies from that for Class I hazardous facilities,Underground Injection Control Program – Information Collection Request Page A-17 

### as Class I nonhazardous facility operators are not re quired to submit information on the calculated AoR.

Burden estimates for specific activities associated with completion of new wells are presented in Column A of

Table A-1B.

Permit Renewals/Modifications

As with hazardous facility operators, EPA assume s that applicants for nonhazardous injection permit

renewals will submit only those attachments to the appli cation form that have change d since the original permit

application. Preparing and submitting the updated materials needed for a pe rmit renewal appli cation will take

an estimated 21 hours. EPA estimates the operator burden associated with contractor oversight to gather the

necessary information for a permit modification to be 8 hours.

Monitoring/Testing

EPA assumes that operator staff will observe and record injection pressure, flow rate, volume, and

temperature and sample their injectat e periodically as normal business activities. However, to comply with UIC

requirements, operators spend more time on these activit ies than they otherwise w ould. Class I nonhazardous

facility operators will spend 38 hours to monitor their injectat e; 5.7 hours to monitor injection pressure, flow

rate, and volume; 1.9 hours to conduct ambient monitori ng; and 24 hours to conduct an annual pressure fall-off

test. In addition, approximately 20 pe rcent of operators will spend 9 hours to demonstrate mechanical integrity

(i.e., five-year MIT).

Reporting and Recordkeeping

Operators will spend 16 hours per facility re porting quarterly on the chemical and physical

characteristics of injectate, flow rate, and volume. Class I nonhazardous facility operators will spend 12 hours

per facility reporting on the results of ambien t monitoring and the pressure fall-off test.

EPA assumes that Class I nonhazard ous facility operators will spend one hour each year to update and

submit revised plugging and abandonment cost estimates. EPA also assumes that operators will spend 4 to 6

hours submitting additional reports (e.g., of changes to the facility, planned workovers, noncompliance or

anticipated noncompliance, or events triggering an alarm or shutdown).

EPA estimates the annual recordkeeping burden on Class I nonhazardous facilities to maintain

monitoring information, calibration and ma intenance records, required reports, application data , and monitoring

results for three years will be 4 hours per facility.

Closure

EPA estimates the annual burden on operators of Cl ass I nonhazardous facilities a ssociated with closure

is 1.5 hours, for notifying the Director.

Burden on Primacy Agencies Associated with Class I Wells

State primacy agencies’ burden associated with imp lementing Class I programs arises from program

oversight and reviewing and responding to permit applications, completion reports, monitoring and testing data,

and closure reports submitted by operators within their states . State burden associated with oversight of Class I

programs is presented in Column A of Tables A-1A and A-1B.

EPA estimates that states will spend from 20 to 58 hours per permit applicati on reviewing applications

for hazardous or nonhazardous Class I wells (depending on whether the permit is issued or denied), and 30Underground Injection Control Program – Information Collection Request Page A-18 

### hours reviewing requests for permit modi fications or renewals. EPA regiona l offices review all no-migration

petitions and petition modification requests submitted by operators of Class I hazardous waste injection

facilities; however, state primacy ag encies assist the regions with this review. States spend 28 hours per nomigration petition application and 10 hours per pe tition modification reques t on this assistance.

State primacy agencies spend from 1 to 4 hours per report reviewing mon itoring and MIT data or

occasional reports submitted by operators (details are pres ented in Tables A-1A and A-1B). States spend one

hour reviewing plugging and abandonment reports s ubmitted by operators of Class I nonhazardous waste

facilities, and 26 hours revi ewing reports and testing results associ ated with closure of hazardous waste

facilities. EPA estimates that state staff will spend 1 hour per request reviewing aquifer exemption requests for

Class I owners or operators in their state and forwarding these requests to the EPA Region for a determination.

Burden Associated with Class II Wells

EPA’s estimates of the annual paperwork burden on operators for permitting, monitoring and testing,

reporting and recordkeeping, and closing wells, and st ate burden for administering Class II programs, are

presented in Table A-2.

Class II Operators

Initial Permitting/Start-up

EPA anticipates that 28 percent of Class II permit applications will be for area permits and 73 percent

will be for individual permits. On average, each area permit application will cover 3.1 wells. EPA or state

primacy agencies will deny applications that do not meet construction standa rds, and others will be withdrawn

by owners.

The average burden for preparing permit applic ation forms and the supporting documentation is

approximately 67 hours per application. The time that a particular operator will spend on a permit application

will likely vary, depending on the specific state submission requirements, the operator’s level of experience,

whether the application is for an indi vidual or an area permit, the use of co ntractors, and other factors. The

following paragraphs summarize the burdens for various components of a Class II permit application.

EPA estimates that operators will spend 2.5 hours to read the application di rections and fill out the

permit application form. With respect to the suppor ting documentation, EPA assu mes that operators would

normally prepare a well schematic and some geological, hydrogeological, and operating data in the course of

business, and/or utilize existing data for the project. For area permits, the operato r generally submits supporting

data for a representative well. Ta ble A-2 provides estimates of the time required, beyond what is considered

customary business practice, to prepar e the attachments to a Class II perm it application. EPA estimates that

permit applicants will spend an average of:

 9.5 hours to prepare geological data on injection and confining zones;

 6 hours to prepare plugging and abandonment plans;

 2.5 hours to identify and determine depth to the bottom of USDWs;

 3 hours to prepare schematics of the wells;

