Geologic Sequestration of Carbon 

Dioxide

Draft Underground Injection Control 

(UIC) Program Class VI Well 

Recordkeeping, Reporting, and Data 

Management Guidance for Owners and 

Operators
Office of Water (4606M)

EPA 816-P-13-001

www.epa.gov/safewater

March 2013 
Draft UIC Program Class VI Well Recordkeeping, iii March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Disclaimer 

The Class VI injection well classification was established by the Federal Requirements Under 

the Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic 

Sequestration (GS) Wells (75 FR 77230, December 10, 2010), referred to as the Class VI Rule, 

which establishes a new class of injection well (Class VI). 

The Safe Drinking Water Act (SDWA) provisions and the United States Environmental 

Protection Agency (EPA) regulations cited in this document contain legally-binding 

requirements. In several sections, this guidance document makes suggestions and offers 

alternatives that go beyond the minimum requirements indicated by the Class VI Rule. This is 

intended to provide information and suggestions that may be helpful for implementation efforts. 

Such suggestions are prefaced by “may” or “should” and are to be considered advisory. They are 

not required elements of the Rule. Therefore, this document does not substitute for those 

provisions or regulations, nor is it a regulation itself, so it does not impose legally-binding 

requirements on EPA, states, or the regulated community. The recommendations herein may not 

be applicable to each and every situation. 

EPA and state decision makers retain the discretion to adopt approaches on a case-by-case basis 

that differ from this guidance where appropriate. Any decisions regarding a particular facility 

will be made based on the applicable statutes and regulations. Mention of trade names or 

commercial products does not constitute endorsement or recommendation for use. EPA is taking 

an adaptive rulemaking approach to regulating Class VI injection wells, and the agency will 

continue to evaluate ongoing research and demonstration projects and gather other relevant 

information as needed to refine the Rule. Consequently, this guidance may change in the future 

without a formal notice and comment period. 

While EPA has made every effort to ensure the accuracy of the discussion in this document, the 

obligations of the regulated community are determined by statutes, regulations, or other legally 

binding requirements. In the event of a conflict between the discussion in this document and any 

statute or regulation, this document would not be controlling. 

Note that this document only addresses issues covered by EPA’s authorities under SDWA. Other 

EPA authorities, such as Clean Air Act (CAA) requirements to report carbon dioxide injection 

activities under the Greenhouse Gas Mandatory Reporting Rule (GHG MRR) are not within the 

scope of this document. 
Draft UIC Program Class VI Well Recordkeeping, iv March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Executive Summary

EPA’s Federal Requirements Under the Underground Injection Control (UIC) Program for 

Carbon Dioxide (CO2) Geologic Sequestration (GS) Wells, codified in the U.S. Code of Federal 

Regulations [40 CFR 146.81 et seq.], known as the Class VI Rule, establishes a new class of

injection well, Class VI, and sets minimum technical criteria for Class VI injection wells for the 

purposes of protecting underground sources of drinking water (USDWs). This document is part 

of a series of guidance documents developed to support owners or operators of Class VI wells 

and the UIC Program permitting authorities. 

Under the Class VI Rule, owners or operators of Class VI wells are required to site, construct, 

and operate their wells according to the specific technical criteria that address specific GS

activities: site characterization; area of review (AoR) delineation and corrective action; well 

construction and operation; financial responsibility; testing and monitoring; reporting and 

recordkeeping; post-injection site care (PISC) and site closure; and emergency and remedial 

response. Data management, recordkeeping, and reporting are important components of the UIC 

Program and help ensure that the activities and operations regulated under the program are 

conducted as planned, are compliant with the regulations and permit conditions, and, ultimately, 

are sufficiently protective of USDWs.

Additionally, EPA is implementing an adaptive rulemaking approach to the Class VI Rule, 

whereby the agency plans to collect and review data every six years on GS projects to determine 

whether the appropriate amount and types of information and appropriate documentation are 

being collected, as well as to determine if modifications to the requirements are necessary. 

Effective GS data management significantly impacts the effectiveness of this effort. 

This guidance closely references other UIC Program Class VI guidance documents for technical 

details and its content complements the information given in the UIC Program Class VI Well 

Recordkeeping, Reporting, and Data Management Guidance for Permitting Authorities. This 

guidance is intended to describe specific information that owners or operators of Class VI wells 

are required or recommended to submit during each GS activity under the Class VI Rule. 

Additionally, the Class VI Rule, at 40 CFR 146.91(e), requires owners or operators of Class VI

wells to submit all required reports, submittals, and notifications to EPA in an approved 

electronic format. Therefore, this guidance document also discusses EPA’s electronic reporting 

and data management system.

1

 Following the introductory section that describes the purpose and 

organization of the document, Sections 2 through 6 describe reporting, recordkeeping, and data 

management activities that take place in the different phases of a GS project’s life cycle. Section 

7 describes the centralized, integrated electronic reporting system maintained by EPA, presenting

1 At the time this draft document was published, the central data system for Class VI data was under development. 

To avoid publishing incomplete information, this draft contains a placeholder for the description of GS data 

management through the use of the central data system. 
Draft UIC Program Class VI Well Recordkeeping, v March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

the overall electronic data submission procedures and data management operations for owners or 

operators of Class VI wells.
Draft UIC Program Class VI Well Recordkeeping, vi March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Table of Contents

Disclaimer ..................................................................................................................................... iii

Executive Summary ..................................................................................................................... iv

Table of Contents ......................................................................................................................... vi

List of Tables ................................................................................................................................ ix

List of Figures ............................................................................................................................... ix

Acronyms and Abbreviations ...................................................................................................... x

Definitions ..................................................................................................................................... xi

1 Introduction ........................................................................................................................... 1

1.1 Purpose of Guidance ............................................................................................................ 1

1.2 GS Project Phases and Reporting Requirements ................................................................. 3

1.2.1 Pre-Injection Phase Reporting ....................................................................................... 6

1.2.2 Injection Phase Reporting ............................................................................................. 7

1.2.3 Post-Injection Phase Reporting ..................................................................................... 7

1.3 Organization of this Document ............................................................................................ 8

2 Class VI Rule Reporting and Recordkeeping Requirements ......................................... 10

2.1 Electronic Reporting Requirement .................................................................................... 10

2.2 Data Format ....................................................................................................................... 10

2.3 Recordkeeping Requirements ............................................................................................ 11

3 Pre-Injection Phase Reporting and Recordkeeping: Prior to Construction ................. 13

3.1 Permit Application Requirements ..................................................................................... 13

3.2 Site Characterization .......................................................................................................... 14

3.2.1 Maps of AoR and Tabulation of Wells ....................................................................... 15

3.2.2 Detailed Geologic and Hydrogeologic Site Characterization ..................................... 16

3.2.3 Geochemical Characterization .................................................................................... 23

3.2.4 Geophysical Characterization ...................................................................................... 24

3.2.5 Baseline Surface Air and/or Soil Gas Characterization .............................................. 25

3.2.6 Proposed Pre-Operational Formation Testing Program .............................................. 25

3.2.7 Demonstration of Storage Capacity ............................................................................ 26

3.3 AoR Delineation and Corrective Action ........................................................................... 27

3.3.1 AoR and Corrective Action Plan ................................................................................. 27

3.3.2 AoR Delineation .......................................................................................................... 28

3.3.3 Corrective Action ........................................................................................................ 29

3.4 Financial Responsibility Demonstration ........................................................................... 30

3.4.1 Financial Instruments .................................................................................................. 31

3.4.2 Cost Estimates ............................................................................................................. 32

3.5 Proposed Activities and Project Plans ............................................................................... 32

3.5.1 Proposed Project Plans ................................................................................................ 33

3.5.2 Alternative PISC Timeframe ....................................................................................... 35
Draft UIC Program Class VI Well Recordkeeping, vii March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.5.3 Proposed Operating Information ................................................................................. 36

3.5.4 Proposed Well Construction Information .................................................................... 36

3.6 Injection Depth Waivers .................................................................................................... 39

3.6.1 Site Characterization Data to Support Injection Depth Waivers ................................. 39

3.6.2 Modeling Demonstration that USDWs Above and Below the Injection Zone are 

Protected ...................................................................................................................... 40

3.6.3 Well Design and Construction .................................................................................... 41

3.6.4 Testing and Monitoring ............................................................................................... 42

3.6.5 Site Resource Use Information .................................................................................... 43

3.6.6 Emergency and Remedial Response and Financial Responsibility ............................. 45

3.7 Wells Transitioning from Class II to Class VI .................................................................. 46

3.7.1 Well Construction ........................................................................................................ 46

3.7.2 Aquifer Exemptions .................................................................................................... 46

3.8 Reporting and Recordkeeping Schedule ............................................................................ 49

4 Pre-Injection Phase Reporting and Recordkeeping: Prior to Injection ........................ 51

4.1 Final AoR and Corrective Action Status ........................................................................... 51

4.2 Site Characterization .......................................................................................................... 52

4.2.1 Well Logs and Core Analyses ..................................................................................... 52

4.2.2 Injection Zone Conditions ........................................................................................... 54

4.2.3 Confining Zone and Injection Zone Properties ........................................................... 54

4.2.4 Updates to Site Characterization Data ......................................................................... 55

4.2.5 Verification of Hydrogeologic Characteristics of the Injection Zone(s) ..................... 55

4.2.6 Compatibility of the Carbon Dioxide Stream with the Subsurface and Well 

Components ................................................................................................................. 56

4.3 Injection Well Construction and Testing ........................................................................... 57

4.4 Final Project Plans and Alternative PISC Timeframe ....................................................... 59

4.5 Reporting and Recordkeeping Schedule ............................................................................ 59

5 Injection Phase Reporting and Recordkeeping ................................................................ 61

5.1 Injection Well Operation ................................................................................................... 61

5.1.1 Injection Well Monitoring ........................................................................................... 61

5.1.2 Alarms and Automatic Shut-Off Devices ................................................................... 62

5.2 Operational Testing and Monitoring ................................................................................. 62

5.2.1 Carbon Dioxide Stream Monitoring ............................................................................ 63

5.2.2 Corrosion Monitoring .................................................................................................. 63

5.2.3 Continuous Monitoring to Demonstrate Internal Mechanical Integrity ...................... 64

5.2.4 External MIT ............................................................................................................... 65

5.2.5 Pressure Fall-Off Testing ............................................................................................ 65

5.2.6 Ground Water Quality and Geochemistry Monitoring ................................................ 66

5.2.7 Pressure-Front Tracking .............................................................................................. 67

5.2.8 Carbon Dioxide Plume Tracking ................................................................................. 68

5.2.9 Surface Air and/or Soil Gas Monitoring ..................................................................... 70

5.2.10 Additional Monitoring ............................................................................................ 70

5.3 AoR Reevaluation and Phased Corrective Action ............................................................. 71

5.4 Financial Responsibility Updates and Notifications ......................................................... 72
Draft UIC Program Class VI Well Recordkeeping, viii March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

5.5 Project Plan Updates .......................................................................................................... 73

5.6 Emergency and Remedial Response .................................................................................. 73

5.7 Reporting and Recordkeeping Schedule ............................................................................ 74

6 Post-Injection Phase Reporting and Recordkeeping ....................................................... 78

6.1 Injection Well Plugging ..................................................................................................... 78

6.1.1 Notice of Intent to Plug the Well ................................................................................. 78

6.1.2 Well Plugging Report .................................................................................................. 78

6.2 PISC and Site Closure ....................................................................................................... 79

6.2.1 Updated PISC and Site Closure Plan .......................................................................... 80

6.2.2 Monitoring During PISC ............................................................................................. 80

6.2.3 Non-Endangerment Demonstration ............................................................................. 82

6.2.4 Site Closure-Related Reporting ................................................................................... 82

6.3 Reporting and Recordkeeping Schedule ............................................................................ 84

7 GS Data Submission and Management ............................................................................. 86

Appendix A. Draft Class VI Rule Reporting Data Elements Matrix ................................... A-1
Draft UIC Program Class VI Well Recordkeeping, ix March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

List of Tables

Table 1-1. Reporting requirements for the different phases of a GS project. ................................. 5

Table 3-1. Reporting and recordkeeping schedule for Class VI activities that take place prior to 

construction. .................................................................................................................................. 49

Table 4-1. Reporting and recordkeeping schedule for Class VI activities that take place after well 

construction but prior to injection. ................................................................................................ 60

Table 5-1. Reporting and recordkeeping schedule for the injection phase. .................................. 75

Table 6-1. Reporting and recordkeeping schedule for the post-injection phase. .......................... 84

Table A-1. Class VI Rule reporting data elements matrix (DRAFT). ........................................ A-1

List of Figures 

Figure 1-1. The phases of a GS project’s life cycle with associated activities required by the 

Class VI Rule and the sections of this guidance document that address each activity. .................. 4
Draft UIC Program Class VI Well Recordkeeping, x March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Acronyms and Abbreviations

AoR Area of review

API American Petroleum Institute

CAA Clean Air Act

CCS Carbon capture and storage 

CFR Code of Federal Regulations

CO2 Carbon dioxide 

EPA Environmental Protection Agency 

FR Federal Register

GHG MRR Greenhouse Gas Mandatory Reporting Rule 

GIS Geographic information system

GPD Gallons per day 

GS Geologic sequestration 

LAS Log ASCII Standard

MIT Mechanical integrity test

PDF Portable document format 

PISC Post-injection site care 

QA/QC Quality assurance/quality control 

RCRA Resource Conservation and Recovery Act 

SDWA Safe Drinking Water Act

SIC Standard Industrial Classification

TDS Total dissolved solids 

UIC Underground Injection Control 

USDW Underground source of drinking water 
Draft UIC Program Class VI Well Recordkeeping, xi March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Definitions 

Key to definition sources: 

1: Class VI Rule Preamble.

2: 40 CFR 144.3. 

3: 40 CFR 146.81(d). 

4: This definition was drafted for the purposes of this document. 

5: EPA’s UIC website (http://water.epa.gov/type/groundwater/uic/glossary.cfm).

6: 40 CFR 144.6(f) and 144.80(f). 

Annulus means the space between the well casing and the wall of the borehole; the space 

between concentric strings of casing; the space between casing and tubing.1

Aquifer exemption refers to a special exemption that removes an aquifer or part of an aquifer 

from SDWA protection when certain requirements [40 CFR 146.4] are met to demonstrate that 

the exempted aquifer does not currently serve as source of drinking water and has no real 

potential to be used as drinking water source in the future. One basis for demonstrating that an 

aquifer will not be used in the future is to show that it is mineral producing or capable of mineral 

production.4

Area of review (AoR) means the region surrounding the GS project where USDWs may be 

endangered by the injection activity. The AoR is delineated using computational modeling that 

accounts for the physical and chemical properties of all phases of the injected carbon dioxide 

stream and displaced fluids, and is based on available site characterization, monitoring, and 

operational data as set forth in 40 CFR 146.84.3

Automatic shut-off device refers to a valve coupled with a control device that closes the valve 

when a pre-determined set pressure or flow value is exceeded. Shut-off devices in injection wells 

can automatically shut down injection activities when operating parameters unacceptably diverge 

from permitted values.

4

Carbon dioxide plume means the extent underground, in three dimensions, of an injected 

carbon dioxide stream.3

Carbon dioxide stream means carbon dioxide that has been captured from an emission source 

(e.g., a power plant), plus incidental associated substances derived from the source materials and 

the capture process, and any substances added to the stream to enable or improve the injection 

process. This subpart [subpart H of 40 CFR 146] does not apply to any carbon dioxide stream 

that meets the definition of a hazardous waste as defined by the Resource Conservation and 

Recovery Act (RCRA) under 40 CFR part 261.3.3

Casing means pipe material placed inside a drilled hole to prevent the hole from collapsing. The 

two types of casing in most injection wells are (1) surface casing, the outer-most casing that 

extends from the surface to the base of the lowermost USDW and (2) long string casing, which 

extends from the surface to or through the injection zone.1
Draft UIC Program Class VI Well Recordkeeping, xii March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Cement means material used to support and seal the well casing to the rock formations exposed 

in the borehole. Cement also protects the casing from corrosion and prevents movement of 

injectate up the borehole. The composition of the cement may vary based on the well type and 

purpose; cement may contain latex, mineral blends, or epoxy.1

Class I well means a technologically sophisticated well that injects wastes into deep, isolated 

rock formations below the lowermost USDW. Class I wells may inject hazardous waste, nonhazardous industrial waste, or municipal wastewater.5

Class II wells means wells that inject brines and other fluids associated with oil and gas

production, or storage of hydrocarbons. Class II well types include salt water disposal wells, 

enhanced oil recovery wells, enhanced gas recovery wells, and hydrocarbon storage wells.5

Class V well means a well designed and constructed for injection, but not included in the 

definitions of Class I, II, III, IV, or VI wells. Class V wells inject non-hazardous fluids into or 

above a USDW and are typically shallow, on-site disposal systems; however, this class also 

includes some deeper injection operations. There are approximately 20 subtypes of Class V

wells.5

Class VI wells means wells that are not experimental in nature that are used for GS of carbon 

dioxide beneath the lowermost formation containing a USDW; or, wells used for GS of carbon 

dioxide that have been granted a waiver of the injection depth requirements pursuant to 

requirements at 40 CFR 146.95; or, wells used for GS of carbon dioxide that have received an 

expansion to the areal extent of an existing Class II enhanced oil recovery or enhanced gas 

recovery aquifer exemption pursuant to 40 CFR 146.4 and 144.7(d).6

Computational code refers to a series of interrelated mathematical equations solved by 

computer to represent the behavior of a complex system. For the purposes of GS, computational 

models represent, at a minimum, the flow and transport of multiple fluids and components in 

varying phases through porous media. Computational codes offer the ability to predict fluid flow 

in the subsurface using scientifically accepted mathematical approximations and theory. The use 

of computational codes is necessary because the mathematical formulations describing fluid flow 

are complicated and in many cases, non-linear. Several codes have been specifically developed 

or tailored for injection activities similar to GS, and can be used for this purpose.4

Computational model means a mathematical representation of the injection project and relevant 

features, including injection wells, site geology, and fluids present. For a GS project, site specific 

geologic information is used as input to a computational code, creating a computational model 

that provides predictions of subsurface conditions, fluid flow, and carbon dioxide plume and 

pressure front movement at that site. The computational model comprises all model input and 

predictions (i.e., output). 4

Confining zone means a geologic formation, group of formations, or part of a formation 

stratigraphically overlying the injection zone(s) that acts as barrier to fluid movement. For Class 

VI wells operating under an injection depth waiver, confining zone means a geologic formation, 
Draft UIC Program Class VI Well Recordkeeping, xiii March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

group of formations, or part of a formation stratigraphically overlying and underlying the 

injection zone(s).3

Corrective action means the use of UIC Program Director-approved methods to ensure that 

wells within the area of AoR do not serve as conduits for the movement of fluids into 

underground sources of drinking water (USDWs).3

Corrosive means having the ability to wear away a material by chemical action. Carbon dioxide 

mixed with water forms carbonic acid, which can corrode well materials.1

Enhanced gas recovery means the process of injecting a gas (i.e., carbon dioxide) into a gasbearing formation to displace available gas to allow it to be produced.4

Enhanced oil recovery means the process of injecting carbon dioxide into an oil reservoir to 

thin (decrease the viscosity) of extractable oil, which is then available for recovery.4 

Enhanced recovery means either enhanced oil recovery or enhanced gas recovery.4

 

Fluid means any material or substance which flows or moves whether in a semisolid, liquid, 

sludge, gas or other form or state. 2

Formation or geological formation means a layer of rock that is made up of a certain type of 

rock or a combination of types.1

Geologic sequestration (GS) means the long-term containment of a gaseous, liquid, or 

supercritical carbon dioxide stream in subsurface geologic formations. This term does not apply 

to carbon dioxide capture or transport.3

Geologic sequestration project means an injection well or wells used to emplace a carbon 

dioxide stream beneath the lowermost formation containing a USDW; or, wells used for geologic 

GS of carbon dioxide that have been granted a waiver of the injection depth requirements 

pursuant to requirements at 40 CFR 146.95; or, wells used for geologic GS of carbon dioxide 

that have received an expansion to the areal extent of an existing Class II enhanced oil recovery 

or enhanced gas recovery aquifer exemption pursuant to 40 CFR 146.4 and 144.7(d). It includes 

the subsurface three-dimensional extent of the carbon dioxide plume, associated area of elevated 

pressure, and displaced fluids, as well as the surface area above that delineated region.3

Injectate means the fluids injected. For the purposes of the Class VI Rule, this is also known as 

the carbon dioxide stream.1

Injection depth waivers refer to the provisions at 40 CFR 146.95 that allow owners or operators 

to seek a waiver from the Class VI injection depth requirements for GS to allow injection into 

non-USDW formations while ensuring that USDWs are protected from endangerment.4

Injection zone means a geologic formation, group of formations, or part of a formation that is of 

sufficient areal extent, thickness, porosity, and permeability to receive carbon dioxide through a 

well or wells associated with a geologic GS project.3
Draft UIC Program Class VI Well Recordkeeping, xiv March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Mechanical integrity means the absence of significant leakage within the injection tubing, 

casing, or packer (known as internal mechanical integrity), or outside of the casing (known as 

external mechanical integrity).

1

Mechanical integrity test (MIT) refers to a test performed on a well to confirm that a well 

maintains internal and external mechanical integrity. MITs are a means of measuring the 

adequacy of the construction of an injection well and a way to detect problems within the well 

system.1

Model means a representation or simulation of a phenomenon or process that is difficult to 

observe directly or that occurs over long time frames. Models that support GS can predict the 

flow of carbon dioxide within the subsurface, accounting for the properties and fluid content of 

the subsurface formations and the effects of injection parameters.1

Owner or operator means the owner or operator of any facility or activity subject to regulation 

under the UIC program.2

Packer means a mechanical device that seals the outside of the tubing to the inside of the long 

string casing, isolating an annular space.1

Phased corrective action refers to a provision of the Class VI Rule [40 CFR 146.84(b)(2)(iv)] 

afforded to Class VI injection well owners or operators to defer some identified corrective action 

needed within the AoR, but farther away from the injection well, until after injection has 

commenced, but prior to carbon dioxide plume and pressure front movement into that particular 

area.4

Post-injection site care (PISC) means appropriate monitoring and other actions (including 

corrective action) needed following cessation of injection to ensure that USDWs are not 

endangered, as required under 40 CFR 146.93.3

Pressure front means the zone of elevated pressure that is created by the injection of carbon 

dioxide into the subsurface. For GS projects, the pressure front of a carbon dioxide plume refers 

to the zone where there is a pressure differential sufficient to cause the movement of injected 

fluids or formation fluids into a USDW.3

Primacy (primary enforcement responsibility) means the authority to implement the UIC 

Program. To receive primacy, a state, territory, or tribe must demonstrate to EPA that its UIC 

program is at least as stringent as the federal standards; the state, territory, or tribal UIC 

requirements may be more stringent than the federal requirements. (For Class II, states must 

demonstrate that their programs are effective in preventing pollution of USDWs.) EPA may grant 

primacy for all or part of the UIC program, e.g., for certain classes of injection wells.5

Site closure means the specific point or time, as determined by the UIC Program Director 

following the requirements under 40 CFR 146.93, at which the owner or operator of a geologic 

GS site (Class VI injection well) is released from post-injection site PISC responsibilities.3
Draft UIC Program Class VI Well Recordkeeping, xv March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Total dissolved solids (TDS) refers to the measurement, usually in mg/L, for the amount of all 

inorganic and organic substances suspended in liquid as molecules, ions, or granules. For 

injection operations, TDS typically refers to the saline (i.e., salt) content of water-saturated 

underground formations.1

Transmissive fault or fracture means a fault or fracture that has sufficient permeability and 

vertical extent to allow fluids to move between formations.3

Tubing refers to a small-diameter pipe installed inside the casing of a well. Tubing conducts 

injected fluids from the wellhead at the surface to the injection zone and protects the long string 

casing of a well from corrosion or damage by the injected fluids.5

Underground Injection Control (UIC) Program refers to the program EPA, or an approved 

state, is authorized to implement under SDWA that is responsible for regulating the underground 

injection of fluids by wells injection. This includes setting the federal minimum requirements for 

construction, operation, permitting, and closure of underground injection wells.4

Underground Injection Control (UIC) Program Director refers to the chief administrative

officer of any state or tribal agency or EPA Region that has been delegated to operate an 

approved UIC program.5

Underground source of drinking water (USDW) means an aquifer or portion of an aquifer that 

supplies any public water system or that contains a sufficient quantity of ground water to supply 

a public water system, and currently supplies drinking water for human consumption, or that 

contains fewer than 10,000 mg/L TDS and is not an exempted aquifer.1

Well bore refers to the hole that remains throughout a geologic (rock) formation after a well is 

drilled.4

Workover refers to any maintenance activity performed on a well that involves ceasing injection

or production and removing the wellhead.4
Draft UIC Program Class VI Well Recordkeeping, 1 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

1 Introduction 

To ensure the protection of underground sources of drinking water (USDWs), the United States

Environmental Protection Agency (EPA) established minimum federal requirements for the 

proper management of carbon dioxide injection and storage under the authority of Part C of the 

Safe Drinking Water Act (SDWA) in December 2010. The Federal Requirements Under the 

Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic 

Sequestration (GS) Wells, found at 75 FR 77230 and hereafter referred to as the Class VI Rule, 

requires well owners or operators to collect, generate, and report specific information needed to 

inform permitting decisions and decisions related to siting, constructing, operating, monitoring, 

and closing a Class VI well [40 CFR 146.81 et seq.]. 

The Class VI Rule defines a new class of injection wells, Class VI, and technical criteria 

addressing: site characterization; area of review (AoR) delineation and corrective action; well

construction and operation; financial responsibility; testing and monitoring; reporting and 

recordkeeping; well plugging, post-injection site care (PISC) and site closure; and emergency 

and remedial response. Figure 1-1 presents a general sequence of these specific activities within 

a GS project workflow. 

Additionally, EPA is implementing an adaptive rulemaking approach for the Class VI Rule, 

whereby the agency plans to collect and review data every six years on GS projects to determine 

whether the appropriate amount and types of information and documentation are being collected, 

as well as to determine if modifications to the requirements are necessary. Effective GS data 

management will significantly impact the effectiveness of this review. 

Pursuant to Section 1445 of SDWA, owners or operators subject to requirements under SDWA 

must establish and maintain records, conduct monitoring, and provide any information that the 

Administrator or a representative, such as a UIC Program Director, may require by regulation to 

comply with the Act. Therefore, data management, recordkeeping, and reporting are important 

components of the UIC Program to ensure that activities and operations regulated under the 

program are conducted as planned, are compliant with the regulations and permit conditions, 

and, ultimately, are sufficiently protective of USDWs. 

1.1 Purpose of Guidance 

This guidance is one of a series of guidance documents that describe Class VI well operations 

that are protective of USDWs and in compliance with the Class VI Rule. The purpose of this 

guidance is to provide: 

• A comprehensive description of the reporting and recordkeeping requirements of the

Class VI Rule for each phase of a GS project and associated activities as shown in Figure

1-1.

A description of the reporting and data management process among the entities with

access to Class VI well data.

•
Draft UIC Program Class VI Well Recordkeeping, 2 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Information on how the reporting, recordkeeping, and data management activities will

ensure USDW protection, inform the adaptive rulemaking approach, support compliance

determinations, and meet interagency data needs.

This document is designed to provide guidance to injection well owners or operators and their 

representatives regarding recordkeeping, reporting, and management of GS project data. As part 

of a series of technical guidance documents, this guidance is intended to provide information and 

possible approaches for addressing various aspects of permitting and operating a Class VI 

injection well. The guidance documents are intended to complement each other and to assist 

owners or operators in preparing permit applications, report on well operations and testing and 

monitoring results, and provide documentation associated with injection well closure and PISC

that satisfy the requirements of the Class VI Rule and are tailored to the characteristics of 

individual sites. Cross-linkages between guidance documents are noted in the text where 

appropriate. As they are finalized, these additional Class VI guidance documents will be made 

available on EPA’s website at http://water.epa.gov/type/groundwater/uic/class6/gsguidedoc.cfm: 

•

•

•

•

•

•

•

•

•

•

•

UIC Program Class VI Financial Responsibility Guidance.

UIC Program Class VI Implementation Manual for State Directors. 

UIC Program Class VI Primacy Manual for State Directors. 

UIC Program Class VI Well Area of Review Evaluation and Corrective Action Guidance. 

UIC Program Class VI Well Construction Guidance. 

UIC Program Class VI Well Injection Depth Waivers Guidance. 

UIC Program Class VI Well Project Plan Development Guidance. 

UIC Program Class VI Well Site Characterization Guidance.

UIC Program Class VI Well Testing and Monitoring Guidance.

UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site 

Closure.

UIC Program Guidance on Transitioning Class II Wells to Class VI Wells.

EPA has also developed the UIC Program Class VI Well Recordkeeping, Reporting, and Data 

Management Guidance for Permitting Authorities, which describes requirements and provides 

recommendations specific to the activities of UIC Program Directors. It also provides 

information on how these activities will ensure USDW protection, inform the adaptive approach, 

support compliance determinations and national oversight, and meet interagency data needs. 
Draft UIC Program Class VI Well Recordkeeping, 3 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

This guidance document complements the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Permitting Authorities and references it in the 

text where appropriate.

The

1.2 GS Project Phases and Reporting Requirements

Class VI Rule requires owners or operators to submit information during various stages of a 

GS project to ensure the protection of USDWs and ensure compliance with the regulations. A GS 

project consists of three main phases: (1) the pre-injection phase, during which the owner or 

operator submits a permit application (and, in some cases, an injection depth waiver report or a 

request to expand the areal extent of an aquifer exemption) and the UIC Program Director 

reviews this information and authorizes well construction and, later, injection; (2) the injection 

phase, when injection operation and associated monitoring and testing are conducted by the 

owner or operator, and compliance and oversight determinations are made by the UIC Program 

Director; and (3) the post-injection phase, when the owner or operator plugs the injection well 

and conducts PISC activities, the UIC Program Director makes compliance and oversight 

determinations after all injection has ceased and until the finalization of site closure, and the site 

is closed. Figure 1-1 illustrates these phases of a GS project and the accompanying activities for 

owners or operators of Class VI wells required by the Class VI Rule. 

During each of the project phases, owners or operators must meet a variety of reporting 

requirements, as summarized in Table 1-1. Many of these are linked to data elements required by 

the Class VI Rule, which are tabulated in Table A-1 in Appendix A (for example, a Testing and 

Monitoring Plan is developed at the time of the permit application and updated throughout the 

operating phase as operational and monitoring data are collected). Sections 3 through 6 present, 

for each element of the Class VI Rule, the information that is required, the anticipated data 

format(s), and the timing at which the information is to be submitted.
Draft UIC Program Class VI Well Recordkeeping, 4 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Figure 1-1. The phases of a GS project’s life cycle with associated activities required by the Class VI Rule and the sections of this guidance document 

that address each activity.
Draft UIC Program Class VI Well Recordkeeping, 5 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Table 1-1. Reporting requirements for the different phases of a GS project. 

