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

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

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

agencies. The first part of this Appendix contains EPA’s estimates of respondent burden associated with UIC 

paperwork requirements. The second part of this Appendix provides EPA’s assumptions about the number of 

respondents subject to each information collection activity. 

A.1 Estimating Respondent Burden 

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

recordkeeping activity required of well operators and state 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 collection activities are performed by contractors. The 

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

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

activity. The mix of operator versus contractor 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 administering Class I hazardous 

and Class I nonhazardous programs are presented in Tables 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 contractors to assist them with most information collection activities, 

including initial/start-up activities (e.g., permit applications, 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 modifications). The operator burdens 

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

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

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

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

existing facilities, and that much of the information these applicants are required to submit is likely to have been 

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

the remaining 30 percent of permits will be issued for wells 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-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response Tota

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Ho

Initial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time 0.0 0.25 0.25 0.0 0.5 $33 $0 8 Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, description of the business.

One-time

3.0 2.0 9.0 6.0 20.0 $1,051 $0 8 

In DI programs, gather and submit a list of landowners within one-quarter mile of the facility boundary.

One-time

4.0 0.0 0.0 1.2 5.2 $399 $0 3 

Prepare and submit a map and tabulation of all wells within the AoR.

One-time

0.0 1.5 5.5 0.0 7.0 $394 $23,082 8 

Prepare and submit AoR protocol. One-time

0.0 0.0 1.3 0.0 1.3 $63 $894 8 

Prepare and submit maps/cross sections of local and regional geology, USDWs.

One-time

0.0 1.5 16.0 0.0 17.5 $906 $47,922 8 

Develop formation testing and stimulation programs and injection procedures.

One-time

0.0 2.0 5.0 1.0 8.0 $440 $6,879 8 

Prepare and submit contingency plans for shut-ins or well failures.

One-time

0.0 3.0 10.0 2.0 15.0 $797 $268 8 

Prepare and submit ambient monitoring plan. One-time

0.0 3.0 0.0 0.0 3.0 $248 $4,509 8 

Prepare and submit Corrective Action Plan. One-time

0.0 2.0 3.0 2.3 7.3 $380 $11,426 8 

Prepare and submit descriptions of logs and tests, construction schematics & operating data.

One-time

0.0 2.0 8.0 5.0 15.0 $700 $5,732 8 

Prepare and submit closure plan, including demonstration of financial responsibility.

One-time

0.0 1.0 3.0 2.6 6.6 $304 $1,689 8 

Prepare and submit post-closure care plan. One-time

0.0 1.4 2.0 1.4 4.8 $254 $2,079 8 

Prepare and submit information to support an aquifer exemption request.

One-time

0.0 2.5 17.0 0.5 20.0 $1,053 $2,079 1.4 

Underground Injection Control Program -- Information Collection Request 
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response Tota

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Ho

Requirements for active hazardous waste facilitiesGather and submit dates of well operation and specific waste information.

One-time

0.0 0.0 26.6 11.4 38.0 $1,620 $8,713 8 

Gather and submit hazardous waste release information.

One-time

0.0 1.9 30.4 22.8 55.1 $2,289 $4,357 0 

Develop waste analysis plan. One-time

0.0 1.9 15.2 1.9 19.0 $955 $2,904 8 

Prepare and submit schedule of construction logs and tests.

One-time

0.0 0.0 0.5 0.5 1.0 $39 $0 8 

Requirements associated with completion reportsPrepare and submit completion report. One-time 0.0 0.0 1.5 2.5 4.0 $144 $0 8 Submit results of deviation checks, other logs and tests; sample formation fluids; test injection and confining zones.

One-time

0.0 0.0 6.0 1.0 7.0 $321 $35,158 8 

Demonstrate mechanical integrity (i.e., casing pressure test, radioactive tracer survey of bottom-hole cement, and noise/temperature logs to check for movement along the borehole).

One-time

0.0 2.0 18.0 0.0 20.0 $1,046 $22,929 8 

Submit information on the anticipated maximum pressure and flow rate.

One-time

0.0 0.0 2.0 0.0 2.0 $97 $153 8 

Submit results of the injection zone and confining zone testing programs.

One-time

0.0 1.0 4.0 0.0 5.0 $279 $38,215 8 

Submit actual injection procedure. One-time 0.0 0.0 1.0 0.0 1.0 $49 $153 8 Demonstrate hydrogeologic compatibility/ compatability of well materials.

One-time

0.0 2.0 6.0 0.0 8.0 $461 $7,643 8 

Prepare and submit information on the calculated AoR.

One-time

0.0 0.0 2.0 0.0 2.0 $97 $3,057 8 

No-migration petition requirementsGather and submit waste information and present modeling data to demonstrate that wastes will not migrate from injection zone.

One-time

0.0 24.0 120.0 30.0 174.0 $8,721 $802,515 8 

Requirements associated with permit renewals/modifications and petition modificationsSubmit updated components of permit application attachments.

Occasional

0.0 9.0 41.5 21.0 71.5 $3,377 $11,312 12 

Prepare and submit request for Permit Modification.

One-time

0.0 2.0 6.0 2.0 10.0 $518 $6,573 5 

Prepare and submit Petition Modification. One-time

0.0 24.0 120.0 30.0 174.0 $8,721 $759,679 6 

Underground Injection Control Program -- Information Collection Request 
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response Tota

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Ho

Monitoring/Testing Requirements (Per Facility)Use continuous recording devices to monitor injection pressure, flow rate, volume, and temperature.

Continuous

0.0 0.0 5.7 0.0 5.7 $278 $0 74 

Conduct chemical monitoring of injected wastes as prescribed in waste analysis plan.

As specified in WAP

0.0 0.0 38.0 0.0 38.0 $1,852 $4,586 295 

Conduct additional chemical monitoring as specified by the Director.

Varies

0.0 0.0 7.6 0.0 7.6 $370 $917 29 

Conduct casing pressure test and radioactive tracer survey of bottom-hole cement.

Annual

0.0 3.8 5.2 0.0 9.0 $573 $6,331 59 

Conduct casing pressure test, radioactive tracer of bottom-hole cement, and noise/temperature logs to check for movement along the borehole.

Every 5 years

0.0 1.0 7.0 0.0 8.0 $425 $43,565 15 

Conduct casing inspection log at workover. Occasional

0.0 3.8 8.0 0.0 11.8 $710 $7,597 4 

Conduct pressure fall-off test. Annual

0.0 6.0 18.0 0.0 24.0 $1,382 $17,726 74 

Conduct ambient monitoring. Annual

0.0 0.4 1.9 0.0 2.3 $125 $6,114 74 

Reporting Requirements (Per Facility)Prepare and submit report on maximum injection pressure, total injectate volume, and monitoring and testing results.

Quarterly

0.0 4.0 15.0 6.0 25.0 $1,627 $0 295 

Prepare and submit report on mechanical integrity testing.

Annual

0.0 1.0 2.0 1.0 4.0 $260 $1,376 74 

Notify Director within 24 hours of: planned physical changes to facility, changes that may result in noncompliance, compliance or noncompliance with a compliance schedule, any indication of possible endangerment of a USDW, or all other noncompliance.

Occasional

0.0 1.0 2.0 3.0 6.0 $260 $0 1 

Prepare and submit revised plugging and abandonment cost estimate.

Annual

0.0 1.0 0.0 0.0 1.0 $91 $0 74 

Prepare and submit report on: events exceeding operating parameters or triggering alarms; changes in annular fluid volume; workovers or other testing.

Occasional

0.0 1.0 1.0 1.0 3.0 $161 $0 4 

Underground Injection Control Program -- Information Collection Request 
Table A-1A

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

AB C D 

Hours and Costs per Response Tota

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Nonlabor Cost (B) No. of Responses 

Ho

Recordkeeping Requirements (Per Facility)Maintain monitoring information, calibration and maintenance records, required reports, application data, monitoring results, and most recent plugging and abandonment cost estimate.