 2 hours to prepare propo sed operating data; and

 20 hours to prepare financial responsibility information.Table A-2Annual Paperwork Burden and Costs Associated with Class II Wells: OperatorsABCDE FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo. ofResponsesTotalHours/Year Total Cost/YearInitial/Start-up RequirementsRequirements associated with permit applications (Per Permit Application)Read permit application directions. One-time0.0 0.0 0.5 0.5 1.0 $39 $0 8,983 8,983 $346,479Gather and submit: description of activitiesrequiring a permit, facility name & address,SIC codes, ownership and facility status,facility location, listing of relevant permits orconstruction approvals, topographic maps,description of the business.One-time0.1 0.0 1.0 0.4 1.5 $69 $0 8,983 13,474 $621,844For DI programs, gather and submit a list ofall land owners within one quarter mile of thefacility boundary.One-time0.2 0.0 0.0 1.0 1.2 $47 $193 351 421 $83,883Prepare and submit plugging andabandonment plan.One-time0.0 0.6 4.8 0.6 6.0 $302 $0 8,983 53,897 $2,708,506Show evidence of financial responsibility forclosure.One-time0.0 5.0 5.0 10.0 20.0 $948 $0 8,983 179,655 $8,519,807Prepare and submit proposed CorrectiveAction Plan.One-time0.0 0.3 2.9 0.2 3.4 $172 $0 898 3,054 $154,770Prepare and submit revised Corrective ActionPlan.One-time0.0 1.0 9.6 0.7 11.3 $572 $0 180 2,030 $102,766Prepare and submit Area of Review map.(State/DI Program performs study)One-time0.0 0.0 1.0 0.0 1.0 $49 $38 1,997 1,997 $173,665Prepare and submit Area of Review map andstudy.One-time0.0 0.1 2.9 2.0 5.0 $206 $208 1,694 8,512 $702,802Prepare and submit proposed operating data. One-time0.0 0.1 1.8 0.1 2.0 $99 $0 8,983 17,966 $889,314Prepare and submit geological data on theinjection and confining zone.One-time0.0 0.5 8.0 1.0 9.5 $460 $0 8,983 85,336 $4,136,207Prepare and submit name and depth tobottom of USDWs.One-time0.0 0.1 2.3 0.1 2.5 $123 $229 8,983 22,457 $3,167,918Prepare and submit schematic of the well. One-time0.0 0.0 2.8 0.2 3.0 $142 $0 8,983 26,948 $1,277,123Prepare and submit information to support anaquifer exemption request.One-time0.0 2.5 17.0 0.5 20.0 $1,053 $0 269 5,390 $283,849For operators in DI states performing HFusing diesel fuels, prepare and submitinformation recommended in DFHF Guidance(e.g., planned fracture extent, geologicinformation, AoR, construction information).One-time0.5 9.5 50.0 20.0 80.0 $3,850 $764 30 2,400 $138,441Underground Injection Control Program -- Information Collection RequestPage A-19Table A-2Annual Paperwork Burden and Costs Associated with Class II Wells: OperatorsABCDE FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo. ofResponsesTotalHours/Year Total Cost/YearRequirements associated with completion reports (Per Well)Prepare and submit completion report. One-time0.0 0.0 1.5 2.5 4.0 $144 $0 8,585 34,340 $1,237,181Perform and report on appropriate logs andother tests during construction.One-time0.0 0.2 1.9 0.2 2.4 $121 $4,586 1,318 3,163 $6,201,871Demonstrate mechanical integrity. One-time0.0 0.0 7.0 0.0 7.0 $341 $206 8,585 60,095 $4,701,158Requirements associated with permit reviews/modifications (Per Permit/Per Operator)Respond to issues raised during permitreview.Every 5 years0.0 0.5 2.0 0.5 3.0 $154 $0 1,765 5,295 $271,432Prepare and submit request for permitmodification.Occasional0.0 0.4 2.8 0.8 4.0 $193 $0 2,648 10,591 $510,680Monitoring/Testing Requirements (Per Operator)Monitor the nature of injected fluids. As necessarytoobtain0.0 0.0 2.0 0.0 2.0 $97 $46 70,606 141,213 $10,121,799Record injection pressure, flow rate, andcumulative volume.At least every30 days.0.0 0.0 0.6 0.3 0.8 $35 $0 212,179 178,231 $7,479,262Demonstrate mechanical integrity. Every 5 years0.0 0.0 3.0 0.0 3.0 $146 $2,064 47,659 142,978 $105,320,229Reporting Requirements (Per Operator)In DI programs, gather and submitgroundwater monitoring data, analyses ofinjected fluids, a description of geologicstrata, and other items as requested.Occasional0.0 3.0 22.0 5.0 30.0 $1,467 $0 33 991 $48,479In DI programs, notify Regional Administrator30 days prior to MIT.Every 5 years0.0 0.0 0.5 0.5 1.0 $39 $0 79 79 $3,053Notify Director of (1) any planned physicalchanges to facility; (2) changes that mayresult in noncompliance, (3) permit transfers,(4) compliance or noncompliance withcompliance schedules, (5) possibleendangerment to a USDW.Occasional0.0 1.0 1.5 2.5 5.0 $228 $0 1,059 5,295 $241,754Report monitoring data, including monthlyrecords of injected fluids, any changes incharacteristics or sources of injected fluids.Annual0.0 0.0 3.3 1.7 5.0 $210 $0 17,682 88,408 $3,708,752Report MIT results. Annual0.0 0.0 1.0 0.0 1.0 $49 $0 17,682 17,682 $861,954Underground Injection Control Program -- Information Collection RequestPage A-20Table A-2Annual Paperwork Burden and Costs Associated with Class II Wells: OperatorsABCDE FHours and Costsper ResponseTotal Hours and CostsDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo. ofResponsesTotalHours/Year Total Cost/YearRecordkeeping Requirements (Per Operator)Retain records of permitting data, nature andcomposition of injected fluids, and allmonitoring results.At least 3years0.0 0.0 1.0 3.0 4.0 $134 $0 17,652 70,606 $2,364,125Closure Requirements (Per Operator)In DI programs, notify director of revisions toplugging and abandonment plan.One-time0.0 0.5 2.5 1.0 4.0 $192 $0 0 2 $78Notify the Director before conversion orabandonment of the well, or in the case ofarea permits, before closure of the project.One-time0.0 1.0 0.0 2.0 3.0 $141 $0 1,044 3,132 $147,146In DI programs, submit a plugging andabandonment report within 60 days afterplugging a well.One-time0.0 0.0 4.5 1.5 6.0 $262 $275 41 245 $21,888Other Requirements (Per Operator)In DI programs, submit reviseddemonstration of financial responsibility.Occasional0.0 0.5 0.5 1.0 2.0 $95 $0 69 138 $6,535TOTALS485,967 1,195,002 166,554,749$Note: Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-21Table A-2 (continued)Annual Paperwork Burden and Costs Associated with Class II Wells: StatesABCD E FHours and Costs per Response Total Hours and CostDescription of Requirement Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearInitial/Start-upPermit applications (Per Permit Application)Review permit application and supportingdocumentation and prepare draft permit.One-time6.0 $249 $0 8,632 51,793 $2,145,463Consider public comments. One-time2.0 $83 $0 8,632 17,264 $715,154Issue final permit decision. One-time2.0 $83 $0 8,632 17,264 $715,154Respond to comments. One-time4.0 $166 $0 8,632 34,528 $1,430,308Review operator's AoR map and study. One-time5.0 $207 $0 1,628 8,139 $337,159Review operator's AoR map and performAoR study.One-time2.5 $104 $0 1,997 4,992 $206,807Review completion report. One-time2.0 $83 $0 8,250 16,500 $683,488Review information related to aquiferexemption requests and forward to EPAregion.One-time1.0 $41 $0 247 247 $10,252Permit reviews/modifications (Per Operator)Review each permit to determine whether itshould be modified, revoked and reissued, orterminated.Every 5 years1.0 $41 $0 1,696 1,696 $70,266Review request for permit modification or reissuance.Occasional4.0 $166 $0 2,544 10,178 $421,595Monitoring/Testing (Per Operator)Review mechanical integrity test datasubmitted by operators.Every 5 years0.5 $21 $0 45,799 22,900 $948,589Review monitoring data submitted byoperators.Annual0.3 $10 $0 16,963 4,241 $175,665RecordkeepingMaintain administrative record in DIprograms.One-time1.0 $41 $0 0 0 $0Underground Injection Control Program - Information Collection Request Page A-22Table A-2 (continued)Annual Paperwork Burden and Costs Associated with Class II Wells: StatesABCD E FHours and Costs per Response Total Hours and CostDescription of Requirement Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearOther Reporting (Per Operator)Respond to periodic notifications by ownersand operators.Occasional2.0 $83 $0 1,018 2,036 $84,319Closure (Per Operator)For DI programs, review plugging andabandonment report.One-time1.0 $41 $0 0 0 $0TOTAL114,710 191,778 $7,944,220Note: Numbers may not add due to roundingUnderground Injection Control Program - Information Collection Request Page A-23Underground Injection Control Program – Information Collection Request Page A-24 

### Based on previous studies of state AoR practices and requirements, EPA proj ects that state primacy

agencies and EPA Regions will determine that a complete AoR is not necessary for approximately 60 percent of

Class II permit applicants. A complete AoR study may not be performed because:

 The AoR is entirely overlapped by the AoRs of wells previously studied;

 A State primacy agency has cross-refere nced AoR studies, ensuring AoR coverage;

 The operator has been granted a state variance based on factors relating to geol ogic setting and/or well

conditions; or

 The well is located in a unitized project, and many of the elements of AoR studies were previously

performed during unitization.

Previous EPA studies also have shown that many stat e primacy agencies perform all or most of the tasks

involved in the AoR study. In these ca ses, the operator typically submits only a map of the AoR and a list of

wells in the AoR. EPA projects that approximately 19 percent of applicants will submit an AoR map and an

AoR study as part of the permit application. Each Ao R map and study will require an average of 5 hours of

operator time. 2 

### Another 22 percent of applicants will submit an AoR map and a listing of the wells in the AoR,

and the state primacy agency will perform most or all of the tasks involved in the AoR study. The operator time

needed to prepare the map and listin g of wells is about one hour.

Based on the historical incidence of corrective action, EPA assumes that operators will incur different

burdens to prepare a corrective action plan. EPA estimates that 90 percent of permit applicants will submit brief

corrective action plans demonstrating that corrective acti on is not necessary to address potential conduits to

USDWs in the AoR; these plans will require one hour to prepare. The remaining 10 percent of applicants will

submit more complex corrective action plans to address specific problems identified by the AoR study, which

will take approximately 25 hours to prepare. Thus, th e weighted average time to prepare a corrective action

plan is 3.4 hours. EPA regional or state primacy staff will require 20 percent of a pplicants to revise their

complex corrective action plans. Each revise d plan will take about 11.3 hours to prepare.

Unless exempted by the Director, operators in DI programs are requi red to submit a list of landowners

within 1⁄4 mile of the facility boundary. EPA estimates th at these applicants will each take 1.2 hours to research

property ownership records and prepare the list. This un it burden assumes that operators will supply about 30

percent of the effort, and the remaining 70 percent will be performed by contractors.

Prior to obtaining approval to begin injection, op erators must submit comple tion reports for each new

Class II well. With the completion report, operators mu st submit results of MITs and any well logs and tests

required by the Director. Operators will take approximately 2.4 hours to pe rform and report on logs and tests

and 4 hours per well to fill out the co mpletion form. The MIT will requir e an additional 7 hours of operator

time, given current MIT practices for various completion types.

Most operators will submit logs for offset wells in their projects. EPA projects that Directors will

require some permit applicants to perform and repor t on new well logs and test s, such as cement bond,

temperature, or density logs. Directors are more likely to require additional logs and tests for II-D (disposal)

wells than for II-R (recovery) wells. EPA assumes that operators will perform additional logs and tests for 50

percent of new II-D wells and 5 percent of new II-R wells. Each of the logs and tests will take approximately

2.4 hours of operator time, primarily to supervise contractors.

2 EPA estimates that some operators will utilize contract AoR serv ices. The unit burden for operators assumes that operators wi ll

perform about 67 percent of the AoR burden themselves and contract out for the remaining 33 percent.Underground Injection Control Program – Information Collection Request Page A-25 

### EPA estimates that owners or operators of Class II wells that apply for an aquifer exemption will submit

geologic and water use-related inform ation to demonstrate that the cr iteria at 40 CFR 144.7 and 40 CFR 146.4

are met. EPA estimates that much of this information will be gathered as part of th e Class II permit application

process, and that applying for an aquifer exemption will require an additional 20 hours for each applicant.

Additionally, operators of production wells in DI states performing hydraulic fracturing (HF) using

diesel fuels (DF) that are issued permits as recomme nded in the DFHF Guidance will submit the same types of

information required of Class II well owners or operat ors, along with additional information to afford an

evaluation of the proposed HF operation, such as information about the form ation(s) to be fractured and the

extent and orientation of the plan ned fracture network, seis mic history, and baseline geochemical data. The

guidance also recommends that owners or operators iden tify a site-specific AoR; demonstrate that the well is

constructed appropriately; perform a pr e-HF MIT; and demonstrate financia l responsibility. EPA estimates that

each of these operators will incur 80 hours to apply for a UIC permit and provide this information to the EPA

DI Program.