Phase Required Reporting* Relevant Sections of this Document

Pre-injection 

(before 

construction)

Permit application • Permit application requirements: Section 3.1

• Site characterization: Section 3.2

• AoR and corrective action: Section 3.3

• Financial responsibility demonstration: Section 3.4

• Proposed project plans: Section 3.5.1

• Alternative PISC timeframe: Section 3.5.2

• Proposed operating information: Section 3.5.3

• Proposed well construction information:

Section 3.5.4

Injection depth waiver 

application report

• Injection depth waiver application report:

Section 3.6

Application to expand the areal 

extent of a Class II aquifer 

exemption

• Aquifer exemption expansion information:

Section 3.7.2

Pre-injection 

(before 

operation)

Updated permit application 

submittals and pre-injection 

logging and testing data

• Permit application requirements: Section 4

• Final AoR and corrective action status: Section 4.1

• Final site characterization information: Section 4.2

• Injection well construction and testing: Section 4.3

• Project plan updates and alternative PISC

timeframe: Section 4.4

Injection Testing and monitoring data • Injection well operation: Section 5.1

• Testing and monitoring: Section 5.2

AoR reevaluation and phased 

corrective action data

• Section 5.3

Financial responsibility updates 

and notifications

• Section 5.4

Project plan updates • Section 5.5

Emergency and remedial 

response information 

• Section 5.6
Draft UIC Program Class VI Well Recordkeeping, 6 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Phase Required Reporting* Relevant Sections of this Document

Post-injection Injection well plugging

information

• Notice of intent to plug the well: Section 6.1.1

• Injection well plugging report: Section 6.1.2

PISC and site closure

information

• Updated PISC and Site Closure Plan: Section 6.2.1

• PISC monitoring: Section 6.2.2

• Non-endangerment demonstration: Section 6.2.3

• Site closure reporting: Section 6.2.4

* Note: this list is not intended to be inclusive of all requirements. For additional information, see the text

of this document. 

1.2.1 Pre-Injection Phase Reporting 

The Class VI Rule, at 40 CFR 146.82(a), requires owners or operators to submit a permit 

application prior to the issuance of a permit for the construction of a new Class VI well or the 

conversion of an existing Class I, Class II, or Class V experimental technology well to a Class VI 

well. The permit application is accompanied by a significant amount of supporting information 

about the well, the proposed injection operation, and the GS site, as well as a series of projectspecific plans. 

The Class VI permit application process is an iterative one. To gain authorization to drill a new 

Class VI well or convert and existing well for GS, owners or operators must submit an initial 

permit application that contains all of the information identified at 40 CFR 146.82(a). Following 

a review of this information, the UIC Program Director will issue a Class VI permit that 

authorizes the owner or operator to construct or convert a Class VI well. Before the owner or 

operator may inject carbon dioxide, they must submit the information specified at 40 CFR 

146.82(c); much of this information will update information submitted pursuant to 40 CFR 

146.82(a) or be gathered through the planned tests described in the initial permit application. 

These two pre-injection phases are described in Section 3 (activities conducted prior to 

construction) and Section 4 (activities conducted prior to injection).

Owners or operators seeking a waiver of the requirement to inject below the lowermost USDW 

must also submit a waiver application report as required at 40 CFR 146.95(a) at the same time as 

the permit application [40 CFR 146.82(d)]. See Section 3.6 for information that owners or 

operators must submit as part of the waiver application report. Owners or operators of Class II

enhanced recovery wells transitioning to GS may also need to submit information to support a 

determination of whether a Class VI permit is required for carbon dioxide injection in wells 

currently permitted as Class II [40 CFR 144.19(b)]. Owners or operators seeking to expand the 

areal extent of an existing aquifer exemption will need to apply to the UIC Program Director 

pursuant to the requirements at 40 CFR 144.7(d)(1). 

During the drilling and construction of a Class VI well, the owner or operator must run logs, 

surveys, and tests that will provide information on the relevant geologic formations; provide a 

final AoR delineation; and submit any updates to site data based on information gathered during 
Draft UIC Program Class VI Well Recordkeeping, 7 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

drilling and testing. The owner or operator must submit this pre-injection testing information to 

the UIC Program Director prior to approval of injection operations [40 CFR 146.82(c)]. See 

Section 4 for additional information on these requirements. 

1.2.2 Injection Phase Reporting

Following issuance of a permit to operate a Class VI well, the owner or operator is required to 

submit operating and monitoring information at varying time intervals throughout the injection 

phase of the GS project [40 CFR 146.91]. A comprehensive report containing operating data and 

the results of periodic monitoring and testing along with a description of any event which 

triggers an automatic shut-off device must be submitted semi-annually by the owner or operator 

pursuant to 40 CFR 146.91(a) or at a more frequent interval set by the permitting authority. 

The semi-annual reports must be submitted electronically, pursuant to requirements under 40 

CFR 146.91(e). EPA recommends that these reports be submitted as Portable Document Format 

(PDF) files with supplemental data submitted separately in a tabular format. EPA recommends 

that the owner or operator present spatial information with maps and/or graphs submitted as 

geographic information system (GIS)-compatible files, including associated tabular data. 

In addition to the semi-annual reports, the owner or operator must comply with the following 

requirements:

• Notifying the UIC Program Director 30 days in advance of planned well workovers,

stimulation activities, and other well tests [40 CFR 146.91(d)]—see Section 5.1.

• Reporting results of well workovers, mechanical integrity tests (MITs), and other well

tests within 30 days [40 CFR 146.91(b)]—see Section 5.2.

• Reporting possible USDW endangerment and other emergency situations within 24 hours

[40 CFR 146.91(c)]—see Section 5.6.

Owners or operators must also periodically reevaluate the AoR and, if necessary, update the AoR 

and Corrective Action, Testing and Monitoring, and Emergency and Remedial Response Plans 

[40 CFR 146.84(e), 40 CFR 146.90(j), and 40 CFR 146.94(d)]. Owners or operators must also 

update financial responsibility information annually [40 CFR 146.85(a)(5)(ii)]. See Section 5.5

for additional information on these updates. 

1.2.3 Post-Injection Phase Reporting 

Following cessation of injection activities, owners or operators will need to plug the injection 

well, perform post-injection monitoring, demonstrate that the site no longer poses an 

endangerment to USDWs, and close the site [40 CFR 146.92 and 146.93]. Reporting activities 

associated with this phase of the GS project will demonstrate that the activities associated with 

the project are not endangering USDWs. These reporting activities include: 

• Submitting a notice of intent to plug the well (see Section 6.1.1).
Draft UIC Program Class VI Well Recordkeeping, 8 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Submitting an injection well plugging report (see Section 6.1.2).

• Submitting an updated PISC and Site Closure Plan (see Section 6.2.1).

• Reporting the results of PISC monitoring (see Section 6.2.2).

• Performing a non-endangerment demonstration (see Section 6.2.3).

• Submitting a site closure report (see Section 6.2.4).

This reporting must be conducted as described in the approved Injection Well Plugging Plan and 

the PISC and Site Closure Plan. See Section 6 for additional information. 

1.3 Organization of this Document 

This guidance document is organized to address the reporting, recordkeeping, and data 

management aspects of the Class VI Rule with respect to requirements for owners or operators of 

Class VI wells. Following this introduction, the remainder of this document is organized as 

follows: 

•

•

•

•

•

Section 2, Class VI Rule Reporting and Recordkeeping Requirements, describes the 

Class VI Rule electronic reporting requirement, suggested data formats for Class VI 

submissions, and recordkeeping requirements. 

Section 3, Pre-Injection Phase Reporting and Recordkeeping: Prior to Construction, 

describes submittals related to pre-injection activities that occur before well construction, 

including site characterization, injection well plans and schematics, planned preoperational testing, information related to re-permitting of Class II wells as Class VI 

wells, and the injection depth waiver application report. 

Section 4, Pre-Injection Phase Reporting and Recordkeeping: Prior to Injection, describes 

submittals related to pre-injection activities that occur before injection, including updates 

to site characterization data collected during construction of the well and pre-operational 

testing results. 

Section 5, Injection Phase Reporting and Recordkeeping, describes specific submittals 

related to injection phase activities, including injection well operation, testing and 

monitoring, AoR reevaluation and phased corrective action, financial responsibility 

updates, emergency and remedial response, and project plan updates. 

Section 6, Post-Injection Phase Reporting and Recordkeeping, describes specific 

submittals related to post-injection phase activities, including injection well plugging, 

PISC, non-endangerment demonstrations, and site closure.
Draft UIC Program Class VI Well Recordkeeping, 9 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Section 7, GS Data Submission and Management, describes the centralized, integrated

electronic reporting system maintained by EPA and presents the overall data submission

procedures and data management operations for owners or operators of Class VI wells.2

The central sections of this document, Sections 3 through 6, are organized around the main 

phases of a GS project’s life cycle (see Figure 1-1). Table A-1 in Appendix A summarizes the 

information provided in Sections 3 through 6 in a table of data elements for each phase of a GS 

project’s life cycle. 

2 At the time this draft document was published, the central data system for Class VI data was under development. 

To avoid publishing incomplete information, this draft contains a placeholder for the description of GS data 

management through the use of the central data system.
Draft UIC Program Class VI Well Recordkeeping, 10 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

2 Class VI Rule Reporting and Recordkeeping Requirements

2.1 Electronic Reporting Requirement 

Under the Class VI Rule, owners or operators are required to submit data generated and collected 

during the lifetime of a GS project directly to EPA in an electronic format approved by EPA [40 

CFR 146.91(e)]. Given the nature of Class VI well operations and the more comprehensive 

requirements of the Class VI Rule compared to those for other UIC well classes, a centralized, 

integrated reporting system that is managed by EPA is essential for effective operation of GS 

projects and management of the GS data. Electronic reporting offers several advantages over 

paper-based reporting, including: 

•

•

•

Reducing burden on permitting authorities that receive and manage the data. 

Reducing the burden on owners or operators for data submittal and recordkeeping. This is 

consistent with the recommendations of the Report of the Interagency Task Force on 

Carbon Capture and Storage (CCS): “State UIC primacy agencies’ efforts could be aided 

by a national data system that would promote regulatory certainty, efficiency, and 

accountability, while allowing transparency of all geologic sequestration related 

information to improve public acceptance of CCS.”3

 

Creating an instantaneous submission process, which is essential for the more frequent 

reporting required under the Class VI Rule, such as 24-hour emergency notifications. 

In light of the nearly universal use of computerized systems (particularly for wells as technically 

complex as Class VI wells), EPA anticipates that most owners or operators will be able to submit 

data electronically. EPA recognizes that there may be some circumstances where it will be 

necessary to submit data non-electronically. One example may include the collection of nondigitized historical data on existing GS projects (e.g., pilot projects underway prior to 

deployment of the GS data system). Therefore, if an owner or operator cannot submit the 

required data using EPA’s electronic reporting system, EPA expects the UIC Program Director 

to seek EPA’s approval regarding an alternate reporting format. Following EPA’s approval of a 

non-electronic submittal format, an alternate reporting procedure may be allowed. However, the 

decision to allow non-electronic submission of data will be based on the inability or inefficiency 

of converting data to electronic formats.

2.2 Data Format

The Class VI Rule requires that owners or operators report data in an electronic format 

acceptable to the UIC Program Director [40 CFR 146.91(e)]. While the UIC Program Director 

3 Interagency Task Force on Carbon Capture and Storage. 2010. Report of the Interagency Task Force on Carbon 

Capture and Storage, p. C-8. Available on the Internet at: http://www.epa.gov/climatechange/Downloads/ccs/CCSTask-Force-Report-2010.pdf. 
Draft UIC Program Class VI Well Recordkeeping, 11 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

has discretion to allow submittals in various formats on a case-by-case basis, EPA recommends 

the following three main data formats for Class VI submissions: narrative information or 

graphics in portable document format (PDF), raw or processed data in tabular formats, and 

spatial data in GIS-compatible formats. This guidance document describes the recommended 

data format for each submittal in Sections 3 through 6, along with a discussion of accepted file 

formats by the electronic data system in Section 7. 

2.3 Recordkeeping Requirements

Under the requirements outlined at 40 CFR 146.91(f), owners or operators of Class VI injection 

wells must retain records as follows: 

• All data collected under 40 CFR 146.82 for a Class VI permit application must be

retained throughout the life of the GS project and for 10 years following site closure.

• Data on the nature and composition of all injected fluids collected under 40 CFR

146.90(a) must be retained until 10 years after site closure. The UIC Program Director

may require the owner or operator to deliver the records at the conclusion of the retention

period.

• All other monitoring data collected under 40 CFR 146.90(b) through (i) must be retained

for 10 years after it is collected.

• Well plugging reports, post-injection data, including, if appropriate, data and information

used to develop the alternative PISC timeframe demonstration, and site closure reports,

must be retained for 10 years following site closure.

The UIC Program Director has authority, pursuant to 40 CFR 146.91(f)(5), to require the owner 

or operator to retain records for longer than 10 years after site closure. Box 2-1 presents a 

hypothetical example of recordkeeping periods for various submittals. 

Other submissions, such as the information related to AoR reevaluations, also have specific 

record retention requirements or recommendations not addressed in this section. These 

requirements, along with those listed above, are described in more detail in Sections 3 through 6

of this guidance. 
Draft UIC Program Class VI Well Recordkeeping, 12 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Box 2-1. Hypothetical Example for Recordkeeping

In a hypothetical GS project, injection occurs for 40 years, followed by a 50-year PISC 

period. Unless additional recordkeeping is required by the UIC Program Director, the owner 

or operator of the Class VI well in this hypothetical project must:

• Retain the following for the life of the project and for 10 years after site closure, for

a total of 100 years from the initiation of the project:

o All information submitted as part of the permit application.

o Data on the nature and composition of injected fluids.

o The plugging report, PISC data, data used for the demonstration of

alternative PISC timeframe, and the site closure report.

• Retain testing and monitoring data collected during the injection phase for 10 years

after it is collected.
Draft UIC Program Class VI Well Recordkeeping, 13 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3 Pre-Injection Phase Reporting and Recordkeeping: Prior to 

Construction 

Owners or operators must submit certain information before receiving a permit for the 

construction of a new Class VI well or the conversion of an existing Class I, Class II, or Class V

experimental technology well to a Class VI well [40 CFR 146.82(a)]. This submittal, which 

makes up the Class VI permit application, includes information related to site characterization, 

AoR delineation, corrective action, injection well construction, and proposed operating 

information. Owners or operators seeking a waiver to the injection depth requirement must also 

submit a waiver application report at this time [40 CFR 146.95(a)]. This section describes the 

submittals that will take place before construction or conversion of the well. 

In addition to the permit application information described in this section, owners or operators of 

Class II enhanced recovery wells transitioning to Class VI may also need to submit information 

to support the UIC Program Director’s evaluation of whether there is increased risk to USDWs 

and, therefore, a Class VI permit is required [40 CFR 144.19(b)]. Owners or operators of 

transitioning wells may also submit information requesting the expansion of a Class II aquifer 

exemption [40 CFR 144.7(d)]. 

More information about the UIC Program Director’s documentation of oversight and compliance 

decisions for the pre-injection period is given in the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Permitting Authorities. 

3.1 Permit Application Requirements

Initial permit application requirements for Class VI wells are described in 40 CFR 146.82, and 

submission requirements related to the permit application are listed below. Specific requirements 

are discussed in more detail in the sections indicated in parentheses.

Pursuant to 40 CFR 146.82(a), the owner or operator must submit the following information 

before the UIC Program Director issues a Class VI well permit:

• The following information as required in 40 CFR 144.31(e)(1) through (6):

o The permitted activities.

o Name, mailing address, and location of the facility.

o Up to four Standard Industrial Classification (SIC) codes.

o The operator’s name, address, telephone number, ownership status, and status as

federal, state, private, public, or other entity.

o Whether the facility is located on Indian lands.
Draft UIC Program Class VI Well Recordkeeping, 14 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

o A listing of all permits or construction approvals.

o Authorization status, permit action type, and permit action date.

• Site characterization data (see Section 3.2).

• Proposed operating data (see Section 3.5.3).

• Proposed pre-operational formation testing program (see Section 3.2.6).

• Proposed stimulation program (see Section 3.5.4.1).

• Proposed procedure to outline steps necessary to conduct injection operation (see Section

3.5.3).

• Schematics or other drawings of the surface and subsurface construction details of the

injection well, as well as proposed programs/procedures for injection well construction

(see Section 3.5.4.1).

• Demonstration of financial responsibility (see Section 3.4).

• Proposed project plans: the AoR and Corrective Action Plan, Testing and Monitoring

Plan, Injection Well Plugging Plan, PISC and Site Closure Plan, and Emergency and

Remedial Response Plan (see Section 3.5.1).

• At the UIC Program Director’s discretion, demonstration of an alternative PISC

timeframe (see Section 3.5.2).

• A list of contacts for all states, tribes, and territories within the AoR.

• Any other information requested by the UIC Program Director.

These data must be retained throughout the life of the GS project and for 10 years following site 

closure [40 CFR 146.91(f)(1)]. 

3.2 Site Characterization

The Class VI Rule, at 40 CFR 146.82(a), requires applicants for a Class VI permit to submit 

certain site characterization information prior to the issuance of a permit for the construction of a 

new Class VI well or the conversion of an existing Class I, Class II, or Class V experimental 

technology well to a Class VI well. This includes information on the geologic, geomechanical, 

and hydrogeologic characteristics of the proposed storage site and overlying formations; a 

tabulation of all wells within the AoR; information on USDWs; baseline geochemical data; and a 

proposed program for formation testing.

Site characterization involves desktop analysis of secondary information as well as gathering 

primary data in the field if needed. Information owners or operators will submit includes data on 
Draft UIC Program Class VI Well Recordkeeping, 15 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

the regional and local geology and hydrogeology and a detailed characterization of the proposed 

injection site. This section outlines the types of information that must be submitted as well as 

EPA’s recommendations regarding the details and format of that information. See the UIC 

Program Class VI Well Site Characterization Guidance for additional information on gathering 

the necessary data and demonstrating the suitability of a proposed GS site. 

3.2.1 Maps of AoR and Tabulation of Wells 

The Class VI Rule, at 40 CFR 146.82(a)(2), requires applicants to submit a map showing the 

location of the proposed injection well and the AoR. This map must include the following 

information: 

• Artificial penetrations, including the number or name and location of all injection wells,

producing wells, abandoned wells, plugged wells or dry holes, and deep stratigraphic

boreholes.

• State- or EPA-approved subsurface cleanup sites.

• Surface bodies of water and springs.

• Mines (surface and subsurface) and quarries.

• Water wells.

• Faults, if known or suspected.

• Other pertinent surface features, including structures intended for human occupancy,

roads, and state, tribal, and territorial boundaries.

Per the Class VI Rule, only publicly-available information must be included on the map of the 

AoR [40 CFR 146.82(a)(2)]. However, additional well information required by 40 CFR 

146.82(a)(4) may need to be generated by the owner or operator if existing information is not 

available or reliable; see the UIC Program Class VI Well Area of Review Evaluation and 

Corrective Action Guidance for additional details. EPA recommends that this map be submitted 

in a GIS-compatible format to allow detailed evaluation of the presented information and 

comparison with other spatial data submitted. 

The Class VI Rule also requires that applicants submit a tabulation of all wells within the AoR 

that penetrate the injection or confining zone(s) [40 CFR 146.82(a)(4)]. This information must 

include, for each well: 

• A description of the well type, construction, drilling date, location, and depth.

• The record of plugging and/or completion.

• Any additional information required by the UIC Program Director.
Draft UIC Program Class VI Well Recordkeeping, 16 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

EPA recommends that the well information be submitted in a tabular format in a spreadsheet or 

database file. As with the map described above, EPA recommends that owners or operators 

submit well location information in a GIS-compatible format to allow for a more detailed

evaluation of submitted information. 

3.2.2 Detailed Geologic and Hydrogeologic Site Characterization 

The Class VI Rule, at 40 CFR 146.82(a)(3), requires owners or operators to submit information 

on the geologic structure and geomechanical and hydrogeologic properties of the proposed 

storage site and overlying formations. Among other materials, the Class VI Rule specifies that 

maps, cross sections, results of testing for hydrogeologic and geomechanical properties (e.g., 

strength, fluid pressures, porosity, and permeability), mineralogic and lithologic information, and 

information on the regional geologic setting be submitted. These specific types of information 

are outlined below. 

3.2.2.1 Maps and Cross Sections of the AoR 

In addition to the map of the AoR required by 40 CFR 146.82(a)(2), the Class VI Rule requires 

owners or operators to submit maps and cross sections of the AoR focusing on structural geology 

and hydrogeology [40 CFR 146.82(a)(3)(i) and 40 CFR 146.82(a)(5)]. EPA expects that these 

will consist primarily of geologic maps and associated cross sections and stratigraphic columns, 

but topographic maps may be included where appropriate or useful. The UIC Program Class VI 

Well Site Characterization Guidance provides further discussion on these requirements. 

In addition to the maps and cross sections themselves, EPA recommends that owners or 

operators submit an accompanying narrative including the following information: 

• The formation names, lithologies, and depths of the injection formation(s), confining

zone(s), and regional USDWs.

• A general description of stratigraphy, including the vertical distance and formations

separating the injection formation from USDWs.

• Structural geology of the local area, including:

o Presence and trends of folds, faults, and fractures.

o Whether the proposed storage site will be bounded by a structural trap (e.g., faults

or a dome).

The Class VI Rule, at 40 CFR 146.82(a)(5), specifically requires maps and stratigraphic cross 

sections indicating the general vertical and lateral limits of all USDWs, water wells, and springs 

within the AoR, their positions relative to the injection zone(s), and the direction of water 

movement, where known. To satisfy this requirement, EPA recommends that owners or 

operators submit the following information: 
Draft UIC Program Class VI Well Recordkeeping, 17 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• The numbers, thicknesses, and lithologies of aquifers (including interbedded low

permeability zones) and confining units.

• Horizontal and vertical hydraulic conductivity, hydraulic gradient, and porosity for all

aquifers for which data are available.

• Any available water quality data.

• Identification of all USDWs in the AoR and in the region, and whether they are currently

being used for drinking water.

• The location of water wells and springs within the AoR.

EPA encourages owners or operators to include any additional information they deem 

appropriate on the maps of the AoR. EPA recommends that narrative information be submitted 

in PDF files, with supplemental data in a tabular format submitted separately in a spreadsheet or 

database file. EPA recommends that spatial data be submitted in a format that is compatible with 

GIS.

3.2.2.2 Faults and Fractures 

Owners or operators are required to document known or suspected fractures and faults that may 

transect the confining zone(s) within the AoR and provide a determination that these faults will 

not interfere with containment [40 CFR 146.82(a)(3)(ii)]. EPA recommends that owners or 

operators obtain information on faults in both the injection and confining zone(s). 

EPA recommends that owners or operators submit the following information to describe faults 

and fractures and demonstrate that they will not interfere with containment: 

• Location and characteristics of the fault or fracture (e.g., geometry, depth, fault

displacement, units juxtaposed by fault).

• Distance from the proposed injection zone.

• Formations intersected or transected by the fault or fracture.

• Methods and results of fault stability analysis and comparison to anticipated (modeled)

pressures during the injection phase of the project.

• A discussion of the faults and fractures in the context of a site geologic conceptual model

that will be used to develop the AoR delineation model.

• Information on faults and fractures in the lower confining zone (in cases where an

injection depth waiver is sought).

Refer to the UIC Program Class VI Well Site Characterization Guidance for examples of 

methods that may be employed to demonstrate that faults or fractures are not transmissive. To 
Draft UIC Program Class VI Well Recordkeeping, 18 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

support this demonstration, EPA recommends that owners or operators submit information such 

as: 

• A description of the approach used to infer whether a fault or fracture is transmissive.

• A summary table of data used to formulate this determination.

• Supporting data and information (e.g., analyses of core samples, results of geophysical

surveys, pore pressure data, maps, and cross sections) and any relevant calculations (e.g.,

calculation of shale gouge ratio).

• A narrative integrating the relevant information, including a discussion of spatial

heterogeneity in sealing properties and whether a fault or fracture is likely to be

transmissive in the project area.

• A discussion of uncertainties in the data.

EPA recommends that the discussions be submitted in PDF files with appropriate references to 

data or maps. EPA recommends that owners or operators submit supplemental data in a tabular 

format such as a spreadsheet or database file. EPA recommends that owners or operators submit 

spatial data in a GIS-compatible format. 

3.2.2.3 Characteristics of the Injection and Confining Zone(s) 

Owners or operators must submit data on the depth, thickness, areal extent, mineralogy, porosity, 

permeability, and capillary pressure of the injection and confining zone(s) [40 CFR 

146.82(a)(3)(iii)]. EPA recommends that owners or operators report the following information 

for the injection and confining zone(s): 

• Estimates of depth, thickness, and areal extent, referencing maps, cross sections, well

logs, geophysical surveys, or any other available information, submitted in a GIScompatible format when possible. EPA recommends that this also include a discussion

(e.g., a narrative submitted in PDF) of data quality and uncertainties.

• Porosity, with data submitted in tabular and graphical form (e.g., histograms) and

accompanying narrative descriptions in PDF as appropriate. While the Class VI Rule

does not require owners or operators to provide both lab and field estimates, EPA

recommends that they submit both if available. EPA recommends that the submitted

information include the following:

o For data from laboratory analyses: core sample locations, depths, and formations;

date and method of sample collection; method of analysis and associated

assumptions; test conditions; any corrections applied for in-situ conditions; and

photomicrographs (if porosity was determined using thin sections).

o For data from field analyses: sampling date and time, well, and intervals tested;

logging method(s) used (e.g., neutron logs, density logs, sonic logs); and
Draft UIC Program Class VI Well Recordkeeping, 19 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

interpretation of data in combination with information on lithology to estimate 

porosity. 

o For both types of data: summary statistics, information on data quality/limitations,

and sources of uncertainty.

• Permeability, with data submitted in tabular and graphical form and accompanying

narrative descriptions in PDF. EPA recommends that owners or operators submit the

following:

o For data from laboratory analyses: core sample locations, depths, and formations;

date and method of sample collection; laboratory method(s) used and associated

assumptions; test conditions; and any corrections made to data (e.g., for

dependence on pressure).

o For data from field analyses: sampling date and time; well location and intervals

tested; logging method (e.g., neutron logs, density logs, and sonic logs); method

used for permeability estimation from well logs; and whether new interpretations

are being made using archived data.

o For both types of data: summary statistics, information on data quality/limitations,

and sources of uncertainty.

• Lithologic and mineralogic descriptions, with narrative information submitted in PDF,

spatial information submitted as maps in a GIS-compatible format, and supplemental data

in a tabular and/or graphical format. Information on mineralogy will be obtained as

required at 40 CFR 146.82(a)(3)(iii), either through existing data or new analyses as

needed. EPA recommends that owners or operators submit information including:

o Core descriptions:

 Location of samples taken (e.g., borehole, depth, formation sampled) and

method of sample retrieval (e.g., core, sidewall core).

 Visual observations (including any photographs taken) from drill cuttings and

core samples.

 Lithologies and approximate percentages of minerals, grain sizes and shapes.

 Correlations between well logging and core samples and extrapolation to other

cores, if applicable.

o Descriptions obtained by microscopy or X-ray diffraction:

 Locations, formations, and depths from which samples were taken.
Draft UIC Program Class VI Well Recordkeeping, 20 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

 Observations (including any photographs) from polarized light microscopy or

scanning electron microscopy.

• Approximate percentages of minerals, grain sizes and shapes, and pore

sizes and shapes.

• Cementation minerals and dissolution features.

• Chemical compositions of minerals, if analyzed or available.

 Results of any X-ray diffraction analyses that may have been performed.

• Capillary pressure, with data submitted in tabular and graphical format and

accompanying narrative descriptions in PDF as appropriate:

o Locations, formations, and depths of samples used for analysis.

o Type of method used (e.g., mercury injection in laboratory or in-situ methods),

fluid used, and test conditions.

o Results including all relevant graphs and curves.

o Summary statistics.

o A discussion of any limitations of the data or methods.

o Any issues associated with extrapolation of results to a setting in which

supercritical carbon dioxide is the non-wetting fluid.

• Information on geology/facies changes, with a narrative PDF report referencing

supporting data (submitted in tabular form) and graphics, and spatial information

presented in a GIS-compatible format. Facies analysis may be based on several types of

information (e.g., variations in grain size and sorting, shifts in lithology, seismic

reflection patterns) that can collectively indicate shifts in depositional environment and

possible variations in physical parameters. Information submitted to support a description

of facies changes may include:

o Geologic maps and stratigraphic columns.

o Stratigraphic cross sections.

o Data from wireline methods and well logs.

o Core description and analysis.

o Petrographic analysis.

o Geophysical data.
Draft UIC Program Class VI Well Recordkeeping, 21 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.2.2.4 Geomechanical Characterization of the Confining Zone 

The Class VI Rule, at 40 CFR 146.82(a)(3)(iv), requires applicants to submit geomechanical 

information on fractures, stress, ductility, rock strength, and in-situ fluid pressures within the 

confining zone(s). This information will help the UIC Program Director understand the potential 

effects of injection on the mechanical stability of the injection zone and confining zone. Further 

information, including recommendations for use in determining the following parameters, is 

provided in the UIC Class VI Well Site Characterization Guidance. 

For the geomechanical parameters listed in 40 CFR 146.82(a)(iv), EPA recommends that owners 

or operators submit the following information: 

• In-situ fluid pressure:

o The name/location of the well or borehole sampled, date and time of

measurement, and depth of measurement.

o Test method used and notes on equipment calibration if appropriate.

• Information on fractures:

o Locations of fractures (estimated areal and vertical extent).

o Method of identification (e.g., geophysical survey, well bore imaging, caliper

logs).

o Orientation and geometry.

• Ductility and rock strength:

o Locations, formations, and depths from which samples were taken.

o Laboratory methods and conditions used.

o Analytical results in tabular form and any associated graphs.

• Stress (vertical, minimum horizontal, and maximum horizontal):

o For vertical (overburden) stress: reference to or results of appropriate density logs

and resulting estimate of overburden stress, and a brief description of procedures

for integrating density to estimate overburden stress.

o For minimum and maximum horizontal stresses: location of well, test performed,

testing conditions, and derived values for minimum and maximum horizontal

stress.
Draft UIC Program Class VI Well Recordkeeping, 22 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• For all geomechanical tests:

o A narrative of results, including any anomalies or uncertainties in the data.

o Comparison of data from different tests if more than one type of test is used for a

particular parameter.

o Any issues associated with sample procurement (e.g., disintegration of poor

quality rocks during transport or sample retrieval, or the existence of

discontinuities such as fractures, or fossils in tested samples).