3 years

0.0 0.0 0.0 5.0 5.0 $142 $0 74 

Closure Requirements (Per Well)Prepare and submit notice of intent to close. One-time

0.0 0.5 0.0 1.0 1.5 $70 $0 1 

Prepare and submit closure report. One-time 0.0 2.0 8.0 0.0 10.0 $558 $3,057 1 Conduct pressure fall-off test prior to well closure.

One-time

0.0 1.0 5.0 0.0 6.0 $328 $17,726 1 

Demonstrate mechanical integrity (i.e., casing pressure test, radioactive tracer of bottomhole cement, and noise/temperature logs to check for movement along the borehole) prior to closure.

One-time

0.0 2.0 18.0 0.0 20.0 $1,046 $28,615 1 

Notify state or local zoning or drilling authorities and Regional Administrator following closure.

One-time

0.0 0.5 1.0 3.0 4.5 $176 $0 1 

TOTAL 1,375 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 Request 
Table A-1A (continued)

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States

ABCD

Hours and Costs per Response Total Hours 

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit Nonlabor 

Cost

Number of 

State 

Responses 

 To

Ho

Initial/Start-upPermit ApplicationsConsider the permit application, AoR, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and construction procedures as required at 146.70 and prepare draft permit.

One-time

40.0 $1,657 $0 5 

 

Provide public notice of issuance of a draft permit or intent to deny.

One-time

1.0 $41 $0 5 

 

Consider public comments. One-time

6.0 $249 $0 5 

 

Issue final permit decision. One-time 2.0 $83 $0 5 

 

Respond to comments. One-time

7.0 $290 $0 5 

 

Review notice of completion of construction. One-time

2.0 $83 $0 5 

 

Review information related to aquifer exemption requests and forward to EPA region.

One-time

1.0 $41 $0 1 

 

No-Migration Petitions Review and respond to petition request. One-time 18.0 $746 $0 5 

 

Public notice/public comment. One-time 10.0 $414 $0 5 

 

Review and respond to petition modification request. One-time

10.0 $414 $0 4 

 

Permit renewals/modificationsReview and respond to requests for permit modifications or reissuance. Occasional 30.0 $1,243 $0 8 

 

Underground Injection Control Program -- Information Collection Request 
Table A-1A (continued)

Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States

ABCD

Hours and Costs per Response Total Hours 

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit Nonlabor 

Cost

Number of 

State 

Responses 

 To

Ho

Monitoring/TestingReview quarterly monitoring and testing results. Quarterly 1.5 $62 $0 201 

 

Review casing pressure test and radioactive tracer survey of bottom-hole cement.

Annual

4.0 $166 $0 40 

 

Review casing pressure test, radioactive tracer survey of bottom-hole cement, and logs.

Every 5 years

4.0 $166 $0 10 

 

Review pressure fall-off test. Annual 2.0 $83 $0 39 

 

Other ReportingRespond to periodic notifications by owners and operators. Occasional 2.0 $83 $0 4 

 

ClosureReview closure and post-closure plans prior to approving plugging and abandonment.

One-time

2.0 $83 $0 1 

 

Witness and review pressure fall-off test prior to authorizing closure.

One-time

24.0 $994 $0 1 

 

TOTAL 

398 

Notes:(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 
Table A-1B

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators

AB C D 

Hours and Costs per Response Total 

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Non-Labor 

Cost (B)

No. of 

Responses

Initial/Startup Requirements (Per Permit Application)Requirements associated with permit applicationsRead permit application directions. One-time 0.0 0.25 0.25 0.0 0.5 $33 $0 14 Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, relevant maps and cross sections, construction specifics, description of the business, proposed injection, formation testing, and stimulation 

One-time

3.0 2.0 9.0 6.0 20.0 $1,051 $0 14 

In DI programs, gather and submit a list of landowners within one-quarter mile of the facility boundary. 

One-time

4.0 0.0 0.0 1.2 5.2 $399 $0 4 

Prepare and submit a map and tabulation of all wells within the AoR.

One-time

0.0 1.5 5.5 0.0 7.0 $394 $18,465 14 

Prepare and submit maps/cross sections of local and regional geology, USDWs.

One-time

0.0 1.5 16.0 0.0 17.5 $906 $47,922 14 

Prepare and submit descriptions of logs and tests, construction schematics and operating data.

One-time

0.0 2.0 8.0 2.5 12.5 $629 $5,732 14 

Develop formation testing and stimulation programs and injection procedures.

One-time

0.0 2.0 7.0 1.0 10.0 $538 $6,879 14 

Prepare and submit contingency plans for shut-ins or well failures.

One-time

0.0 3.0 10.0 2.0 15.0 $797 $268 14 

Prepare and submit ambient monitoring plan. One-time

0.0 3.0 3.0 3.0 9.0 $484 $4,509 14 

Prepare and submit Corrective Action Plan. One-time

0.0 2.0 3.0 2.3 7.3 $380 $8,789 14 

Prepare and submit closure plan, including demonstration of financial responsibility.

One-time

0.0 1.0 3.0 2.6 6.6 $304 $1,689 14 

Prepare and submit information to support an aquifer exemption request.

One-time

0.0 2.5 17.0 0.5 20.0 $0 $0 2.4 

Requirements associated with completion reportsPrepare and submit completion report. One-time

0.0 0.0 1.5 2.5 4.0 $144 $0 14 

Prepare and submit a report of deviation checks and other logs and tests during 

One-time

0.0 0.0 6.0 1.0 7.0 $321 $35,158 14 

Demonstrate mechanical integrity (i.e., casing pressure test and noise/temperature logs to 

One-time

0.0 2.0 3.5 0.0 5.5 $339 $9,936 14 

Underground Injection Control Program -- Information Collection Request 
Table A-1B

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators

AB C D 

Hours and Costs per Response Total 

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Non-Labor 

Cost (B)

No. of 

Responses

Submit information on the anticipated maximum pressure and flow rate.

One-time

0.0 0.0 2.0 0.0 2.0 $97 $153 14 

Submit results of the formation testing program. 

One-time

0.0 1.0 4.0 0.0 5.0 $279 $38,215 14 

Submit actual injection procedure. One-time

0.0 0.0 1.0 0.0 1.0 $49 $153 14 

Demonstrate hydrogeologic compatibility/ compatibility of well materials.

One-time

0.0 2.0 6.0 0.0 8.0 $461 $7,643 14 

Requirements associated with permit renewals/modificationsSubmit updated components of permit application attachments.

Occasional

0.0 8.0 11.0 2.0 21.0 $1,266 $5,350 20 

Prepare and submit request for permit modification.

Occasional

0.0 2.0 6.0 0.0 8.0 $461 $3,822 9 

Monitoring/Testing Requirements (Per Facility)Analyze injected fluids. Per permit

0.0 0.0 38.0 0.0 38.0 $1,852 $3,057 1,484 

Monitor injection pressure, flow rate and volume, and annulus pressure.

Continuous

0.0 0.0 5.7 0.0 5.7 $278 $0 371 

Demonstrate mechanical integrity (i.e., casing pressure test and noise/temperature logs to check for movement along the borehole).

Every 5 years

0.0 1.0 8.0 0.0 9.0 $474 $18,878 74 

Conduct pressure fall-off test. Annual 0.0 8.0 16.0 0.0 24.0 $1,453 $17,726 371 Conduct ambient monitoring. Annual 0.0 0.4 1.5 0.0 1.9 $106 $6,114 371 Reporting Requirements (Per Facility)Report on: physical, chemical, and other characteristics of injected fluids; injection pressure, flow rate, and volume; and monitoring of USDWs.