Following permitting, owners or operators of wells following the DFHF Guidance recommendations

will monitor injection pressure, flow rate and cumula tive volume during HF operations, perform an MIT if

needed, monitor ground water quality if directed, and pe rform the same reporting and recordkeeping activities

as other Class II owners or operators, as described below.

Permit Reviews/Modifications

Class II permits are valid “up to the operating life of the facility” [40 CFR 144.36]. While the

regulations do not require permit renewals, most permits ar e reviewed every five years. These reviews may be

formal compliance reviews or informal reviews, usually conducted in conjunction with reviews of MIT results.

Operators may be required to respond to any issues rais ed during the permit review. For purposes of calculating

operator burden, EPA assumes that each operator will take 3 hours to respond to issues raised during the review.

Operators occasionally submit requests for permit modifications in response to changes in well

ownership or injection practices, to a dd wells to existing area permits, and for other reasons. EPA expects that

preparing each request will ta ke an average of 4 hours.

Monitoring/Testing

For purposes of estimating the number of respondent s for monitoring and testing, EPA assumes that the

typical Class II operator has approximately 10 wells. An ope rator with wells in multiple states is treated as a

separate operator in ea ch state, since the operator w ould have to submit separate reports to each state primacy

agency or EPA regional office.

In general, all operators located in DI programs and operators of commercial II-D wells in primacy

states are required to submit annual injectate analyses. EPA estimates that approximately 40 percent of Class II

operators submit annual inje ctate analyses each year. EPA assumes that operators submit samples for

approximately 20 percent of their wells. Each operator takes 2 hours (1 hour per well) per year to sample and

analyze its injectate. This includes the time it takes for operators to analy ze their injectate or, in some cases,

send it to a commercial laboratory for analysis.

Most operators are required to obs erve injection pressure, flow rate , and cumulative volume weekly for

II-D wells and monthly for II-R wells. EPA anticipates that operators, especially operators of II-R wells,

perform periodic observations of pressu re, flow rate, and cumulative volume as a customary business practice.

Thus, the incremental time needed to perform these observations is about 0.84 hour s per operator (0.08 hours,

or 5 minutes, per well) per month. This represents th e time required to record the data on a field report.Underground Injection Control Program – Information Collection Request Page A-26 

### Based on information reported on the UIC reporting fo rms, EPA assumes that 27 percent of operators

will perform MITs on their wells each year. Each ope rator will spend 3.0 hours (0.3 hours per well) performing

MITs. The unit burden assumes that contractors perform many of the tasks involved in an MIT.

Reporting and Recordkeeping

Each year, Class II operators sp end about 5 hours to prepare annual monitoring reports. These reports

include summaries of monthly or week ly observations of flow, pressure, and cumulative volume. In addition,

27 percent of operators will spend 1 hour per op erator to prepare reports on MITs performed.

From time to time, operators submit other reports or notify UIC staff of various events. These include

notifications of planned changes to the injection facility, permit transfers, progress in achieving compliance

milestones, and noncompliance or malfunctions which may endanger a USDW. EPA estimates that

approximately 6 percent of operators submit one of these occasional reports each year. Operators will spend an

average of 5 hours to prepare each report.

Operators of rule-authorized we lls in DI states may be require d to gather and submit groundwater

monitoring data, analyses of injected fluids, a description of geologic strata , and other items as requested. EPA

projects that each request will take 30 hours to prepare. In addition, oper ators of rule-authorized wells will

spend one hour per operator to notify the Region prior to performing MITs.

Each operator will spend about 4 hours annually to maintain records on permitting, monitoring, and

testing.

Closure

Each operator that closes a well will spend about 3.0 hours (0.3 hours per well) to notify UIC officials

prior to abandoning the wells.

In addition, EPA assumes that op erators in DI programs who elect to plug their wells in a manner

different from the one specified in their plugging and abandonment plans will spend 4 hours to prepare revised

plugging and abandonment plans. In addition, operators who plug wells in DI programs will spend 6 hours to

prepare and submit plugging and abandonment reports.

Other Activities

DI programs may require some operators of wells with lifetime permits to submit revised financial

responsibility demonstrations. EPA estimates that 10 pe rcent of operators in DI programs will each take 2

hours to prepare and submit revised financial data.

Burden on Primacy Agencies Associated with Class II Wells

Class II primacy agencies review and respond to pe rmit applications and permit reviews/modifications,

as well as monitoring and testing data submitted by operators within their states. State burden associated with

each activity involved in the oversig ht of Class II programs is presen ted in Column A of Table A-2.

EPA estimates that states will spend 23.5 hours per a pplication reviewing Class II injection well permit

applications. Primacy agency staff spend one hour to de termine whether to reissue, modify, or revoke each

permit during the five-year review process. Primacy agencies spend four hours reviewing each request for a

permit modification or renewal. EPA estimates that stat e staff will spend 1 hour per request reviewing aquiferUnderground Injection Control Program – Information Collection Request Page A-27 

### exemption requests for Class II owners or operators in their state and forwarding these requests to the EPA

Region for a determination.

State primacy agencies spend from 0.3 to 0.5 hour s per report reviewing mon itoring and MIT data or

occasional reports submitted by Class II ope rators (see details in Table A-2).

Burden Associated with Class III Wells

Table A-3 presents EPA’s estimate of the annual paperwork burden on operators for permitting,

monitoring and testing, reporting and r ecordkeeping, and closing their facili ties, as well as state burden for

administering Class III programs.

Class III Operators

Initial Permitting/Start-up

A Class III operator will spend an average of 132 hours to prepare a new permit application form and

the required attachments. Reading th e directions and filling out the applic ation form account for 11 hours of the

total. Table A-3 provides estimates of the operator time, incremental to that considered customary business

practice, required to prepare each component of the permit application. EPA estimates that permit applicants

will spend an average of:

 32 hours to prepare AoR maps and studies;

 22 hours to prepare maps and cross sections of USDWs within the AoR, and of local and regional

geology;

 16 hours to prepare monitoring plans;

 14 hours to prepare proposed corrective action plans;

 9 hours to prepare proposed operating data, formation testing and stim ulation programs, and injection

procedures;

 8 hours to prepare plugging and abandonment plans;

 5 hours to prepare schematics of the wells; and

 3.5 hours to demonstrate fi nancial responsibility.

In addition, EPA estimates that, when requested by th e Director, revised corrective action plans will take

10 hours each. Applicants in DI programs will spend 1.2 hour s each to gather a list of landowners adjacent to

the facility.Underground Injection Control Program – Information Collection Request Page A-28 

### Operators completing wells must perform a two-pa rt MIT and submit a completion form. The burden

associated with preparing completion reports is difficult to determine. Operators of Class III facilities,

especially uranium mining facilities, typically develop their projects in multiple phases under the same area

permit. Based on conversations with operators and states , EPA estimates that operators of Class III wells will

spend an average of 4 hours to prep are a completion report, 10 hours to de monstrate mechanical integrity, and

2.4 hours to perform and submit the results of required logs and tests during construction.

EPA estimates that owners or operators of Class III wells that apply for an aquifer exemption will

submit geologic and water use-related information to dem onstrate that the criteria at 40 CFR 144.7 and 40 CFR

146.4 are met. EPA estimates that much of this inform ation will be gathered as part of the Class III permit

application process, and that applying for an aqui fer exemption will require an additional 20 hours for each

applicant.

Permit Renewals, Reviews, and Modifications

EPA estimates that, each year, 20 percent of Class III op erators will have a formal or informal review of

their permits. Each operator will take 4 hours to respond to any issues raised duri ng the review. In addition,

Class III operators will take an average of 28 hours to prepare re quests for permit modifications.

Monitoring/Testing

EPA anticipates that operators of salt solution mi ning facilities will submit annual analyses of their

injectate. On average, each operato r will take 8 hours per year to sample and analyze its injectate in-house.

Operators of Class III facilities wi ll monitor injection pre ssure, flow rate, or volume of injected fluids

semi-monthly, or meter injected and produced fluid volumes continuously. EPA expects that operators perform

this activity periodically as a customary business practice to ensure the efficient operation of their facilities, and

that the incremental collection burd en is approximately 4.6 hours per opera tor to complete the field reports.

EPA estimates that operators of salt solution mining facilities will perform two-part MITs on all of their

wells each year. 3 

### The burden is estimated to be 161 hours per operator.

All uranium facility operators monitor water qualit y at selected monitoring wells completed in the

injection zone and overlying freshwat er aquifers. Some active faciliti es monitor semi-monthly, while other

facilities that are performing aquife r restoration monitor monthly. EPA estimates that the typical uranium

facility has about 110 monitoring wells. As with pre ssure, flow, and volume monito ring, operators will perform

about two-thirds of this monitoring as a customary business practice to identify potential excursions from the

injection zone. EPA assumes that UIC requirements incr ease the monitoring burden to these operators by about

30.5 hours per monitoring period.