For the submittals listed above, EPA recommends that descriptions be submitted as a narrative in 

PDF, spatial information be submitted as maps in a GIS-compatible format, and supplemental 

data be submitted in tabular and/or graphical format in a spreadsheet or database file. EPA also 

recommends that owners or operators submit PDF copies of laboratory or field reports. 

3.2.2.5 Seismic History

Evaluation and characterization of the site also includes information on the seismic history of the 

region, including the locations and depths of seismic sources. This information is required by the 

Class VI Rule at 40 CFR 146.82(a)(3)(v). EPA recommends that the following information be 

provided: 

• A tabulation and/or map of seismic sources and their depths.

• The history and periodicity of seismic events (EPA recommends that owners or operators

present a seismic history going as far back in time as information is available), including

event hypocenters and magnitudes.

• The sources of all seismic history data.

• Information on any seismic risk models used and the results.

• A discussion of seismic history, which may refer to maps and cross sections provided to

satisfy requirements at 40 CFR 146.82(a)(3)(i) and (ii).

EPA recommends that owners or operators provide this information in narrative form as a PDF. 

Supporting data may be provided in a tabular format in a spreadsheet or database file. The owner 

or operator may also choose to use GIS-compatible formats to present the spatial information. 

3.2.2.6 Regional and Local Geologic Setting 

Geologic and topographic maps and cross sections illustrating regional geology, hydrogeology, 

and the geologic structure of the local area are required by 40 CFR 146.82(a)(3)(vi). These maps 

and cross sections will show similar information to the maps and cross sections of the AoR, but 

they will be at a broader scale. EPA recommends that information presented in these maps and 

cross sections include: 
Draft UIC Program Class VI Well Recordkeeping, 23 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• The injection formation, confining zone(s), and major regional USDWs.

• Regional faults, including fault type and orientation, and whether the faults transect the

injection formation(s) and/or confining zone(s).

• Other structural features such as folds and domes.

• Direction of regional ground water movement, where known.

EPA recommends that these items be accompanied by a narrative that discusses key features of 

the maps and cross sections that demonstrate their potential suitability as a storage site. The 

discussion should also describe the proposed project site with respect to the regional geologic 

setting. EPA recommends that the narrative be submitted in PDF with any supplemental data 

submitted in a tabular format in a spreadsheet or database file. EPA recommends that owners or 

operators submit spatial information, including maps, in GIS-compatible formats.

3.2.3 Geochemical Characterization

The Class VI Rule, at 40 CFR 146.82(a)(6), requires the owner or operator to submit baseline 

geochemical data on subsurface formations, including all USDWs in the AoR. EPA recommends 

that owners or operators submit the following information in support of the geochemical 

characterization. These suggestions apply to both pre-existing data and new data.

• Fluid geochemistry:

o Date/time, location, and sampling method, including sample preservation

methods.

o Temperature, pH, specific conductivity, and pressure values taken at the time of

sampling.

o Results of laboratory analysis for pH, specific conductivity, and dissolved

constituents including total dissolved solids (TDS), major ions, and selected trace

elements.

o Laboratory reports, if available and required by the UIC Program Director,

including methods used and quality assurance/quality control (QA/QC) samples.

o Any interpretive plots (e.g., Piper or Stiff diagrams).

• Solid-phase geochemistry:

o Date/time and location of sampling (e.g., borehole, depth, formation sampled).

o Method of sample retrieval (e.g., core, sidewall core).
Draft UIC Program Class VI Well Recordkeeping, 24 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

o Methods used for whole-rock chemical analysis (e.g., digestion and elemental

analysis, X-ray fluorescence).

o Results of analyses (as percent of total rock).

EPA recommends that this information be submitted as a narrative that discusses key findings 

relevant to the proposed GS project and references the supporting data where appropriate. 

Owners or operators should submit data in a tabular and/or graphical format and submit spatial 

information in a GIS-compatible format. Where appropriate, contact information and chain of 

custody information for contractors or laboratories performing sampling and analysis is 

recommended. Further information on geomechanical characterization is provided in the UIC 

Class VI Well Site Characterization Guidance. 

3.2.4 Geophysical Characterization

To support the requirement at 40 CFR 146.82(a)(3)(iii) to submit data on the injection and 

confining zone(s), owners or operators may use a variety of field data, including seismic surveys 

or other geophysical methods. Descriptions of available geophysical methods and associated 

technical information can be found in the UIC Program Class VI Well Site Characterization 

Guidance. 

EPA recommends that owners or operators submit the following information when reporting the 

results of geophysical methods: 

• The type of survey and other details of the deployment (e.g., date, location/areal extent of

the survey, party that performed the survey).

• The source of the data and whether they are vintage or newly collected.

• The locations of boreholes, if boreholes were used.

• Assumptions and limitations associated with the method, data, and their interpretation.

• The type of data processing used, including any reprocessing of vintage data.

• Images, with locations of profiles indicated on a map and salient geologic features

identified (including formations below the injection zone where an injection depth waiver

is sought).

• A narrative discussing the results in the context of the site geologic conceptual model that

will be used to develop the AoR delineation model.

• A discussion of alternative interpretations if the data suggest non-unique interpretations.

EPA recommends that the discussion of geophysical characteristics be submitted as a narrative 

that describes key findings relevant to the proposed GS project and references supporting data 

where appropriate. The data should be submitted in a tabular format as a spreadsheet or database 
Draft UIC Program Class VI Well Recordkeeping, 25 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

file and/or graphical format; EPA recommends that any spatial information be submitted in a 

GIS-compatible format. 

3.2.5 Baseline Surface Air and/or Soil Gas Characterization 

The Class VI Rule allows the UIC Program Director, at his or her discretion, to require surface 

air and/or soil gas monitoring [40 CFR 146.90(h)]. The UIC Program Class VI Well Testing and 

Monitoring Guidance provides recommendations for these measurements, and additional 

information related to reporting this type of information is provided in Section 5.2.9. The UIC 

Program Class VI Well Site Characterization Guidance also provides information on collecting 

baseline data. If surface air and/or soil gas monitoring is required by the UIC Program Director, 

the owner or operator must use baseline data to determine the frequency and spatial distribution 

of the sampling [40 CFR 146.90(h)(1)]. Therefore, while surface air and/or soil gas monitoring is 

not required by the Class VI Rule, baseline information will be necessary in all cases where this 

type of monitoring is required by the UIC Program Director.

If baseline surface air and/or soil gas analyses are needed, EPA recommends that owners or 

operators submit the following: 

• Site characteristics: soil type, soil organic carbon content, vegetation type and density,

topography, and surface water hydrology.

• Sampling locations (in map form) and dates.

• Soil temperature and moisture data and atmospheric conditions.

• Sampling and analytical methods, including detection limits.

• Results in tabular and graphic form, including QA samples and analyses.

• Methods and results of regression analysis.

• Methods and results of any ecological modeling performed, including input data, outputs,

and sensitivity analyses.

EPA recommends that the data be submitted in tabular and/or graphical format, with 

accompanying narrative information in PDF as appropriate. Owners or operators may also 

submit spatial data in a GIS-compatible format.

3.2.6 Proposed Pre-Operational Formation Testing Program 

With the permit application, the owner or operator must submit a proposed pre-operational 

formation testing program to obtain an analysis of the chemical and physical characteristics of 

the injection zone(s) and confining zone(s) [40 CFR 146.82(a)(8)]. This proposed program must 

meet the requirements at 40 CFR 146.87, which include elements related to both site 

characterization and well integrity. Components to include in the proposed testing program are as 

follows: 
Draft UIC Program Class VI Well Recordkeeping, 26 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• A plan for well logging before and upon installation of the surface casing. This plan must

include resistivity, spontaneous potential, and caliper logs before the casing is installed

[40 CFR 146.87(a)(2)(i)].

• A plan for well logging before and upon installation of the long string casing. This plan

must include the following logs before the casing is installed: resistivity, spontaneous

potential, porosity, caliper, gamma ray, fracture finder, and any other logs the UIC

Program Director requires [40 CFR 146.87(a)(3)(i)].

• Sampling plans for cores (whole cores or sidewall cores), including proposed number and

locations of core samples [40 CFR 146.87(b)], analyses to be performed on cores, and

coring methods to be used.

• A plan for obtaining formation fluids from the injection zone(s), including proposed

sampling method (e.g., wireline) [40 CFR 146.87(b)], and analyses to be performed on

fluids.

• A plan for measuring fluid temperature, pH, conductivity, reservoir pressure, and static

fluid level in the injection zone(s), including identification of the type of apparatus to be

used [40 CFR 146.87(c)].

• A plan for characterizing the injection and confining zones, including a formation

integrity test for determining fracture pressure [40 CFR 146.87(d)(1)] and any other tests

for determining the physical and chemical characteristics of the injection and confining

zone(s) and formation fluids in the injection zone(s) [40 CFR 146.87(d)(2) and (3)].

• Plans for a pressure fall-off test and either a pump test or injectivity test to verify the

hydrogeologic characteristics of the injection zone(s).

EPA recommends that the description of the proposed pre-operational formation testing program 

be submitted as a PDF.

3.2.7 Demonstration of Storage Capacity 

The Class VI Rule, at 40 CFR 146.83(a)(1), requires that the geologic system at the proposed 

project site have adequate areal extent, thickness, porosity, and permeability to receive the total 

anticipated volume of the carbon dioxide. Some of the information required to support a 

demonstration of this, including the areal extent, thickness, porosity, and permeability of the 

injection zone, must be submitted pursuant to 40 CFR 146.82(a)(3)(iii) and is described above. 

To demonstrate storage capacity, the owner or operator will need to use these data, in addition to 

other parameters, to provide a capacity estimate. Depending upon the method selected for 

estimation of storage capacity, a number of types of data may be needed, and field and/or 

laboratory data collection may be needed if existing data are not available. Additional 

information on capacity estimation methods and required data is provided in the UIC Program 

Class VI Well Site Characterization Guidance. 
Draft UIC Program Class VI Well Recordkeeping, 27 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

For the capacity estimate, EPA recommends that the following information be submitted: 

• A summary table of all of the data used to formulate the estimate (e.g., porosity values,

permeability, injectivity, fracture pressure), with indications of uncertainty to the extent

possible.

• Information on collection of additional data (e.g., sampling and measurement locations,

methods, results) not required elsewhere under 40 CFR 146.82(a).

• Description of the method/model used to estimate storage capacity, including any

inherent assumptions and a description of the method’s suitability for the formation type.

• Any supporting calculations or model results.

• A discussion of the results, relating them to proposed operational parameters and the

anticipated total volume of carbon dioxide to be injected over the lifespan of the project.

• A discussion of any uncertainties or limitations in the results and a discussion of

uncertainty based on the results of a sensitivity analysis.

• A discussion of how the results are supported by the AoR delineation modeling.

EPA recommends that any new data be submitted in tabular and/or graphical format, with spatial 

data in a GIS-compatible format; original data submitted to meet other permit application 

requirements may be referenced. EPA recommends that owners or operators submit 

accompanying information related to key findings of this demonstration as a narrative in PDF. 

3.3 AoR Delineation and Corrective Action

The Class VI Rule, at 40 CFR 146.84(a), requires that the AoR be delineated using 

computational modeling that accounts for the physical and chemical properties of all phases of 

the injected carbon dioxide stream based on available site characterization, monitoring, and 

operational data. The delineation of the AoR must be consistent with the methodology described 

in the AoR and Corrective Action Plan submitted by the owner or operator as part of the permit 

application [40 CFR 146.84(b)(1)]. Detailed information on model development and AoR 

delineation can be found in the UIC Program Class VI Well Area of Review Evaluation and 

Corrective Action Guidance.

3.3.1 AoR and Corrective Action Plan 

As part of the permit application [40 CFR 146.82(a)(13) and 40 CFR 146.84(b)], owners or 

operators of Class VI injection wells are required to submit an AoR and Corrective Action Plan 

that describes how they plan to delineate the final AoR using computational modeling, address 

all deficient artificial penetrations within the AoR, and update the AoR modeling periodically 

throughout the life of the operation. Additional information on the Class VI project plans is 

provided in Section 3.5.1. 
Draft UIC Program Class VI Well Recordkeeping, 28 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

The UIC Program Class VI Well Project Plan Development Guidance presents detailed 

information on development of this plan and its evaluation by the UIC Program Director, as well 

as information on amending the AoR and Corrective Action Plan, if necessary, following each 

reevaluation of the AoR [40 CFR 146.84(e)].

The required content of this plan includes: 

• A description of the method for delineating the AoR and planned computational

modeling (including the name and description of the model, planned assumptions and

inputs, etc.).

• The proposed minimum fixed frequency (at least every five years) for reevaluating the

AoR.

• An explanation of monitoring and operating conditions under which a reevaluation would

be needed prior to the next scheduled reevaluation.

• A description of how monitoring and operational data will be used to inform an AoR

reevaluation.

• A description of how corrective action will be conducted, including which corrective

action activities will be performed prior to injection and how corrective action activities

will be adjusted if there are changes to the AoR (see also Section 3.3.3).

• A description of the portions of the AoR that will have corrective action addressed on a

phased basis (if applicable) and how the schedule for phased corrective action will be

determined.

• An explanation of how site access will be guaranteed for future corrective action.

EPA recommends that the AoR and Corrective Action Plan be submitted in PDF, supplemented 

with data (e.g., information for each existing well) in a tabular and/or GIS-compatible format. 

EPA encourages the use of GIS-compatible maps for presenting spatial information, such as the 

location of wells that will receive corrective action at various times under a phased corrective 

action approach. 

3.3.2 AoR Delineation

EPA recommends that owners or operators of Class VI wells submit all information that the UIC 

Program Director would need for the evaluation and possible replication of the AoR delineation. 

EPA recommends that the following information be submitted to support the AoR delineation: 

• The conceptual site model and all supporting data on which the model is based, including

the description of geologic stratigraphy and any relevant geologic features.
Draft UIC Program Class VI Well Recordkeeping, 29 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• The attributes of the code used to create the computational model (e.g., code name, name

of the developing organization, governing equations employed, and simplifying

assumptions).

• A description of the model’s lateral and vertical extents, geologic layer thickness, and

grid cell sizes, as presented on maps and cross sections.

• An accounting of all equations of state used to describe the thermophysical properties of

all modeled fluids (e.g., ground water, carbon dioxide).

• The constitutive relationships of the permeable medium (e.g., relative permeabilitysaturation relationship) and a description of how they were determined.

• The values of all model parameters and a description of how model parameters were

determined based on site characterization.

• The model results, depicting the extent of carbon dioxide plume and pressure-front

migration over the lifetime of the project as a function of time, as well as the results of

simulations of the maximum risk scenario and the outcome of parameter sensitivity

analyses.

• Raw model input and output files, if requested by the UIC Program Director.

• The relevant qualifications and professional experience of any individuals and/or

consulting firms responsible for model development and AoR delineation, including

examples of previous multiphase modeling studies conducted, if required by the UIC

Program Director.

This information allows the UIC Program Director to replicate the computational modeling 

exercise or run alternative simulations/scenarios with the model if he or she elects to do so. EPA

also recommends that information pertaining to the AoR delineation be submitted in a PDF 

report with supporting data in tabular and/or GIS-compatible formats. EPA recommends the use 

of GIS-compatible maps and cross sections for presenting information where applicable, such as 

model boundary conditions and layers and simulation results. EPA also encourages the use of 

graphical representations, where possible, to accompany submitted tabular data. 

3.3.3 Corrective Action

The Class VI Rule, at 40 CFR 146.84(c)(2), requires owners or operators of Class VI injection 

wells to identify all artificial penetrations (e.g., active and abandoned wells, underground mines) 

within the delineated AoR that penetrate the confining zone and provide information about each 

well to the UIC Program Director. Well identification and assessments and any needed corrective 

action must be conducted as described in the AoR and Corrective Action Plan [40 CFR 

146.84(b)(2)(iv)] that is submitted as part of the permit application. 
Draft UIC Program Class VI Well Recordkeeping, 30 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

EPA recommends that owners or operators submit the following information pertaining to 

corrective action as part of the AoR and Corrective Action Plan: 

• A tabulation of all wells within the AoR that penetrate the confining zone(s) and each

well’s type, construction, date drilled, location, depth, record of plugging and/or

completion, and any additional information required by the UIC Program Director [40

CFR 146.84(c)(2)].

• The results of any site investigations performed to establish the condition of wells for

which no records are available.

• A determination of whether wells in the AoR have been plugged in a manner that

prevents the movement of carbon dioxide or other fluids that may endanger USDWs [40

CFR 146.84(c)(3)].

• Any reports of tests done on abandoned wells.

• A list of wells for which corrective action will be conducted.

EPA recommends that information pertaining to corrective action be submitted in a PDF file 

with supplemental data in tabular and/or GIS-compatible formats. EPA also encourages the use 

of GIS-compatible maps, in addition to the submission of tabular data, when indicating the 

location of wells or presenting various phases of corrective action. 

At the discretion of the UIC Program Director, the owner or operator may perform corrective 

action for wells in the AoR of Class VI injection wells on a phased basis [40 CFR 

146.84(b)(2)(iv)]. The UIC Program Class VI Well Area of Review Evaluation and Corrective 

Action Guidance provides further information on phased corrective action. If phased corrective 

action is authorized by the UIC Program Director, EPA recommends that the owner or operator 

submit a schedule of corrective action activities, including the date(s) on which corrective action 

is planned for all wells in the AoR that require it. Reporting requirements and recommendations 

related to phased corrective action activities are discussed in Section 5.3. 

3.4 Financial Responsibility Demonstration

The Class VI Rule, at 40 CFR 146.85, requires owners or operators of Class VI wells to 

demonstrate and maintain financial responsibility for performing corrective action, injection well 

plugging, PISC, site closure, and emergency and remedial response. More detailed information is 

given in the UIC Program Class VI Financial Responsibility Guidance. 

Owners or operators must submit an initial financial responsibility demonstration with the permit 

application [40 CFR 146.82(a)(14)]. This section describes the components of the initial 

demonstration; reporting related to financial responsibility updates and notifications are 

described in Section 5.4. The rest of this subsection discusses each of these components and the 

reporting activities associated with them. 
Draft UIC Program Class VI Well Recordkeeping, 31 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.4.1 Financial Instruments

The owner or operator must submit a document that proves an independent third-party 

instrument or self insurance is in place and is sufficient to cover the estimated costs as discussed 

in Section 3.4.2. The Class VI Rule describes the following qualifying financial instruments [40 

CFR 146.85(a)(1)]: 

• Trust funds.

• Surety bonds.

• Letter of credit.

• Insurance.

• Self insurance.

• Escrow account.

• Any other instrument(s) satisfactory to the UIC Program Director.

In all cases, EPA recommends that a hard copy of the signed agreement be provided to the UIC 

Program Director along with a PDF version submitted electronically. For insurance policies, 

EPA recommends that a copy of the policy be included in addition to the certificate of insurance. 

Because the specifications required for submission will vary somewhat depending on the type of 

instrument, owners or operators should consult the UIC Program Class VI Financial 

Responsibility Guidance to understand the required specifications and other specifications 

recommended by EPA. 

For third-party instruments, the owner or operator must document the financial strength of the 

provider [40 CFR 146.85(a)(6)(ii)]. The following information about the third party may be 

requested of the owner or operator to demonstrate the third party’s financial strength and may be 

submitted as PDF files or in a tabular format in spreadsheets or database files:

• Third-party credit rating.

• Third-party minimum capitalization evaluation (in some cases).

• Third-party bond rating.

For self insurance, the financial strength of the owner or operator or its corporate parent must be 

documented. The requirements for meeting the financial coverage criteria and financial tests are 

listed at 40 CFR 146.85(a)(6)(v) and are discussed in depth in the UIC Program Class VI 

Financial Responsibility Guidance. EPA recommends the owner or operator submit the 

following information to demonstrate that the company passes the financial tests required by the 

Class VI Rule:
Draft UIC Program Class VI Well Recordkeeping, 32 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• A letter from the Chief Financial Officer of the company stating that the coverage criteria

and either the bond rating or the financial ratio test requirements have been satisfied.

• A copy of the independent certified public accountant’s report on examination of the

owner’s or operator’s financial statements for the latest completed fiscal year.

• A letter from an independent certified public accountant to the owner or operator stating

that:

o The certified public accountant has compared the data specified in the Chief

Financial Officer’s letter with the amounts in the financial statements for the latest

completed fiscal year.

o The certified public accountant followed Generally Accepted Accounting

Principles.

In addition, other information may be submitted to provide additional proof of financial strength 

and may be requested by the UIC Program Director such as:

• A copy of the most recent Securities and Exchange Commission 10-K report.

• A copy of the most recent Federal Energy Regulatory Commission Form 2 report.

EPA recommends that all of the above information be submitted as PDF files. 

3.4.2 Cost Estimates

Owners or operators of Class VI wells are required under 40 CFR 146.85(c) to submit a detailed 

written estimate in the permit application, in current dollars, for each of the activities required to 

be covered by the financial responsibility instrument(s) [40 CFR 146.85(a)(2)]. The costs must 

be estimated based on the current cost of hiring an independent third party to perform the work 

required [40 CFR 146.85(c)(1)]. 

EPA recommends that the cost estimates be reported to the UIC Program Director in the form of 

PDF files with any supporting data in tabular form. These estimates may be supported by 

engineering reports included in the same submission. The UIC Program Class VI Financial 

Responsibility Guidance includes more information on how to document and perform cost 

estimates for required GS activities. 

3.5 Proposed Activities and Project Plans

The Class VI Rule, at 40 CFR 146.82(a)(7) through (19), requires owners or operators to submit 

information related to the construction and operation of the proposed injection well. This 

includes a set of proposed project plans, as well as proposed operating data and construction 

plans. This section describes the submissions associated with these activities. 
Draft UIC Program Class VI Well Recordkeeping, 33 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.5.1 Proposed Project Plans

The Class VI Rule requires owners or operators to submit a set of proposed project plans as part 

of the permit application [40 CFR 146.82(a)(13), (15), (16), (17), and (19)]. These plans are: 

• The AoR and Corrective Action Plan, which describes how owners or operators plan to

delineate the AoR using computational modeling, address all deficient artificial

penetrations within the AoR, and update the AoR modeling periodically throughout the

life of the Class VI project. More detailed information on the AoR and Corrective Action

Plan is provided in Section 3.3.1.

• The Testing and Monitoring Plan, which describes how owners or operators will meet

the Class VI testing and monitoring requirements at 40 CFR 146.90 by including, at a

minimum, a discussion of the following:

o Procedures and frequencies for analysis of the chemical and physical

characteristics of the carbon dioxide stream.

o MITs.

o Corrosion monitoring.

o Determination of the position of the carbon dioxide plume and elevated pressure.

o Monitoring of geochemical changes in the subsurface.

o If required by the UIC Program Director, surface air and/or soil gas monitoring

for carbon dioxide fluxes.

o Any additional tests necessary to ensure USDW protection.

• The Injection Well Plugging Plan, which describes how the owner or operator will meet

the Class VI injection well plugging requirements at 40 CFR 146.92 by including, at a

minimum, a discussion of the following:

o Appropriate tests or measures to determine bottom-hole reservoir pressure.

o Appropriate testing methods to ensure external mechanical integrity.

o The type and number of plugs to be used.

o The placement of each plug, including the elevation of the top and bottom of each

plug. EPA recommends that the plan include schematics and drawings.

o The type, grade, and quantity of material to be used in plugging.
Draft UIC Program Class VI Well Recordkeeping, 34 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

o The method of plug placement, such as the balance method, retainer method, or

two-plug method.

• The PISC and Site Closure Plan, which, pursuant to the Class VI Rule at 146.93, must

include the following information:

o The differential between pre-injection and predicted post-injection pressures in

the injection zone(s).

o The predicted position of the carbon dioxide plume and associated pressure front

at site closure as demonstrated in the AoR evaluation.

o A description of post-injection monitoring locations, methods, and proposed

frequency.

o A proposed schedule for submitting PISC monitoring results to the UIC Program

Director.

o The duration of the PISC timeframe and, if approved by the UIC Program

Director, the demonstration that an alternative PISC timeframe is appropriate (see

Section 3.5.2).

• The Emergency and Remedial Response Plan, which does not have specific content

required by the Class VI Rule but may include information such as the following:

o A list of all potentially impacted environmental resources (e.g., ground water or

surface water) or infrastructure (e.g., the well or other structures) near the well.

o Potential risk scenarios for each identified resource or infrastructure element (e.g.,

a well blowout, equipment failure, fluid movement, metals leaching,

contamination of the water supply).

o Response actions to address the identified risk scenarios (e.g., remedial cementing

of the well or treatment of ground water or drinking water supplies).

o Personnel and equipment needed to implement the response actions (e.g., first

responders, GS project facility staff, or environmental contractors).

o Other related information, such as:

 Facility emergency 24-hour contacts, including phone numbers and email

addresses.

 A list of people to notify in case of an adverse event.

 The location of the well, such as the specific town or county.
Draft UIC Program Class VI Well Recordkeeping, 35 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

 A map of the area, including the location of the well and nearby

population centers or sensitive environments.

 Schematics and diagrams of the facility and well, including the location of

monitoring equipment and emergency shutoffs.

 A communications plan and emergency notification procedures describing

potential audiences, communication methods, and messages.

Details on the development of each of the project plans are provided in the UIC Program Class 

VI Well Project Plan Development Guidance. EPA recommends that the narrative components of 

each plan be submitted as PDF files, with supporting tabular data included as appropriate in 

spreadsheets or database files. EPA encourages the use of GIS-compatible maps for presenting 

spatial information in the plans, such as locational information for the wells that will receive 

corrective action at various times under a phased corrective action approach in the AoR and 

Corrective Action Plan.

3.5.2 Alternative PISC Timeframe 

The Class VI Rule, at 40 CFR 146.93(c), allows UIC Program Directors to approve alternative 

PISC timeframes in consultation with EPA, based on a demonstration by the owner or operator. 

The UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site 

Closure provides more information on the alternative PISC timeframe demonstration. 

Pursuant to 40 CFR 146.93(c)(1), the demonstration must include documentation of: 

• The results of site-specific computational modeling.

• The predicted timeframe for pressure decline such that formation fluids may not be

forced into USDWs, and/or the timeframe for pressure decline to pre-injection pressures.

• The predicted rate of carbon dioxide plume migration within the injection zone.

• Site-specific chemical processes that will result in carbon dioxide trapping.

• The predicted rate of carbon dioxide trapping.

• Characterization of the confining zone(s).

• Laboratory analyses or research studies to verify the information on trapping.

• The presence of potential conduits for fluid movement and the quality of abandoned well

plugs within the AoR.

• The distance between the injection zone and the USDWs above and/or below the

injection zone.
Draft UIC Program Class VI Well Recordkeeping, 36 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Any additional site-specific factors determined by the UIC Program Director.

EPA recommends that the submission consist of a PDF report with maps, figures, and tabular 

data included as appropriate. EPA encourages the use of GIS-compatible formats for presenting 

any spatial information.

3.5.3 Proposed Operating Information 

As part of the permit application, owners or operators must submit proposed operating data for 

the Class VI project, including: 

• The average and maximum daily rate and volume and/or mass and total anticipated

volume and/or mass of the carbon dioxide stream [40 CFR 146.82(a)(7)(i)].

• The average and maximum injection pressure [40 CFR 146.82(a)(7)(ii)].

• The source(s) of the carbon dioxide stream [40 CFR 146.82(a)(7)(iii)].

• An analysis of the chemical and physical characteristics of the carbon dioxide stream [40

CFR 146.82(a)(7)(iv)].

Owners or operators must also submit information on proposed operating procedures, outlining 

the steps necessary to conduct injection operation [40 CFR 146.82(a)(10)]. EPA recommends 

that the proposed operating information be submitted as a PDF narrative, with the proposed 

operating parameters (rate, volume, etc.) submitted in a tabular format.

3.5.4 Proposed Well Construction Information 

The Class VI Rule requires owners or operators to submit information about the proposed well 

design to demonstrate that the planned well construction is adequate to prevent movement of 

fluids into USDWs or other unauthorized zones [40 CFR 146.86(a)(1)]. This information 

includes well schematics and construction processes, as well as specific information pertaining to 

some well components. 

3.5.4.1 Schematics and Construction Plans 

The owner or operator must submit schematics showing details of the well construction and 

proposed construction procedures. The schematics and construction procedures as designed must 

be submitted with the permit application as required at 40 CFR 146.82(a)(11) and (12). 

Drawings submitted by the owner or operator must include all the appropriate details of well 

construction including above- and below-ground details [40 CFR 146.82(a)(11)]. The UIC Class 

VI Well Construction Guidance contains more specific information on construction elements 

necessary to comply with 40 CFR 146.86. EPA recommends that the schematics and drawings 

include the following elements:

• The wellhead.
Draft UIC Program Class VI Well Recordkeeping, 37 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• The surface casing.

• The long string casing.

• Any intermediate casings.

• Cement placement.

• Tubing.

• Packer placement.

• The type and location of the safety valve(s) and any landing nipples, if used.

• Completion details, including perforated zones and material to be used.

Schematics and drawings may be from computer-aided design programs or blueprints and EPA 

recommends that they be submitted as PDF files. The owner or operator must also submit 

injection well construction procedures that meet the requirements of 40 CFR 146.86 [40 CFR 

146.82(a)(12)]. The following are examples of documents that may be submitted to aid the UIC 

Program Director in establishing the effectiveness of the construction procedures: 

• A copy of the construction specifications, including casing diameter, radius of curvature,

and angle of deviation.

• References to any standards or best management practices to be used in construction

(e.g., American Petroleum Institute (API) specifications) to be followed.

• Manufacturer specifications on materials used for well construction including corrosion

and temperature resistance ratings and material strengths.

• Proposed drilling procedures.

• Proposed cementing procedures.

• Perforation techniques.

• A list of logs or measurements that will be made to guide/verify the construction process.

EPA recommends that these documents be submitted as PDF files. Final construction procedures 

and the associated reporting requirements are described in Section 4.3. 

If applicable, owners or operators must also submit a description of the proposed stimulation 

program, including the proposed stimulation fluids and a determination that stimulation will not 

interfere with containment [40 CFR 146.82(a)(9)]. EPA recommends that this submission take 

the form of a PDF report, with supporting data (e.g., pressure data, modeling results) in tabular 
Draft UIC Program Class VI Well Recordkeeping, 38 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

or GIS-compatible formats. The UIC Program Class VI Well Construction Guidance contains 

more information about injection pressure and stimulation. 