Quarterly

0.0 0.0 4.0 12.0 16.0 $536 $0 1,484 

Report results of ambient monitoring and pressure fall-off test.

Annual

0.0 2.0 6.0 4.0 12.0 $574 $1,266 371 

Underground Injection Control Program -- Information Collection Request 
Table A-1B

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators

AB C D 

Hours and Costs per Response Total 

Description of Requirement Frequency (A) Legal Managerial Technical Clerical 

Unit 

Burden

Unit Labor 

Cost

Unit Non-Labor 

Cost (B)

No. of 

Responses

Notify Director within 24 hours of: planned physical changes to facility, changes that may result in noncompliance, compliance or noncompliance with a compliance schedule, any indication of possible endangerment of a 

Occasional

0.0 1.0 2.0 3.0 6.0 $267 $0 19 

Submit periodic updates of financial responsibility for closure that account for inflation. 

Occasional

0.0 1.0 0.0 0.0 1.0 $84 $0 124 

Report results of: any required mechanical integrity tests, other required tests, and well workovers.

Occasional

0.0 1.0 2.0 1.0 4.0 $210 $1,376 4 

Recordkeeping Requirements (Per Facility)Maintain monitoring information, calibration and maintenance records, required reports, application data, and monitoring results.

At least 3 years

0.0 0.0 0.0 4.0 4.0 $114 $0 371 

Closure Requirements (Per Well)Notify the Director before conversion or abandonment of the well or, in the case of area permits, before closure of the project.

One-time

0.0 0.5 0.0 1.0 1.5 $70 $0 1 

TOTAL 

5,319 

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 Request 
Table A-1B (continued)

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous 

ABCDE

Hours and Costs per Response Total Hours a

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit NonLabor Cost

Number of 

State 

Responses

Total 

Hours

Initial/Start-upPermit applicationsConsider the permit application, AoR, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and construction procedures as required at 146.14 and issue notice of intent to deny.

One-time

20.0 $828 $0 1 

Consider the permit application, AoR, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and construction procedures as required at 146.14 and prepare draft permit.

One-time

40.0 $1,657 $0 9 

Provide public notice of issuance of a draft permit or intent to deny.

One-time

1.0 $41 $0 10 

Consider public comments. One-time 6.0 $249 $0 10 Issue final permit decision. One-time

2.0 $83 $0 10 

Respond to comments. One-time

7.0 $290 $0 10 

Review notice of completion of construction. One-time 2.0 $83 $0 10 Review information related to aquifer exemption requests and forward to EPA region.

One-time

1.0 $41 $0 2 

Permit renewals/modificationsReview and respond to requests for permit modifications or re-issuance.

Occasional

30.0 $1,243 $0 14 

Underground Injection Control Program -- Information Collection Request 
Table A-1B (continued)

Annual Paperwork Burden and Costs Associated with Class I Nonhazardous 

ABCDE

Hours and Costs per Response Total Hours a

Description of Requirement Frequency (A)

Unit Burden 

(B)

Unit Labor 

Cost

Unit NonLabor Cost

Number of 

State 

Responses

Total 

Hours

Monitoring/TestingReview casing pressure test and logs. Every 5 years 4.0 $166 $0 51 Review pressure fall-off test. Annual 2.0 $83 $0 253 Review monitoring data submitted by operators.

Quarterly

2.0 $83 $0 1,012 

Other ReportingRespond to periodic notifications by owners and operators.

Occasional

1.0 $41 $0 7 

ClosureReview plugging and abandonment report. One-time 1.0 $41 $0 1 TOTAL 1,396 Notes:(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 
Underground 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 time 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 locate a subsurface zone suitable for 

injection. EPA assumes that 50 percent of the geological characterization required of permit applicants 

is customary business practice. Most of the incremental ICR burden is attributable to the requirement to 

submit detailed maps of local geology. 

 Operators would customarily develop and conduct formation 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 contingency plans to reduce potential liability should a 

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

EPA assumes that 25 percent of the burden of developing these plans is customary business practice. 

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

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

compiling this data is customary business practice. 

 As part of their overall industrial 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 plan and conducting waste compatibility testing is 

customary business practice. 

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

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

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

 Operators would routinely observe injection pressure, flow rate, volume, and temperature, and analyze 

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

nearly all the burden for continuous monitoring and 75 percent of the 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 information to demonstrate that the criteria 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 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 hazardous facilities include: permitting and start-up-related 

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

and closure-related paperwork. 

 Initial Permitting/Start-up 

 EPA estimates that, of the new Class I hazardous waste facility operating 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 for 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 estimates 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 application 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 corrective 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 Resource Conservation and Recovery Act (RCRA) 

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

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

estimate. 

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

submitting completion reports will be 49 hours per facility. The burden to perform 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, operators of newly constructed hazardous Class I wells 

will submit no-migration petitions to the EPA Regional Administrator. 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 petition in the process of 

permitting and preparing petitions for existing wells at their 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 years, after which operators must apply to renew their 

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

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

and petition modifications. 

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

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

submitting a letter of intent to continue operating the facility 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 information and those attachments that have changed or been 

updated since their last application, such as the AoR, corrective action plan, 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 contractor activities associated with preparing and 

submitting a request for a permit modification is 10 hours per 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 facilities 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 composition 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 operators would perform some chemical monitoring during 

the course of business. EPA estimates the additional 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 authorities 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 casing 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 temperature, noise, or other logs to check for movement along the borehole, is 

estimated to be 8 hours per facility. 

 Operators must conduct casing inspection 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 test every year; EPA estimates that 

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

burden associated with required annual ambient monitoring at Class I hazardous 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 includes 25 hours per report (100 hours annually) for quarterly 

monitoring reports, and 4 hours to report on the results of MITs. In addition, EPA assumes that 5 percent of 

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

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

devices). Operators will also spend one hour submitting 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, calibration and maintenance records, required reports, 

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

cost estimate for one year. 

 Closure 

 EPA estimates that the total annual burden associated with closure of a Class I hazardous well is 42 

hours. This includes 1.5 hours to notify the permitting authority prior to closing, 6 hours to perform pressure 

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

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

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

following closure. 

Class I Nonhazardous Facilities 

 Paperwork requirements for operators of Class I nonhazardous facilities include permitting and start-uprelated reporting, permit renewals and modifications, monitoring and testing, reporting and recordkeeping, and 

closure-related paperwork activities. 

 Initial Permitting/Start-up 

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

waste injection permits issued each year will be for new 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 nonhazardous 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 smaller AoR. Consequently, the burden for the AoR 

study and for developing a corrective action plan for wells 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 injectate; nor are they required to gather 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 burden 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 required 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 assumes that applicants for nonhazardous injection permit 

renewals will submit only those attachments to the application form that have changed since the original permit 

application. Preparing and submitting the updated materials needed for a permit renewal application 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 injectate periodically as normal business activities. However, to comply with UIC 

requirements, operators spend more time on these activities than they otherwise would. Class I nonhazardous 

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

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

test. In addition, approximately 20 percent 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 reporting 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 ambient monitoring and the pressure fall-off test. 

 EPA assumes that Class I nonhazardous 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 maintenance 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 Class I nonhazardous facilities associated 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 implementing 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 application reviewing applications 

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

hours reviewing requests for permit modifications or renewals. EPA regional offices review all no-migration 

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

facilities; however, state primacy agencies assist the regions with this review. States spend 28 hours per nomigration petition application and 10 hours per petition modification request on this assistance. 

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

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

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

facilities, and 26 hours reviewing reports and testing results associated 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 state 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 standards, and others will be withdrawn 

by owners. 