3 Some operators may be allowed to submit cementing records in lieu of performing temperature or noise logs.ABCDE FDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo ofResponsesTotalHours/Year Total Cost/YearInitial/Start-up RequirementsRequirements associated with permit applications (Per Permit Application)Read permit application directions. One-time0.0 0.0 0.5 0.5 1.0 $39 $0 32 32 $1,234Gather and submit the following information: (1) a descriptionof activities requiring a permit, (2) facility name and address,(3) SIC codes, (4) ownership and facility status, (5) facilitylocation, (6) listing of relevant permits or construction approOne-time0.52.0 4.7 2.8 10.0 $523 $0 32 320 $16,721For DI programs, gather and submit a list of all land ownerswithin one quarter mile of the facility boundary.One-time0.20.0 0.0 1.0 1.2 $47 $193 23 27 $5,429Prepare and submit plugging and abandonment plan. One-time0.00.0 6.4 1.6 8.0 $357 $0 32 256 $11,438Show evidence of financial responsibility for closure. One-time0.00.5 1.0 2.0 3.5 $148 $0 32 112 $4,724Prepare and submit proposed Corrective Action Plan. One-time0.02.0 10.0 2.0 14.0 $713 $0 32 448 $22,803Prepare and submit revised Corrective Action Plan. One-time0.01.0 8.0 1.0 10.0 $503 $0 6 64 $3,216Prepare and submit AoR map and study. One-time0.03.2 25.5 3.4 32.0 $1,606 $1,139 32 1,024 $87,820Prepare and submit maps and cross-sections of USDWs withinAoR, local geology, and regional geology.One-time0.00.0 18.0 4.0 22.0 $991 $229 32 704 $39,051Prepare and submit proposed operating data, formation testingprogram, stimulation program, and injection procedure.One-time0.02.0 6.0 1.0 9.0 $489 $0 32 288 $15,654Prepare and submit schematic of the well. One-time0.00.0 4.2 0.8 5.0 $227 $0 32 160 $7,279Prepare and submit monitoring plan. One-time0.00.0 12.0 4.0 16.0 $699 $0 32 512 $22,354Requirements associated with completion reports (Per Well)Prepare and submit completion form and supportingdocumentation (7520-9).One-time0.00.0 1.5 2.5 4.0 $144 $0 21 84 $3,026Prepare and submit appropriate logs and tests duringconstruction.One-time0.00.2 1.9 0.2 2.4 $121 $5,246 1 3 $5,810Demonstrate mechanical integrity. One-time0.01.0 8.0 1.0 10.0 $503 $4,586 21 210 $106,855Prepare and submit information to support an aquiferexemption request.One-time0.02.5 17.0 0.5 20.0 $1,053 $0 0.2 4 $221Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)Respond to issues raised during permit review. Every 5 years0.03.0 1.0 0.0 4.0 $301 $0 34 137 $10,301Prepare and submit request for permit modification. Occasional0.02.0 22.0 4.0 28.0 $1,354 $0 24 672 $32,505Monitoring/Testing Requirements (Per Facility)Monitor the nature of injected fluids. As necessaryto obtainrepresentative0.00.0 6.0 2.0 8.0 $349 $0 47 375 $16,389Monitor injection pressure and flow rate or volume of injectedfluids, or meter and record injected and produced fluidvolumes.Semi-monthly/Continuous0.00.0 3.3 1.3 4.6 $199 $0 4,446 20,607 $884,720Demonstrate mechanical integrity. Every 5 years0.016.1 128.7 16.1 160.9 $8,084 $73,771 9 1,510 $768,167Monitor the fluid level in the injection zone where appropriateand monitor parameters chosen to measure water quality in themonitoring wells.Semi-monthly/monthly0.00.0 27.5 3.0 30.5 $1,426 $0 271 8,272 $386,678Annual Paperwork Burden and Costs Associated with Class III Wells: OperatorsTable A-3Total Hours and CostsHours and Costs per ResponseUnderground Injection Control Program -- Information Collection RequestPage A-29ABCDE FDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit NonLabor CostNo ofResponsesTotalHours/Year Total Cost/YearAnnual Paperwork Burden and Costs Associated with Class III Wells: OperatorsTable A-3Total Hours and CostsHours and Costs per ResponseReporting Requirements (Per Facility)Notify Director of (1) planned physical changes to the facility,(2) anticipated noncompliance, (3) permit transfers, (4)progress in meeting compliance schedule in permit, (5)possible endangerment to a USDW.Occasional0.01.0 3.0 2.0 6.0 $287 $0 17 103 $4,911Report to the Director on required monitoring, mechanicalintegrity tests, and other required tests.Quarterly0.01.0 10.0 19.0 30.0 $1,111 $0 684 20,520 $760,020Recordkeeping Requirements (Per Facility)Retain records of permitting data, calibration and maintenancedata, and monitoring results.At least 3years0.00.0 0.4 3.0 3.4 $105 $0 171 581 $17,901Closure Requirements (Per Facility)Notify the Director before conversion or abandonment of thewell or in the case of area permits before closure of the project.One-time0.01.0 0.5 0.5 2.0 $123 $0 2 4 $245In DI programs, submit a plugging and abandonment reportwithin 60 days after plugging a well or at the time of the nextquarterly report.One-time0.00.0 0.8 0.3 1.0 $44 $0 1 1 $42Other Requirements (Per Facility)In DI programs, submit revised demonstration of financialresponsibility.Occasional0.00.5 0.5 1.0 2.0 $95 $0 77 155 $7,328TOTALS6,17657,184 3,242,842$Note: Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-30Table A-3 (continued)Annual Paperwork Burden and Costs Associated with Class III Wells: StatesABCDE FHours and Costs per Response Total Hours and CostProgram Oversight Activities Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearInitial/Start-upPermit applications (Per Permit Application)Consider the permit application, area of review,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andt ti d d i ti fOne-time20.0 $828 $0 13 260 $10,770Consider the permit application, area of review,relevant maps and cross sections, fluidinjection rate and volume, proposedcontingency plans, monitoring plans, andt ti d d d ftOne-time40.0 $1,657 $0 18 720 $29,825Provide public notice of issuance of a draftpermit or intent to deny.One-time2.0 $83 $0 48 96 $3,977Consider public comments. One-time8.0 $331 $0 48 384 $15,907Issue final permit decision. One-time10.0 $414 $0 48 480 $19,884Respond to comments. One-time15.0 $621 $0 48 720 $29,825Review completion report. One-time2.0 $83 $0 21 42 $1,740Review information related to aquifer exemptionrequests and forward to EPA region.One-time1.0 $41 $0 0.2 0.2 $9Underground Injection Control Program -- Information Collection RequestPage A-31Table A-3 (continued)Annual Paperwork Burden and Costs Associated with Class III Wells: StatesABCDE FHours and Costs per Response Total Hours and CostProgram Oversight Activities Frequency Unit BurdenUnit LaborCostUnit NonLabor CostNumber ofResponsesTotalHours/YearTotalCost/YearPermit reviews/modifications (Per Facility)Review each permit to determine whether itshould be modified, revoked and reissued, orterminated.Every 5 years4.0 $166 $0 18 71 $2,931Review request for permit modification or reissuance.Occasional20.0 $828 $0 23 460 $19,055Monitoring/Testing (Per Facility)Review mechanical integrity test data submittedby operators.Every 5 years0.5 $21 $0 18 9 $366Review monitoring data submitted by operators. Quarterly0.25 $10 $0 354 88 $3,663Other Reporting (Per Facility)Respond to periodic notifications by ownersand operators.Occasional4.0 $166 $0 18 72 $2,983Recordkeeping (Per Facility)Maintain administrative record (DI). One-time4.0 $166 $0 0 0 $0Closure (Per Facility)Review plugging and abandonment report (DIonly).One-time4.0 $166 $0 0 0 $0TOTAL674 3,402140,934$Note: Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-32Underground Injection Control Program – Information Collection Request Page A-33 

### Reporting and Recordkeeping

Operators of Class III facilities will incur a bur den of 30 hours per facility per quarter for quarterly

reporting on monitoring and any MITs performed. About 10 percent of operators will spend 6 hours per year on

occasional reporting activities. EPA estimates that each Class III operator spends approximately 3.4 hours on

recordkeeping annually.

Closure

EPA estimates that Class III operators who close their projects will take 2 hours to prepare written

notifications to the Director. Operators in DI programs will spend one hour to submit a plugging and

abandonment report.

Burden on Primacy Agencies Associated with Class III Wells

For the Class III Program, primacy agency staff review and respond to permit applications, permit

reviews/modifications, and monitoring and testing data submitted by operators. State burden associated with

each activity involved in the oversig ht of Class III programs is pres ented in Column A of Table A-3.

Depending on whether the permit is issued or denie d, EPA estimates that states will spend between 20

and 77 hours reviewing each Class III pe rmit application. Primacy agency staff will spend 4 hours determining

whether to reissue, modify, or revoke each permit duri ng the five-year review pro cess, and 20 hours reviewing

each request for a permit modification or re-issuance. Class III primacy agencies spend from 0.25 to 4 hours

per report reviewing monitoring and MIT data or occasio nal reports submitted by operators (see details in Table

A-3). EPA estimates that state staff will spend 1 hour per request reviewing aquifer exemption requests for

Class III owners or operators in their state and forwardi ng these requests to the EPA Region for a determination.

Burden Associated with Class IV and Endangering Class V Wells

Paperwork burden on operators of Class IV/endange ring Class V wells and on states for administering

these wells is presented Table A-4.