3.5.4.2 Casing and Cementing 

In order for the UIC Program Director to determine and specify casing and cementing 

requirements, the owner or operator must submit the information required in 40 CFR 

146.86(b)(1)(i) through (ix). See the UIC Class VI Well Construction Guidance for more details 

on the design of the casing to prevent fluid movement. The required information includes: 

• Depth to the injection zone.

• Injection pressure, external pressure, internal pressure, and axial loading.

• Hole size.

• Size and grade of all casing strings (including wall thickness, external diameter, nominal

weight, length, joint specification, and construction material).

• Corrosiveness of the carbon dioxide stream and formation fluids.

• Down-hole temperatures.

• Lithology of the injection and confining zones.

• Type or grade of cement and cement additives.

• Quantity, chemical composition, and temperature of the carbon dioxide stream.

If staged cementing is used, the owner or operator must submit the staging procedures with the 

permit application [40 CFR 146.86(a)(4)]. EPA recommends that the owner or operator submit 

information on the location and timing of each stage as part of this submission. Additionally, if 

cement cannot be recirculated to the surface and the UIC Program Director approves an 

alternative method of cementing, owners or operators must submit logs to demonstrate that the 

cement does not allow fluid migration behind the well bore [40 CFR 146.86(b)(4)]. Regardless 

of the cement technique used, the cement placement must be verified using logs (see Section 

4.3). The UIC Program Class VI Well Testing and Monitoring Guidance describes logs that can 

be used to verify external mechanical integrity and the location of the cement. 

EPA recommends owners or operators submit data in a tabular format with accompanying 

descriptions in a PDF file or files.

3.5.4.3 Tubing and Packer 

In order for the UIC Program Director to determine and specify requirements for the tubing and 

packer, the owner or operator must submit the following information [40 CFR 146.86(c)(3)]: 
Draft UIC Program Class VI Well Recordkeeping, 39 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Depth of packer setting.

• Characteristics of the carbon dioxide stream (chemical content, corrosiveness,

temperature, and density) and formation fluids.

• Maximum proposed injection pressure.

• Maximum proposed annulus pressure.

• Proposed injection rate (intermittent or continuous) and volume and/or mass of the

carbon dioxide stream.

• Size of tubing and casing.

• Tubing tensile, burst, and collapse strengths.

The data may be submitted in tabular format in a spreadsheet and/or database file. EPA 

recommends that accompanying descriptions be submitted in a PDF narrative. The UIC Class VI 

Well Construction Guidance contains more detailed information on design considerations for 

tubing and packer for Class VI wells. 

3.6 Injection Depth Waivers

The Class VI Rule, at 40 CFR 146.95(a), requires owners or operators seeking a Class VI waiver 

of the injection depth requirements to submit additional information for a comprehensive 

assessment of site suitability to inject into a non-USDW above or between USDWs. Owners or 

operators must submit a waiver application report at the same time as the Class VI permit 

application [40 CFR 146.82(d) and 146.95(a)]. The waiver application report is a separate 

submittal which complements the Class VI permit application. 

EPA expects that the waiver application report will contain some information that is similar to 

(or references) information submitted in the permit application. However, the submittal must be 

tailored to demonstrate that all USDWs—above and below the injection zone—will be protected. 

For more information, see the UIC Program Class VI Well Injection Depth Waivers Guidance. 

EPA recommends that owners or operators retain a copy of the report throughout the life of the 

GS project and 10 years following site closure. 

In addition to the information described below, owners or operators of Class VI wells must also 

submit in the waiver application report any other information requested by the UIC Program 

Director to inform the Regional Administrator’s decision to issue a waiver [40 CFR 

146.95(a)(7)]. 

3.6.1 Site Characterization Data to Support Injection Depth Waivers

The Class VI Rule, at 40 CFR 146.95(a)(1) and (2), requires that the waiver application report 

include demonstrations of the suitability of the injection and confining zones. Specifically, the 

report must demonstrate that each injection zone is laterally continuous, is not a USDW, and is 
Draft UIC Program Class VI Well Recordkeeping, 40 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

not hydraulically connected to USDWs; does not outcrop; has adequate injectivity, volume, and 

sufficient porosity to safely contain the injected carbon dioxide and formation fluids; and has 

appropriate geochemistry [40 CFR 146.95(a)(1)]. In addition, the waiver application report must 

demonstrate that each injection zone is bounded, above and below, by laterally continuous, 

impermeable, confining units [40 CFR 146.95(a)(2)]. 

These demonstrations may be supported by site characterization information that is similar to the 

information submitted in the permit application and the information described in Section 3.2. 

EPA recommends that owners or operators submit the following types of supporting information 

as part of these demonstrations: 

• Geologic maps and perpendicular cross sections.

• Geophysical surveys (e.g., seismic survey data) and well logs.

• Petrophysical measurements on core samples.

• Chemical analyses of formation fluids.

• Carbon dioxide storage volume calculations.

EPA recommends that owners or operators report the description of these demonstrations in 

PDF, including narrative and graphical information. Data supporting the discussions or graphs 

may be submitted separately in a tabular format, such as a spreadsheet or database file. EPA also 

recommends that any spatial data be submitted in a GIS-compatible format for allowing more 

flexible visualization and evaluation of the data. 

Owners or operators may also need to submit additional site characterization information to 

support the UIC Program Director’s submission on the proposed waiver to the EPA Regional 

Administrator [40 CFR 146.95(b)]. More details on this submission and the Regional 

Administrator’s review are provided in the UIC Program Class VI Well Recordkeeping, 

Reporting, and Data Management Guidance for Permitting Authorities and the UIC Program 

Class VI Well Injection Depth Waivers Guidance.

3.6.2 Modeling Demonstration that USDWs Above and Below the Injection Zone 

are Protected

The Class VI Rule requires, at 40 CFR 146.95(a)(3), that the owner or operator include in the 

waiver application report a demonstration, using computational modeling, that USDWs above 

and below the injection zone will not be endangered as a result of fluid movement. This 

modeling must be conducted in conjunction with the AoR delineation required at 40 CFR 146.84 

and is expected to be similar in format and type to the information described in Section 3.3.2 of 

this guidance document. Information submitted to satisfy this requirement as part of the waiver 

application report may include (but is not limited to) the following: 
Draft UIC Program Class VI Well Recordkeeping, 41 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Attributes of the code used to create the computational model (e.g., code name, name of

the developing organization, governing equations employed, and simplifying

assumptions).

• Additional input parameters beyond those developed as part of the Class VI AoR

delineation (e.g., formation elevation and thickness, intrinsic permeability, porosity, and

characteristic curve parameters describing the lower confining zone, lowermost USDW,

and any zones intermediary to the lower confining zone and lowermost USDW).

• The conceptual model, accounting for additional formations above and below the

injection zone(s) and all supporting data (e.g., structural geology including folding and

fracture and fault systems).

• The model results, showing the vertical fluid migration and pressure changes above and

below the injection zone as well as the lateral extent of the AoR.

• A description of the model’s lateral and vertical extents, geologic layer thickness, and

grid cell sizes as presented on maps and cross sections.

• Additional constitutive relationships of the permeable medium (e.g., relative

permeability-saturation relationship) and a description of how they were determined.

• The values of additional model parameters and a description of how model parameters

were determined based on site characterization.

• If requested by the UIC Program Director, raw model input and output files.

Section 3.3.2 provides more information about submitting model results. EPA recommends that 

the descriptions of the modeling demonstration be submitted in narrative form as a PDF file. The 

waiver application report may reference some of the background information on the model that is 

included in the Class VI permit application, as long as it is readily available, and the model and 

its results are clearly explained in the waiver application report. Any new supporting data may be 

submitted in a tabular format as a spreadsheet or database file. EPA recommends that spatial data 

be submitted in a GIS-compatible format. 

3.6.3 Well Design and Construction 

The Class VI Rule requires, at 40 CFR 146.95(a)(4), that the owner or operator include in the 

waiver application report a demonstration that the injection well will be constructed to ensure 

isolation of the injectate. In addition to the information pertaining to injection well construction 

provided in Section 3.5.4 of this guidance document, information to be submitted in the waiver 

application report may include: 

• Construction plans and procedures that demonstrate that the wellbore will not act as a

conduit for fluid movement out of the injection zone and indicate the placement and
Draft UIC Program Class VI Well Recordkeeping, 42 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

location of all casing strings in relation to the injection zone, upper and lower confining 

zones, and all USDWs above and below the injection zone. 

• Complete construction schematics, indicating the depth, thickness, and materials used in

all casings and cement; the type of cement used; and the placement of cement along the

entire lengths of both the surface and long string casings.

• A demonstration of the effectiveness of the casing and cement design by resubmitting

the information described in Section 3.5.4.2 of this guidance document along with a

description of the intended cementing procedures indicating how cement will be

circulated to the surface and any special considerations for weak geologic or overpressured zones.

• Strength calculations for casing and tubing.

• Information on the compatibility of materials used for cement, casing, tubing, and packer

with carbon dioxide and formation fluids.

Similar to the information described in Section 3.5.4, EPA recommends that this information be 

submitted in a combination of PDF for narrative components and tabular formats for any 

supporting data. 

3.6.4 Testing and Monitoring

The waiver application report must also describe how the owner or operator intends to perform 

additional testing and monitoring for GS projects operating under injection depth waivers. 

Additional requirements at 40 CFR 146.95(f)(3)(i) address the need to monitor below the lower 

confining zone for geochemical changes and pressure in the first USDWs immediately above and 

below the injection zone(s). EPA recommends that the waiver application report include a 

description of the following: 

• Ground water quality monitoring above and below the injection zone(s) (e.g., monitoring

parameters, frequency of sampling, depth of monitoring) and planned locations for

testing and monitoring.

• Carbon dioxide plume and pressure front tracking technologies to be employed to obtain

data below the lower confining zone.

• Pressure monitoring above and below the injection zone.

EPA recommends that the description be submitted in narrative form in a PDF file, with 

supporting data submitted in a tabular format and spatial data in the form of GIS-compatible 

maps. 
Draft UIC Program Class VI Well Recordkeeping, 43 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.6.5 Site Resource Use Information

In addition to the above requirements, the waiver application report must also contain 

information for evaluating site resource use as outlined at 40 CFR 146.95(a)(6). This information 

will also be necessary to support the UIC Program Director’s submission to the Regional 

Administrator, as described in 40 CFR 146.95(b)(1)(v) through (viii). 

EPA recommends that the information in the following three subsections be submitted to meet 

the requirement at 40 CFR 146.95(a)(6) and inform the submission under 40 CFR 

146.95(b)(1)(v) through (viii). EPA recommends that the information be submitted in a PDF 

report with supporting data in tabular and/or GIS-compatible formats where needed. 

3.6.5.1 Information on Current Drinking Water Resources

The Class VI Rule requires that owners or operators submit information on public water supplies 

served by USDWs in the AoR and USDWs that may be affected by Class VI activities [40 CFR 

146.95(a)(6)]. EPA recommends that owners or operators submit the following information 

related to current drinking water resources in or near the AoR: 

• Names and contact information for drinking water utilities that are within the AoR or

that draw from USDWs that might be affected by the project.

• Population served by those drinking water utilities.

• Number and locations of production wells and the aquifers from which the wells draw.

• Average gallons per day (GPD) withdrawn by each drinking water utility.

• Average GPD delivered by each drinking water utility.

• Locations of private drinking water wells within the AoR.

• Maps showing aquifers currently in use and their relationship to the injection and/or

storage formation.

3.6.5.2 Information on Future Drinking Water Resources

The UIC Program Director’s evaluation must address planned needs and potential and/or future 

use of USDWs and non-USDWs [40 CFR 146.95(b)(1)(vi)]. EPA recommends that owners or 

operators describe the following: 

• Anticipated population growth over the proposed life of the GS project in the region.

• Anticipated land use changes during the operational phase of the project.

• Locations of aquifers that are not currently used but that may be used in the future.
Draft UIC Program Class VI Well Recordkeeping, 44 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Future projections of water usage over five, 10, and 20 years, if available.

• Potential changes in water supply.

3.6.5.3 Information on Potential Water, Hydrocarbon, and Mineral Resource Use

The UIC Program Director must also evaluate information related to planned or permitted water 

(i.e., non-drinking water), hydrocarbon, and mineral resource exploitation potential [40 CFR 

146.95(b)(1)(vii)]. This includes formations both above and below the injection zone(s), if there 

are any plans to drill through the formation to access resources in or below the injection zone(s). 

EPA recommends that this submittal include:

• Geologic maps and cross sections showing all non-USDWs above and below the

injection zone.

• Names, thicknesses, and depths of all non-USDWs above and below the injection zone in

the region.

• Any available chemical analyses of ground water in non-USDWs.

• Any available information on projected water use/development of currently unused

USDWs or installation of new wells in currently used non-USDWs.

• A map with the location of economically viable and potentially economically viable

deposits.

• The depths and host formations of deposits.

• Geologic maps and cross sections of the region showing information on resources, or

copies of the maps required under 40 CFR 146.82(a)(3) with resource information

highlighted.

• Maps and descriptions of any past or current mining or hydrocarbon recovery activities,

including well locations and API numbers.

• Information on whether future use of minerals and hydrocarbons has been permitted

and/or planned.

EPA recommends that narrative information be submitted in PDF files with supplemental data in 

tabular format submitted separately in a spreadsheet or database file, preferably in a format that 

is compatible with GIS (if applicable). EPA recommends that maps be submitted in a GIScompatible format for greater flexibility in evaluating the information.

3.6.5.4 Information on Water Treatment or Alternative Resources

UIC Program Directors are required, at 40 CFR 146.95(b)(1)(viii), to consider and submit to the 

Regional Administrator a plan for securing alternative water resources or treating ground water 
Draft UIC Program Class VI Well Recordkeeping, 45 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

in case of contamination of a water supply. EPA recommends that the owner or operator provide 

this plan in the waiver application report, as well as make it a part of the Emergency and 

Remedial Response Plan submitted as part of the permit application. EPA recommends that 

owners or operators submit the following information as part of the water resources plan: 

• The condition of currently used water supply sources, including total capacity and

existing treatment facilities.

• The condition of currently used water distribution systems, including contamination

problems and potential for connection to an alternate water supply source.

• The capabilities of other regional water supply systems, including available excess

capacity and ease of connection to the distribution system of the contaminated water

supply system.

• The hydrogeology and hydrology of water resources currently supplying water and those

that could potentially serve as a water supply.

3.6.6 Emergency and Remedial Response and Financial Responsibility

The Class VI Rule requires that the UIC Program Director provide to the Regional Administrator 

an evaluation of the owner or operator’s proposed Emergency and Remedial Response Plan and 

demonstration of financial responsibility [40 CFR 146.95(b)(1)(iv)]. 

EPA recommends that the owner or operator provide, in the waiver application report, a 

demonstration of sufficient, additional financial responsibility to address any contamination of 

USDWs. Because the financial responsibility demonstration for the project must address the 

considerations described above, owners or operators may submit a copy of the financial 

responsibility demonstration submitted for the permit application with the injection depth waiver 

application. 

EPA recommends that the owner or operator provide in the waiver application report a 

description of how the proposed Emergency and Remedial Response Plan will address any 

contamination that impacts USDWs above and below the injection zone and a demonstration of 

sufficient, additional financial responsibility to address any contamination of all USDWs. 

Because the Emergency and Remedial Response Plan that is submitted with the permit 

application will need to consider the information described above, owners or operators may 

submit a copy of the Emergency and Remedial Response Plan from the permit application with 

the injection depth waiver application. See the UIC Program Class VI Well Injection Depth 

Waivers Guidance for additional information on how owners or operators can develop an 

Emergency and Remedial Response Plan that addresses all considerations for projects with 

injection depth waivers. The UIC Program Class VI Financial Responsibility Guidance provides 

additional information on the financial responsibility demonstration. See Sections 3.4 and 3.5.1

and of this guidance document for reporting information related to the financial responsibility 

demonstration and the Emergency and Remedial Response Plan, respectively.
Draft UIC Program Class VI Well Recordkeeping, 46 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.7 Wells Transitioning from Class II to Class VI

Class II wells must be re-permitted as Class VI if a determination is made that the primary 

purpose of the carbon dioxide injection is for GS and there is an increased risk to USDWs 

compared to Class II operations [40 CFR 144.19]. Following re-permitting as a Class VI project, 

the owner or operator must comply with all Class VI requirements. Therefore, the reporting, 

recordkeeping, and data management aspects of projects seeking to transition to Class VI 

Program are expected to be the same as described in this guidance document with some 

exceptions, such as well construction grandfathering and expanding existing aquifer exemptions. 

3.7.1 Well Construction

At the discretion of the UIC Program Director, at 40 CFR 146.81(c), certain components of Class 

II well construction may be grandfathered into the Class VI Program, provided the owner or 

operator can demonstrate to the UIC Program Director that the wells were engineered and 

constructed to meet the requirements at 40 CFR 146.86(a). The owner or operator must also 

demonstrate that the wells are constructed to ensure protection of USDWs in lieu of the 

requirements for casing and cementing of Class VI wells at 40 CFR 146.86(b) and the 

requirements for logging, surveying, and testing prior to injection well operation at 40 CFR 

146.87(a). 

In these cases, EPA recommends that the following information be submitted along with the 

more detailed reporting requirements for Class VI well construction as described in Section 3.5.4

of this guidance document: 

• Original well schematics, construction procedures, and as-built specifications.

• Recent internal and external MIT results.

• Cementing records for the well.

• Logs showing the location and quality of the existing cement.

• Logs showing the quality of the casing.

The above test results may be presented in tabular format in a spreadsheet or database file, with 

accompanying narrative information in PDF. Graphs, such as temperature vs. depth for 

temperature logs, may be provided in PDF files with supporting data submitted separately in a 

tabular format. 

3.7.2 Aquifer Exemptions

No new aquifer exemptions will be granted for Class VI wells [40 CFR 144.7(a)]. However, 

Class II enhanced recovery wells injecting into exempted aquifers may need to transition to Class 

VI, and owners or operators of these wells may request an expansion of the areal extent of the 

previously approved aquifer exemption [40 CFR 144.7(d)]. 
Draft UIC Program Class VI Well Recordkeeping, 47 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.7.2.1 Demonstration of Aquifer Exemption Criteria

Owners or operators of transitioning wells need to define the expanded extent of the exempted 

aquifer and demonstrate that the proposed exempted area meets all of the following criteria [40 

CFR 146.4(d)]: 

• It does not currently serve as a source of drinking water.

• The TDS content of the ground water is more than 3,000 mg/L and less than 10,000

mg/L.

• It is not reasonably expected to supply a public water system.

The UIC Program Guidance on Transitioning Class II Wells to Class VI Wells contains 

additional information about aquifer exemption expansions. Owners or operators may submit 

various types of information to support this demonstration. To demonstrate that the expanded 

area of the exempted aquifer does not currently serve as a source of drinking water, the owner or 

operator may submit information on local drinking water supply and use including: 

• Names and contact information for area drinking water utilities.

• Number and locations of production wells and the aquifers in which they are screened.

• Locations of private drinking water wells within the AoR.

• Map(s) of the region showing the locations of drinking water wells, the AoR, and the

proposed exemption area.

• Cross sections of the region showing the aquifers being used for drinking water and their

stratigraphic relationship to the injection formation and the proposed exemption area.

• Local and regional population numbers, along with associated surface land uses (e.g.,

cities, agriculture, etc.).

The owner or operator must demonstrate that the ground water in the expanded area has between 

3,000 mg/L and 10,000 mg/L TDS [40 CFR 146.4(d)(2)]. EPA recommends that owners or 

operators submit the following: 

• Map(s) of the region showing sample locations and associated TDS concentrations.

• Original laboratory reports or tabulated data, if available.

• New laboratory reports, if additional samples were taken.

Finally, the owner or operator must demonstrate that the aquifer is not reasonably expected to 

supply a public water system [40 CFR 146.4(d)(3)]. Information to support this demonstration 

may include:
Draft UIC Program Class VI Well Recordkeeping, 48 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Maps and cross sections showing the locations of aquifers that are not currently used but

that may be used in the future (if applicable) and their relationship to the injection zone,

both laterally and stratigraphically.

• Future projections of regional water usage, population, and urban development over five,

10, and 20 years, if available.

• Potential changes in water supply, including new wells, implementation of aquifer

storage and recovery, or the need to purchase water from other systems if available

sources are likely to be insufficient for increased population growth.

EPA recommends that the submittals described above include narrative information and graphics 

in PDF, accompanied by supporting data in a tabular and/or GIS-compatible format.

3.7.2.2 Defining the New Limits of the Aquifer Exemption

The expanded aquifer exemption area will be based upon the predicted extent of the injected 

carbon dioxide plume, the associated pressure front, and any mobilized fluids that may result in 

degradation of water quality over the lifetime of the project [40 CFR 144.7(d)(2)(ii)]. This 

prediction will be informed by the computational modeling performed for the AoR determination 

required at 40 CFR 146.84(c)(1). 

EPA recommends that owners or operators submit the following information defining the areal 

extent of the expanded aquifer exemption: 

• Regional and local maps showing the areal extent of the current aquifer exemption and

the area of the requested expansion. Maps may be submitted specifically for the aquifer

exemption, and/or a narrative may be provided that references a highlighted area on maps

provided as part of the Class VI permit application requirements at 40 CFR 146.82.

• Perpendicular cross sections to demonstrate the stratigraphic and structural characteristics

of the aquifer in the region of the expansion.

• A discussion of any structures or other features that differ between the original exemption

area and the requested expansion area.

• A synopsis of the results of the computational modeling conducted to support the AoR

delineation for the Class VI well required at 40 CFR 146.84(c)(1), including a map

showing the anticipated AoR and the requested expansion.

Owners or operators may submit narrative information and graphics in PDF, accompanied by 

supporting data in tabular format in a spreadsheet or database file. EPA recommends that maps 

and spatial data be provided in a GIS-compatible format.
Draft UIC Program Class VI Well Recordkeeping, 49 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

3.8 Reporting and Recordkeeping Schedule

Owners or operators must submit the data described in this section with the initial permit 

application, prior to well construction or conversion [40 CFR 146.82(a)]. All information 

submitted as part of the permit application must be retained throughout the life of the GS project 

and for 10 years following site closure [40 CFR 146.91(f)(3)]. 

Pursuant to 40 CFR 146.82(d) and 146.95(a), the waiver application report must be submitted at 

the same time as the Class VI permit application. EPA recommends that owners or operators 

retain a copy of the report throughout the life of the GS project and for 10 years following site 

closure. EPA expects that submissions related to well transitioning and/or an expansion of the 

areal extent of an aquifer exemption will occur at the time of the permit application.

Table 3-1 lists the timing of record submission and the required retention periods as described in 

the Class VI Rule. 

Table 3-1. Reporting and recordkeeping schedule for Class VI activities that take place prior to construction.

Pre-Injection Data Class VI Rule Citation Time for Submission Record Retention

Site characterization 

information

40 CFR 146.82(a)(2) 

through (6)

To support 40 CFR 

146.82(a)(3)(iii)

At UIC Program Director 

discretion to support 40 

CFR 146.90(h)

With the initial 

permit application, 

before well 

construction or 

conversion

[40 CFR 146.82(a)]

10 years following

site closure

[40 CFR 146.91(f)(3)]

Demonstration of storage 

capacity 40 CFR 146.83(a)(1)

Proposed pre-operational 

formation testing program

40 CFR 146.82(a)(8)

AoR delineation 40 CFR 146.84(c) With the initial 

permit application, 

before well 

construction or 

conversion

[40 CFR 146.82(a)]

10 years following

site closure

[40 CFR 146.91(f)(3)]

Financial responsibility 

demonstration 40 CFR 146.85(a)

Proposed project plans 40 CFR 146.82(a)(13), 

(15), (16), (17), (19)
Draft UIC Program Class VI Well Recordkeeping, 50 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Pre-Injection Data Class VI Rule Citation Time for Submission Record Retention

Proposed operating information 40 CFR 146.82(a)(7), 

(10) With the initial 

permit application, 

before well 

construction or 

conversion

[40 CFR 146.82(a)]

10 years following

site closure

[40 CFR 146.91(f)(3)]

Pre-injection stimulation plan 40 CFR 146.82(a)(9)

Proposed well construction 

information

40 CFR 146.82(a)(9), 

(11), (12)

Injection depth waiver 

application report (if applicable) 40 CFR 146.95(a)

Concurrently with 

permit application

[40 CFR 146.82(d)]

10 years following 

site closure

(recommended)

Information to support 

transitioning from Class II to 

Class VI (if applicable)

40 CFR 144.19

Before or concurrent 

with permit 

application 

(recommended)

10 years following 

site closure

(recommended)

Demonstration of criteria 

related to expanding the areal 

extent of an aquifer exemption

(if applicable) 

40 CFR 146.4(d)

Before or concurrent 

with the Class VI 

permit application

(recommended)

10 years following 

site closure

(recommended)
Draft UIC Program Class VI Well Recordkeeping, 51 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

4 Pre-Injection Phase Reporting and Recordkeeping: Prior to 

Injection 

Following the construction of a Class VI well, owners or operators must submit additional 

information before receiving authorization to begin injection [40 CFR 146.82(c)]. This 

information is primarily related to final site characterization and well construction data based on 

the results of pre-injection testing. This section describes the submittals that will take place 

during this phase of the GS project. More information about the UIC Program Director’s 

documentation of oversight and compliance decisions is given in the UIC Program Class VI Well 

Recordkeeping, Reporting, and Data Management Guidance for Permitting Authorities. 

Pursuant to 40 CFR 146.82(c), the following information must be submitted for consideration by 

the UIC Program Director before approval for the operation of a Class VI well may be granted: 

• The final AoR, based on modeling using data obtained during logging and testing of the

well and geologic formations (see Section 4.1).

• Any relevant updates to the information on the geologic structure and hydrogeologic

properties of the proposed storage site and overlying formations, based on data obtained

during logging and testing of the well and formations (see Section 4.2).

• Results of the formation testing program (see Section 4.2).

• Information on the compatibility of the carbon dioxide stream with fluids in the injection

zone(s) and minerals in both the injection and the confining zone(s), based on the results

of the formation testing program, and with the materials used to construct the well (see

Section 4.2.6).

• Final injection well construction procedures (see Section 4.3).

• Status of corrective action on wells in the AoR (see Section 4.1).

• All available logging and testing program data on the well (see Section 4.3).

• Demonstration of mechanical integrity (see Section 4.3).

• Any updates to the proposed project plans (see Section 4.4).

• Any other information requested by the UIC Program Director.

4.1 Final AoR and Corrective Action Status 

The Class VI Rule, at 40 CFR 146.82(c)(1), requires owners or operators to submit the final AoR 

delineation before receiving approval for injection. The final AoR will be based on modeling, 

using data obtained during the logging and testing of the well and the formation. The UIC 
Draft UIC Program Class VI Well Recordkeeping, 52 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Program Class VI Well Area of Review Evaluation and Corrective Action Guidance contains 

more information on the development of the final AoR. EPA expects that this submittal will be 

similar in content and format to the initial AoR delineation; see Section 3.3.2 of this guidance 

document for specific information related to this submittal.

Before receiving authorization to inject, owners or operators must also submit a description of 

the status of corrective action on wells in the AoR [40 CFR 146.82(c)(6)]. EPA recommends that 

owners or operators submit the following information to satisfy this requirement: 

• Reports indicating the number, type, and location of plugs used in corrective action

activities.

• Records of any remedial cementing performed along with cement logs showing the

methods used and the results of the remedial cementing.

As noted in Section 3.3.1, at the discretion of the UIC Program Director, the owner or operator 

may perform corrective action for wells in the AoR of Class VI injection wells on a phased basis 

[40 CFR 146.84(b)(2)(iv)]. The UIC Program Class VI Well Area of Review Evaluation and 

Corrective Action Guidance provides further information on phased corrective action. If phased 

corrective action is authorized, the owner or operator should provide relevant information, 

including the date(s) on which corrective action is planned for all wells in the AoR that require it.

Reporting requirements and recommendations related to documenting the completion of phased 

corrective action activities are discussed in Section 5.3. 

As noted above, EPA recommends that information pertaining to corrective action be submitted 

in PDF with supplemental data in tabular and/or GIS-compatible formats. EPA also encourages 

the use of GIS-compatible maps, in addition to the submission of tabular data, when indicating 

the location of wells or presenting various phases of corrective action. 

4.2 Site Characterization

Following issuance of a Class VI permit and during drilling and construction of a Class VI well, 

the owner or operator must run logs, surveys, and tests to provide information on relevant 

geologic formations and determine the hydrogeologic characteristics of the injection zone(s) [40 

CFR 146.87]. These procedures must be done in accordance with the approved pre-operation 

formation testing program required at 40 CFR 146.82(a)(8), and results must be submitted for the 

UIC Program Director’s consideration [40 CFR 146.82(c)(4)] before the UIC Program Director 

may authorize injection. Related information is provided in the UIC Program Class VI Well Site 

Characterization Guidance. Note that logs and tests are also required to verify that the well was 

properly constructed; see Section 4.3 for additional information. 

4.2.1 Well Logs and Core Analyses 

Well log analysts’ reports, required at 40 CFR 146.87(a), will provide information pertaining 

both to site characteristics and well integrity resulting from well logging and testing conducted 

during well construction. The required well logging tests include the following:
Draft UIC Program Class VI Well Recordkeeping, 53 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Logs and tests performed before and upon installation of the surface casing:

o Resistivity, spontaneous potential, and caliper logs before the casing is installed

[40 CFR 146.87(a)(2)(i)].

o A cement bond log and variable density log to evaluate cement quality radially

and a temperature log after the casing is set and cemented [40 CFR

146.87(a)(2)(ii)].

• Logs and tests performed before and upon installation of the long string casing:

o Resistivity, spontaneous potential, porosity, caliper, gamma ray, fracture finder,

and any other logs the UIC Program Director requires before the casing is

installed [40 CFR 146.87(a)(3)(i)].

o A cement bond log and variable density log to evaluate cement quality radially

and a temperature log after the casing is set and cemented [40 CFR

146.87(a)(3)(ii)].

Additional information on well logs is provided in the UIC Program Class VI Well Site 

Characterization Guidance and the UIC Program Class VI Well Construction Guidance.

EPA recommends that the content of this report include: 

• Charts showing the results of each log and any supplemental data.

• Core analyses performed (e.g., porosity, permeability, geomechanical properties,

petrographic/mineralogic analysis) [40 CFR 146.87(b)].

• Interpretation of the well logs by a log analyst, including determination of porosity,

permeability, lithology, thickness, depth, and formation fluid salinity of relevant geologic

formations, as well as any assumptions.