 The average burden for preparing permit application 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 individual or an area permit, the use of contractors, 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 directions and fill out the 

permit application form. With respect to the supporting documentation, EPA assumes 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 operator generally submits supporting 

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

customary business practice, to prepare the attachments to a Class II permit 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 proposed operating data; and 

 20 hours to prepare financial responsibility information. 
Table A-2

Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

ABCD

Hours and Costs per Response T

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No. of Responses 

Initial/Start-up Requirements Requirements associated with permit applications (Per Permit Application)Read permit application directions. One-time 0.0 0.0 0.5 0.5 1.0 $39 $0 8,983 Gather and submit: description of activities requiring a permit, facility name & address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, topographic maps, description of the business.

One-time

0.1 0.0 1.0 0.4 1.5 $69 $0 8,983 

For DI programs, gather and submit a list of all land owners within one quarter mile of the facility boundary. 

One-time

0.2 0.0 0.0 1.0 1.2 $47 $193 351 

Prepare and submit plugging and abandonment plan.

One-time

0.0 0.6 4.8 0.6 6.0 $302 $0 8,983 

Show evidence of financial responsibility for closure.

One-time

0.0 5.0 5.0 10.0 20.0 $948 $0 8,983 

Prepare and submit proposed Corrective Action Plan.

One-time

0.0 0.3 2.9 0.2 3.4 $172 $0 898 

Prepare and submit revised Corrective Action Plan.

One-time

0.0 1.0 9.6 0.7 11.3 $572 $0 180 

Prepare and submit Area of Review map. (State/DI Program performs study)

One-time

0.0 0.0 1.0 0.0 1.0 $49 $38 1,997 

Prepare and submit Area of Review map and study.

One-time

0.0 0.1 2.9 2.0 5.0 $206 $208 1,694 

Prepare and submit proposed operating data. One-time

0.0 0.1 1.8 0.1 2.0 $99 $0 8,983 

Prepare and submit geological data on the injection and confining zone.

One-time

0.0 0.5 8.0 1.0 9.5 $460 $0 8,983 

Prepare and submit name and depth to bottom of USDWs.

One-time

0.0 0.1 2.3 0.1 2.5 $123 $229 8,983 

Prepare and submit schematic of the well. One-time 0.0 0.0 2.8 0.2 3.0 $142 $0 8,983 Prepare and submit information to support an aquifer exemption request.

One-time

0.0 2.5 17.0 0.5 20.0 $1,053 $0 269 

For operators in DI states performing HF using diesel fuels, prepare and submit information recommended in DFHF Guidance (e.g., planned fracture extent, geologic information, AoR, construction information).

One-time

0.5 9.5 50.0 20.0 80.0 $3,850 $764 30 

Underground Injection Control Program -- Information Collection Request 
Table A-2

Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

ABCD

Hours and Costs per Response T

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No. of Responses 

Requirements associated with completion reports (Per Well)Prepare and submit completion report. One-time

0.0 0.0 1.5 2.5 4.0 $144 $0 8,585 

Perform and report on appropriate logs and other tests during construction.

One-time

0.0 0.2 1.9 0.2 2.4 $121 $4,586 1,318 

Demonstrate mechanical integrity. One-time

0.0 0.0 7.0 0.0 7.0 $341 $206 8,585 

Requirements associated with permit reviews/modifications (Per Permit/Per Operator)Respond to issues raised during permit review.

Every 5 years

0.0 0.5 2.0 0.5 3.0 $154 $0 1,765 

Prepare and submit request for permit modification.

Occasional

0.0 0.4 2.8 0.8 4.0 $193 $0 2,648 

Monitoring/Testing Requirements (Per Operator)Monitor the nature of injected fluids. As necessary 

to obtain 0.0 0.0 2.0 0.0 2.0 $97 $46 70,606 

Record injection pressure, flow rate, and cumulative volume.

At least every 30 days. 0.0 0.0 0.6 0.3 0.8 $35 $0 212,179 

Demonstrate mechanical integrity. Every 5 years

0.0 0.0 3.0 0.0 3.0 $146 $2,064 47,659 

Reporting Requirements (Per Operator)In DI programs, gather and submit groundwater monitoring data, analyses of injected fluids, a description of geologic strata, and other items as requested.

Occasional

0.0 3.0 22.0 5.0 30.0 $1,467 $0 33 

In DI programs, notify Regional Administrator 30 days prior to MIT.

Every 5 years

0.0 0.0 0.5 0.5 1.0 $39 $0 79 

Notify Director of (1) any planned physical changes to facility; (2) changes that may result in noncompliance, (3) permit transfers, (4) compliance or noncompliance with compliance schedules, (5) possible endangerment to a USDW.

Occasional

0.0 1.0 1.5 2.5 5.0 $228 $0 1,059 

Report monitoring data, including monthly records of injected fluids, any changes in characteristics or sources of injected fluids.

Annual

0.0 0.0 3.3 1.7 5.0 $210 $0 17,682 

Report MIT results. Annual 0.0 0.0 1.0 0.0 1.0 $49 $0 17,682 

Underground Injection Control Program -- Information Collection Request 
Table A-2

Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

ABCD

Hours and Costs per Response T

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No. of Responses 

Recordkeeping Requirements (Per Operator)Retain records of permitting data, nature and composition of injected fluids, and all monitoring results.

At least 3 years

0.0 0.0 1.0 3.0 4.0 $134 $0 17,652 

Closure Requirements (Per Operator)In DI programs, notify director of revisions to plugging and abandonment plan.

One-time

0.0 0.5 2.5 1.0 4.0 $192 $0 0 

Notify the Director before conversion or abandonment of the well, or in the case of area permits, before closure of the project.

One-time

0.0 1.0 0.0 2.0 3.0 $141 $0 1,044 

In DI programs, submit a plugging and abandonment report within 60 days after plugging a well.

One-time

0.0 0.0 4.5 1.5 6.0 $262 $275 41 

Other Requirements (Per Operator)In DI programs, submit revised demonstration of financial responsibility.

Occasional

0.0 0.5 0.5 1.0 2.0 $95 $0 69 

TOTALS 485,967 

Note: Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-2 (continued)

Annual Paperwork Burden and Costs Associated with Class II Wells: States

ABCD E 

Hours and Costs per Response Total Hours and Co

Description of Requirement Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Tota

Hours/Y

Initial/Start-upPermit applications (Per Permit Application)Review permit application and supporting documentation and prepare draft permit.

One-time

6.0 $249 $0 8,632 51

Consider public comments. One-time 2.0 $83 $0 8,632 17Issue final permit decision. One-time 2.0 $83 $0 8,632 17Respond to comments. One-time 4.0 $166 $0 8,632 34Review operator's AoR map and study. One-time 5.0 $207 $0 1,628 8Review operator's AoR map and perform AoR study.

One-time

2.5 $104 $0 1,997 4

Review completion report. One-time 2.0 $83 $0 8,250 16Review information related to aquifer exemption requests and forward to EPA region.

One-time

1.0 $41 $0 247 

Permit reviews/modifications (Per Operator)Review each permit to determine whether it should be modified, revoked and reissued, or terminated.

Every 5 years

1.0 $41 $0 1,696 1

Review request for permit modification or reissuance. Occasional 4.0 $166 $0 2,544 10

Monitoring/Testing (Per Operator)Review mechanical integrity test data submitted by operators.

Every 5 years

0.5 $21 $0 45,799 22

Review monitoring data submitted by operators.

Annual

0.3 $10 $0 16,963 4

RecordkeepingMaintain administrative record in DI programs.

One-time

1.0 $41 $0 0 

Underground Injection Control Program - Information Collection Request 
Table A-2 (continued)

Annual Paperwork Burden and Costs Associated with Class II Wells: States

ABCD E 

Hours and Costs per Response Total Hours and Co

Description of Requirement Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Tota

Hours/Y

Other Reporting (Per Operator)Respond to periodic notifications by owners and operators.