Class IV and Endangering Class V Well Operators

Class IV wells and Class V wells that are found to be endangering USDWs are banned from injection,

and owners of these wells are require d to close them and submit plugging and abandonment reports to states or

DI programs. The exception to the ban is for those Cl ass IV wells used to inject contaminated ground water

that has been treated and re-injected into the same formation from which it was drawn. These wells are

authorized by rule for the life of th e well if such subsurface emplacement of fluid is approved by EPA or a State

pursuant to the provisions for the cleanup of releases under the Compre hensive Environmental Response,

Compensation, and Liability Act of 1980 or RCRA. EPA estimat es that the operator burde n associated with this

one-time requirement to submit a plugging and abandonmen t report will be 10 hours per well (See Table A-4).

Because these wells are banned, there are no permitting or monitoring requirements.

Burden on Primacy Agencies Associated with Class IV and Endangering Class V Wells

State burden associated with Class IV and e ndangering Class V wells involves review by primacy

agency staff of closure plans submitted by operators. EP A estimates the state burden to be one hour per review.Underground Injection Control Program – Information Collection Request Page A-34 

### Burden Associated with Class V Wells

EPA’s estimate of the annual paperw ork burden on operators and states associated with Class V wells is

presented in Column A of Table A-5.

Class V Operators

Activities for Class V well operators include submitting inventory information and permitting and/or

closure of motor vehicle waste disposal we lls (MVWDWs) and large-capacity cesspools.

Inventory Activities

Recent efforts by the Regions and state primacy agen cies to address the potential threats to USDWs

posed by Class V wells will likely increase compliance with the inventory requirement. Each Class V well

operator will take 0.5 hours to prepare and submit invent ory information to the appr opriate Regional or state

primacy agency.

Activities Required Under the Class V Rule

Under the Class V Rule, facilities that wish to co ntinue operating motor vehicle waste disposal wells

must seek waivers from the ban on existing motor vehicl e waste disposal wells and apply for permits. As a

condition of the permit, facilities must submit all monitoring reports to the UIC Director. Owners of

MVWDWs and large-capacity cesspools that close are required to submit pr e-closure notifications.

Note: While the Class V Rule required that all clos ure or permitting activitie s be completed by January

2007 (the latest date by which operators with state-granted extensions woul d be required to have closed or

applied for a permit), EPA assumes that existing wells wi ll continue to be located and permitted or closed.

Thus, some permitting/closure burden is included in this ICR.

Operators of Large-Capacity Cesspools

Operators of facilities with large-capacity cesspoo ls will need to become familiar with the Class V

requirements and prepare and submit a pre-closure notific ation to their primacy agencies. EPA assumes that

each facility will require a total of 4.5 hours to comp lete these activities.

Operators of Motor Vehicle Waste Disposal Wells

All operators of facilities with MVWDWs must read the regulations and contact their primacy agencies

to determine if their wells are located in a source wa ter protection area (SWPA) or other sensitive ground water

area. These activities will re quire 4 hours. If a well is located within one of these areas, the owner/operator will

either close the well or seek a waiver and apply for a permit.

 If they choose to close their wells, owners of MV WDWs must notify the UIC Pr ogram Director at least

30 days prior to well closure, sample their inject ate, and submit a pre-closure notification form (Form

7520-17 or a state equivalent). These opera tors would incur a burden of 3 hours.Table A-4Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: OperatorsAB C DEFTotal Hours and CostsDescription of Requirement Questions Frequency Managerial Technical Clerical Unit BurdenUnit LaborCostUnit Nonlabor CostNo. ofResponsesTotalHours/YearTotalCost/YearClosure Requirements (Per Well)Submit a plugging and abandonment reportwithin 60 days after plugging a well.One-time0 7.5 2.5 10.0 $238 $0 990 9,900 $235,165TOTAL990 9,900 $235,165Note:Numbers may not add due to rounding.Underground Injection Control Program - Information Collection RequestPage A-35Table A-4 (continued)Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: StatesABCDEFHours and Costs per Response Total Hours and CostDescription of RequirementFrequencyUnit Burden(A)Unit LaborCostUnitNonlaborCostNumber ofResponsesTotalHours/YearTotalCost/YearClosureReview closure plan.One-time 1.0 $41 $0 758 758 $31,399TOTAL758 758 $31,399Note:Numbers may not add due to rounding.Underground Injection Control Program - Information Collection Request Page A-36Table A-5Annual Paperwork Burden and Costs Associated with Class V Wells: OperatorsAB C D E FHours and Costs per ResponseDescription of Requirement Frequency Legal Managerial Technical Clerical Unit BurdenUnit LaborCostUnit Non-laborCost (A)No. ofResponsesTotalHours/YearTotalCost/YearInventory RequirementsIn DI programs, submit inventory information prior tocommencing injection.One-time0.0 0.0 0.0 0.5 0.5 $10 $0 24,860 12,430 $237,462Class V Rule Requirements for Owners/Operators of Large-Capacity CesspoolsRead regulations. One-time0.0 0.0 3.0 0.0 3.0 $76 $0 7 20 $506Prepare and submit pre-closure notification (Form7520-17).One-time0.0 0.5 0.8 0.3 1.5 $54 $0 7 10 $357Class V Rule - Startup Requirements for Owners / Operators of Motor Vehicle Waste Disposal WellsContact state or local agency to determinerequirements.One-time0.0 0.0 1.0 0.0 1.0 $25 $0 33 33 $843Read regulations. One-time0.0 0.0 3.0 0.0 3.0 $76 $0 33 100 $2,530For wells that will close, sample injectate andmaintain record.One-time0.0 0.0 1.0 0.5 1.5 $35 $706 32 48 $23,467Prepare and submit pre-closure notification (Form7520-17).One-time0.0 0.5 0.8 0.3 1.5 $54 $0 32 48 $1,695For wells obtaining a waiver, conduct initial sampling.One-time0.0 0.0 1.0 0.5 1.5 $35 $706 2 3 $1,235For wells obtaining a waiver, prepare and submitpermit application.One-time0.0 8.0 25.0 21.0 54.0 $1,510 $0 2 90 $2,517Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal WellsConduct quarterly injectate sampling. Quarterly0.0 0.0 1.0 0.5 1.5 $35 $706 5,916 8,874 $4,384,165Conduct annual sludge sampling (concurrent withinjectate sampling).Annual0.0 0.0 1.0 0.5 1.5 $35 $1,847 1,479 2,219 $2,782,598Annual reporting and recordkeeping of all monitoringresults.Annual0.0 0.0 3.0 1.0 4.0 $95 $0 1,479 5,916 $140,529TOTAL33,88129,789$7,577,905Notes:(A) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-37Table A-5 (continued)Annual Paperwork Burden and Costs Associated with Class V Wells: StatesA B CD E FHours and Costs per Response Total Hours and CostDescription of RequirementFrequency Unit Burden (A) Unit Labor CostUnit NonlaborCostNumber ofResponses Total Hours/Year Total Cost/YearInitial/StartupReview inventory information.One-time 0.5 $21 $0 16,154 8,077 $334,573Primacy State Activities Associated With the Class V RuleProvide technical assistance to owners/operators (at start-up).One-time 1.0 $41 $0 78 78 $3,230Review and file pre-closure notifications.One-time 1.3 $52 $0 75 93 $3,869Review, approve, and file waivers/permit applications.One-time 8.3 $344 $0 3 27 $1,117Review and file annual monitoring reports.Annual 0.8 $33 $0 961 769 $31,848TOTAL17,271 9,044 374,637$Notes:(A) Unit burdens for initial/start-up activities reported on a per-permit basis. Unit burden for other activities reported ona per-operator basis.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-38Underground Injection Control Program – Information Collection Request Page A-39 

###  The specific information required in a permit applicati on will be defined by the States or EPA regions.

For purposes of this analysis, EPA assumes that the permit requirements will be similar to those required

in existing UIC permit applications (40 CFR 144.31) including: a desc ription of activities requiring a

permit, inventory information, topographic maps, a nd a brief description of the business. These

operators will also sample their in jectate. The burden for these activ ities is estimated to be 55.5 hours,

the majority of which is for pr eparing the permit application.

Operators of MVWDWs that are granted permits will be required to sample their injectate quarterly and

sludge annually and submit these results once per year. These operators will incur an annual burden of 7 hours.

Burden on Primacy Agencies Associated with Class V Wells

State primacy agencies’ burden associated with Cla ss V wells includes time associated with reviewing

inventory information, processing permit applications and pre-closure notifica tions, and reviewing and

responding to monitoring data submitted by operators within their states. State burden associated with oversight

of Class V programs is presente d in Column A of Table A-5.

EPA estimates that states will spend 0.5 hours per Cl ass V facility reviewing inventory information.

EPA estimates that states will review permit applications and pre-closure notifications submitted by operators of

facilities with motor vehicle waste dis posal wells and large-cap acity cesspools. State pr imacy agencies will also

review annual monitoring reports submitted by oper ators (details are presented in Table A-5).

Burden Associated with Class VI Wells

EPA’s estimate of the annua l paperwork burden on operators and states associated with Class VI wells is

presented in Column A of Table A-6. The burden estimates presented for Class VI wells are weighted averages

that take into account the formation t ype, injection depth waiver status, and number of facilities that are active

during this ICR clearance period. As su ch, these burden estimates are not re presentative of any one situation

under which a GS project will operate.