• Any changes in the interpretation of site stratigraphy based on formation testing logs.

• Identification of any deficiencies in the well construction detected in well testing logs and

steps taken to address these deficiencies.

• The date and time of each test, the date of wellbore completion, and the date of

installation of all casings and cements.

• Records of the most recent calibration of any instruments used during wellbore logging.

• The name of the logging company (if applicable) and log analyst(s).
Draft UIC Program Class VI Well Recordkeeping, 54 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

EPA recommends that the report be submitted in PDF with supplemental data submitted in 

tabular format in a spreadsheet or database file. Spatial information on test locations and such 

may be presented in a map in GIS-compatible format. 

4.2.2 Injection Zone Conditions

Owners or operators must record and submit the following information regarding downhole 

conditions in the injection zone(s) [40 CFR 146.87(c)]: fluid temperature, pH, specific 

conductivity, reservoir pressure, and static fluid level. EPA recommends that owners or operators 

submit this information in tabular form along with the depth, location, date, and time of 

measurement.

4.2.3 Confining Zone and Injection Zone Properties

Owners or operators of Class VI wells are required to determine or calculate the fracture pressure 

of the injection and confining zone(s) [40 CFR 146.87(d)(1)]. EPA recommends that owners or 

operators submit supporting information that includes:

• Date, time, and type of formation integrity test performed (e.g., step-rate test or leak-off

test).

• Test conditions.

• Type and location of the pressure gauge.

• Type of flow meter and calibration records.

• Raw pressure and flow data.

• Plot of flow rate versus pressure data.

• Interpretation, including discussion of any anomalous data.

• Information on the contractor performing the test, if applicable.

At this point in the permitting process, the owner or operator must determine any other relevant 

physical and chemical characteristics of the injection and confining zone(s) [40 CFR 

146.87(d)(2)]. These characteristics will be specified in the approved formation testing program 

and they may include: 

• Updates on geologic characteristics (e.g., geomechanical properties, porosity and

permeability, bulk chemistry), some of which may be provided with the log analyst’s

report.

• Any relevant information regarding tests performed, including any limitations in the data.

• Any new site characterization information that is relevant to the operation.
Draft UIC Program Class VI Well Recordkeeping, 55 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Similarly, the owner or operator must determine the physical and chemical characteristics of the 

formation fluids in the injection zone(s) [40 CFR 146.87(d)(3)] and is encouraged to submit: 

• Type of sampling or measurement equipment used and field procedures.

• If the sample was pumped: flow rate, type of pump, and location of the pump.

• Data from field measurements (e.g., pH, specific conductivity, temperature, pressure).

• Laboratory results, including QA samples (e.g., blanks, duplicates, matrix spikes).

• Notes on any anomalous data.

• Results of calculations/modeling indicating the likely geochemical speciation of fluids at

depth.

EPA recommends that any newly acquired data be submitted in tabular and/or graphical format 

in a spreadsheet or database file, with spatial data in a GIS-compatible format. EPA recommends 

owners or operators submit accompanying information related to key findings of these tests in a 

narrative PDF report. 

4.2.4 Updates to Site Characterization Data

The Class VI Rule, at 40 CFR 146.82(c)(2), requires the owner or operator to submit relevant 

updates to the information on the geologic structure and hydrogeologic properties of the 

proposed injection zone and confining zone(s). This updated information will be based upon data 

obtained during logging and testing of the well and formation as discussed previously in this 

section. EPA recommends a summary of updates be submitted as a PDF file. 

4.2.5 Verification of Hydrogeologic Characteristics of the Injection Zone(s)

Upon completion of the well, the owner or operator must verify the hydrogeologic characteristics 

of the injection zone through a pressure fall-off test and either a pump test or an injectivity test 

[40 CFR 146.87(e)]. 

The owner or operator should submit the date of the test and the contact information for the 

contractor performing the test, if applicable. EPA recommends that the owner or operator submit 

the following information for each test: 

• Pressure fall-off tests:

o Raw pressure data.

o Flow data from the injection portion of the test.

o Test parameters (e.g., injection time, shut-in time, fluid viscosity, temperature,

wellbore diameter, pressure gauge type and location).
Draft UIC Program Class VI Well Recordkeeping, 56 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

o Semi-log plots used for data analysis.

o Parameters calculated from the analysis.

o Discussion of the results, including data quality and any anomalous values.

• Pump test and injectivity tests:

o Raw pressure data.

o Flow data including rates and times.

o Test parameters (e.g., injection time, fluid viscosity, temperature, wellbore

diameter, pressure gauge type and location).

o Semi-log plots used for data analysis.

o Parameters calculated from the analysis.

o A discussion of the results, including data quality and any anomalous values.

Submittals may be PDF files including narrative components and graphs, with supplemental data 

submitted separately in tabular format (such as a spreadsheet or database file). The owner or 

operator may also submit spatial information in a GIS-compatible format. 

4.2.6 Compatibility of the Carbon Dioxide Stream with the Subsurface and Well 

Components 

The Class VI Rule, at 40 CFR 146.82(c)(3), requires the owner or operator to submit information 

on the compatibility of the carbon dioxide stream with fluids in the injection zone(s), with 

minerals in both the injection and confining zone(s), and with well materials. Information about 

compatibility with subsurface fluids and lithologies is based on the results of the initial site 

characterization as well as the formation testing program. 

Any of the following types of information may be submitted to provide information on the 

interactions between the injectate and the formation fluids and minerals: 

• A detailed discussion of the geochemical characteristics of the injection and confining

zone(s) and the injectate composition in the context of what is known in the literature

about the reactivity of the minerals and anticipated reactions with the carbon dioxide and

carbon-dioxide-rich brine.

• Results of laboratory bench-top testing of interactions between carbon dioxide, carbon

dioxide-rich brine, and formation minerals. EPA recommends that owners or operators

submit a description of all testing methods, materials, results, and interpretations.
Draft UIC Program Class VI Well Recordkeeping, 57 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Results of geochemical or reactive transport modeling. EPA recommends that owners or

operators provide information on the program used, input data, modeling parameters, and

results, indicating potential for dissolution and precipitation of mineral phases and

potential release of trace elements. For more information on submitting modeling results,

see Section 3.3.2.

Any of the following types of information may be submitted regarding interactions between the 

injectate and formation fluids and the well tubular and cement materials:

• Results of modeling of cement-injectate interactions. EPA recommends that owners or

operators provide information on the program used, input data, and results indicating

potential corrosion or lack of corrosion of the cement.

• Results of bench-top testing of interactions between the injectate, carbon dioxide-rich

brine, and well metal and cement materials. EPA recommends that owners or operators

submit a description of all testing methods, materials, results, and interpretation.

Submittals may be PDF files including narrative text and graphs of data or references to data 

submitted in another section in tabular format. The owner or operator may also submit spatial

information in a GIS-compatible format. 

4.3 Injection Well Construction and Testing

The Class VI Rule, at 40 CFR 146.82(c)(5), requires owners or operators to submit final 

construction procedures (that meet the requirements of 40 CFR 146.86) before receiving 

approval for well operation. If any changes are made to the proposed procedures in the permit 

application, based on conditions in the field discovered during site characterization or drilling, 

the final procedures must include necessary revisions. To satisfy this requirement, EPA 

recommends that owners or operators submit final as-built drawings as well as a description of 

any deviations from the proposed construction procedures. Specific components of this 

submission may include: 

• Any updates to the information used by the UIC Program Director to determine the

specifications for the casing and cementing specifications, described in Section 3.5.4.2.

• Any updates to the information used by the UIC Program Director to determine the

specifications for the tubing and packer, described in Section 3.5.4.3.

• Any changes from the proposed drilling and cementing procedures.

EPA recommends that this information be submitted in a narrative PDF file, with supplemental 

data submitted in a tabular format in a spreadsheet or database file. 

The Class VI Rule requires several logs to be run to verify construction specifications of the 

injection well, and collect baseline measurements for future comparison at 40 CFR 146.87(a). 

These logs include: 
Draft UIC Program Class VI Well Recordkeeping, 58 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Deviation checks [40 CFR 146.87(a)(1)].

• Caliper logs [40 CFR 146.87(a)(2)(i) and 40 CFR 146.87(a)(3)(i)].

• Cement bond and variable density logs [40 CFR 146.87(a)(2)(ii) and 40 CFR

146.87(a)(3)(ii)].

• Temperature logs [40 CFR 146.87(a)(2)(ii) and 40 CFR 146.87(a)(3)(ii)].

Owners or operators must submit a descriptive report prepared by a log analyst that includes an 

interpretation of the results of these logs and tests. EPA recommends that the well log analyst’s 

report include: 

• Chart results of each log.

• Interpretation of log results provided by the log analyst.

• Any changes in interpretation of site stratigraphy based on formation testing logs.

• Identification of any deficiencies in the well construction identified from well testing logs

and steps taken to address these deficiencies.

• The date and time of each test, the date of wellbore completion, and the date of

installation of all casings and cements.

• Records of the most recent calibration of any instruments used during wellbore logging.

• The name of the logging company and log analyst(s).

EPA recommends that this report be submitted in a PDF file and include narrative text and 

graphics, with data or graphs supporting the discussions submitted separately in a tabular format. 

Log results may also be submitted in Log ASCII Standard (LAS) format. 

Owners or operators must demonstrate internal and external mechanical integrity prior to 

injection [40 CFR 146.87(a)(4)]. Further information on MITs is provided in the UIC Program 

Class VI Well Testing and Monitoring Guidance. 

For the initial MIT, EPA recommends that owners or operators submit the following 

information: 

• The date and time of the test.

• Test pressure and criterion for failure.

• Chart and/or tabular results (e.g., a graph of pressure with time).

• The amount of liquid returned after the isolation period.
Draft UIC Program Class VI Well Recordkeeping, 59 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Records and schematics of all instrumentation used for the test(s) and the most recent

calibration of any instrumentation.

• An interpretation of the results (i.e., provided by the log analyst) and any limitations in

the data.

• The name of the logging company and log analyst(s), if applicable.

EPA recommends that these results be submitted in a tabular format. If allowed by the UIC 

Program Director, the contractor’s report may be submitted as a PDF file. Graphs, such as 

temperature vs. depth for temperature logs, may be provided as PDF files with supporting data 

submitted separately in a tabular format. Spatial information (e.g., of test locations) may be 

presented in a map or in a GIS-compatible format, and log results may also be submitted in LAS 

format. 

4.4 Final Project Plans and Alternative PISC Timeframe

The Class VI Rule, at 40 CFR 146.82(c)(9), requires owners or operators to submit any updates 

to the proposed project plans (AoR and Corrective Action, Testing and Monitoring, Injection 

Well Plugging, PISC and Site Closure, and Emergency and Remedial Response) that are 

necessary to address new information collected during logging and testing of the well and the 

formation. If the owner or operator submitted an alternative PISC timeframe demonstration with 

the initial permit application, he or she should also submit any necessary updates at this time. In 

addition, if modifications to the AoR and Corrective Action, Injection Well Plugging, PISC and 

Site Closure, or Emergency and Remedial Response Plans lead to increased costs, the owner or 

operator must update the cost estimate supporting the financial responsibility demonstration 

within 60 days [40 CFR 146.85(c)(3)]. See Section 5.4 for more information about updating the 

cost estimate. 

EPA expects that the revised project plans will have a similar content and format as the original 

approved plans. EPA recommends that any revised plans be submitted as PDF files with 

supporting data submitted separately in a tabular format. The owner or operator may also present 

some of the information with maps and/or graphs submitted in PDF, with supporting data in a 

tabular or GIS-compatible format.

See the UIC Program Class VI Well Project Plan Development Guidance and the UIC Program 

Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site Closure for more 

information on project plan updates and the alternative PISC timeframe, respectively. 

4.5 Reporting and Recordkeeping Schedule

Owners or operators must submit the data described in this chapter prior to receiving 

authorization to begin injection operation [40 CFR 146.82(c)]. These data must be retained 

throughout the life of the GS project and for 10 years following site closure [40 CFR 

146.91(f)(3)]. Table 4-1 summarizes the timing of record submission and the required retention 

periods for this phase of the GS project. 
Draft UIC Program Class VI Well Recordkeeping, 60 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Table 4-1. Reporting and recordkeeping schedule for Class VI activities that take place after well 

construction but prior to injection. 

Pre-Injection Data Class VI Rule 

Citation Time for Submission Record Retention

Final AoR delineation 40 CFR 146.82(c)(1)

Before well operation

[40 CFR 146.82(c)] 

10 years following site 

closure

[40 CFR 146.91(f)(3)]

Status of corrective action on 

wells in the AoR 40 CFR 146.82(c)(6)

Site characterization data

and formation testing results

40 CFR 146.82(c)(2), 

(3), (4); 

40 CFR 146.87

Final construction 

procedures 40 CFR 146.82(c)(5)

Logging and testing data, MIT 

results

40 CFR 146.82(c)(7), 

(8);

40 CFR 146.87

Project plan updates 40 CFR 146.82(c)(9)
Draft UIC Program Class VI Well Recordkeeping, 61 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

5 Injection Phase Reporting and Recordkeeping

This section addresses reporting activities that take place during the injection phase of a Class VI 

project, including those related to injection well operation, testing and monitoring, AoR 

reevaluation, financial responsibility and project plan updates, and emergency and remedial 

response. More information about the UIC Program Director’s documentation of oversight and 

compliance decisions is given in the UIC Program Class VI Well Recordkeeping, Reporting, and 

Data Management Guidance for Permitting Authorities. 

5.1 Injection Well Operation

During injection well operation, the owner or operator must record and report certain information 

to the UIC Program Director. Information required from the owner or operator includes 

measurements of routine injection parameters as well as reporting of alarm and emergency 

situations. 

5.1.1 Injection Well Monitoring

The Class VI Rule requires that the injection pressure not exceed 90 percent of the injection zone 

fracture pressure except during UIC Program Director-approved stimulation [40 CFR 146.88(a)]. 

Therefore, continuous monitoring of various parameters must be conducted during GS projects, 

with results submitted periodically [40 CFR 146.90(b) and 146.91(a)]. These continuous 

monitoring requirements are discussed in Section 5.2.3. 

Stimulation may be carried out during well construction or over the course of the project. If 

stimulation is to be performed, the owner or operator must submit: 

• A plan for the stimulation procedure (submitted with the permit application) and the

proposed method of stimulation, including:

o A demonstration that it will not fracture the confining layer or otherwise allow

fluid to move out of the injection zone, including, for example:

 Modeling results with predicted pressures and a comparison against the

fracture pressure of the confining zone.

 If chemicals are to be used in stimulation, a determination that the

chemicals will not react with the confining layer and/or compromise the

effectiveness of the confining layer.

• Notification to the UIC Program Director at least 30 days before the stimulation

operation. This does not apply to stimulation for formation testing conducted during the

pre-injection phase, pursuant to 40 CFR 146.91(d)(2).
Draft UIC Program Class VI Well Recordkeeping, 62 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

EPA recommends that information pertaining to any stimulation activities be submitted in PDF. 

In addition, EPA recommends that any supporting data necessary to demonstrate compliance 

with the Class VI Rule requirements be submitted in a tabular format along with the PDF file(s). 

Per 40 CFR 146.91(d), owners or operators must notify the UIC Program Director in writing 30 

days before planned workovers, planned stimulation activities (other than stimulation for 

formation testing), and any other planned test of the injection well. EPA recommends that these 

notifications be submitted in PDF. Owners or operators must also report, within 30 days, the 

results of any well workover and any other tests of the injection well required by the UIC 

Program Director [40 CFR 146.91(b)]. Reporting of the results of well workovers and other tests 

of the injection well is discussed in Section 4.3. 

5.1.2 Alarms and Automatic Shut-Off Devices

The Class VI Rule requires installation of alarms and automatic shut-off systems at 40 CFR 

146.88(e)(2) and 40 CFR 146.88(e)(3). The UIC Program Class VI Well Construction Guidance 

and the references therein describe these devices in more detail. If an alarm triggers the 

automatic shut-off device or a loss of mechanical integrity is detected, the owner or operator 

must cease injection and report the incident to the UIC Program Director [40 CFR 146.88(f)(3)]. 

Prior to resuming injection, the owner or operator must demonstrate to the UIC Program Director 

that mechanical integrity has been restored to the well [40 CFR 146.88(f)(4)]. The demonstration 

may include records of remedial or workover activities, test results, and additional integrity tests. 

The owner or operator must also notify the UIC Program Director of the date and time of 

planned resumption of injection activities after an emergency shut-down [40 CFR 146.88(f)(5)]. 

These notices may be submitted to the UIC Program Director as PDF files. 

5.2 Operational Testing and Monitoring 

The Class VI Rule, at 40 CFR 146.90, requires owners or operators to develop and follow a 

Testing and Monitoring Plan to ensure that the site is operating in a manner that protects 

USDWs. The requirements include a broad suite of tests, and the results will generally be 

provided by the owner or operator either in the required semi-annual reports [40 CFR 146.91(a)] 

or within 30 days of specific activities [40 CFR 146.91(b)], depending on the item reported. All 

testing and monitoring must be performed as described in the approved Testing and Monitoring 

Plan. 

This section outlines the types of information that may be submitted to meet the testing and 

monitoring requirements of the Class VI Rule, as well as EPA’s recommendations regarding data 

formats. For all tests performed, EPA recommends that the owner or operator submit the 

following general information:

• Date, time, and location of sampling or survey.

• The names of any contractors or laboratories involved in sampling and analysis (and their

certifications, if applicable).
Draft UIC Program Class VI Well Recordkeeping, 63 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• A brief description of methods used or a list of standardized methods.

• Interpretation of results with respect to regulatory requirements and past results.

• Any identified data gaps.

• QA and surveillance procedures employed.

• Any identified necessary changes to the project Testing and Monitoring Plan to continue

protection of USDWs.

Specific information for the various types of monitoring is provided below. Background 

information on conducting all required testing and monitoring for GS projects can be found in 

the UIC Program Class VI Well Testing and Monitoring Guidance. 

5.2.1 Carbon Dioxide Stream Monitoring 

The Class VI Rule, at 40 CFR 146.90(a), requires analysis of the carbon dioxide stream. The 

frequency will be established in the Testing and Monitoring Plan and approved by the UIC 

Program Director, and results will be reported in the semi-annual reports [40 CFR 146.91(a)]. 

Information to be submitted may include the following:

• A list of chemicals analyzed, including carbon dioxide and other constituents (e.g., sulfur

dioxide, hydrogen sulfide, nitrous oxides).

• A description of the sampling methodology, including schematics of the monitoring

equipment if using flue-gas methods.

• A tabulation of all available carbon dioxide stream analyses, including any quality

assurance/quality control (QA/QC) samples.

Original laboratory reports may be submitted in PDF. EPA recommends that owners or operators 

submit analytical results as well as sampling information in tabular form. EPA also recommends 

that owners or operators submit new data in an updated file that includes all previous analyses to 

facilitate evaluation of temporal trends. 

5.2.2 Corrosion Monitoring 

The Class VI Rule, at 40 CFR 146.90(c), requires quarterly corrosion monitoring of well 

materials, by analyzing coupons of well material, routing the carbon dioxide stream through a 

loop of well material, or an alternate method approved by the UIC Program Director.

Furthermore, the UIC Program Director may require casing inspection logs to be run [40 CFR 

146.89(d)]. 
Draft UIC Program Class VI Well Recordkeeping, 64 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

In reporting the results of corrosion monitoring, EPA recommends that the following information 

be provided in addition to the general information noted above (Section 5.2):

• Method of sampling (e.g., method for retrieval of coupons), including the material from

which coupons or loops are made.

• Measurement of mass and thickness loss in any corrosion coupons or loops used.

• Assessment of additional corrosion, including pitting, in corrosion coupons or loops.

In addition, if the UIC Program Director has required casing inspection logs to be run, EPA 

recommends that the owner or operator submit the following:

• All measured casing inspection logs and comparison to previous logs.

• The thickness of the casing, referencing the original casing thickness.

• The locations of anomalies such as pits, scratches, and splits, including information on

any changes from previous measurements.

EPA recommends that results be presented in tabular format, such as a spreadsheet or database 

file. EPA recommends that the owner or operator maintain and update a master version that 

contains all previous analyses with an accompanying narrative describing the key results as a 

PDF report. 

5.2.3 Continuous Monitoring to Demonstrate Internal Mechanical Integrity 

Owners or operators must demonstrate internal mechanical integrity by continuously monitoring 

injection pressure, injection rate, injected volume, pressure on the annulus between the tubing 

and long-stem casing, and annulus fluid during injection [40 CFR 146.89(b)]. 

EPA recommends that the following information be submitted with the semi-annual reports that 

are required at 40 CFR 146.91(a): 

• Tabular data of all flow rate, volume, and pressure measurements.

• Monthly average values for flow rate, volume, injection pressure, and annular pressure.

• Monthly maximum and minimum values for flow rate, volume, injection pressure, and

annular pressure.

• Total volume (mass) injected each month.

• Cumulative volume (mass) injected for the project.

• If the flow rate or pressure exceeded permit limits during the reporting period, a

description of the event(s), an explanation of the event(s), including the cause of the
Draft UIC Program Class VI Well Recordkeeping, 65 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

excursion, the duration of the excursion, and the owner or operator’s response to the 

excursion. 

• A description of any event that triggers a shutdown (see Section 5.1.2).

EPA recommends any description be submitted as a narrative PDF report and supporting data be 

submitted in tabular format in a spreadsheet or database file. 

5.2.4 External MIT 

The Class VI Rule, at 40 CFR 146.89(c) and 40 CFR 146.90(e), requires annual external MITs. 

This testing may take the form of a tracer survey (e.g., oxygen activation log), a temperature log, 

a noise log, or another test required or allowed by the UIC Program Director. 

Owners or operators must report the results of the external MIT to EPA within 30 days of each 

test [40 CFR 146.91(b)]. In addition to the general information noted above in Section 5.2, EPA 

recommends the following information be provided: 

• For tests conducted during injection: operating conditions during measurement including

injection rate, pressure, and temperature.

• For shut-in tests: conditions prior to shut-in, the date and time of shut-in, and the records

of well stabilization.

• The numbers and locations of measurement stations (e.g., for oxygen activation logs).

• The name of the logging company and log analyst(s).

• The results of each log or test and the interpretation of results provided by the log analyst.

• Records and schematics of all instrumentation used for the test(s) and the most recent

calibration of any instrumentation.

• Identification of any loss of mechanical integrity, evidence of fluid leakage, and

corrective action taken.

The interpretation of results may be submitted as narratives with maps (e.g., location of the well) 

and graphs (e.g., temperature vs. depth from temperature logs) as PDF files along with 

supporting data in tabular format such as a spreadsheet or database file. Log results may also be 

submitted in LAS format. If allowed by the UIC Program Director, the contractor’s report may 

be submitted as a PDF file. 

5.2.5 Pressure Fall-Off Testing

Pressure fall-off testing is required by the Class VI Rule [40 CFR 146.90(f)] at least once every 

five years unless more frequent testing is required by the UIC Program Director. Results of 

pressure fall-off testing must be reported within 30 days of the test, if required by the UIC 
Draft UIC Program Class VI Well Recordkeeping, 66 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Program Director [40 CFR 146.91(b)(3)]. In reporting the results of pressure fall-off testing, 

EPA recommends the following information be provided (in addition to the general information 

noted in Section 5.2): 

• The date and time of shut-in.

• Measured injection rates and pressures from the test well and any off-set wells in the

same zone.

• Status of off-set wells, if applicable (either constant injection pressure and rate or shut-in

time).

• Well completion diagrams.

• Whether bottomhole or surface pressure measurements (or both) were used and the

depths of bottomhole pressure and temperature.

• Records of gauges (if they are lowered and raised) and gauge calibration.

• Raw data collected during the fall-off test.

• Plot of change in pressure as a function of time, as well as a graph of temperature (this

may be provided for the time period prior to the test as well as the duration of the test).

• Any temperature anomalies and whether they correspond to pressure anomalies.

• Log-log and semi-log diagnostic plots of observed pressure and time.

• Calculated formation characteristics (i.e., transmissivity, well skin factor), and

comparison to previous tests and to values used in computational modeling and AoR

delineation.

• Description of quantitative analysis of pressure-test results, including use of any

commercial software.

Owners or operators may submit the results as a narrative in PDF that describes any changes to 

formation characteristics of the near-wellbore environment, and any indication of fluid leakage 

during the test may be submitted in PDF. Supporting data may be provided in tabular format in a 

spreadsheet or database file. Output from commercial software used to analyze the data may also 

be provided. EPA recommends that the comparison of new test results with previous results be 

compiled in tabular form and any spatial data be submitted in a GIS-compatible format.

5.2.6 Ground Water Quality and Geochemistry Monitoring

Periodic monitoring of ground water quality above the confining zone(s) is required by the Class 

VI Rule [40 CFR 146.90(d)]. Owners or operators of wells operating under injection depth 
Draft UIC Program Class VI Well Recordkeeping, 67 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

waivers must also sample ground water below the lower confining zone [40 CFR 

146.95(f)(3)(i)]. 

Owners or operators must include the results of ground water quality monitoring in the semiannual reports [40 CFR 146.91(a)]. In addition to the general information noted above in Section 

5.2, specific data that the owner or operator may submit include: 

• A map showing the injection well and all monitoring wells tested that identifies:

o The names or numbers of the monitoring wells.

o Those wells that are believed to be within the boundary of the separate-phase

carbon dioxide plume.

• Records of calibration of field equipment, where appropriate.

• Notes on field procedures and values for parameters measured in the field (e.g., fluid

pressure in the well, notes on well purging, temperature measurement, redox potential,

pH, and specific conductivity).

• Analytical data, including results, methods used, and data for QA/QC samples (matrix

spikes, duplicates, field blanks, and equipment rinsate).

• Interpretive analysis (e.g., using Piper or Stiff diagrams, time series graphs, or isopleth

maps).

• Any information specific to ground water monitoring in the first USDW below the

injection zone for owners or operators operating under injection depth waivers.

• The most up-to-date historical database of all ground water monitoring results and

QA/QC monitoring results.

Owners or operators may submit the interpretation of results as a narrative report in a PDF file 

discussing any changing trends, evaluation of fluid leakage, and fluid migration. The narrative 

may be supported by maps and graphs. EPA recommends that monitoring data be submitted in 

tabular form in a spreadsheet or database file that also includes previous test results for 

comparison. Any spatial data should be submitted in a GIS-compatible format to allow flexibility 

in UIC Program Director evaluations. If required by the UIC Program Director, owners or 

operators may need to submit PDF files of laboratory reports. 

5.2.7 Pressure-Front Tracking

The Class VI Rule, at 40 CFR 146.90(g)(1), requires the owner or operator to perform direct 

monitoring (e.g., in-situ measurements of fluid pressure in the injection zone) to track the area of 

elevated pressure (i.e., the pressure front). 
Draft UIC Program Class VI Well Recordkeeping, 68 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Results of pressure-front tracking must be included in the semi-annual reports [40 CFR 

146.91(a)]. In addition to the general information noted above in Section 5.2, EPA recommends 

that owners or operators submit specific data including: 

• A map showing the injection well and all monitoring wells tested, including the names or

numbers of the monitoring wells.

• Wellhead and measuring point elevations.

• Measured depth to fluid or pressure transducer readings in all wells, fluid density, fluid

temperature and the depth of all casing collars and packers, if requested by the UIC

Program Director.

• Depth to the perforated intervals of injection wells and monitoring wells.

• If using pressure transducers, records of the most recent calibration or verification of the

measurement instrument.

• The dates and times of pressure measurements and pressure values in tabular form.

• Time-series graphs and pressure or head maps used in interpretation of pressure data for

each well.

• The threshold value for the pressure front (to provide context for pressure readings).

• Comparison of data with modeling predictions.

• Geomechanical data that would inform or impact pressure monitoring data.

• Presentation, synthesis, and interpretation of the entire historical data set, including an

assessment of whether pressure data are indicative of fluid leakage.

• Any information specific to pressure monitoring in the first USDW below the injection

zone (Class VI projects operating under injection depth waivers).

Owners or operators may submit the assessment of pressure monitoring results and whether they 

indicate fluid leakage into USDWs as a narrative, with maps and graphs supporting the 

discussions, in a PDF file. EPA recommends that the supporting data be submitted in tabular 

format in a spreadsheet or database file. Also, spatial data (e.g., location of monitoring and 

presentation of results) may be submitted in a GIS-compatible format to allow independent 

evaluation of the results and comparison with the predicted pressure front from AoR 

delineations. 

5.2.8 Carbon Dioxide Plume Tracking 

Owners or operators must use indirect methods (i.e., geophysical techniques) to track the extent 

of the carbon dioxide plume [40 CFR 146.90(g)(2)] unless the UIC Program Director determines 
Draft UIC Program Class VI Well Recordkeeping, 69 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

that such methods are not appropriate for the site (this would be described in the approved 

Testing and Monitoring Plan). Indirect methods include seismic profiling, gravity surveys, and 

electromagnetic surveys. 

The Class VI Rule requires that owners or operators submit the results of any indirect 

geophysical monitoring in the semi-annual reports [40 CFR 146.91(a)]. EPA recommends the 

following information be submitted by the owner or operator, in addition to the general 

information noted in Section 5.2: 

• A map showing the locations of the survey equipment during the test.

• A description of the use of survey markers and/or measurement stations in the

geophysical surveys.

• If required by the UIC Program Director, raw data collected by the survey equipment, a

description of all data processing steps taken, as well as the major assumptions used

during data processing that may affect the interpretation of the data.

• An interpretation of all geophysical surveys relating to the position of the plume and/or

pressure front and fluid leakage, including any available information on method

sensitivity and any out-of-zone anomalies that require follow-up.

• Maps showing the interpreted location of separate-phase carbon dioxide in the injection

zone and its location in any additional zones in which it was detected.

• A comparison of the measured position of the carbon dioxide plume to modeled

predictions or previous measurements corresponding to the time of the survey.

• Presentation, synthesis, and interpretation of the entire historical data set.

• Any information specific to carbon dioxide plume tracking below the lower confining

zone (for owners or operators operating under injection depth waivers).

Contractor’s reports, including images, maps, data interpretation, and the assessment of 

comparisons to model predictions, previous surveys, and identification of data gaps may be 

submitted as a narrative in PDF. If raw data are required, they may be submitted in tabular or 

graphical form, as appropriate for the method. EPA recommends any spatial data, such as the 

measured or estimated extent of the carbon dioxide plume, be submitted in GIS-compatible 

format to assist in an independent evaluation of results by the UIC Program Director. 