Occasional

2.0 $83 $0 1,018 2

Closure (Per Operator)For DI programs, review plugging and abandonment report.

One-time

1.0 $41 $0 0 

TOTAL 114,710 191Note: Numbers may not add due to rounding

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

 Based on previous studies of state AoR practices and requirements, EPA projects 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-referenced AoR studies, ensuring AoR coverage; 

 The operator has been granted a state variance based on factors relating to geologic 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 state primacy agencies perform all or most of the tasks 

involved in the AoR study. In these cases, 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 AoR 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 listing 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 action 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, the weighted average time to prepare a corrective action 

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

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

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

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

property ownership records and prepare the list. This unit 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, operators must submit completion reports for each new 

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

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

and 4 hours per well to fill out the completion form. The MIT will require 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 report on new well logs and tests, 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 services. The unit burden for operators assumes that operators will 

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 information to demonstrate that the criteria 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 the 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 recommended in the DFHF Guidance will submit the same types of 

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

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

extent and orientation of the planned fracture network, seismic history, and baseline geochemical data. The 

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

constructed appropriately; perform a pre-HF MIT; and demonstrate financial 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 cumulative volume during HF operations, perform an MIT if 

needed, monitor ground water quality if directed, and perform 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 are 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 raised 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 add wells to existing area permits, and for other reasons. EPA expects that 

preparing each request will take an average of 4 hours. 

 Monitoring/Testing 

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

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

separate operator in each state, since the operator would 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 injectate 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 analyze their injectate or, in some cases, 

send it to a commercial laboratory for analysis. 

 Most operators are required to observe 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 pressure, flow rate, and cumulative volume as a customary business practice. 

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

or 5 minutes, per well) per month. This represents the 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 forms, EPA assumes that 27 percent of operators 

will perform MITs on their wells each year. Each operator 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 spend about 5 hours to prepare annual monitoring reports. These reports 

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

27 percent of operators will spend 1 hour per operator 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 wells in DI states may be required 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, operators 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 operators 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 percent 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 permit 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 oversight of Class II programs is presented in Column A of Table A-2. 

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

applications. Primacy agency staff spend one hour to determine 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 state staff will spend 1 hour per request reviewing aquifer 
Underground 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 hours per report reviewing monitoring and MIT data or 

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

Burden Associated with Class III Wells 

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

monitoring and testing, reporting and recordkeeping, and closing their facilities, 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 the directions and filling out the application 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 stimulation 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 financial responsibility. 

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

10 hours each. Applicants in DI programs will spend 1.2 hours 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-part 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 prepare a completion report, 10 hours to demonstrate 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 demonstrate that the criteria 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 the Class III permit 

application process, and that applying for an aquifer 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 operators will have a formal or informal review of 

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

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

 Monitoring/Testing 

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

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

 Operators of Class III facilities will monitor injection pressure, 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 burden is approximately 4.6 hours per operator 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 quality at selected monitoring wells completed in the 

injection zone and overlying freshwater aquifers. Some active facilities monitor semi-monthly, while other 

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

facility has about 110 monitoring wells. As with pressure, flow, and volume monitoring, 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 increase 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. 
ABCD

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No of Respons

Initial/Start-up RequirementsRequirements associated with permit applications (Per Permit Application)Read permit application directions. One-time 0.0 0.0 0.5 0.5 1.0 $39 $0 Gather and submit the following information: (1) a description of activities requiring a permit, (2) facility name and address, (3) SIC codes, (4) ownership and facility status, (5) facility location, (6) listing of relevant permits or construction appro

One-time

0.5 2.0 4.7 2.8 10.0 $523 $0 

For DI programs, gather and submit a list of all land owners within one quarter mile of the facility boundary. 

One-time

0.2 0.0 0.0 1.0 1.2 $47 $193 

Prepare and submit plugging and abandonment plan. One-time 0.0 0.0 6.4 1.6 8.0 $357 $0 Show evidence of financial responsibility for closure. One-time 0.0 0.5 1.0 2.0 3.5 $148 $0 Prepare and submit proposed Corrective Action Plan. One-time 0.0 2.0 10.0 2.0 14.0 $713 $0 Prepare and submit revised Corrective Action Plan. One-time 0.0 1.0 8.0 1.0 10.0 $503 $0 Prepare and submit AoR map and study. One-time 0.0 3.2 25.5 3.4 32.0 $1,606 $1,139 Prepare and submit maps and cross-sections of USDWs within AoR, local geology, and regional geology.

One-time

0.0 0.0 18.0 4.0 22.0 $991 $229 

Prepare and submit proposed operating data, formation testing program, stimulation program, and injection procedure.

One-time

0.0 2.0 6.0 1.0 9.0 $489 $0 

Prepare and submit schematic of the well. One-time 0.0 0.0 4.2 0.8 5.0 $227 $0 Prepare and submit monitoring plan. One-time 0.0 0.0 12.0 4.0 16.0 $699 $0 Requirements associated with completion reports (Per Well)Prepare and submit completion form and supporting documentation (7520-9).

One-time

0.0 0.0 1.5 2.5 4.0 $144 $0 

Prepare and submit appropriate logs and tests during construction.

One-time

0.0 0.2 1.9 0.2 2.4 $121 $5,246 

Demonstrate mechanical integrity. One-time 0.0 1.0 8.0 1.0 10.0 $503 $4,586 Prepare and submit information to support an aquifer exemption request.

One-time

0.0 2.5 17.0 0.5 20.0 $1,053 $0 

Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)Respond to issues raised during permit review. Every 5 years 0.0 3.0 1.0 0.0 4.0 $301 $0 Prepare and submit request for permit modification. Occasional 0.0 2.0 22.0 4.0 28.0 $1,354 $0 Monitoring/Testing Requirements (Per Facility)Monitor the nature of injected fluids. As necessary 

to obtain 

representative 0.0 0.0 6.0 2.0 8.0 $349 $0 

Monitor injection pressure and flow rate or volume of injected fluids, or meter and record injected and produced fluid volumes.

Semi-monthly/ Continuous

0.0 0.0 3.3 1.3 4.6 $199 $0 4,4

Demonstrate mechanical integrity. Every 5 years 0.0 16.1 128.7 16.1 160.9 $8,084 $73,771 Monitor the fluid level in the injection zone where appropriate and monitor parameters chosen to measure water quality in the monitoring wells.

Semi-monthly/ monthly

0.0 0.0 27.5 3.0 30.5 $1,426 $0 2

Annual Paperwork Burden and Costs Associated with Class III Wells: Operators

Table A-3

Hours and Costs per Response 

Underground Injection Control Program -- Information Collection Request 
ABCD

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost No of Respons

Annual Paperwork Burden and Costs Associated with Class III Wells: Operators

Table A-3

Hours and Costs per Response 

Reporting 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.

Occasional

0.0 1.0 3.0 2.0 6.0 $287 $0 

Report to the Director on required monitoring, mechanical integrity tests, and other required tests.

Quarterly

0.0 1.0 10.0 19.0 30.0 $1,111 $0 6

Recordkeeping Requirements (Per Facility)Retain records of permitting data, calibration and maintenance data, and monitoring results.

At least 3 years 0.0 0.0 0.4 3.0 3.4 $105 $0 1

Closure Requirements (Per Facility)Notify the Director before conversion or abandonment of the well or in the case of area permits before closure of the project.

One-time

0.0 1.0 0.5 0.5 2.0 $123 $0 

In DI programs, submit a plugging and abandonment report within 60 days after plugging a well or at the time of the next quarterly report.

One-time

0.0 0.0 0.8 0.3 1.0 $44 $0 

Other Requirements (Per Facility)In DI programs, submit revised demonstration of financial responsibility.