Class VI Operators

Activities for Class VI well operators include permitting and start-up-related reporting, demonstration of

financial responsibility, monitoring a nd testing, AoR reevaluations and asso ciated plan revisions, and closure

and post-injection site care related paperwork activities.

EPA anticipates that Class VI facility operators w ill rely on contractors to assist them for information

collection activities such as 3D seismic surveys, aerial surveys, and te st well drilling. The costs associated with

contractor labor and other c ontractor services are included in the opera tor costs presented in Column C of Table

A-6. However, as geologic sequestra tion is a relatively new endeavor, ther e are still many activities for which

uncertainty exists as to whether they will customarily be performed by operators or contractors. Those

activities were classified as operato r burden to provide a conservatively large estimate of operator burden.

EPA assumes that some activities required of Class VI operators (s uch as developing maps and crosssections of the receiving formation) are customary bus iness practices that would be performed by operators

even in the absence of regulation. Un it burden and costs used in Table A- 6 represent the co sts of performing

each activity required of Class VI operators that are incremental to customary business practices.AB C DE FDescription Of Requirement FrequencyTechnical 1(Engineer)Technical 2(Geologist) Unit BurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ Year Total Cost/YearInitial/Startup Requirements (Per Permit Application)Requirements Associated with Permit ApplicationsPrepare and submit Class VI permit application,including attachments and the testing and monitoringplan, emergencyand remedial response, injection wellplugging, and post-injection site care and site closureplan. One-Time240 300 540 $58,524 $546,184 3.31,800$2,015,694Conduct 3D seismic surveyto identifyfaults andfractures; obtain and analyze seismic history. One-Time0 180 180 $19,074 $605,365 3.3600$2,081,463Obtain geomechanical and geochemical informationon injection zone, subsurface aquifers including allUSDWs, and the confining zone in the area of review. One-Time30 129 159 $17,012 $140,292 3.3530$524,346Develop maps and cross sections of the injectionzone, subsurface aquifers including all USDWs, andthe confining zone in the area of review. One-Time0 44 44 $4,705 $0 3.3148$15,683Take initial samples to develop ageochemicalbaseline for injection zones and confining zones. One-Time0 10 10 $1,060 $18,276 3.333$64,453Prepare geologic characterization reportdemonstrating: suitability of receiving zone, storagecapacity and injectivity, trapping mechanism free ofnonsealing faults, competent confining system, etc. One-Time0 240 240 $25,432 $0 3.3800$84,774Demonstrate financial responsibilityto ensure fundswill be available for required future actions. One-Time40 0 40 $4,456 $0 3.3133$14,852Conduct aerial and database search for artificialpenetrations (wells) within the area of review;determine integrity/plugging status of each. One-Time140 300 440 $47,385 $101,646 3.31,467$496,770Perform complex modelingof CO2 fluid flow andmigration (reservoir simulations) and prepare AoRand corrective action plan. One-Time724 1,2001924 $207,809 $0 3.36,413$692,698Compile and submit information to support aninjection depth waiver application. One-Time100 200 300 $32,333 $0 1.0300$32,333Total Hours andCostsHours and Costs Per ResponseTable A-6Annual Paperwork Burden and Costs Associated with Class VI Wells: OperatorsUnderground Injection Control Program -- Information Collection RequestPage A-40AB C DE FDescription Of Requirement FrequencyTechnical 1(Engineer)Technical 2(Geologist) Unit BurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ Year Total Cost/YearTotal Hours andCostsHours and Costs Per ResponseTable A-6Annual Paperwork Burden and Costs Associated with Class VI Wells: OperatorsRequirements Associated with Injection Well ConstructionDesign and install equipment for injection wells tomeasure: injected volumes, pressure, flow rates, andannulus pressure. One-Time0 0 0 $0 $399,518 3.30 $1,331,726Install check/shut-off valve on injection well.One-Time0 0 0 $0 $2,759 3.30 $9,197Construct monitoringwells. One-Time0 0 0 $0 $2,370,3183.30 $7,901,061Design and install equipment for monitoringwells tomeasure: pressure, temperature, resisitivity, salinity,CO2, and any other required parameters. One-Time0 0 0 $0 $169,956 3.30 $566,522Monitoring/Testing Requirements (Per Operator)Analyze injectate stream and perform corrosionmonitoring. Quarterly62 0 62 $6,851 $16,303 13.3820 308,715$Operate and maintain monitoringwells and themonitoring equipment within them. Annual13 0 13 $1,395 $462,195 3.3 42 $1,545,301Conduct periodic monitoringofgroundwater qualityand geochemistry. Monthly21 0 21 $2,339 $10,906 40.0 840 $529,816Conduct external mechanical integritytests.Annual0 0 0 $0 $181,8043.3 0 $606,013Conduct pressure fall-off testing.EveryFiveYears0 0 0 $0 $34,268 0.7 0 $22,845Conduct 3D seismic surveyto track movement of theCO2 plume and pressure front.EveryFiveYears0 0 0 $0 $1,194,570 0.7 0 $796,380Activities Associated with Area of Review ReevaluationsConduct updated AoR modeling. Based on newresults, update AoR and Corrective Action Plan,Testing and Monitoring Plan, and Emergency andRemedial Response Plan.Every FiveYears1,1180 1,118$124,536 $0 0 0 $0Underground Injection Control Program -- Information Collection RequestPage A-41AB C DE FDescription Of Requirement FrequencyTechnical 1(Engineer)Technical 2(Geologist) Unit BurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ Year Total Cost/YearTotal Hours andCostsHours and Costs Per ResponseTable A-6Annual Paperwork Burden and Costs Associated with Class VI Wells: OperatorsReporting and Recordkeeping Requirments (Per Operator)Report to regulators; maintain records of data from alldata gathering activities. Semi-Annual33 0 33 $3,676 $0 6.7 220 $24,506Plugging, Post-Injection Site Care, and Site Closure Requirements (Per Operator)Demonstrate financial ability (accounting for inflation)to close site.PostInjection,One-Time8 0 8 $891 $0 0 0 $0Perform a MIT prior to plugging the injection well.PostInjection,One-Time0 0 0 $0 $34,776 0 0 $0Conductground water monitoring- operate andmaintain monitoring wells and the monitoringequipment within them.PostInjection,Annual0 0 0 $0 $531,971 0 0 $0Track the CO2 plume and pressure front.PostInjection,Every 50 0 0 $0 $1,194,570 0 0 $0Submit results of post-injection monitoring.PostInjection,Every 540 0 40 $4,456 $0 0 0 $0TOTAL112.3 14,14619,665,149$Notes:(A)Unit Non-Labor Cost inflated by20% to account for G&ANumbers maynot add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-42AB C DE FDescription Of Requirement Frequency Unit BurdenUnit LaborCostUnit NonLabor Cost(A)Number ofResponsesTotalHours/ YearTotalCost/YearInitial/Startup Requirements (Per Permit Application)Review the permit application and other informationsubmitted by the operator, considering: AoR, relevant maps,site geology, formation testing results, well schematics andconstruction procedures, proposed injection procedure,status of corrective action on wells in the AoR, well logging,testing, and mechanical integrity data, and project plans. One-time780$32,311 $0 0.33260.0 $10,770Review financial responsibility demonstration. One-time100$4,142 $0 0.3333.3 $1,381Determine and specify tubing, packing, casing, andcementing requirements based on review of informationsubmitted by operator. One-time140$5,799 $0 0.3346.7 $1,933Witness logging and testing. One-time20$828 $0 0.336.7 $276Review applications for waviers to inject above thelowermost underground source of drinking water. One-time200$8,285 $0 0.3366.7 $2,762Monitoring and RecordkeepingReview reports submitted by operators; recordkeeping ofdata from all data gathering activities. Annual40 $1,657 $0 0 0 $0Review mechanical integrity test data. Annual14 $559 $0 0 0 $0Area of Review ReevaluationReview updated AoR modeling and updated plans.Every 5years150 $6,214 $0 0 0 $0Site ClosureReview relevant data prior to granting approval for pluggingand abandonment of a well. One-time40 $1,657 $0 0 0 $0Project-Independent ActivitiesPrepare and submit primacy application. One-time1,040$43,081 $0 2.3 2,427$100,522TOTAL4.0 2,840117,644$Notes:Numbers may not add due to rounding.Annual Paperwork Burden and Costs Associated with Class VI Wells: StatesTable A-6 (continued)Hours and Costs Per Response Total Hours and CostsUndergound Injection Control Program -- Information Collection RequestPage A-43Underground Injection Control Program – Information Collection Request Page A-44 

### Initial Permitting/Start-up

EPA estimates that the operator burden associat ed with applying for Class VI permits, including

submitting all required attachments and plans will be 540 hours per permit. Submitted plans include an Area of

Review and Corrective Action Plan, a Testing and Monitoring Plan, an Emergency and Remedial Response

Plan, an Injection Well Plugging Plan, and a Post-I njection Site Care and Site Closure Plan.

In addition to applying for permits, EPA estimates that owners or operators of Class VI wells will incur

burden above customary business practices to perform the following start-up activities:

 Conduct a 3D seismic survey to identify faults an d fractures and to obtain and analyze the seismic

history of the site (180 hours).

 Obtain geomechanical and geochemical information on the injection zone, other subsurface aquifers

(including all USDWs), and the conf ining zone in the AoR (159 hours).