The Class VI Rule does not require the use of direct monitoring (e.g., ground water geochemical 

monitoring from wells perforated within the injection zone) for the purposes of tracking the 

extent of the carbon dioxide plume, unless indirect methods are determined to be inappropriate 

based on site-specific criteria [40 CFR 146.90(g)(2)]. The UIC Program Class VI Well Testing 

and Monitoring Guidance describes these criteria and provides further technical information on 

this subject. In certain cases, where the UIC Program Director determines collaboratively with 
Draft UIC Program Class VI Well Recordkeeping, 70 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

the owner or operator that the use of geochemical ground water monitoring may be necessary for 

sufficient plume tracking, EPA recommends that the results be submitted in similar formats as 

for indirect monitoring and geochemical monitoring conducted above the confining zone, as 

described in Section 5.2.6. 

5.2.9 Surface Air and/or Soil Gas Monitoring

The Class VI Rule allows the UIC Program Director, at his or her discretion, to require surface 

air and/or soil gas monitoring [40 CFR 146.90(h)]. If such tests are determined to be necessary, 

results from surface air and/or soil gas monitoring must be included in the semi-annual reports 

[40 CFR 146.91(a)]. In addition to the general information described in Section 5.2, EPA 

recommends that the following information be submitted when reporting the results of surface 

air and/or soil gas monitoring: 

• A map showing the locations of the equipment and/or sampling stations.

• Records of field procedures (e.g., vacuum-volume purge tests, sample probe purging, and

sampling rates) and equipment calibration records where appropriate.

• Description of existing areas of geologic and artificial structures that are potential

conduits for carbon dioxide migration.

• Soil and air temperatures and atmospheric pressure.

• Interpretive maps and/or graphs of carbon dioxide trends.

• A database of all available soil gas data from each sampling location and depth, including

any background data and QA/QC samples.

• A database of all available surface air data from each sampling location, including any

background data and QA/QC samples.

Owners or operators may submit the interpretation of results describing any significant changes 

in carbon dioxide levels compared to background levels or any detection of leakage that may 

impact a USDW in a narrative supported by images, maps, or graphs in a PDF file. EPA 

recommends that new data be submitted in an updated spreadsheet or database file containing 

data from all previous sampling events. Spatial data presented in maps may also be submitted in 

a GIS-compatible format for an independent and more detailed evaluation by the UIC Program 

Director. 

5.2.10 Additional Monitoring

The Class VI Rule, at 40 CFR 146.90(i), affords the UIC Program Director discretion to require 

additional monitoring if necessary to support, upgrade, and improve computational modeling of 

the AoR evaluation and to determine compliance with standards under 40 CFR 144.12. This 

testing must be carried out as described in the approved Testing and Monitoring Plan. 
Draft UIC Program Class VI Well Recordkeeping, 71 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

The specific information to submit will depend on the testing performed, but owners or operators 

should, as appropriate, submit all relevant information about the test methods performed, any 

required analyses or interpretation of the data, and the results to inform the UIC Program 

Director’s review of the results. 

EPA recommends that owners or operators submit new data in an updated spreadsheet or 

database file containing data from all previous sampling events if appropriate. Spatial data 

presented in maps may also be submitted in a GIS-compatible format for an independent and 

more detailed evaluation by the UIC Program Director. The owner or operator should provide an 

interpretation of results in a narrative supported by images, maps, or graphs in a PDF file. 

5.3 AoR Reevaluation and Phased Corrective Action

Owners or operators of Class VI injection wells are required to reevaluate the AoR delineation 

on a regular basis, at a fixed frequency of no less than once every five years, as determined in the 

AoR and Corrective Action Plan [40 CFR 146.84(e)]. These reevaluations will occur during the 

injection and post-injection phases of the project. 

When observations based on monitoring data agree with the predicted AoR, a reevaluation may 

simply consist of a demonstration to the UIC Program Director that monitoring data validate 

modeled predictions [40 CFR 146.84(e)(4)]. However, if monitoring data and modeling 

predictions differ significantly, then the owner or operator must revise the computational model 

and submit updated AoR delineation results. 

Information that the owner or operator may submit to demonstrate that the current AoR 

delineation remains valid and that no amendment to the AoR or any of the GS project plans is 

needed includes the following: 

• Any new operational, monitoring, or site characterization data that have been generated

since the last AoR reevaluation and a verification that existing operational and site

characterization data have been incorporated into the site computational model (e.g.,

input parameters affected by the new operational or site characterization data).

• A comparison of monitoring data (e.g., geochemical data, pressure monitoring data,

geophysical surveys) and model predictions in the form of graphics and informative maps

showing general agreement between monitored data and model predictions.

If revisions to the AoR delineation model are necessary, the owner or operator must submit the 

adjusted model results and newly delineated AoR to the UIC Program Director. Information the 

owner or operator may submit in reporting an AoR computational model and delineation revision 

includes the following: 

• Re-submission of all model attributes as described in Section 3.3.2.

• A new conceptual site model schematic with any changes highlighted (e.g., new injection

wells, newly elucidated geologic features, and a revised permeability field).
Draft UIC Program Class VI Well Recordkeeping, 72 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• A description of the model calibration process, and final results.

• A list of adjusted input parameters and their values.

• Graphs comparing observed and modeled values of carbon dioxide migration and fluid

pressure.

• Maps presenting the newly delineated AoR in comparison to previous AoR delineations.

• A revised AoR and Corrective Action Plan, along with other related project plans (see

Section 5.5).

EPA recommends that the results of AoR reevaluations be submitted as narrative PDF files 

supplemented with maps or graphs, in the manner described in Section 3.3.2. Owners or 

operators may submit the supporting data in a spreadsheet or database file. EPA encourages the 

submission of any spatial information in a GIS-compatible file to allow for an independent and 

more flexible evaluation of the data by the UIC Program Director. 

As part of the AoR reevaluation, owners or operators must identify all wells in the reevaluated 

AoR that require corrective action [40 CFR 146.84(d)(2)]. The owner or operator must submit a 

description of each well’s type, construction, date drilled, location, depth, and record of plugging 

and/or completion, as well as any additional information required by the UIC Program Director 

[40 CFR 146.84(c)(2)] and perform corrective action on these wells [40 CFR 146.84(d)(2)]. 

After completing corrective action, EPA recommends that the owner or operator submit a report 

of the number, type, and location of the plugs. EPA recommends that owners or operators also 

submit records of any remedial cementing, along with cement logs showing the methods used 

and the results of the remedial cementing. These requirements and recommendations also apply 

to owners or operators who are implementing phased corrective action. 

5.4 Financial Responsibility Updates and Notifications

The Class VI Rule requires that the owner or operator update the cost estimates on an annual 

basis for the activities requiring a financial responsibility demonstration, to adjust for inflation 

[40 CFR 146.85(c)(2)]. The cost estimate must also be updated if: 

• The AoR and Corrective Action Plan, the Injection Well Plugging Plan, the PISC and

Site Closure Plan, or the Emergency and Remedial Response Plan are amended [40 CFR

146.85(c)(2)].

• The UIC Program Director determines during the annual adjustment that it is no longer

adequate [40 CFR 146.85(e)].

The financial responsibility instruments and associated demonstration must also be updated if the 

current cost estimate increases to an amount greater than the face amount of a financial 

instrument currently in use [40 CFR 146.85(c)(4)]. Alternatively, owners or operators may 

obtain other financial responsibility instruments to cover the increased cost. Pursuant to 40 CFR 
Draft UIC Program Class VI Well Recordkeeping, 73 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

146.85(b)(2), an owner or operator may be released from a financial instrument if the associated 

project phase has been completed and the owner or operator has fulfilled all necessary financial 

obligations, or the owner or operator has submitted a replacement financial instrument and 

received written approval of the new instrument from the UIC Program Director. (Only the UIC 

Program Director can release or retire the owner or operator from his/her financial responsibility 

obligations.) Whenever the cost estimates or financial instruments are updated, the applicable 

information must be resubmitted electronically in accordance with 40 CFR 146.91(e). EPA 

recommends that these submissions be made up of PDF files. 

The owner or operator must notify the UIC Program Director of any adverse financial conditions 

that may affect the ability to carry out any of the required activities guaranteed by the financial 

responsibility instruments [40 CFR 146.85(d)]. These events could include bankruptcy by the 

owner or operator, bankruptcy of a third party provider of a financial instrument provider, or 

bankruptcy of the corporate guarantor. In the case of bankruptcy proceedings, notification must 

also be sent by certified mail [40 CFR 146.85(d)(1)]. In all cases, EPA recommends that this 

information also be provided in PDF. 

5.5 Project Plan Updates 

Owners or operators must periodically review the AoR and Corrective Action, Testing and 

Monitoring, and Emergency and Remedial Response Plans and make amendments if necessary 

[40 CFR 146.84(e)(4), 40 CFR 146.90(j), and 40 CFR 146. 94(d), respectively]. These reviews 

must occur after AoR reevaluations and/or significant changes to the facility, as well as when 

required by the UIC Program Director. The Class VI Rule does not require formal periodic 

reviews and amendments of the Injection Well Plugging Plan or the PISC and Site Closure Plan 

during the injection phase; however, EPA recommends that owners or operators communicate 

with the UIC Program Director regarding potential changes to these plans, including any changes 

to the alternative PISC timeframe demonstration, in the post-injection period and complete 

reviews if there are significant changes to the facility and/or emergency events. More 

information on completing and documenting plan updates can be found in the UIC Program 

Class VI Well Project Plan Development Guidance and the UIC Program Guidance on Class VI 

Well Plugging, Post-Injection Site Care, and Site Closure. 

EPA expects that the revised plans will have a similar content and format as the original 

approved plans. EPA recommends that any revised plans be submitted as PDF files with 

supporting data submitted separately in a tabular format. The owner or operator may choose to 

present some of the information with maps and/or graphs submitted as PDF files with supporting 

data in a tabular or GIS-compatible format.

5.6 Emergency and Remedial Response

If an owner or operator obtains evidence that the injected carbon dioxide stream and the 

associated pressure front may endanger a USDW, he or she must notify the UIC Program 

Director within 24 hours, in addition to taking the other steps listed in 40 CFR 146.94(b). The 

owner or operator must notify the UIC Program Director within 24 hours if any of the following 

occur:
Draft UIC Program Class VI Well Recordkeeping, 74 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Evidence is obtained that a USDW may be endangered [40 CFR 146.94(b)].

• Any noncompliance with permit conditions or equipment malfunctions that may cause

fluid movement into a USDW [40 CFR 146.91(c)(2)].

• Any triggering of the automatic shut-off system [40 CFR 146.91(c)(3)].

• A loss of mechanical integrity [40 CFR 146.91(c)(4)].

• Any release of carbon dioxide to the atmosphere or biosphere (assuming the UIC

Program Director has required surface air and/or soil gas monitoring) [40 CFR

146.91(c)(5)].

EPA recommends that this notification be submitted in a PDF file. The owner or operator must 

also implement the Emergency and Remedial Response Plan [40 CFR 146.94(b)(4)], including 

completing remedial action as appropriate. If remedial action is required, EPA recommends that 

the owner or operator submit a notification that remedial action has been completed, including a 

description of the remedial activities. 

Before resuming injection, the owner or operator must demonstrate that USDWs will not be 

endangered by the resumption of injection. EPA recommends that this demonstration include, at 

a minimum, results of external and internal MITs, as well as other appropriate data such as well 

logs, plume monitoring, and/or geochemical analyses. The information may be submitted in PDF 

files with supplementary data submitted in a tabular format. Pursuant to 40 CFR 146.94(c), the 

UIC Program Director may allow injection to resume prior to remediation, if the owner or 

operator demonstrates that resuming injection will not endanger USDWs. 

5.7 Reporting and Recordkeeping Schedule

Reporting during the injection phase takes place at varying intervals, from routine semi-annual 

submissions to 24-hour emergency notifications. Table 5-1 summarizes the reporting and 

recordkeeping schedule for the different injection phase submissions. 

Most monitoring data must be retained for 10 years after they are collected [40 CFR 

146.91(f)(3)], although EPA recommends that data be kept for the duration of the operational 

and post-injection phases of the project. All modeling inputs and data used to support AoR 

reevaluations must be retained for 10 years following the reevaluation [40 CFR 146.84(g)]. At 

the discretion of the UIC Program Director, the owner or operator may be required to retain this 

information for a longer period if the reevaluation resulted in significant changes to the original 

delineation submitted with the permit application. 
Draft UIC Program Class VI Well Recordkeeping, 75 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Table 5-1. Reporting and recordkeeping schedule for the injection phase. 

Injection Phase Data Class VI Rule 

Citation Time for Submission Record Retention

Notification of stimulation 40 CFR 146.91(d)(2) 30 days before event

[40 CFR 146.91(d)]

10 years following 

event 

(recommended)

Notification of triggered 

shutdown or loss of 

mechanical integrity

40 CFR 146.88(f)

Within 24 hours of event 

[40 CFR 146.88(3)

Include in semi-annual 

reports

[40 CFR 146.91(a)]

Demonstration of 

restoration of mechanical 

integrity

40 CFR 146.88(f)(4) Before resuming 

injection

Notification of resumption 

of injection 40 CFR 146.88(f)(5) Before resuming 

injection

Carbon dioxide stream

monitoring results 40 CFR 146.90(a)

Include in semi-annual 

reports 

[40 CFR 146.91(a)]

10 years following site 

closure

[40 CFR 145.91(f)(2)]

Corrosion monitoring

results 40 CFR 146.90(c)

10 years after 

collection

[40 CFR 146.91(f)(3)]

Continuous monitoring to 

demonstrate internal 

mechanical integrity 

40 CFR 146.90(b)

External MIT results

40 CFR 146.90(c)

40 CFR 146.90(e)

Notice 30 days before 

event

[40 CFR 146.91(d)(3)]

Report results within 30 

days

[40 CFR 146.91(b)]

Include in semi-annual 

reports

[40 CFR 146.91(a)]

Pressure fall-off testing

results 40 CFR 146.90(f)

Include in semi-annual 

reports

[40 CFR 146.91(a)]

Ground water quality 

monitoring results 40 CFR 146.90(d) Include in semi-annual 

reports

[40 CFR 146.91(a)]

If data suggest USDW 

10 years after 

collection

[40 CFR 146.91(f)(3)] Pressure-front tracking 

results – direct methods 40 CFR 146.90(g)
Draft UIC Program Class VI Well Recordkeeping, 76 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Injection Phase Data Class VI Rule 

Citation Time for Submission Record Retention

Plume tracking results – 

indirect methods 40 CFR 146.90(g)

endangerment, 24-hour 

emergency reporting

[40 CFR 146.91(c)]

Surface air and/or soil gas

monitoring results 40 CFR 146.90(h)

Additional monitoring

results 40 CFR 146.90(i)

Include in semi-annual 

reports

[40 CFR 146.91(a)]

AoR reevaluation 40 CFR 146.84(e)

Schedule as determined 

in the AoR and Corrective 

Action Plan

[40 CFR 146.84(e)]

10 years after 

reevaluation

[40 CFR 146.84(g)]

Financial responsibility 

instruments 40 CFR 146.85(a)

Annual updates

[40 CFR 146.85(a)(5)(ii)]

Within 60 days of cost 

estimate increase to 

greater than value of 

current instrument 

[40 CFR 146.85(c)(4)]

Within 60 days of 

notification of the third 

party’s adverse financial 

conditions

[40 CFR 146.85(d)(3)] 10 years following site 

closure

(recommended)

Financial responsibility 

cost estimate 40 CFR 145.85(c)

Annual updates, 60 days 

before instrument 

anniversary

[40 CFR 146.85(c)(2)]

Within 60 days of plan 

amendment or 

notification by UIC 

Program Director 

[40 CFR 146.85(c)(2), 

146.85(e)]

Notifications of adverse 

financial conditions 40 CFR 146.85(d)

Within 10 days of start of 

bankruptcy proceedings

[40 CFR 146.85(d)(1)] 
Draft UIC Program Class VI Well Recordkeeping, 77 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Injection Phase Data Class VI Rule 

Citation Time for Submission Record Retention

Project plan updates: AoR 

and Corrective Action, 

Testing and Monitoring, 

Emergency and Remedial 

Response

40 CFR 146.84(e)(4)

40 CFR 146.90(j)

40 CFR 146.94(d)

Following AoR 

reevaluations, no less 

often than every five 

years 

[40 CFR 146.84(e)(4), 

146.90(j), and 146.94(d)]

Notification to UIC 

Program Director of 

evidence of 

endangerment of a USDW

40 CFR 146.94(b)(3) Within 24 hours

[40 CFR 146.91(c)]

Demonstration that 

injection will not endanger 

USDWs

40 CFR 146.94(c)

Before resuming

injection

[40 CFR 146.94(c)]

10 years following site 

closure

(recommended)
Draft UIC Program Class VI Well Recordkeeping, 78 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

6 Post-Injection Phase Reporting and Recordkeeping

Following cessation of injection, the injection well(s) at a GS project must be plugged, and the 

project enters the post-injection phase. The well plugging and PISC requirements at 40 CFR 

146.92 and 40 CFR 146.93 are intended to ensure that the site is managed and monitored 

properly following the cessation of injection to maintain protection of USDWs. Information that 

owners or operations will submit during this phase of a GS project is summarized below. More 

information about the UIC Program Director’s documentation of oversight and compliance 

decisions is given in the UIC Program Class VI Well Recordkeeping, Reporting, and Data 

Management Guidance for Permitting Authorities. 

6.1 Injection Well Plugging

Requirements for injection well plugging are provided in the Class VI Rule at 40 CFR 146.92. 

The sections below provide guidance on the information to submit to meet those requirements.

For all procedures, EPA recommends that the owner or operator submit: 

• Date and time of the activity.

• Location and identification of the well.

• Names and other relevant information regarding contractors performing the work.

6.1.1 Notice of Intent to Plug the Well

The owner or operator must notify the UIC Program Director in writing at least 60 days before 

plugging the injection well [40 CFR 146.92(c)]. If the original Injection Well Plugging Plan has 

been revised, the owner or operator must also provide the revised plan at this time. EPA 

recommends that the notice be submitted in a PDF file. 

6.1.2 Well Plugging Report 

Well plugging requirements are provided in the Class VI Rule at 40 CFR 146.92. Following 

plugging of the injection well, owners or operators must submit a report detailing how the well 

was plugged. EPA recommends that the well plugging report [40 CFR 146.92(d)] include a 

description of pre-plugging activities and the plugging procedures used. 

The Class VI Rule, at 40 CFR 146.92(a), requires that the owner or operator flush the well, 

determine bottomhole pressure, and perform a final external MIT before plugging the well. EPA 

recommends that the owner or operator submit supporting information related to these preplugging activities, including the following: 

• Final pressure reading from downhole pressure transducer, if applicable.

• Notes on any procedures prior to flushing (e.g., removal of packers).
Draft UIC Program Class VI Well Recordkeeping, 79 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Flushing procedures, including fluid type and volume used.

• Notes on removal of well components (e.g., pressure transducer, packer, shut-off

devices), injection tubing, and obstructions or large debris.

• Information related to the external MIT:

o Conditions prior to test including date and time and time elapsed since flushing.

o The numbers and locations of measurement stations.

o The results of each log or test and the interpretation of results provided by the log

analyst.

o A description of any remedial actions taken.

EPA recommends that the well plugging report include: 

• The type and number of plugs installed.

• The placement of the plugs, including top and bottom elevations and formations where

they are emplaced.

• The cement type, grade, weight, and quantity used.

• The method of emplacement.

• Plugging fluid type and volume used to establish static conditions.

• Notes on any plugs that were tagged.

EPA recommends that information pertaining to pre-plugging activities and injection well 

plugging be submitted in a PDF file. In addition, EPA recommends that any supporting data 

necessary to demonstrate compliance with the Class VI Rule requirements be submitted in a 

tabular format in a spreadsheet or database file along with the PDF file.

6.2 PISC and Site Closure

The Class VI Rule, at 40 CFR 146.93, requires owners or operators to monitor the GS project 

after injection ceases, until it can be demonstrated that the site no longer poses a risk of 

endangerment to USDWs. Upon cessation of injection, the owner or operator must submit an 

amended PISC and Site Closure Plan or a demonstration that no amendment is needed [40 CFR 

146.93(a)(3)]. Other information to be submitted during this post-injection time include: (1) 

reports of PISC monitoring results, (2) a non-endangerment demonstration, and (3) site closurerelated reporting. The types of information that may be submitted to meet these requirements are 

outlined below. 
Draft UIC Program Class VI Well Recordkeeping, 80 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

6.2.1 Updated PISC and Site Closure Plan

Upon cessation of injection, the Class VI Rule [40 CFR 146.93(a)(3)] requires that owners or 

operators either submit an amended PISC and Site Closure Plan or demonstrate to the UIC 

Program Director through monitoring data and modeling results that no amendment to the plan is 

needed. 

Information that may be submitted at this time includes:

• A history of monitoring results for downhole pressure, pressure measured at monitoring

wells in the injection zone and above the confining zone, pressure fall-off tests, and the

results of geophysical monitoring. (These data are submitted in detail as part of the

monitoring requirements during the operational phase.)

• A history of modeling results and how these indicate whether a change to the PISC and

Site Closure Plan is warranted. (See Section 3.3.2 for information to submit with

modeling results.) Interpretive narratives may be provided, including a description of any

changes that may have been made in the modeling approach, choice of model, or

assumptions.

• A discussion of historical monitoring and modeling results describing how the

monitoring results have generally tracked with respect to modeling predictions.

• A discussion of how the most recent modeling predictions compare with model

predictions used at the time of formulation of the PISC and Site Closure Plan.

• The revised predicted timeframe for pressure decline within the injection zone.

• A comparison of anticipated monitoring frequency with predicted rate of movement of

plume and predicted rate of pressure decay.

EPA recommends this information be submitted as a narrative, supported by maps and graphs, in 

a PDF file, and that supplementary data be submitted in tabular format in a spreadsheet or 

database file. Spatial information may be submitted in a GIS-compatible format for an 

independent evaluation of data, such as monitoring results, by the UIC Program Director. EPA 

also recommends that further amendments to the plan be submitted periodically throughout the 

PISC phase, as described in the approved plan. 

6.2.2 Monitoring During PISC 

During the post-injection period, the owner or operator must follow the approved PISC and Site 

Closure Plan. Post-injection monitoring must be performed for at least 50 years or for the 

duration of an alternative timeframe approved by the UIC Program Director, or until the owner 

or operator can demonstrate non-endangerment to USDWs [40 CFR 146.93(b)(1)]. During this 

time, owners or operators will continue to conduct AoR reevaluations according to the schedule 

specified in the AoR and Corrective Action Plan (see Section 5.3). EPA expects that most 
Draft UIC Program Class VI Well Recordkeeping, 81 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

reevaluations in the post-injection phase will not result in changes to the AoR delineation or the 

AoR and Corrective Action Plan. 

Because PISC monitoring is an extension of certain components of injection phase monitoring, 

much of the same types of data will be submitted during the PISC period. Section 5.2 of this 

guidance covers reporting of monitoring results collected during injection. Sections relevant to 

PISC monitoring are as follows: 

• For water quality monitoring to track the carbon dioxide plume and verify that water

quality changes are not occurring above the confining zone, see Section 5.2.6.

• For monitoring of the pressure front, see Section 5.2.7.

• For indirect monitoring of the carbon dioxide plume (i.e., geophysical surveys), see

Section 5.2.8.

• For surface air and/or soil gas monitoring (if required by the UIC Program Director), see

Section 5.2.9.

In addition to the results of specific monitoring activities, EPA recommends that owners or 

operators also provide the following information with each submission: 

• A list of all monitoring events that have taken place during the reporting period,

including all monitoring dates.

• Identification of any data gaps.

• Identification of any changes to the monitoring program during the reporting period (e.g.,

drilling of new monitoring wells, closure of monitoring wells).

• Presentation, synthesis, and interpretation of the entire historical data set of monitoring

results as related to any change in risk of endangerment to USDWs.

• Any necessary changes to the project PISC and Site Closure Plan to continue protection

of USDWs.

Descriptions and interpretations of results may be submitted as narratives in a PDF file and 

supported by maps or graphs. EPA recommends that any supporting data be submitted in a 

tabular format. 

As during the injection phase, if the owner or operator obtains evidence that the injected carbon 

dioxide stream and associated pressure front may cause an endangerment to a USDW, the owner 

or operator must identify and characterize any release, submit a 24-hour notification, and 

implement the Emergency and Remedial Response Plan [40 CFR 146.94(b)(2) through (4)]. See 

Section 5.6 for information related to emergency and remedial response reporting. 
Draft UIC Program Class VI Well Recordkeeping, 82 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

6.2.3 Non-Endangerment Demonstration 

Prior to authorization for site closure, the owner or operator must submit to the UIC Program 

Director a demonstration that no additional monitoring is needed to ensure that the GS project 

does not pose an endangerment to USDWs [40 CFR 146.93(b)(3)]. This demonstration will be 

based upon monitoring data and other site-specific information. 

EPA recommends that the following data be submitted to support the non-endangerment 

demonstration: 

• A summary of the pressure monitoring data (in tabular and/or graphical form) that were

collected and submitted pursuant to the approved PISC and Site Closure Plan.

• A summary of ground water quality monitoring data that demonstrates that water quality

above the confining zone has stabilized and that there are no water quality changes above

the confining zone that suggest leakage of carbon dioxide or brine.

• A summary of monitoring results, including images, that shows that migration of the

carbon dioxide plume has stabilized.

• The results of any updated modeling demonstrating anticipated continued pressure

decline and the timeframe in which pressure would no longer be able to force fluids into a

USDW.

• A comparison of monitoring data with model predictions.

For projects that operated under an injection depth waiver, this demonstration will need to 

include formations and USDWs both above and below the injection zone. This information may 

be submitted in a PDF file, as a narrative supported by maps and graphs. 

6.2.4 Site Closure-Related Reporting 

The owner or operator must notify the UIC Program Director by submitting a site closure notice 

in writing at least 120 days in advance of the intended site closure date [40 CFR 146.93(d)]. At 

this time, if any changes have been made to the original PISC and Site Closure Plan, the owner 

or operator must also provide the revised plan. The UIC Program Director may allow for a 

shorter notice period. EPA recommends that the site closure notice include the following 

information: 

• Facility information, such as the facility name and location.

• A list of contact personnel (including names, titles, phone numbers, and email addresses)

to facilitate timely direct communication to resolve any pressing issues.

• A projected site closure date.
Draft UIC Program Class VI Well Recordkeeping, 83 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

EPA recommends that this notification take the form of a letter and be submitted as a PDF file. 

The UIC Program Guidance on Class VI Well Plugging, Post-Injection Site Care, and Site 

Closure includes a template for this letter.

The Class VI Rule, at 40 CFR 146.93(e) requires owners or operators to plug all monitoring 

wells after the UIC Program Director has authorized site closure. While the Class VI Rule does 

not specifically require advance notification of monitoring well plugging, EPA recommends that 

owners or operators notify the UIC Program Director before carrying out these activities. EPA 

recommends that owners or operators use a letter similar to the one submitted in advance of 

injection well plugging and submit it as a PDF file. 

The Class VI Rule requires the owner or operator to submit a report within 90 days of site 

closure [40 CFR 146.93(f)]. Specifically, the site closure report must include: 

• Documentation of appropriate injection and monitoring well preparation and plugging

[40 CFR 146.93(f)(1)], as described in Section 6.1.

• A copy of a survey plat that has been submitted to the local zoning authority designated

by the UIC Program Director [40 CFR 146.93(f)(1)]. A copy must also be submitted to

the Regional Administrator of the appropriate EPA regional office. The plat must indicate

the location of the injection well relative to permanently surveyed benchmarks.

• Documentation of notification to the state, local, and tribal entities that have authority

over drilling activities [40 CFR 146.93(f)(2)]. EPA recommends that the documentation

include the names of the informed authorities and copies of letters sent. EPA

recommends that the notifications themselves include the following information:

o Contact information for the owner or operator.

o Dates of operation of the project and dates of post-injection phase.

o Maps of the AoR and the locations of the injection well and all monitoring wells.

o Depth of the injection well.

o Name and depth interval of formation containing the injection zone.

o Names and depth intervals of confining zones.

o Pressure in confining zones and monitored zones above the confining layer at the

time of site closure.

o Fluid composition in the injection zone and above the injection zone at the time of

site closure.

o If available, an image and/or map of the most recent geophysical survey

indicating the extent of the carbon dioxide plume.
Draft UIC Program Class VI Well Recordkeeping, 84 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

• Records reflecting the nature, composition, and volume of the carbon dioxide stream [40

CFR 146.93(f)(3)]. EPA recommends that owners or operators submit the following

information to satisfy this requirement:

o Historical graphs or tabular results of injectate analyses.

o Historical graphs or tabular data showing the total volume of injectate at the time

of cessation of injection.

EPA recommends that this report be submitted as a narrative in PDF, supported by maps and 

graphs as needed. 

Following site closure, the owner or operator must record a notation on the deed to the facility 

property or any other document that is normally examined during a title search by a potential 

purchaser of the property [40 CFR 146.93(g)]. The notation must include the following 

information: 

• That the land has been used for GS.

• The name of the state agency, local authority, and/or tribe with which the survey plat was

filed, as well as the address of the EPA regional office to which it was submitted.

• The volume of carbon dioxide injected, the injection zone(s), and the period over which

the injection occurred.

EPA recommends that the owner or operator provide evidence of this notation to the UIC 

Program Director or attach copies of it to the site closure report. 

6.3 Reporting and Recordkeeping Schedule

Table 6-1 below shows the reporting schedule for injection well plugging, PISC, and site closure 

activities. The Class VI Rule, at 40 CFR 146.91(f)(4), states that well plugging reports, PISC 

data (including information used to develop the alternate PISC timeframe), and site closure 

reports must be retained for 10 years following site closure. Submission of this information takes 

place at various times throughout the post-injection phase, as summarized in Table 6-1. 

Table 6-1. Reporting and recordkeeping schedule for the post-injection phase. 