Occasional

0.0 0.5 0.5 1.0 2.0 $95 $0 

TOTALS 6,176 Note: Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Table A-3 (continued)

Annual Paperwork Burden and Costs Associated with Class III Wells: States

ABCDE 

Hours and Costs per Response Total Hours and C

Program Oversight Activities Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Total Hours/Year 

Initial/Start-upPermit applications (Per Permit Application)Consider the permit application, area of review, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and 

t ti d d i ti f

One-time

20.0 $828 $0 13 260 

Consider the permit application, area of review, relevant maps and cross sections, fluid injection rate and volume, proposed contingency plans, monitoring plans, and 

t ti d d d ft

One-time

40.0 $1,657 $0 18 720 

Provide public notice of issuance of a draft permit or intent to deny.

One-time

2.0 $83 $0 48 96 

Consider public comments. One-time 8.0 $331 $0 48 384 Issue final permit decision. One-time 10.0 $414 $0 48 480 Respond to comments. One-time

15.0 $621 $0 48 720 

Review completion report. One-time

2.0 $83 $0 21 42 

Review information related to aquifer exemption requests and forward to EPA region.

One-time

1.0 $41 $0 0.2 0.2 

Underground Injection Control Program -- Information Collection Request 
Table A-3 (continued)

Annual Paperwork Burden and Costs Associated with Class III Wells: States

ABCDE 

Hours and Costs per Response Total Hours and C

Program Oversight Activities Frequency Unit Burden 

Unit Labor 

Cost

Unit NonLabor Cost Number of Responses Total Hours/Year 

Permit reviews/modifications (Per Facility)Review each permit to determine whether it should be modified, revoked and reissued, or terminated.

Every 5 years

4.0 $166 $0 18 71 

Review request for permit modification or reissuance. Occasional 20.0 $828 $0 23 460 

Monitoring/Testing (Per Facility)Review mechanical integrity test data submitted by operators.

Every 5 years

0.5 $21 $0 18 9 

Review monitoring data submitted by operators. Quarterly

0.25 $10 $0 354 88 

Other Reporting (Per Facility)Respond to periodic notifications by owners and operators.

Occasional

4.0 $166 $0 18 72 

Recordkeeping (Per Facility)Maintain administrative record (DI). One-time

4.0 $166 $0 0 0 

Closure (Per Facility)Review plugging and abandonment report (DI only).

One-time

4.0 $166 $0 0 0 

TOTAL 674 3,402 

Note: Numbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
Underground Injection Control Program – Information Collection Request Page A-33 

Reporting and Recordkeeping 

 Operators of Class III facilities will incur a burden 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 oversight of Class III programs is presented in Column A of Table A-3. 

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

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

whether to reissue, modify, or revoke each permit during the five-year review process, and 20 hours reviewing 

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

per report reviewing monitoring and MIT data or occasional 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 forwarding 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/endangering 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 required to close them and submit plugging and abandonment reports to states or 

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

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

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

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

Compensation, and Liability Act of 1980 or RCRA. EPA estimates that the operator burden associated with this 

one-time requirement to submit a plugging and abandonment 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 endangering Class V wells involves review by primacy 

agency staff of closure plans submitted by operators. EPA 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 paperwork 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 wells (MVWDWs) and large-capacity cesspools. 

 Inventory Activities 

 Recent efforts by the Regions and state primacy agencies 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 inventory information to the appropriate Regional or state 

primacy agency. 

 Activities Required Under the Class V Rule 

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

must seek waivers from the ban on existing motor vehicle 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 pre-closure notifications. 

 Note: While the Class V Rule required that all closure or permitting activities be completed by January 

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

applied for a permit), EPA assumes that existing wells will 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 cesspools will need to become familiar with the Class V 

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

each facility will require a total of 4.5 hours to complete 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 water protection area (SWPA) or other sensitive ground water 

area. These activities will require 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 MVWDWs must notify the UIC Program Director at least 

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

7520-17 or a state equivalent). These operators would incur a burden of 3 hours. 
Table A-4 

Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: Operators

AB C DE

Total Hours a

Description of Requirement Questions Frequency Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit Nonlabor Cost No. of Responses Tota

Hours/Y

Closure Requirements (Per Well)Submit a plugging and abandonment report within 60 days after plugging a well.

One-time

0 7.5 2.5 10.0 $238 $0 990 9,

TOTAL 990 9,Note:Numbers may not add due to rounding.

Underground Injection Control Program - Information Collection Request 
Table A-4 (continued)

Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: 

ABCDE

Hours and Costs per Response Total Hours 

Description of Requirement Frequency

Unit Burden 

(A)

Unit Labor 

Cost

Unit 

Nonlabor 

Cost

Number of 

Responses

Tot

Hours/

ClosureReview closure plan.

One-time 1.0 $41 $0 758 

TOTAL 758 Note:Numbers may not add due to rounding.

Underground Injection Control Program - Information Collection Request 
Table A-5

Annual Paperwork Burden and Costs Associated with Class V Wells: Operators

AB C D 

Hours and Costs per Response

Description of Requirement Frequency Legal Managerial Technical Clerical Unit Burden

Unit Labor 

Cost

Unit Non-labor 

Cost (A)

No. of 

Responses

Inventory RequirementsIn DI programs, submit inventory information prior to commencing injection.

One-time

0.0 0.0 0.0 0.5 0.5 $10 $0 24,86

Class V Rule Requirements for Owners/Operators of Large-Capacity CesspoolsRead regulations. One-time 0.0 0.0 3.0 0.0 3.0 $76 $0 Prepare and submit pre-closure notification (Form 7520-17).

One-time

0.0 0.5 0.8 0.3 1.5 $54 $0 

Class V Rule - Startup Requirements for Owners / Operators of Motor Vehicle Waste Disposal Wells Contact state or local agency to determine requirements.

One-time

0.0 0.0 1.0 0.0 1.0 $25 $0 3

Read regulations. One-time 0.0 0.0 3.0 0.0 3.0 $76 $0 3For wells that will close, sample injectate and maintain record.

One-time

0.0 0.0 1.0 0.5 1.5 $35 $706 3

Prepare and submit pre-closure notification (Form 7520-17).

One-time

0.0 0.5 0.8 0.3 1.5 $54 $0 3

For wells obtaining a waiver, conduct initial sampling.One-time

0.0 0.0 1.0 0.5 1.5 $35 $706 

For wells obtaining a waiver, prepare and submit permit application.

One-time

0.0 8.0 25.0 21.0 54.0 $1,510 $0 

Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal Wells Conduct quarterly injectate sampling. Quarterly 0.0 0.0 1.0 0.5 1.5 $35 $706 5,91Conduct annual sludge sampling (concurrent with injectate sampling).

Annual

0.0 0.0 1.0 0.5 1.5 $35 $1,847 1,47

Annual reporting and recordkeeping of all monitoring results.

Annual

0.0 0.0 3.0 1.0 4.0 $95 $0 1,47

TOTAL 

33,88

Notes:(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 Request 
Table A-5 (continued)

Annual Paperwork Burden and Costs Associated with Class V Wells: States

A B CD E 

Hours and Costs per Response Total Hours and Cost

Description of Requirement Frequency Unit Burden (A) Unit Labor Cost

Unit Nonlabor 

Cost

Number of 

Responses Total Hours/Year T

Initial/StartupReview inventory information. One-time 0.5 $21 $0 16,154 8,077  Primacy State Activities Associated With the Class V RuleProvide technical assistance to owners/operators (at start-up). One-time 1.0 $41 $0 78 78 Review and file pre-closure notifications. One-time 1.3 $52 $0 75 93 Review, approve, and file waivers/permit applications. One-time 8.3 $344 $0 3 27 Review and file annual monitoring reports. Annual 0.8 $33 $0 961 769 TOTAL 17,271 9,044 

$ 

Notes:(A) Unit burdens for initial/start-up activities reported on a per-permit basis. Unit burden for other activities reported on a per-operator basis.Numbers may not add due to rounding.