 Develop maps and cross-sections of the injectio n zone, other subsurface aquifers (including all

USDWs), and the confining zone in the AoR (44 hours).

 Prepare a geologic characterization report demonstrating the suitability of the injection zone, storage

capacity and injectivity, the pres ence of a trapping m echanism free of non-sealing faults, and a

competent confining zone (240 hours).

 Estimate the costs of activities to be covered by financial responsibility an d demonstrate financial

responsibility for thes e activities (40 hours).

 Conduct aerial and database searches for artificial pe netrations (wells) within the AoR, and determine

integrity and plugging status of each (440 hours).

 Perform complex modeling (reservoir simulations) of carbon dioxide flow a nd fluid migration to

delineate the AoR (1,924 hours).

Monitoring/Testing

Class VI well operators will be required to perfor m quarterly analysis of the injectate stream and

perform corrosion testing of the injection well, which is estimated to require approximately 61.5 hours per

operator per quarter. Additionally, operators will incur an annual burden of approximately12.5 hours to operate

and maintain monitoring wells and the monitoring e quipment within them. Operators must also perform

groundwater quality and geochemical monitoring which is estimated to require approximately 21 hours per

month. Owners or operators will also hire contractors to perform annual external MITs and to track the extent of

the carbon dioxide plum e and pressure front.

Area of Review Reevaluations

Owners or operators of Class VI wells must reevalua te the AoR for the GS project at least every five

years. Based on the results of the reevaluation, operators wi ll update and resubmit their Area of Review and

Corrective Action Plan, the Testing a nd Monitoring Plan, and the Emergency and Remedial Response Plan or

demonstrate that no updates are necessary. They will also update the financial responsibility demonstration as

needed to address any changes to these plans. (Note that owners or operators will also review their financial

responsibility demonstrations annually to account for infl ation; this is assumed to involve a negligible burden

that is accounted for in the AoR reevaluation estimate.)Underground Injection Control Program – Information Collection Request Page A-45 

### EPA estimates that, each year, 20 percent of ope rators will reevaluate the AoR and update the

aforementioned plans and submit them to the primacy ag ency for review and approval. Each operator is

estimated to incur 1,118 hours of burden once every five years for AoR reevaluations, which is assumed to

include burden incurred by ope rators to respond to issues raised during a review of the Class VI permit, which

is required every five years, per 40 CFR 144.36.

Reporting and Recordkeeping

Operators of Class VI wells will spend 33 hours ever y six months (or 66 hours pe r year) to report the

results of required monitoring and testing and ke ep records of all data-gathering activities.

Closure and Post-In jection Site Care

There are two closure and post-injection site care activities for which operators incur burden. It is

estimated that operators will require 8 hours to demons trate financial ability (accounting for inflation) to

properly close the site. This occurs once at the beginning of the post-injec tion period. Subse quently, operators

are assumed to report monitoring results to regulators every five years during the post-injection site care period,

which is estimated to require 40 hours pe r operator, every five years.

Burden on Primacy Agencies Associated with Class VI Wells

State primacy agencies’ burden associated with Cl ass VI wells includes reviewing and responding to

permit applications, monitoring and te sting data, AoR reevalua tions, and closure and po st-injection site care

information submitted by operators. Due to the potenti ally long life spans of injection operations, no AoR

reevaluations or closure and post-injec tion site care activities are anticipated to occur during the ICR clearance

period. State burden associated with each activity involved in the oversight of Class VI programs is presented in

Column A of Table A-6.

EPA estimates that states will incur 1,040 burden hour s per permit application to review Class VI permit

applications and all supporting information, including reviewing geologic information and well schematics;

evaluating the AoR modeling; and review ing the draft project plans and fina ncial responsibility cost estimates

and instruments.

State primacy agencies will incur an estimated 2.2 hours of burden annually per operator reviewing

reports and data records submitted by operators. Every year, they will also incur approximately 13.5 hours of

burden per operator reviewing MIT re sults. State primacy agencies will review modeling updates to the AoR

and other revised plans submitted by operators every fi ve years, requiring approximately 20 hours per review.

States as Respondents

State burden associated with program oversight and compiling and reporting data using the 7520 forms

and the UIC measures reporting proc ess is presented in Column A of Table A-7. The burden on states

associated with completing the 7520 forms ranges from 2 to 6 hours per form. States will also report annually

to EPA on the UIC Program measures via an online reporting system. EPA es timates the annual burden

associated with this effort will be 60 hours per stat e primacy agency. States will also report inventory

information annually to EPA. The burden associated with the oversight activities for the UIC Program well

inventory includes compiling the number of each Class of well, and reporting to an EPA online inventory. EPA

estimates the annual burden associated with th is effort will be 60 hours per primacy agency.Underground Injection Control Program – Information Collection Request Page A-46 

### EPA estimates that the annual recordkeeping burden on state primacy agencies associated with the 7520

forms and the inventory form will be 40 hours per agency. EPA estimates that maintenance of inventory data

will account for the bulk of the recordkeeping burden.

EPA estimates that, in each primacy program, one-half of an FTE (1,040 hours) is devoted to

implementing the state UIC Program. Implementation activities states may perform include updating state

regulations as needed to reflect new federal rules or providing guidance, tr aining, or other information to well

operators.

State Activities Associated w ith the National UIC Database

EPA Headquarters deployed the National UIC database in December 2007. States are able to transfer

the data needed to generate the information they cu rrently report via the 7520 form s, the inventory, and the

measures data to Headquarters. (Once th ey set up this data transfer process, States will no longer be required to

complete the 7520 forms, report UIC inventory or measures data, or retain records. ) Appendix B describes the

data transfer activities in detail, EPA’s burden and cost estimates, and th e burden and cost sa vings to states

associated with the national UIC database.

Start-up costs for states that have UIC databases include the costs associ ated with developing the data to

transfer to the National UIC Database and setting up the data flow process. EPA estimates that, on average, the

total “data development” burden to th ese programs is about 310 hours. Annua lizing the effort over the estimated

6-year phase-in schedule, this equals 51.6 hours per program annually, of which 10 hours will be conducted by

state staff (the remaining work will be performed by contractors).

States with existing data bases will also need to set up a data flow (i.e., data mapping, conversion to

Extensible Markup Language, and setti ng up the data transfer through EPA’s Central Data Exchange). The total

data flow burden is estimated to be 210 hours per program. Annualized over 6 years, this equates to 35 hours

per year per program, of wh ich 25 hours are state burden.

To assist states without a UIC da ta base, EPA Headquarters developed an Access database. Because the

database would be designed to the needs of the Na tional UIC Database and Hea dquarters would perform the

basic programming, the start-up effort for states without a UIC data base is assumed to be less intensive than for

those states that already have a da tabase. EPA estimates the start-up burden to these state programs is 250

hours/ program (state and contractor labor), or 41.6 hours per year, annualized over 6 years. Of this, 8 hours will

be state burden.

Following establishment of a data flow, states will n eed to enter UIC data into their data bases; EPA

estimated that states will spend 40 hours annually on this ongoing effort. States will also submit their data to the

National UIC Database and respond to QA and data valid ation issues. EPA estimat es that these tasks will

require 4 hours, and be incurre d twice annually (8 hours total).Table A-7Annual State Burden and Cost for Program Oversight and ReportingA BC D E FHours and Costs per Response Total Hours and CostDescription of Requirement FrequencyUnit BurdenUnit LaborCostUnit NonlaborCostNumber ofResponsesTotalHours/Year Total Cost/YearProgram OversightOversee and implement UIC program in the State, forexample, update regulations or guidances as needed.Ongoing1,040 $43,081 $0 5860,320 $2,498,6967520 Forms ReportingComplete and submit Permit Review and Issuance Form(7520-1)Annual4.5 $186 $0 1883 $3,417Complete and submit Compliance Evaluation Form (7520-2A)Semi-annual6.0 $249 $0 37220 $9,113Complete and submit Compliance Evaluation forSignificant Non-Compliance Form (7520-2B)Semi-annual5.5 $228 $0 37202 $8,354Complete and submit Mechanical IntegrityTests/Remedial Action Form (7520-3)Annual5.0 $207 $0 1892 $3,797Complete and submit Quarterly Exceptions List Form(7520-4)Quarterly2.0 $83 $0 73147 $6,076Inventory and Measures ReportingConduct inventory-related activities, e.g., review operatordata and report to EPA's online inventory data system.Annual60 $2,485 $0 181,100 $45,566Report on UIC Measures to Headquarters Annual60 $2,485 $0 181,100 $45,566Activities related to populating the National UIC DatabaseStart-up activities (per program)Develop data to meet UIC database needs (programswith UIC databases)One-time10 $428 3,782$ 776 $30,870Build data flow through data node (programs with UICdatabases)One-time25 $1,036 2,082$ 7183 $22,866Build data flow through data node (programs withoutdatabases)One-time8 $345 4,219$ 5 42 $22,822Ongoing activities (per program)Enter UIC data into state database Ongoing40 $1,657 $0 40 1,587 $65,726Data flow and QA checks Semi-annual4 $166 $0 79317 $13,145RecordkeepingMaintain records of 7520 forms Ongoing40 $1,657 $0 18733 $30,378435 66,201 $2,806,393Notes:There may be more than one agency per state with Primacy authority.EPA assumes that once states transition to electronic reporting, they will no longer complete7520 forms or submit inventory and measures data to EPA. See Appendix B.Numbers may not add due to rounding.Underground Injection Control Program -- Information Collection RequestPage A-47Underground Injection Control Program – Information Collection Request Page A-48 

### A.2 Estimating the Respondent Universe

In this section, EPA describes the number of responde nts subject to each paperwor k activity in this ICR.