Post-Injection Data Class VI Rule Citation Time for Submission Record Retention

Updated PISC and Site 

Closure Plan 40 CFR 146.93(a)(3) Upon cessation of injection

[40 CFR 146.93(a)(3)] 10 years following site 

closure

Notice of intent to plug (recommended)

the injection well 40 CFR 145.92(c) 60 days before event

[40 CFR 146.92(c)]
Draft UIC Program Class VI Well Recordkeeping, 85 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Post-Injection Data Class VI Rule Citation Time for Submission Record Retention

Well plugging report 40 CFR 146.92(d) Within 60 days

[40 CFR 146.92(d)] 10 years following site 

closure 

[40 CFR 146.91(f)(4)] PISC monitoring results 40 CFR 146.93(b)

As specified in the 

approved PISC and Site 

Closure Plan

Non-endangerment 

demonstration 40 CFR 146.93(b)(3)

At end of 50 years or the 

approved alternative 

timeframe, or based on 

site-specific data

[40 CFR 146.93(b)(3)]

10 years following site 

closure (recommended) Notice of intent for site 

closure 40 CFR 146.93(d)

At least 120 days before 

site closure

[40 CFR 146.93(d)]

Notice of intent to plug 

monitoring wells N/A* N/A

Site closure report 40 CFR 146.93(f) Within 90 days of closure

[40 CFR 146.93(f)]

10 years following site 

closure (by UIC Program 

Director) 

[40 CFR 146.93(f); 

40 CFR 146.91(f)(4)]

*This item is not specifically required by the Class VI Rule; however, EPA recommends that owners or

operators provide notification before plugging monitoring wells. The requirement to plug monitoring 

wells appears in the Class VI Rule at 40 CFR 146.93(e).
Draft UIC Program Class VI Well Recordkeeping, 86 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

7 GS Data Submission and Management

Note: At the time this draft document was published, the central data system for Class VI data 

was under development. To avoid publishing incomplete information, this draft contains a 

placeholder for the description of GS data management through the use of the central data 

system.
Appendix A. Draft Class VI Rule Reporting Data Elements Matrix

Table A-1, the draft Class VI Rule reporting data elements matrix, lists the data elements associated with the Class VI Rule 

requirements for each GS project phase, along with the recommended submittals to fulfill each reporting requirement, the 

recommended data format, and the required or recommended timing and frequency of the submissions. The table is organized

according to the content of the Class VI Rule Subpart H requirements, beginning with 40 CFR 146.82. 

Table A-1. Class VI Rule reporting data elements matrix (DRAFT). 

Anticipated Data

Format Data Element Potential Submittals Timing & Frequency

PRE-INJECTION ACTIVITIES

40 CFR 146.82 Required Class VI permit information

40 CFR 146.82(a) Prior to the issuance of a permit for the construction or conversion of a new Class VI well or the conversion of a Class I, Class II, or Class V well to 

a Class VI well

40 CFR146.82(a)(1)

Information required in 40 CFR 144.31 

(e)(1) through (6):

(1) The permitted activities 

(2) Name, mailing address, and 

location of the facility

(3) Up to four SIC codes 

(4) The operator’s name, address, 

telephone number, ownership status, 

and status as Federal, State, private, 

public, or other entity 

(5) Whether the facility is located on 

Indian lands

(6) A listing of all permits or 

construction approvals

• Authorization status, Permit

action type, and Permit action 

• Facility information • Tabular Data •

•

•

•

Once, as part of the permit application

Note: Facility information may need to 

be submitted with each submittal 

(depending on the reporting procedure 

employed)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

May require update upon modification, 

re-issuance, or transfer of the permit

Draft UIC Program Class VI Well Recordkeeping, A-1 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators
Draft UIC Program Class VI Well Recordkeeping, A-2 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

date 

40 CFR 146.82(a)(2)

A map showing the injection well for 

which a permit is sought and the 

applicable Area of Review (AoR) 

consistent with 40 CFR 146.84. The 

map must show only public record 

information of:

• The number/name, and location

of all:

o injection wells;

o producing wells;

o abandoned wells;

o plugged wells;

o dry holes; and

o deep stratigraphic

boreholes.

• State- or EPA-approved

subsurface cleanup sites;

• Surface bodies of water/springs;

• Surface and subsurface

mines/quarries;

• Pertinent surface features (e.g.,

buildings, infrastructure)

• State, Tribal, and Territory

boundaries; and

• Faults, if known or suspected.

See 40 CFR 146.84 below.

• The conceptual site model and all supporting data on

which the model is based;

• Attributes of the code used to create the

computational model (e.g., code name, name of the

developing organization, governing equations

employed, simplifying assumptions);

• A description of model’s initial and boundary

(vertical and lateral) conditions and layers as

presented on maps and cross sections;

• A description of numerical space discretization,

solution methods/options employed, computational

parameters, and time-stepping information;

• An accounting of all equations of state used to

describe thermophysical properties of all fluids

modeled (e.g., ground water, carbon dioxide);

• Constitutive relationships of the permeable medium

(e.g., relative permeability-saturation relationship)

and a description of how they were determined;

• Values of all model parameters and a description of

how model parameters were determined based on

site characterization;

• If requested by the UIC Program Director, raw model

input and output files;

• Model results depicting the extent of carbon dioxide

plume and pressure-front migration over the lifetime

of the project as a function of time, and results of

simulations of maximum-risk scenario and the

outcome of parameter sensitivity analyses; and

• If required by the UIC Program Director, the relevant

qualifications and professional experience of any

individuals and/or consulting firms responsible for

• A combination

of PDF, tabular

data and/or

GIS-compatible

format

•

•

•

•

Submitted as part of the permit 

application prior to issuance of a 

permit for the construction under 40 

CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)

AoR reevaluation conducted and 

submitted at a fixed frequency, not 

exceeding once every 5 years under 40 

CFR 146.84(e) or when deemed 

necessary

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-3 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

model development, AoR delineation, and 

reevaluation, including examples of previous 

multiphase modeling studies conducted.

40 CFR 146.82(a)(3)

Information on geologic structure and 

hydrogeologic properties of storage 

site and overlying formations 

including:

•

•

Information listed below; and

See 40 CFR 146.83 below.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(i) Maps and cross-sections of AoR •

•

•

Must identify the injection formation, confining 

zone(s), and any USDWs;

Must identify geologic structures, including faults, 

folds, structural traps;

Must show the locations and orientations of known 

or suspected faults and fractures that may transect 

the AoR (information specified at 40 CFR 

146.82(a)(3)(ii)); and

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(ii) Location, orientation, and 

properties of known or suspected 

faults and fractures that may 

transect confining zone(s) in AoR 

and a determination that they 

would not interfere with 

containment

•

•

Locations and orientations of known or suspected 

faults and fractures illustrated on maps and cross 

sections. 

Determination that faults or fractures would not 

interfere with containment. Such information may 

include:

o A description of the approach used to infer

whether a fault or fracture is transmissive;

o A summary table of data used to formulate the

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 
Draft UIC Program Class VI Well Recordkeeping, A-4 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o

o

o

o

estimate;

Supporting data and information (e.g., analyses of 

core samples, results of geophysical surveys, 

pore pressure data, maps and cross sections);

A description of the characteristics of the fault or 

fracture (e.g., geometry, depth, fault 

displacement, units juxtaposed by fault);

Any relevant calculations (e.g., calculation of 

shale gouge ratio); and

A narrative integrating the relevant information, 

including a discussion of spatial heterogeneity in 

sealing properties and whether a fault or fracture 

is likely to be transmissive in the project area. 

146.91(f)(1)

(iii)Data on depth, areal extent, 

thickness, mineralogy, porosity, 

permeability, and capillary 

pressure of the injection and 

confining zone(s); including 

geology/facies changes based on 

field data which may include 

geologic cores, outcrop data, 

seismic surveys, well logs, and 

names and lithologic descriptions

•

•

•

•

Estimates of depth, thickness, and areal extent, 

referencing maps, cross sections, well logs, 

geophysical surveys, or any other available 

information. 

Estimates of porosity based on data from laboratory 

analyses and/or field analysis

Estimates of permeability based on data from 

laboratory analyses and/or field analysis

Lithologic and mineralogic descriptions, including:

o Locations, formations, and depths from which

samples were taken;

o Visual observations (e.g., including photographs)

from drill cuttings and core samples;

o Observations (e.g., including photographs) from

thin sections and results of other techniques

(e.g., X-ray diffraction, scanning electron

microscopy);

o Approximate percentages of minerals and notes

on texture; and

o Correlations between well logging and core

•A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-5 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

samples and extrapolation to other cores if 

applicable.

Estimates of capillary pressure:

o Description of methodologies used

o Results including all relevant graphs

A description of geology/facies changes, based on:

o Geological maps, and stratigraphic columns

o Stratigraphic cross sections

o Data from wireline methods and well logs

o Core description and analysis

o Geophysical data

(iv)Geomechanical information on 

fractures, stress, ductility, rock 

strength, and in situ fluid 

pressures within confining zones

•

•

•

•

In-situ fluid pressure:

o The name/location of the well or borehole

sampled, date and time of measurement, and

depth of measurement;

o Test method used and notes on equipment

calibration if appropriate.

Information on fractures: 

o Locations of fractures (estimated areal and

vertical extent), method of identification (e.g.,

geophysical survey, wellbore imaging, caliper

logs), orientation, and geometry.

Ductility and rock strength: 

o Locations, formations, and depths from which

samples were taken;

o Laboratory methods and conditions used; and

o Results in tabular form and any associated

graphs.

Stress (vertical, minimum horizontal, and maximum 

horizontal): 

o For vertical (overburden) stress: reference

appropriate density logs (if used in porosity

estimation) or provide density log data and

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-6 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o

o

tabulate associated value for overburden stress.

For minimum horizontal stress: location of well, 

leak-off test results or annular pressure test 

results, and derived values for minimum 

horizontal stress. 

For maximum horizontal stress: method of 

determining stress through either testing (e.g., 

image logs) or calculation based on vertical and 

minimum horizontal stresses. Relevant 

calculations and/or data should be provided in 

tabular format or PDF as appropriate. 

(v) Information on seismic history 

including presence and depth of 

seismic sources and determination 

that seismicity would not interfere 

with containment

•

•

•

Dates, locations (both in description and in 

coordinates), and depths of seismic events; 

The history and periodicity of seismic events (as far 

back as information is available); and

A discussion, which may refer to maps and cross 

sections provided for 40 CFR 146.82(a)(3)(i) and (ii) 

to reference faults. 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(vi)Geologic and topographic maps 

and cross sections illustrating 

regional geology, hydrogeology, 

and geologic structure of local 

area

• Maps should present:

o Injection formation,

o confining zone(s),

o all USDWs,

o structural features, and

o direction of water movement where known.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(4) • A list of all artificial penetrations through the • A combination • Submitted as part of the permit
Draft UIC Program Class VI Well Recordkeeping, A-7 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

A tabulation of all wells within AoR 

which penetrate injection or confining 

zone(s), including description of each 

well’s:

• Type;

• Construction;

• Date drilled;

• Depth;

• Location;

• Record of plugging and/or

completion; and

• Any additional information.

injection and confining zone(s). of PDF and 

tabular data 

and/or GIScompatible 

format

•

•

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(5)

Maps and stratigraphic cross sections 

indicating general vertical and lateral 

limits of all USDWs, water wells and 

springs within the AoR, their positions 

relative to injection zone(s), and 

direction of water movement, where 

known

• Must illustrate the following hydrogeologic features

[40 CFR 146.82(a)(5)]:

o The general vertical and lateral limits of USDWs

within the AoR;

o Locations of water wells, and springs within the

AoR and their positions relative to the injection

zone(s); and

o Direction of water movement, where known.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(6)

Baseline geochemical data on 

subsurface formations, including all 

USDWs in AoR

• Fluid geochemistry:

o Date/time and location of samples taken;

o Results of fluid analyses for dissolved

constituents, which may include pH, specific

conductivity, total dissolved solids, major ions,

and selected trace elements;

o Laboratory reports if available and required by

the UIC Program Director, including methods

used and QA/QC samples; and

o Any interpretive plots (e.g., piper or stiff

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-8 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

diagrams)

Formation mineralogy including information 

regarding the compatibility of the solids with the 

injectate as well as the potential for release of trace 

constituents:

o Date/time and location of sampling (e.g.,

borehole, depth, formation sampled) and

method of sample retrieval (e.g., core, sidewall

core);

o Methods used for whole-rock chemical analysis

(e.g., digestion and elemental analysis, x-ray

fluorescence); and

o Results of analyses (as percent of total rock).

Geochemistry of specific minerals, this information 

may be reported as well. This may include analyses 

obtained via scanning electron microscopy or 

electron microprobe. 

o Location of samples taken (borehole, depth,

formation sampled) and method of sample

retrieval (e.g., core, sidewall core);

o Method used for mineralogic analysis; and

o Compositions (in mole percent) of minerals.

40 CFR 146.82(a)(7) • A description of planned operation. • A combination • Submitted as part of the permit

Proposed operating data: of PDF and

tabular data

•

•

application prior to the well

construction under 40 CFR 146.82(a)

Update submitted as part of the permit

application prior to authorization for

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS

project and 10 years following site

closure as required under 40 CFR

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-9 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(i) Average and maximum daily 

rate and volume and/or mass 

and total anticipated volume 

and/or mass of carbon dioxide

stream

• Planned values based on the site characterization

and planned operation

• Tabular Data •

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(ii) Average and maximum 

injection pressure

• Planned values based on the site characterization

and planned operation

• Tabular Data •

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(iii) Source(s) of the

stream

carbon dioxide • A list of industrial sources of carbon dioxide • Tabular Data •

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(iv) Analysis of chemical and 

physical characteristics of

• A list of chemical parameters to be analyzed, • PDF and/or • Submitted as part of the permit
Draft UIC Program Class VI Well Recordkeeping, A-10 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

carbon dioxide stream

•

•

•

•

•

•

•

including constituents of the injectate, such as 

carbon dioxide and other impurities (e.g., sulfur 

dioxide, hydrogen sulfide, nitrous oxides); 

A list of physical parameters to be 

analyzed/measured, including temperature and 

pressure;

A description of the sampling methodology, including 

schematics of the monitoring equipment if 

applicable;

Any analytical methods used and the name of the 

certified laboratory performing analysis;

All sample dates and times;

All data resulting from carbon dioxide stream 

analyses, including dates and any quality 

assurance/quality control (QA/QC) samples;

Interpretation of the results with respect to 

regulatory requirements and past results (if 

applicable); and

Identification of data gaps.

tabular data

•

•

•

•

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection as required under 40 CFR 

146.82(c)(2)

Information submitted in the permit 

application to be retained throughout 

the life of the GS project and 10 years 

following site closure as required under 

40 CFR 146.91(f)(1)

Conducted during the injection 

operation at a frequency specified in 

the approved Testing and Monitoring 

Plan as required under 40 CFR 

146.90(a), any changes in the results to 

be submitted in the semi-annual report 

as required under 40 CFR 146.91(a)(1)

Information submitted in the semiannual report to be retained 10 years 

after collection as required under 40 

CFR 146.91(f)(3).

40 CFR 146.82(a)(8)

Proposed pre-operational formation 

testing program to obtain an analysis 

of the chemical and physical 

characteristics of the injection zone(s) 

and confining zone(s) and that meets 

the requirements at 40 CFR 146.87 

See 40 CFR 146.87(a) below.

• A plan for well logging before and upon installation

of the surface casing. This plan must include 

resistivity, spontaneous potential, and caliper logs 

[40 CFR 146.87(a)(2)(i)]. 

• A plan for well logging before and upon installation

of the long string casing. This plan must include the 

following logs: resistivity, spontaneous potential, 

porosity, caliper, gamma ray, fracture finder, and any 

other logs the UIC Program Director requires [40 CFR 

146.87(a)(3)(i)]. 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-11 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

•

•

•

Sampling plans for cores (whole cores or sidewall 

cores) including proposed number and locations of 

core samples [40 CFR 146.87(b)], analyses to be 

performed on cores, and coring methods to be used. 

Plan for obtaining formation fluids from the injection 

zone(s) including proposed sampling method (e.g., 

wireline) [40 CFR 146.87(b)], and analyses to be 

performed on fluids. 

Plan for measuring fluid temperature, pH, 

conductivity, reservoir pressure, and static fluid level 

in the injection zone(s), including a brief description 

of the apparatus to be used [40 CFR 146.87(c)]. 

Plan for characterizing the injection and confining 

zones: Planned formation integrity test for 

determining fracture pressure [40 CFR 146.87(d)(1)]; 

any other tests for determining the physical and 

chemical characteristics of the injection and 

confining zone(s) and formation fluids in the 

injection zone(s) [40 CFR 146.87(d)(2) and (3)]. 

Tests for verifying the hydrogeologic characteristics 

of the injection zone(s): Plans for a pressure fall-off 

test and either a pump test or injectivity test [40 CFR 

146.87(e)].

40 CFR 146.82(a)(9)

Proposed stimulation program, 

description of stimulation fluids, and 

determination that stimulation will 

not interfere with containment

• A description of the proposed stimulation procedure

which must include:

o A demonstration that it will not fracture the

confining layer or otherwise allow fluid to move

out of the injection zone:

 Any modeling results presenting predicted

pressures and a comparison against the

fracture pressure of the confining zone;

 If chemicals are to be used in stimulation, a

determination that chemical will not react

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-12 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o

with the confining layer and/or 

compromise the effectiveness of the 

confining layer; 

An explanation of how routine injection 

monitoring will confirm the predicted pressures 

and demonstrate the compliance with the Rule 

requirements.

40 CFR 146.82(a)(10)

Proposed procedure to outline steps 

necessary to conduct injection 

operation

• A description of injection operation. • A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(11)

Schematics or other appropriate 

drawings of surface and subsurface 

construction details of the well 

• Schematics and drawings including details of:

o The wellhead;

o The surface casing;

o The long string casing;

o Any intermediate casings;

o Cement placement;

o Tubing;

o Packer placement; and

o Completion details, including perforated,

screened, or open hole zones

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 146.82(a)(12)

Injection well construction procedures 

that meet requirements of 40 CFR 

146.86

• A list of documentation, including:

o A copy of the construction specifications;

o References to any standards or best management

practices to be used in construction (e.g. API

specifications to be followed);

• PDF •

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 
Draft UIC Program Class VI Well Recordkeeping, A-13 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o

o

o

o

o

Manufacturer specifications on materials used for 

well construction including corrosion and 

temperature resistance ratings and material 

strengths;

Proposed drilling procedures;

Proposed cementing procedures;

Perforation techniques; and

A list of logs or measurements that will be made 

to guide/verify the construction process. 

•

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(13)

Proposed Area of Review (AoR) and 

Corrective Action Plan that meets 

requirements under 40 CFR 146.84 

See 40 CFR 146.84(b) below. • A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(14)

A demonstration that applicant has 

met financial responsibility 

requirements under 40 CFR 146.85

See 40 CFR 146.85 below. • A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application as required under 40 CFR 

146.82(a)(14).

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Updates submitted:

o Annually;

o When the instrument(s) are

insufficient to cover the cost

estimates; or

o Within 60 days of amendment of a
Draft UIC Program Class VI Well Recordkeeping, A-14 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

plan or notification by the UIC 

Program Director. As noted under 

40 CFR 146.85

40 CFR 146.82(a)(15)

Proposed Testing and Monitoring Plan 

required by 40 CFR 146.90

• The Testing and Monitoring Plan, including proposed

procedures and frequencies for:

o Analysis of the chemical and physical

characteristics of the carbon dioxide stream;

o Mechanical integrity testing (MIT);

o Corrosion monitoring;

o Determination of the position of the carbon

dioxide plume and are of elevated pressure;

o Monitoring of geochemical changes in the

subsurface;

o At the discretion of the UIC Program Director,

surface air and soil gas monitoring for carbon

dioxide fluxes; and

o Any additional tests necessary to ensure USDW

protection from endangerment.

• A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(16)

Proposed Injection Well Plugging Plan 

required by 40 CFR 146.92(b)

• The Injection Well Plugging Plan, including a

description of:

o Appropriate tests or measures to determine

bottom-hole reservoir pressure;

o Appropriate testing methods to ensure external

mechanical integrity;

o The type and number of plugs to be used [40

CFR 146.92(b)(3)];

o The placement of each plug, including the

elevation of the top and bottom of each plug.

EPA recommends that the plan describe the

placement of all plugs; schematics and

drawings may be appropriate to demonstrate

this;

• A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-15 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o

o

The type, grade, and quantity of material to be 

used in plugging. EPA recommends that the 

plan demonstrate that the cement is 

appropriate to withstand contact with the 

carbon dioxide or acidified formation fluids; 

and 

The method of plug placement, e.g., the 

balance method, retainer method, or two-plug 

method.

40 CFR 146.82(a)(17)

Proposed Post-Injection Site Care 

(PISC) and Site Closure Plan required 

by 40 CFR 146.93(a)

• The Post-Injection Site Care (PISC) and Site Closure

Plan, including:

o The pressure differential between pre-injection

and predicted post-injection pressures in the

injection zone(s);

o The predicted position of the carbon dioxide

plume and associated pressure front at site

closure as demonstrated in the AoR evaluation;

o A description of post-injection monitoring

locations, methods, and proposed frequency;

o A proposed schedule for submitting post-injection

site care monitoring results to the UIC Program

Director; and

o The duration of the post-injection site care

timeframe;

o Any additional site-specific factors determined by

the UIC Program Director.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(18)

A demonstration of an alternative 

post-injection site care timeframe 

required by 40 CFR 146.93(c) (At the 

UIC Program Director’s discretion)

• If approved by the UIC Program Director, the

demonstration that an alternative post-injection site

care timeframe is appropriate [as described at 40

CFR 146.93(c)]. The demonstration must include

documentation of:

o The results of site-specific computational

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)
Draft UIC Program Class VI Well Recordkeeping, A-16 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o

o

o

o

o

o

o

modeling; 

The predicted timeframe for pressure decline; 

The predicted rate of carbon dioxide plume 

migration; 

Site-specific chemical processes that will result in 

carbon dioxide trapping; 

The predicted rate of carbon dioxide trapping; 

characterization of the confining zone(s);

Laboratory analyses or studies to verify the 

information on trapping; 

The presence of potential conduits for fluid 

movement and the quality of abandoned well 

plugs within the AoR; 

The distance between the injection zone and the 

USDWs above and/or below the injection zone.

• Retained throughout the life of the GS

project and 10 years following site

closure as required under 40 CFR

146.91(f)(1)

40 CFR 146.82(a)(19)

Proposed Emergency and Remedial 

Response Plan required by 40 CFR 

146.94(a)

• Emergency and Remedial Response Plan, including:

o A list of all potentially impacted environmental

resources (e.g., ground water or surface water)

or infrastructure (e.g., the well or nearby

structures) near the well.

o Potential risk scenarios for each identified

resource or infrastructure element (e.g., a well

blowout, equipment failure, fluid movement,

metals leaching, contamination of the water

supply).

o Response actions to address the identified risk

scenarios (e.g., remedial cementing of the well or

treatment of ground water or drinking water

supplies).

o Personnel and equipment needed to implement

the response actions (e.g., first responders, GS

project facility staff, or environmental

contractors).

• A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-17 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o Other information that may be included in the

Emergency and Remedial Response Plan

includes:

 Facility emergency 24-hour contacts,

including phone/pager numbers and email

addresses;

 A list of people to notify in case of an

adverse event;

 The location of the well, such as the

specific town or county;

 A map of the area, including the location of

the well and nearby population centers or

sensitive environments;

 Schematics and diagrams of the facility and

well, including the location of monitoring

equipment and emergency shutoffs; and

 A communications plan and emergency

notification procedures that describe

potential audiences, communication

methods, audiences, and messages.

40 CFR 146.82(a)(20)

List of contacts for States, Tribes, and 

Territories within AoR based on 40 

CFR 146.82(a)(2)

• Contact information • A combination

of tabular data

PDF and/or

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(a)(21)

Any other information required by 

• Any information • A combination

of PDF and

• Submitted as part of the permit

application prior to the well
Draft UIC Program Class VI Well Recordkeeping, A-18 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

Director tabular data 

and/or GIScompatible 

format

•

•

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(b) 

The Director will notify, in writing, any States, Tribes, or Territories 

to 40 CFR145.23(f)(13)

within the AoR based on 40 CFR 146.82(a)(2) and (19) of the permit application and pursuant 

40 CFR 146.82(c) Prior to Director’s approval for operation of a Class VI well

40 CFR 146.82(c)(1) 

The final AoR based on modeling, 

using data obtained during logging 

and testing of the well and the 

formations as required by 40 CFR 

146.82(c)(2), (3), (4), (6), (7), and (10). 

See 40 CFR 146.84 below.

• The conceptual site model and all supporting data on

which the model is based;

• Attributes of the code used to create the

computational model (e.g., code name, name of the 

developing organization, governing equations 

employed, simplifying assumptions);

• A description of model’s initial and boundary

(vertical and lateral) conditions and layers as 

presented on maps and cross sections;

• A description of numerical space discretization,

solution methods/options employed, computational 

parameters, and time-stepping information;

• An accounting of all equations of state used to

describe thermophysical properties of all fluids 

modeled (e.g., ground water, carbon dioxide);

• Constitutive relationships of the permeable medium

(e.g., relative permeability-saturation relationship) 

and a description of how they were determined;

• Values of all model parameters and a description of

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

AoR reevaluation conducted and 

submitted at a fixed frequency, not 

exceeding once every 5 years under 40 

CFR 146.84(e) or when deemed 

necessary

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-19 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

•

how model parameters were determined based on 

site characterization;

If requested by the UIC Program Director, raw model 

input and output files;

Model results depicting the extent of carbon dioxide 

plume and pressure-front migration over the lifetime 

of the project as a function of time, and results of 

simulations of maximum-risk scenario and the 

outcome of parameter sensitivity analyses; and

If required by the UIC Program Director, the relevant 

qualifications and professional experience of any 

individuals and/or consulting firms responsible for 

model development, AoR delineation, and 

reevaluation, including examples of previous 

multiphase modeling studies conducted.

40 CFR 146.82(c)(2) 

Any relevant updates, based on data 

obtained by 40 CFR 146.82(c)(3), (4), 

(6), (7), and (10) to the information on 

the geologic structure and 

hydrogeologic properties of storage 

site and overlying formation 

submitted under 40 CFR 146.82(a)(3)

• Any updates to the submittals under 40 CFR

146.82(a)(3), see above.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(c)(3) 

Information on compatibility of

carbon dioxide stream with fluids in 

injection zone and minerals in both 

injection and confining zone(s), based 

on the results of formation testing 

program, and with the materials used 

to construct the well

• Information on the interactions between the

injectate and the formation fluids and minerals:

o Results of laboratory bench-top testing of

interactions between carbon dioxide, carbon

dioxide-rich brine, and formation minerals.

Information should be submitted describing all

testing methods, results, and interpretation.

o Results of equilibrium geochemical speciation

calculations. Information should be provided on

• A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-20 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

the program used, input data, and results, 

indicating aqueous speciation of fluid 

constituents and saturation indices for relevant 

mineral phases. 

o Results of reactive transport modeling.

Information should be provided on the program

used, input data, and results, indicating potential

for dissolution and precipitation of mineral

phases and potential release of trace elements.

For more information on submitting modeling

results.

Information on the interactions between the 

injectate and formation fluids and the well tubular 

and cement materials:

o Results of modeling of cement-injectate

interactions. Information should be provided on

the program used, input data, and results

indicating potential corrosion or lack of corrosion

of the cement.

o Results of bench-top testing of interactions

between the injectate, carbon dioxide-rich brine,

and well metal and cement materials.

Information should be submitted describing all

testing methods, results, and interpretation.

40 CFR 146.82(c)(4) 

The results of formation testing 

program as required at 40 CFR 

146.82(a)(8)

See 40 CFR 146.87 below. • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-21 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

40 CFR 146.82(c)(5) 

Final injection well construction 

procedures that meet requirements of 

40 CFR 146.86

See 40 CFR 146.86 below. • A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(c)(6) 

The status of corrective action on 

wells in AoR 

•

•

•

Reports on completion of corrective action activities 

indicating the number, type, and location of plugs 

used; and

Records of any remedial cementing performed along 

with cement logs showing the methods used and the 

results of the remedial cementing.

A list of wells that have not received corrective 

action and a schedule/description of phased 

corrective action.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(c)(7) 

All available logging and testing 

program data on well required by 40 

CFR 146.87

See 40 CFR 146.87(a) below • A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(c)(8) 

Demonstration of mechanical integrity 

pursuant to 40 CFR 146.89 

See 40 CFR 146.89 below. • A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 
Draft UIC Program Class VI Well Recordkeeping, A-22 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

146.91(f)(1)

40 CFR 146.82(c)(9) 

Any updates to the proposed AoR and 

corrective action plan, testing and 

monitoring plan, injection well 

plugging plan, post-injection site care 

and site closure plan, or the 

emergency and remedial response 

plan submitted under 40 CFR 

146.82(a) that are necessary to 

address new information collected 

under 40 CFR 146.82(c) 

• Revised plans, see:

o 40 CFR 146.84(b) for the AoR and Corrective

Action Plan

o 40 CFR 146.82(a)(15) for the Testing and

monitoring Plan

o 40 CFR 146.82(a)(16) for the Injection Well

Plugging Plan

o 40 CFR 146.82(a)(17) for the PISC and Site Closure

Plan; and

o 40 CFR 146.82(a)(19) for the Emergency and

Remedial Response Plan

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(c)(10) 

Any other information required by 

Director

• To be determined by the UIC Program Director • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.82(d)

A waiver application report as required 

at 40 CFR 146.95(a) for a waiver of the 

requirement to inject below the 

lowermost USDW, if applicable. This 

report is submitted in addition to the 

permit application.

See 40 CFR 146.95 • A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.83 Minimum criteria for siting 

40 CFR 146.83(a)

Demonstration that the wells will be 

• All information submitted in the permit application; • A combination • Submitted as part of the permit
Draft UIC Program Class VI Well Recordkeeping, A-23 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

sited in areas with a suitable geologic 

system and the geologic system is 

comprised of:

•

and

A demonstration of storage capacity, including: 

o A summary table of all of data used to formulate

the estimate (e.g., porosity values, permeability, 

injectivity, fracture pressure);

o For any data not already included as part of the

requirements above under 40 CFR 146.82(a), 

information should be provided on collection of 

those data (sampling and measurement 

locations, methods, results);

o Description of method/model used for estimation

of capacity and any inherent assumptions;

o Any supporting calculations or model results; and

o A discussion of any uncertainties or limitations in

the estimates.

of PDF and 

tabular data

•

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.83(a)(1) 

An injection zone of sufficient areal 

extent, thickness, porosity, and 

permeability to receive the total 

anticipated volume 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application prior to authorization of the 

injection operation under 40 CFR 

146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.83(a)(2) • A combination • Submitted as part of the permit

Confining zones free of transmissive of PDF and application prior to authorization of the

faults or fractures and of sufficient tabular data injection operation under 40 CFR

areal extent and integrity to contain and/or GIS- 146.82(c)(2)

injected carbon dioxide and displaced compatible • Retained throughout the life of the GS

formation fluids and allow injection at format project and 10 years following site

proposed maximum pressures and closure as required under 40 CFR

volumes without initiating or 146.91(f)(1)

propagating fractures in the confining 

zone(s)

40 CFR 146.83(b) • A combination • Submitted as part of the permit

At the Director’s discretion, of PDF and application prior to authorization of the

identification and characterization of tabular data injection operation under 40 CFR

additional zones that will impede 146.82(c)(2)

vertical fluid movement, • Retained throughout the life of the GS

demonstration that they are free of project and 10 years following site

faults and fractures, allow for pressure closure as required under 40 CFR
Draft UIC Program Class VI Well Recordkeeping, A-24 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

dissipation, and provide additional 

opportunities for monitoring, 

mitigation and remediation

146.91(f)(1)

40 CFR 146.84 Area of review (AoR) and corrective action

40 CFR 146.84(b) 

Proposed AoR and corrective action 

plan must include:

(1) The method for delineating the 

AoR that meets the requirements 

at 40 CFR 146.84(c), including the 

model to be used, assumptions 

that will be made, and site 

characterization data on which 

model will be based

(2) A description of 

(i) The minimum fixed frequency 

to reevaluate the AoR

(ii) The monitoring and 

operational conditions that 

would warrant a reevaluation 

of the AoR

(iii) How monitoring and 

operational data will be used 

to inform an AoR reevaluation

(iv) How corrective action will be 

conducted to meet the 

requirements of 40 CFR 

146.84(d)

• The AoR and Corrective Action Plan, including:

o A description of the method for delineating the

AoR and planned computational modeling

(including the name and description of the

model, planned assumptions and inputs, etc.);

o A description of proposed minimum fixedfrequency to reevaluate the AoR;

o An explanation of monitoring and operating

conditions under which a reevaluation would be

needed prior to the next scheduled reevaluation;

o Descriptions of how monitoring and operational

data will be used to inform an AoR reevaluation;

o An explanation of how the corrective action will

be conducted including a schedule for completing

corrective action on all improperly plugged wells

located within the AoR;

o How access to all wells needing corrective action

will be guaranteed; and

o Justification of phased corrective action, if

applicable.