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

 The specific information required in a permit application 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 description of activities requiring a 

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

operators will also sample their injectate. The burden for these activities is estimated to be 55.5 hours, 

the majority of which is for preparing 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 Class V wells includes time associated with reviewing 

inventory information, processing permit applications and pre-closure notifications, and reviewing and 

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

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

 EPA estimates that states will spend 0.5 hours per Class 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 disposal wells and large-capacity cesspools. State primacy agencies will also 

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

Burden Associated with Class VI Wells 

 EPA’s estimate of the annual 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 type, injection depth waiver status, and number of facilities that are active 

during this ICR clearance period. As such, these burden estimates are not representative of any one situation 

under which a GS project will operate. 

Class VI Operators 

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

financial responsibility, monitoring and testing, AoR reevaluations and associated plan revisions, and closure 

and post-injection site care related paperwork activities. 

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

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

contractor labor and other contractor services are included in the operator costs presented in Column C of Table 

A-6. However, as geologic sequestration is a relatively new endeavor, there 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 operator burden to provide a conservatively large estimate of operator burden. 

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

even in the absence of regulation. Unit burden and costs used in Table A-6 represent the costs of performing 

each activity required of Class VI operators that are incremental to customary business practices. 
A B C D

Description Of Requirement Frequency

Technical 1 

(Engineer)

Technical 2 

(Geologist) Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Ho

Initial/Startup Requirements (Per Permit Application)

Requirements Associated with Permit ApplicationsPrepare and submit Class VI permit application, including attachments and the testing and monitoring plan, emergency and remedial response, injection wellplugging, and post-injection site care and site closure plan. One-Time 240 300 540 $58,524 $546,184 3.3 

 

Conduct 3D seismic survey to identify faults and 

fractures; obtain and analyze seismic history. One-Time 0 180 180 $19,074 $605,365 3.3 

 

Obtain geomechanical and geochemical information on injection zone, subsurface aquifers including all USDWs, and the confining zone in the area of review. One-Time 30 129 159 $17,012 $140,292 3.3 

 

Develop maps and cross sections of the injection zone, subsurface aquifers including all USDWs, and the confining zone in the area of review. One-Time 0 44 44 $4,705 $0 3.3 

 

Take initial samples to develop a geochemical 

baseline for injection zones and confining zones. One-Time 0 10 10 $1,060 $18,276 3.3 

 

Prepare geologic characterization report demonstrating: suitability of receiving zone, storage capacity and injectivity, trapping mechanism free of nonsealing faults, competent confining system, etc. One-Time 0 240 240 $25,432 $0 3.3 

 

Demonstrate financial responsibility to ensure funds 

will be available for required future actions. One-Time 40 0 40 $4,456 $0 3.3 

 

Conduct aerial and database search for artificial penetrations (wells) within the area of review; determine integrity/plugging status of each. One-Time 140 300 440 $47,385 $101,646 3.3 

 

Perform complex modeling of CO2 fluid flow and 

migration (reservoir simulations) and prepare AoR and corrective action plan. One-Time 724 1,200 1924 $207,809 $0 3.3 

 

Compile and submit information to support an injection depth waiver application. One-Time 100 200 300 $32,333 $0 1.0 

 

Hours and Costs Per Response Total 

Table A-6

Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators

Underground Injection Control Program -- Information Collection Request 
A B C D

Description Of Requirement Frequency

Technical 1 

(Engineer)

Technical 2 

(Geologist) Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Ho

Hours and Costs Per Response Total 

Table A-6

Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators

Requirements Associated with Injection Well ConstructionDesign and install equipment for injection wells to 

measure: injected volumes, pressure, flow rates, and annulus pressure. One-Time 0 0 0 $0 $399,518 3.3 

Install check/shut-off valve on injection well. One-Time 0 0 0 $0 $2,759 3.3 

Construct monitoring wells. One-Time 0 0 0 $0 $2,370,318 

3.3

Design and install equipment for monitoring wells to 

measure: pressure, temperature, resisitivity, salinity, CO2, and any other required parameters. One-Time 0 0 0 $0 $169,956 3.3 

Monitoring/Testing Requirements (Per Operator)

Analyze injectate stream and perform corrosion 

monitoring. Quarterly 62 0 62 $6,851 $16,303 13.3 

Operate and maintain monitoring wells and the 

monitoring equipment within them. Annual 13 0 13 $1,395 $462,195 3.3 

Conduct periodic monitoring of groundwater quality

and geochemistry. Monthly 21 0 21 $2,339 $10,906 40.0 Conduct external mechanical integrity tests. Annual 0 0 0 $0 $181,804 3.3 

Conduct pressure fall-off testing.

Every Five 

Years 0 0 0 $0 $34,268 0.7 

Conduct 3D seismic survey to track movement of the 

CO2 plume and pressure front.

Every Five 

Years 0 0 0 $0 $1,194,570 0.7 

Activities Associated with Area of Review Reevaluations

Conduct updated AoR modeling. Based on new results, update AoR and Corrective Action Plan, Testing and Monitoring Plan, and Emergency and Remedial Response Plan.

Every Five Years 0 1,118 1,118 $124,536 $0 0 

Underground Injection Control Program -- Information Collection Request 
A B C D

Description Of Requirement Frequency

Technical 1 

(Engineer)

Technical 2 

(Geologist) Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Ho

Hours and Costs Per Response Total 

Table A-6

Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators

Reporting and Recordkeeping Requirments (Per Operator)Report to regulators; maintain records of data from all 

data gathering activities. Semi-Annual 33 0 33 $3,676 $0 6.7 

Plugging, Post-Injection Site Care, and Site Closure Requirements (Per Operator)

Demonstrate financial ability (accounting for inflation) to close site.

PostInjection, One-Time 8 0 8 $891 $0 0 

Perform a MIT prior to plugging the injection well.

PostInjection, One-Time 0 0 0 $0 $34,776 0 

Conduct ground water monitoring - operate and 

maintain monitoring wells and the monitoring equipment within them.

PostInjection, Annual 0 0 0 $0 $531,971 0 

Track the CO2 plume and pressure front.

PostInjection, Every 5 0 0 0 $0 $1,194,570 0 

Submit results of post-injection monitoring.

PostInjection, Every 5 40 0 40 $4,456 $0 0 

TOTAL 112.3 

 

Notes:

(A) Unit Non-Labor Cost inflated by 20% to account for G&ANumbers may not add due to rounding.

Underground Injection Control Program -- Information Collection Request 
AB C DE 

Description Of Requirement Frequency Unit Burden

Unit Labor 

Cost

Unit NonLabor Cost 

(A)

Number of 

Responses

Total 

Hours/ Year

To

Cost

Initial/Startup Requirements (Per Permit Application)Review the permit application and other information submitted by the operator, considering: AoR, relevant maps, site geology, formation testing results, well schematics and construction procedures, proposed injection procedure, status of corrective action on wells in the AoR, well logging, testing, and mechanical integrity data, and project plans. One-time $32,311 $0 0.33 780 260.0 $Review financial responsibility demonstration. One-time $4,142 $0 0.33 100 33.3 Determine and specify tubing, packing, casing, and cementing requirements based on review of information submitted by operator. One-time $5,799 $0 0.33 140 46.7 Witness logging and testing. One-time $828 $0 0.33 20 6.7 Review applications for waviers to inject above the lowermost underground source of drinking water. One-time $8,285 $0 0.33 200 66.7 Monitoring and RecordkeepingReview reports submitted by operators; recordkeeping of data from all data gathering activities. Annual 40 $1,657 $0 0 0 Review mechanical integrity test data. Annual 14 $559 $0 0 0 Area of Review ReevaluationReview updated AoR modeling and updated plans.