The number of responses for each activity is shown in Column D of Tables A-1 through A-7. This number,

known as the respondent universe, is based on EPA’s assump tions of the number of permittees subject to each

paperwork requirement, e.g., the number of permit applica tions or well closures expe cted, or the percent of

permittees subject to monitoring or reporting requirements and the frequency with which they must comply

with those requirements. The frequency at which each ac tivity is performed is also presented in Tables A-1

through A-7, along with EPA’s description of each ac tivity. Specific assumptions about the respondent

universe for each well class are described below.

Class I

EPA inventory data indicate that there are 845 Class I wells, of whic h 140 inject hazardous waste, and

705 inject nonhazardous waste.

Class I Hazardous

According to EPA’s inventory, there are 140 Class I h azardous waste wells, with an average of 1.9 wells

at each facility. EPA estimates that 8 new Class I hazardous waste facility operating permits will be issued each

year (6 for one new well at an existing facility, and th e remaining two for newly constructed facilities). EPA

further anticipates that 12 Class I hazardous facility op erators will renew their permits each year; 5 will modify

their permits each year, and 6 operators will modify their petitions each year. EPA estimates that, on average,

1.4 owners or operators of Class I hazardous waste well wi ll apply for aquifer exemptions each year, and that all

of these will constitute non-substant ial revisions to their state’s UIC progr am. All operators of Class I hazardous

waste facilities must monitor and repo rt at various frequencie s (see Table A-1A). EPA expects that one Class I

hazardous well will close during each year of the life of this ICR.

Class I Nonhazardous

EPA estimates that there are 705 Class I nonhazardous waste wells at 371 facili ties, an average of 1.9

wells per facility. The Agency estimates that 14 new nonhazardous waste injection permits will be issued each

year. EPA anticipates that 20 Class I nonhazardous facili ty operators will renew their permits each year, and 9

Class I nonhazardous facility operators will modify their pe rmits each year. EPA estimates that, on average, 2.4

owners or operators of Class I nonhazardous waste well will apply for aquifer exemptions each year, and that all

of these will constitute non-substant ial revisions to their state’s UIC pr ogram. Every operator of a Class I

nonhazardous waste facility must monito r and report at various frequencies, as shown in Table A-1B. Based on

past data, EPA anticipates that one Class I nonhazardous well in a primacy state will close each year.

Class II

The UIC inventory includes 176,516 Class II wells. EP A assumes that the typica l Class II facility has

approximately 10 wells, thus there are approximately 17,652 Class II facilities.

EPA anticipates that, collectively, EPA regional offices and primacy states will receive approximately

8,983 permit applications for Class II wells each year during the lif e of this ICR. Details of the numbers of

Class II operators subject to each paperwork requir ement are presented in Column D of Table A-2.

Based on previous studies of state AoR practices and requirements, EPA proj ects that state primacy

agencies and EPA Regions will determine that a complete AoR is not necessary for approximately 80 percent ofUnderground Injection Control Program – Information Collection Request Page A-49 

### permit applications, and the remainin g applicants will submit an AoR map and an AoR study as part of the

permit application. EPA estimates that 898 applicants will submit correctiv e action plans to address specific

problems identified by the AoR study, and that EPA regional or state primacy staff wi ll require 20 percent of

these owners or operators to revi se their corrective action plans.

EPA estimates that 269 Class II owners or operators will apply for aquifer exemptions each year, and

that all of these will constitute non-substantial revisions to their state’s UIC program. EPA also estimates that

30 owners or operators of production wells in DI states will perform HF usi ng diesel fuels and be subject to the

permitting and monitoring and reporting recommendations in the DFHF Guidance.

Prior to obtaining approval to begin injection, op erators must demonstrate mechanical integrity and

submit completion reports for an estima ted 8,585 new Class II wells each year.

EPA estimates that approximately 88,258 Class II wells (50 percent of the inve ntory) are permitted, and

that 20 percent of operators will under go permit reviews each year, and half of these will need to respond to

issues raised during the reviews. In addition, EPA e xpects that 2,648 Class II operato rs will submit requests for

permit modifications.

EPA projects that 17,682 Class II well owners or operators will perform annual MITs and sample

ground water and report the results to the permitting authority each year.

EPA projects that, each year, approximately 1,044 ope rators will plug and abandon their wells. In

addition, EPA assumes that approximately one operator in a DI program will elect to plug its wells in a manner

different from the one specified in its plugging and abandonmen t plan, triggering a revi sion to the plugging and

abandonment plan.

Class III

EPA estimates that there are approximately 171 faci lities with Class III we lls (10 uranium mining, 47

salt solution mining, and 114 brine mining/other sites). A typical uranium facility has approximately 2,072

Class III wells, a typical salt mining facility has 19 wells , and a typical brine mining/ot her facility has 2 wells.

EPA regional offices and state primacy agencies exp ect to receive 32 permit applications from Class III

operators each year. EPA estimates that, on average, 0.2 Class III owners or opera tors will apply for aquifer

exemptions each year, and that all of these will constitute non-substantial revisions to their state’s UIC program.

Operators of all 171 Class III facilities will monitor in jection pressure, flow rate, or volume of injected

fluids semi-monthly, or meter injected and produced fluid volumes continuously. EPA anticipates that

operators of salt solution mining facilities will submit anal yses of their injectate once each year, and operators

of salt solution mining faci lities will perform two-part MITs on all of their wells ev ery five years. All uranium

well operators monitor water quality in the injection zone and overlying freshwateraquifers either semimonthly or monthly. EPA estimates that approximately 2 Class III operators will clos e their projects annually.

Class IV/Endangering Class V

Based on UIC measures data reported by the states in 2003, EPA anticipates that 990 Class IV wells and

endangering Class V wells will close each year. EPA estimates 23 percent of Class IV and endangering Class V

wells are in DI states.Underground Injection Control Program – Information Collection Request Page A-50 

### Class V

The current EPA inventory of Cl ass V wells includes 479,838 wells. This number is imprecise, and it is

estimated that perhaps 3 to 5 times as many Class V wells actually exist. EPA anticipates that approximately

24,860 operators of Class V facilities will submit inventory information each year over the life of this ICR,

based on trends in the UIC program inventory.

Facilities Subject to the Class V Rule

The Class V rule required that all large-capacity cesspools be closed and that all motor vehicle waste

disposal wells (MVWDWs) either close their well or ob tain a permit by 2007 (the burde n associated with these

activities was estimated in previous UI C Program ICRs). EPA assumes that mo st facilities affected by the Class

V Rule will have closed their wells or obtained a permit by this time; however, a limited number of largecapacity cesspools and MVWDWs are expe cted to be identified during the course of inspections or other

activities. EPA understands that primacy agencies ha ve focused their efforts on closing MVWDWs and not

issuing permits. Thus, this ICR assumes that some permitting and closure activities associated with Class V

Rule will occur during this clearance period.

EPA estimates, based on data from the states, that ope rators of 20 large-capacity cesspools need to close

their facilities during the clea rance period (an average of 7 per year). In addition, EPA estimates that operators

of 285 MVWDWs (95/year) will close and 15 MVWDW op erators (5/year) will apply for a permit during the

clearance period. Furthermore, operators of 1,479 MVWDWs that have opted to ob tain a permit will conduct

quarterly injectate sampling and annual sludge sampling, as required under the Class V rule.

Class VI

EPA estimates that, over the clearan ce period, 10 owners or operators will apply for a Class VI permit.

Of these, 9 will be in DI states, and the other will be in a primacy state (and one will be accompanied by an

application for an injection depth waiver). On an annua lized average basis, this equates to primacy states

processing 0.33 permit applications per year and DI states reviewing 3 permit applications per year.

Permit application reviews and the s ubsequent drilling procedures take up to a few years to complete.

Thus, EPA assumes that by the end of the clearance peri od, 10 wells will be in ope ration, with most beginning

operations in the second and third years of the clearance period. EPA does not anticipate that any Class VI well

owners or operators will perf orm AoR reevaluations or pos t-injection site care /site closure activiti es during the

clearance period. EPA estimates that 7 states will apply for Class VI primacy during the clearance period.

States as Respondents

EPA assumes that 58 primacy agencies in 40 states and two tribes (Navajo and Fort Peck) will report

UIC data to EPA, either electronically or on paper forms. This number refl ects the fact that, in some states,

more than one agency oversees UIC activities (e.g., stat es typically regulate Clas s II wells through agencies

other than those overseeing other classes of wells for which they have primacy).

Because of the effort involved in initiating data tr ansfer to the National UIC database EPA assumes that

states will accomplish this at varying paces, depending on many variables including available funding and staff.

This results in a phased-in schedule for populating th e National UIC Database. EPA estimates that, at the

beginning of this information collection, 14 programs will have transitioned to electronic reporting. Fifteen (15)

additional programs are expected to transition to e-re porting in 2015; 10 programs are expected to do so in

2016; and the remaining 12 programs ar e expected to transition in 2017.