Every 5 years 150 $6,214 $0 0 0 

Site ClosureReview relevant data prior to granting approval for plugging and abandonment of a well. One-time 40 $1,657 $0 0 0 Project-Independent ActivitiesPrepare and submit primacy application. One-time $43,081 $0 2.3 2,427 1,040 $1TOTAL 4.0 2,840 1

$ 

Notes:Numbers may not add due to rounding.

Annual Paperwork Burden and Costs Associated with Class VI Wells: States

Table A-6 (continued)

Hours and Costs Per Response Total Hours and Costs

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

 Initial Permitting/Start-up 

 EPA estimates that the operator burden associated 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-Injection 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 and 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 confining zone in the AoR (159 hours). 

 Develop maps and cross-sections of the injection 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 presence of a trapping mechanism free of non-sealing faults, and a 

competent confining zone (240 hours). 

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

responsibility for these activities (40 hours). 

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

integrity and plugging status of each (440 hours). 

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

delineate the AoR (1,924 hours). 

 Monitoring/Testing 

 Class VI well operators will be required to perform 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 equipment 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 plume and pressure front. 

 Area of Review Reevaluations 

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

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

Corrective Action Plan, the Testing and 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 inflation; 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 operators will reevaluate the AoR and update the 

aforementioned plans and submit them to the primacy agency 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 operators 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 every six months (or 66 hours per year) to report the 

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

 Closure and Post-Injection 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 demonstrate financial ability (accounting for inflation) to 

properly close the site. This occurs once at the beginning of the post-injection period. Subsequently, 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 per operator, every five years. 

 Burden on Primacy Agencies Associated with Class VI Wells 

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

permit applications, monitoring and testing data, AoR reevaluations, and closure and post-injection site care 

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

reevaluations or closure and post-injection 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 hours 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 reviewing the draft project plans and financial 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 results. State primacy agencies will review modeling updates to the AoR 

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

States as Respondents 

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

and the UIC measures reporting process 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 estimates the annual burden 

associated with this effort will be 60 hours per state 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 this 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, training, or other information to well 

operators. 

State Activities Associated with 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 currently report via the 7520 forms, the inventory, and the 

measures data to Headquarters. (Once they 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 the burden and cost savings to states 

associated with the national UIC database. 

Start-up costs for states that have UIC databases include the costs associated 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 these programs is about 310 hours. Annualizing 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 setting 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 which 25 hours are state burden. 

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

database would be designed to the needs of the National UIC Database and Headquarters 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 database. 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 need 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 validation issues. EPA estimates that these tasks will 

require 4 hours, and be incurred twice annually (8 hours total).
Table A-7

Annual State Burden and Cost for Program Oversight and Reporting

A BC D E 

Hours and Costs per Response Total Hours and Cost

Description of Requirement Frequency Unit Burden

Unit Labor 

Cost

Unit Nonlabor 

Cost

Number of 

Responses

Total 

Hours/Year Total Co

Program OversightOversee and implement UIC program in the State, for example, update regulations or guidances as needed. 

Ongoing

1,040 $43,081 $0 58 60,320 $2,

7520 Forms ReportingComplete and submit Permit Review and Issuance Form (7520-1)

Annual

4.5 $186 $0 18 83 

Complete and submit Compliance Evaluation Form (7520-

2A)

Semi-annual

6.0 $249 $0 37 220 

Complete and submit Compliance Evaluation for Significant Non-Compliance Form (7520-2B)

Semi-annual

5.5 $228 $0 37 202 

Complete and submit Mechanical Integrity Tests/Remedial Action Form (7520-3)

Annual

5.0 $207 $0 18 92 

Complete and submit Quarterly Exceptions List Form (7520-4)

Quarterly

2.0 $83 $0 73 147 

Inventory and Measures ReportingConduct inventory-related activities, e.g., review operator data and report to EPA's online inventory data system.

Annual

60 $2,485 $0 18 1,100 

Report on UIC Measures to Headquarters Annual

60 $2,485 $0 18 1,100 

Activities related to populating the National UIC Database Start-up activities (per program)Develop data to meet UIC database needs (programs with UIC databases)

One-time

10 $428 3,782 $ 7 76 

Build data flow through data node (programs with UIC databases)

One-time

25 $1,036 2,082 $ 7 183 

Build data flow through data node (programs without databases)

One-time

8 $345 4,219 $ 5 42 

Ongoing activities (per program)Enter UIC data into state database Ongoing 40 $1,657 $0 40 1,587 Data flow and QA checks Semi-annual 4 $166 $0 79 317 

RecordkeepingMaintain records of 7520 forms Ongoing 40 $1,657 $0 18 733 

435 66,201 $2,

Notes:There may be more than one agency per state with Primacy authority.

EPA assumes that once states transition to electronic reporting, they will no longer complete 7520 forms or submit inventory and measures data to EPA. See AppendiNumbers may not add due to rounding.

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

A.2 Estimating the Respondent Universe 

 In this section, EPA describes the number of respondents subject to each paperwork 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 assumptions of the number of permittees subject to each 

paperwork requirement, e.g., the number of permit applications or well closures expected, or the percent of 

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

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

through A-7, along with EPA’s description of each activity. 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 which 140 inject hazardous waste, and 

705 inject nonhazardous waste. 

 Class I Hazardous 

 According to EPA’s inventory, there are 140 Class I hazardous 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 the remaining two for newly constructed facilities). EPA 

further anticipates that 12 Class I hazardous facility operators 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 will apply for aquifer exemptions each year, and that all 

of these will constitute non-substantial revisions to their state’s UIC program. All operators of Class I hazardous 

waste facilities must monitor and report at various frequencies (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 facilities, 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 facility operators will renew their permits each year, and 9 

Class I nonhazardous facility operators will modify their permits 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-substantial revisions to their state’s UIC program. Every operator of a Class I 

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

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

Class II 

 The UIC inventory includes 176,516 Class II wells. EPA assumes that the typical 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 life of this ICR. Details of the numbers of 

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

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

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

permit applications, and the remaining applicants will submit an AoR map and an AoR study as part of the 

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

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

these owners or operators to revise 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 using diesel fuels and be subject to the 

permitting and monitoring and reporting recommendations in the DFHF Guidance. 

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

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

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

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

issues raised during the reviews. In addition, EPA expects that 2,648 Class II operators 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 operators 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 abandonment plan, triggering a revision to the plugging and 

abandonment plan. 

Class III 

 EPA estimates that there are approximately 171 facilities with Class III wells (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/other facility has 2 wells. 

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

operators each year. EPA estimates that, on average, 0.2 Class III 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. 

 Operators of all 171 Class III facilities will monitor injection 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 analyses of their injectate once each year, and operators 

of salt solution mining facilities will perform two-part MITs on all of their wells every five years. All uranium 

well operators monitor water quality in the injection zone and overlying freshwater aquifers either semimonthly or monthly. EPA estimates that approximately 2 Class III operators will close 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 Class 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 obtain a permit by 2007 (the burden associated with these 

activities was estimated in previous UIC Program ICRs). EPA assumes that most 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 expected to be identified during the course of inspections or other 

activities. EPA understands that primacy agencies have 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 operators of 20 large-capacity cesspools need to close 

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

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

clearance period. Furthermore, operators of 1,479 MVWDWs that have opted to obtain 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 clearance 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 annualized 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 subsequent drilling procedures take up to a few years to complete. 

Thus, EPA assumes that by the end of the clearance period, 10 wells will be in operation, 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 perform AoR reevaluations or post-injection site care /site closure activities 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 reflects the fact that, in some states, 

more than one agency oversees UIC activities (e.g., states typically regulate Class 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 transfer 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 the 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-reporting in 2015; 10 programs are expected to do so in 

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