• A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction as required under 40 CFR 

146.82(a)(13)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)(2)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1.

40 CFR 146.84(c)(1)

Predicted lateral and vertical 

migration of carbon dioxide plume 

and formation fluids by using 

•

•

The conceptual site model and all supporting data on 

which the model is based;

Attributes of the code used to create the 

computational model (e.g., code name, name of the 

• A combination

of PDF and

tabular data

and/or GIS-

•

•

Submitted as part of the permit 

application under 40 CFR 146.82(a)

AoR reevaluation conducted and 

submitted at a fixed frequency, not 
Draft UIC Program Class VI Well Recordkeeping, A-25 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

computational modeling. The model 

must:

(i) Be based on geologic data 

collected to characterize the 

injection zone, confining zone 

and any additional zones; and 

anticipated operating data

including injection pressures, 

rates, and total volumes.

(ii) Take into account any 

geologic heterogeneities, 

other discontinuities, and 

data quality.

(iii) Consider potential migration 

through faults, fractures, and 

artificial penetrations.

•

•

•

•

•

•

•

•

developing organization, governing equations 

employed, simplifying assumptions);

A description of model’s initial and boundary 

(vertical and lateral) conditions and layers as 

presented on maps and cross sections;

A description of numerical space discretization, 

solution methods/options employed, computational 

parameters, and time-stepping information;

An accounting of all equations of state used to 

describe thermophysical properties of all fluids 

modeled (e.g., ground water, carbon dioxide);

Constitutive relationships of the permeable medium 

(e.g., relative permeability-saturation relationship) 

and a description of how they were determined;

Values of all model parameters and a description of 

how model parameters were determined based on 

site characterization;

If requested by the UIC Program Director, raw model 

input and output files;

Model results depicting the extent of carbon dioxide 

plume and pressure-front migration over the lifetime 

of the project as a function of time, and results of 

simulations of maximum-risk scenario and the 

outcome of parameter sensitivity analyses; and

If required by the UIC Program Director, the relevant 

qualifications and professional experience of any 

individuals and/or consulting firms responsible for 

model development, AoR delineation, and 

reevaluation, including examples of previous 

multiphase modeling studies conducted.

compatible 

format

•

exceeding once every 5 years under 40 

CFR 146.84(e) or when deemed 

necessary

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.84(c)(2)

Identification of all penetrations in the 

AoR. Description of each well’s type, 

•

•

A tabulation of all wells within the AoR which 

penetrate the injection or confining zone(s); and

For each well within the AoR, the well’s type, 

• A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application under 40 CFR 146.82(a)

Retained throughout the life of the GS 
Draft UIC Program Class VI Well Recordkeeping, A-26 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

construction, date drilled, location, 

depth, record of plugging and/or 

completion, and any additional 

information

construction, date drilled, location, depth, record of 

plugging and/or completion, and any additional 

information required by the UIC Program Director.

and/or GIScompatible 

format

•

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.84(c)(3)

Determination of which abandoned 

wells in the AoR are appropriately 

plugged

•

•

•

•

Results of any site investigation performed where 

needed (e.g., where there are no available records);

A determination whether wells in the AoR have been 

plugged in a manner that prevents the movement of 

carbon dioxide or other fluids that may endanger 

USDWs;

Reports of any tests done on abandoned wells; and

A list of wells for which corrective action will be 

conducted.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application under 40 CFR 146.82(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.84(d)

Performing corrective action on all 

wells in the AoR that are determined 

to need corrective action.

•

•

Reports on completion of corrective action activities 

indicating the number, type, and location of plugs 

used; and

Records of any remedial cementing performed along 

with cement logs showing the methods used and the 

results of the remedial cementing.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application under 40 CFR 146.82(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.84(e)

Reevaluation of AoR 

(1) in the same manner specified in 

40 CFR 146.84(c)(1)

(2) identification of all wells as 

specified in 40 CFR 146.84(c)

(3) corrective action demonstration 

as specified in 40 CFR 146.84(d)

(4) submission of an amended AoR 

and corrective action plan or 

demonstration of no amendment 

is needed

•

•

•

•

•

•

Re-submission of all model attributes. 

A new conceptual site model schematic with any 

changes highlighted (e.g., new injection wells, newly 

elucidated geologic features, a revised permeability 

field);

A description of the model calibration process, and 

final results;

A list of adjusted input parameters and their values;

Graphs comparing observed and modeled values of 

carbon dioxide migration and fluid pressure;

Maps presenting the newly delineated AoR in 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

At the minimum fixed frequency (not to 

exceed five years) specified in the AoR 

and Corrective Action Plan under 40 

CFR 146.84 (e); or

Following identification of significant 

changes in site operations, monitoring 

results indicating deviation from the 

predictions, or new site 

characterization data. 

10 years following the reevaluation. 
Draft UIC Program Class VI Well Recordkeeping, A-27 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

•

comparison to previous AoR delineations;

An identification of additional artificial penetrations;

A demonstration of additional corrective action; and

A revised AoR and Corrective Action Plan, along with 

other related project plans. 

40 CFR 146.84(f)

The emergency and remedial response 

plan (40 CFR 146.94) and a 

demonstration of financial 

responsibility (40 CFR 146.85) must 

account for the AoR delineated under 

40 CFR 146.84(c)(1) or reevaluated 

under 40 CFR 146.84(e)

• Revised plans • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application under 40 CFR 146.82(a)

Repeated when necessary (e.g., due to 

results of AoR delineation) under 40 

CFR 146.84 (f)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.85 Financial Responsibility

40 CFR 146.85(a)

Demonstration of financial 

responsibility that meets the 

conditions of:

(1) Qualifying instrument(s): 

(i) Trust Funds

(ii) Surety Bonds

(iii) Letter of Credit

(iv) Insurance

(v) Self Insurance

(vi) Escrow Account

(vii) Any other instrument(s) 

satisfactory to the Director

(i) Instrument(s) sufficient to cover 

the cost of corrective action (40 

CFR 146.84); injection well 

plugging (40 CFR 146.92); post-

• A proof of financial responsibility, including:

o A detailed written estimate of costs, in current

dollars, for each of the activities required to be

covered.

o An original hard copy and an electronic copy of

the signed agreement for the financial

instrument(s).

o For insurance policies, a copy of the policy in

addition to the certificate of insurance.

o For third party instruments, a demonstration of

financial strength, as:

 Third party credit rating;

 Third party bond rating; or

 Third party calculated financial ratios.

o For self insurance, a documentation to present

the financial strength of the company or its

• A combination

of PDF and

tabular data

•

•

Submitted as part of the permit 

application as required under 40 CFR 

146.82(a)(14)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-28 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(2)

(3)

(4)

(5)

injection site care and site 

closure (40 CFR 146.93); and 

emergency and remedial 

response (40 CFR 146.94)

Instrument(s) sufficient to address 

endangerment of USDWs

Instrument(s) comprise protective 

conditions of coverage

Instrument(s) approved by the 

Director

One or more qualifying 

instruments can be used for 

specific phases of the GS project to 

demonstrate financial 

responsibility

parent, as:

 A letter signed by the Chief Financial

Officer of the company; 

 A copy of the independent certified public

accountant's report on examination of the 

owner's or operator's financial statements 

for the latest completed fiscal year; 

 A special report from the owner's or

operator's independent certified public 

accountant to the owner or operator;

 Additional proof of financial strength may

be requested by the UIC Program Director 

such as a copy of the most recent 

Securities and Exchange Commission10-K 

report or a copy of the most recent Federal 

Energy Regulatory Commission Form 2 

report.

40 CFR 146.85(c)

An annual inflation update and written 

updates of adjustment to the cost 

estimate to account for any 

amendments to the AoR and 

corrective action plan (40 CFR 146.84), 

and the injection well plugging plan 

(40 CFR 146.92), and the postinjection site care and site closure 

plan(40 CFR 146.93)

• An updated proof of financial responsibility, as

described under 40 CFR 146.85(a) above.

• A combination

of PDF and

tabular data

•

•

Submitted 

o Annually;

o When the instrument(s) are

insufficient to cover the cost

estimates; or

o Within 60 days of amendment of a

plan or notification by the UIC

Program Director.

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.85(d)

Notifications to the Director in writing 

of adverse financial conditions (e.g., 

• A notice of adverse financial conditions • PDF • Within 10 days of start of proceedings

under 40 CFR 146.85(d)(1)
Draft UIC Program Class VI Well Recordkeeping, A-29 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

bankruptcy), that may affect the 

ability to carry out injection well 

plugging and post injection site care 

and site closure

40 CFR 146.85(e)

An adjustment of the cost estimate if 

the Director determines that the 

original demonstration is no longer 

adequate 

See 40 CFR 146.85(c) above. • A combination

of PDF and

tabular data

• Within 60 days of amendment of a plan

or notification by the UIC Program

Director under 40 CFR 146.85(e)

40 CFR 146.86 Injection well construction requirements

40 CFR 146.86(b) Casing and cementing of Class VI wells 

40 CFR 146.86(b)(1)

In order for the Director to determine 

and specify requirements for casing 

and cementing, the following 

information must be submitted:

(i) Depth to the injection zone 

(ii) Injection pressure, external 

pressure, internal pressure and 

axial loading

(iii) Hole size

(iv) Size and grade of all casing 

strings (wall thickness, external 

diameter, nominal weight, 

length, joint specification and 

construction material)

(v) Corrosiveness of carbon dioxide

stream, and formation fluids

(vi) Down-hole temperatures

(vii) Lithology of injection and 

confining zones 

•

•

•

Measured and/or estimated values.

Depth, location, date, time of each measurements 

and methodology used. 

Interpretation of results.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(5)
Draft UIC Program Class VI Well Recordkeeping, A-30 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(viii)

(ix)

Type or grade of cement and 

cement additives

Quantity, chemical composition, 

and temperature of carbon 

dioxide stream 

40 CFR 146.86(b)(2)

Surface casing must extend through 

the base of the lowermost USDW and 

be cemented to the surface through 

the use of a single or multiple strings 

of casing and cement.

• A demonstration of surface casing construction

details may be shown in schematics.

• A

combination

PDF and

tabular data

of 

•

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(5)

40 CFR 146.86(b)(3)

At least one long string casing, using a 

sufficient number if centralizers, must 

extend to the injection zone and must 

be cemented by circulating cement to 

the surface in one or more stages. 

• A demonstration of construction details, may be

shown in schematics, and description of cementing

procedure.

• A

combination

PDF and

tabular data

of 

•

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(5)

40 CFR 146.86(b)(4)

Demonstration of cement not allowing 

fluid movement behind well bore by 

using logs for the use of an alternative 

method of cementing in cases where 

the cement cannot be recirculated to 

the surface.

•

•

•

A description of cementing procedures, including 

staging procedures.

A description of cementing materials. 

Results of modeling of cement-injectate interactions. 

Information should be provided on the program 

used, input data, and results indicating potential 

• A

combination

PDF and

tabular data

of 

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 
Draft UIC Program Class VI Well Recordkeeping, A-31 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

40 CFR 146.86(b)(5)

Determination of compatibility of the 

cement and cement additives with the

carbon dioxide stream and formation 

fluids and of sufficient 

quality/quantity to maintain integrity 

over the design life of the GS project. 

A verification of the integrity and 

location of the cement by evaluating 

cement quality radially and identifying 

location of channels. 

•

•

corrosion or lack of corrosion of the cement. 

Results of bench-top testing of interactions between 

the injectate, carbon dioxide-rich brine, and well 

metal and cement materials. Information should be 

submitted describing all testing methods, results, 

and interpretation. 

Testing and logging results, see 40 CFR 146.87.

•

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(5)

40 CFR 146.86(c) Tubing and packer

40 CFR 146.86(c)(3)

In order for the Director to determine 

and specify requirements for tubing 

and packer, the following information 

must be submitted:

(i) Depth of setting

(ii) Characteristics of carbon dioxide

stream (chemical content, 

corrosiveness, temperature, and 

density) and formation fluids

(iii) Maximum proposed injection 

pressure

(iv) Maximum proposed annular 

pressure

(v) Proposed injection rate 

(intermittent or continuous) and 

volume of the carbon dioxide

stream

(vi) Size of tubing and casing

(vii) Tubing tensile, burst, and 

•

•

•

Measured and/or estimated values.

Depth, location, date, time of each measurement 

and methodology used. 

Interpretation of results.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(5)
Draft UIC Program Class VI Well Recordkeeping, A-32 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

collapse strengths

40 CFR 146.87 Logging, sampling, and testing prior to injection well operation

40 CFR 146.87(a)

A descriptive report, prepared by a 

knowledgeable log analyst, of logging, 

sampling, and testing results and their 

interpretation of results of 

appropriate logs, surveys, and tests to 

determine or verify depth, thickness, 

porosity, permeability, and lithology

of, and the salinity of any formation 

fluids in all relevant geologic 

formations to ensure

• Conformance with the

injection well construction

requirements under 40 CFR

146,86; and

• Establish accurate baseline

data.

At minimum, such logs and tests must 

include:

•

•

•

•

•

•

•

•

•

Chart results of each log;

Test conditions;

Core analyses performed (e.g., porosity, 

permeability, geomechanical properties, 

petrographic/mineralogic analysis) [40 CFR 

146.87(b]); 

Interpretation of the well logs by the log analyst, 

including determination of porosity, permeability, 

lithology, thickness, depth, and formation fluid 

salinity of relevant geologic formations [40 CFR 

146.87(a)]; 

Any changes in the interpretation of site stratigraphy 

based on formation testing logs;

Identification of any deficiencies in the well 

construction identified from well testing logs and 

steps taken to address these deficiencies;

The date and time of each test, the date of wellbore 

completion, and the date of installation of all casings 

and cements;

Records of the most recent calibration of any 

instruments used during wellbore logging; and

The name and professional certification of the 

logging company and log analyst.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(4) and 

(c)(7)

40 CFR 146.87(a)(1)

Deviation checks during drilling on all 

holes at sufficiently frequent intervals

• The purpose is to identify any deviation from a true

vertical by evaluating 3D path of the wellbore by

using mathematical algorithms and measured data

of:

o The angle between the well and true vertical;

o The acceleration due to gravity, can result in 3D

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 
Draft UIC Program Class VI Well Recordkeeping, A-33 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

information;

o The borehole depth and direction; or

o Others, if applicable.

The results may include measured data as a function 

of depth, presentation of the data on schematics 

and/or graphs, and interpretation of the results.

•

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(4) and 

(c)(7) 

40 CFR 146.87(a)(2) Before and upon installation of surface casing

(i) Resistivity, spontaneous 

potential, and caliper logs 

before casing is installed

•

•

•

•

•

Resistivity logs are used to provide information on 

rock type, formation fluid properties (e.g., salinity, 

TDS), and porosity and indirect estimates of 

permeability by measuring:

o The electrical resistivity of the formation at

different distances from the borehole.

The results may include measured data, presentation 

of the data on schematics, graphs, or maps, and 

interpretation of the results.

Spontaneous potential (SP) logs are used to detect 

permeable and impermeable formations, therefore 

identifying site stratigraphy and formation depths, 

and salinity differences by measuring:

o The direct current potential between the

wellbore and the surface.

The results may include measured data, presentation 

of the data on schematics, graphs, or maps, and 

interpretation of the results.

Caliper logs are used to ensure that the borehole 

diameter is consistent throughout the vertical length 

of the well and detect any collapse or washout 

before casing is installed by measuring:

o The borehole diameter.

•

•

A combination 

of PDF and 

tabular data 

and/or GIScompatible 

format 

Log results may 

also be

submitted in 

LAS format

•

•

•

Conducted before and upon installation 

of surface casing and results and 

interpretations submitted as part of the 

well log analyst’s report in the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(4) and 

(c)(7) 
Draft UIC Program Class VI Well Recordkeeping, A-34 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

• The results may include measured data, presentation

of the data on schematics and/or graphs, and

interpretation of the results.

(ii) A cement bond and variable 

density log, and a 

temperature log after casing 

is set and cemented

•

•

•

•

Cement bond and variable density logs are used to 

indicate the presence or absence of cement behind 

the casing and the quality of the cement-formation 

bond by measuring:

o The amplitude and travel time of transmitted and

reflected sonic signals.

The results may include measured data, presentation 

of the data on schematics, graphs, or photographic 

display, and interpretation of the results.

Temperature logs are used to detect absence of 

cement and fluid leakage by measuring:

o The variation in temperature with depth within

the borehole.

The results may include measured data as a function 

of depth, presentation of the data on schematics 

and/or graphs, and interpretation of the results.

•

•

A combination 

of PDF and 

tabular data 

and/or GIScompatible 

format 

Log results may 

also be

submitted in 

LAS format

•

•

•

Conducted before and upon installation 

of surface casing and results and 

interpretations submitted as part of the 

well log analyst’s report in the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(4) and 

(c)(7) 

40 CFR 146.87(a)(3) Before and upon installation of long string casing

(i) Resistivity, spontaneous 

potential, porosity, caliper, 

gamma ray, fracture finder 

logs, and any other logs 

before casing is installed

See above for Resistivity and SP logs.

• Caliper logs are used to conduct casing inspection to

detect any breaks, distortion, or corrosion after 

casing installation by measuring:

o The internal radii of the casing.

• The results may include measured data, presentation

of the data on schematics and/or graphs, and

interpretation of the results.

• Porosity logs are used to indirectly estimate porosity

and formation lithology by using:

•

•

A combination 

of PDF and 

tabular data 

and/or GIScompatible 

format 

Log results may 

also be

submitted in 

LAS format

•

•

Conducted before and upon installation 

of long string casing and results and 

interpretations submitted as part of the 

well log analyst’s report in the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 
Draft UIC Program Class VI Well Recordkeeping, A-35 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

•

•

•

o Nuclear Magnetic Resonance logs;

o Sonic logs;

o Density logs; or

o Neutron logs.

The results may include measured data, presentation 

of the data on schematics, graphs, or maps, and 

interpretation of the results.

Gamma ray logs are used to identify permeable and 

impermeable formations and evaluate site 

stratigraphy and formation depths by measuring:

o The natural radioactivity in formations.

The results may include measured data, presentation 

of the data on schematics, graphs, or maps, and 

interpretation of the results.

Fracture finder logs are used to detect fractures by 

using:

o Sonic logs;

o Borehole televiewers;

o Electrical borehole imaging logs; and

o Borehole video imaging logs.

The results may include measured data, presentation 

of the data on schematics, graphs, maps, or 

photographic imaging and interpretation of the 

results.

•

146.91(f)(1)

Required under 40 CFR 146.82(c)(4) and 

(c)(7) 

(ii) A cement bond and variable 

density log, and temperature 

log after casing is set and 

cemented

See above for cement bond and variable density log, 

and temperature log.

•

•

A combination 

of PDF and 

tabular data 

and/or GIScompatible 

format 

Log results may 

• Conducted before and upon installation

of long string casing and results and

interpretations submitted as part of the

well log analyst’s report in the permit

application following the issuance of

the construction permit and prior to

authorization of the injection operation
Draft UIC Program Class VI Well Recordkeeping, A-36 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

also be

submitted in 

LAS format

as required under 40 CFR 146.82(c)(4)

• Retained throughout the life of the GS

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

• Required under 40 CFR 146.82(c)(4) and

(c)(7) 

40 CFR 146.87(a)(4) A series of tests designed to demonstrate internal and external mechanical integrity of injection wells

(i) A pressure test with liquid or gas • The purpose is to demonstrate internal mechanical

integrity by measuring:

o The annulus pressure.

• The results may include measured data, presentation

of the data on schematics and/or graphs, and

interpretation of the results.

• A combination

of PDF and

tabular data

• Conducted after drilling, construction,

and completion of the well and

interpretations submitted as part of the

well log analyst’s report in the permit

application following the issuance of

the construction permit and prior to

authorization of the injection operation

as required under 40 CFR 146.82(c)(4),

(7), and (8)

• Information submitted in the permit

application is to be retained throughout

the life of the GS project and 10 years

following site closure as required under

40 CFR 146.91(f)(1)

• A tracer survey, or temperature or

noise log to be conducted at least once

a year under 40 CFR 146.89(c), and a

casing inspection log to be conducted, if

required by the UIC Program Director

under 40 CFR 146.89(d), at a frequency

specified in the Testing and Monitoring

Plan. Resulting reports to be submitted

within 30 days of conducting the

testing as required under 40 CFR

(ii) A tracer survey such as oxygenactivation logging

• The purpose is to demonstrate internal and external

mechanical integrity by measuring:

o The gamma rays.

• The results may include measured data, presentation

of the data on schematics and/or graphs, and

interpretation of the results.

• A combination

of PDF and

tabular data

(iii) A temperature or noise log • The purpose is to demonstrate external mechanical

integrity by measuring:

o Changes in temperature; or

o Noise.

• The results may include measured data, presentation

of the data on schematics and/or graphs, and

interpretation of the results.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

• Log results may

also be

submitted in

LAS format

(iv)A casing inspection log • The purpose is to demonstrate internal and/or • A combination
Draft UIC Program Class VI Well Recordkeeping, A-37 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

external mechanical integrity by detecting corrosion 

based on measuring:

o The thickness of the long string casing.

The results may include measured data, presentation 

of the data on schematics and/or graphs, and 

interpretation of the results.

of PDF and 

tabular data 

and/or GIScompatible 

format

•

146.91(b) and in the semi-annual 

report as required under 40 CFR 

146.91(a).A notification to be 

submitted 30 days prior to the planned 

testing as required under 40 CFR 

146.91(d).

Information submitted in the semiannual report and notifications to be 

retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.87(a)(5) 

Any alternative methods that provide 

equivalent or better information and 

that are required by and/or approved 

of by the Director.

• Any other methods. • A combination

of PDF and

tabular data

•

•

•

Conducted before and upon installation 

of long string casing and results and 

interpretations submitted as part of the 

well log analyst’s report in the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Required under 40 CFR 146.82(c)(4) and 

(c)(7)

40 CFR 146.87(b)

A detailed report and well log 

information about whole cores and 

sidewall cores taken from injection 

zone and confining system (including 

well log analyses and core analyses) 

and formation fluid sample 

information taken from injection 

•

•

•

•

•

Chart results of each log;

Test conditions;

Core analyses performed (e.g., porosity, 

permeability, geomechanical properties, 

petrographic/mineralogic analysis); 

Any changes in the interpretation of site 

stratigraphy;

The date and time of each test, the date of wellbore 

•

•

A combination 

of PDF and 

tabular data 

and/or GIScompatible 

format 

Log results may 

also be

•

•

Submitted as part of the permit 

application following the issuance of

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)(4) 

and (c)(7)

Retained throughout the life of the GS 

project and 10 years following site 
Draft UIC Program Class VI Well Recordkeeping, A-38 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

zone(s) completion, and the date of installation of all casings 

and cements.

submitted in 

LAS format

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.87(c) Records of the following at the injection zone(s):

• Fluid temperature • Measured values of fluid temperature, pH,

conductivity, reservoir pressure, and static fluid level;

and

• Depth, location, date and time of each

measurements.

•

• A combination

of PDF and

tabular data

and/or GIScompatible

format

• Submitted as part of the permit

application following the issuance of

the construction permit and prior to

authorization of the injection operation

as required under 40 CFR 146.82(c)

• Retained throughout the life of the GS

project and 10 years following site

closure as required under 40 CFR

146.91(f)(1)

• Required under 40 CFR 146.82(c)(4) and

(c)(7)

• pH

• Conductivity

• Reservoir pressure

• Static fluid level

40 CFR 146.87(d) Determination of calculation of the following information concerning the injection and confining zone(s):

(1) Fracture Pressure • Date, time, and type of formation integrity test

performed (e.g., step-rate test, leak-off test, fracture

gradient test);

• Test conditions, graphs or tables of data, and

interpretation; and

• Contractor’s information if applicable.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

• Submitted as part of the permit

application following the issuance of

the construction permit and prior to

authorization of the injection operation

as required under 40 CFR 146.82(c)(4)

and (c)(7)

• Retained throughout the life of the GS

project and 10 years following site

closure as required under 40 CFR

146.91(f)(1)

(2) Other physical chemical 

characteristics of injection and 

confining zone(s) 

• Updates on a number of geologic characteristics

(e.g., geomechanical properties, porosity and

permeability, bulk chemistry), some of which may be

provided with the log analyst’s report;

• Any relevant information regarding tests performed,

including any limitations to the data; and

• Any new site characterization information that is

relevant to the operation.

(3) Physical and chemical • Any analyses performed on fluids obtained from the
Draft UIC Program Class VI Well Recordkeeping, A-39 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

characteristics of formation 

fluids in injection zone

injection zone for the parameters established in the 

formation testing program; and

• A description of the sampling method employed, any

relevant laboratory results, and any limitations to the 

data such as contamination or representativeness.

40 CFR 146.87(e) Upon completion, but prior to operation, verifying hydrogeologic characteristics of the injection zone(s) by conducting:

(1) A pressure fall-off test • The date and time of shut-in, and the injection rate

and pressure prior to shut-in.

• Status of off-set wells, if applicable (either constant

injection pressure and rate or shut-in time).

• Whether bottomhole or surface pressure

measurements were used (or both) and depths of

bottomhole pressure and temperature.

• Records of gauges (if they are lowered and raised)

and gauge calibration.

• Raw data collected during the fall-off test.

• Plot of change in pressure as a function of time, as

well as a graph of temperature. This may be provided

for the time period prior to the test as well as the

duration of the test.

• Any temperature anomalies and whether they

correspond to pressure anomalies.

• Log-log and semi-log diagnostic plots of observed

pressure and time.

• Calculated formation characteristics (i.e.,

transmissivity, well skin factor), and comparison to

previous tests and to values used in computational

modeling and AoR delineation.

• Identification of software used to analyze the data.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

• Submitted as part of the permit

application following the issuance of

the construction permit and prior to

authorization of the injection operation

as required under 40 CFR 146.82(c)

• Retained throughout the life of the GS

project and 10 years following site

closure as required under 40 CFR

146.91(f)(1)

• Required under 40 CFR 146.82(c)(4) and

(c)(7)

• Pressure fall-off test to be conducted at

least once every five years or at a

frequency determined by the UIC

Program Director as required under 40

CFR 146.90(f), and results to be

submitted in the semi-annual report as

required under 40 CFR 146.91(a)

• Data collected and submitted in the

semi-annual report to be retained 10

years after collection as required under

40 CFR 146.91(f)(3)

(2) A pump test • Information on the test methods (e.g., pumping rate,

frequency of measurements);
Draft UIC Program Class VI Well Recordkeeping, A-40 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Data Element

•

•

•

Potential Submittals

Raw data;

The method for analyzing data, any limitations to the 

method and any software programs used; and

Results (hydraulic conductivity, transmissivity), and 

relevant graphs.

Anticipated Data Timing & Frequency Format

(3) Injectivity test •

•

•

•

Test parameters (injection test rates, durations of 

steps, pressures, and volumes);

Raw data;

Methods or software for analyzing data;

Results (injectivity, reservoir pressure, skin factor), 

and any limitations to the data. 

(f) A schedule of testing activities 30 • Schedule of testing activities • Tabular Data • Submitted 30 days prior to the first test;

days prior to conducting the first or 30 days prior to the next test along

test and any changes to the the any changes under 40 CFR

schedule 30 days prior to the next 146.87(e)

scheduled test.

INJECTION-PHASE ACTIVITIES

40 CFR 146.88 Injection well operating requirements

40 CFR 146.88(e)

Installation and use of:

(1) Continuous recording devices to 

detect divergence beyond 

permitted ranges and/or gradients 

specified in the permit:

• Injection pressure

• Injection rate of the carbon

dioxide stream

• Injection volume and/or mass

of the carbon dioxide stream

• Temperature of the carbon

•

•

•

•

•

Monthly average, maximum, and minimum values 

for injection pressure;

Monthly average, maximum, and minimum values 

for flow rate and volume;

Monthly average, maximum, and minimum values 

for annular pressure;

A description of any event that exceeds operating 

parameters for annular pressure or injection 

pressure that are submitted with permit application 

under 40 CFR 146.82(a)(7);

Monthly volume (mass) of carbon dioxide injected 

over the reporting period and cumulatively for the 

• A combination

of PDF and

tabular data

•

•

Continuous measurements, submitted 

as part of the semi-annual reports as 

required under 40 CFR 146.90(b) and 

146.91(a)

Retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)
Draft UIC Program Class VI Well Recordkeeping, A-41 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

dioxide stream

• Pressure on the annulus

between the tubing and the 

long string casing

• Annulus fluid volume

(2) Alarms and automatic surface 

shut-off systems, or down-hole 

shut-off systems if required by the 

Director for onshore wells or, 

other mechanical devices that 

provide equivalent protection

(3) Alarms and automatic down-hole 

shut-off systems for wells located 

offshore

•

•

project; and

Monthly volume of annulus fluid added; and

A description of any event which triggers a shut-off 

device and the response taken. 

40 CFR 146.88(f)

If a shutdown is triggered or a loss of 

mechanical integrity is discovered:

(1) Cease of injection;

(2) A determination of whether 

there may have been a release 

of the injected carbon dioxide

stream or formation fluids into 

any unauthorized zone(s);

(3) Notification within 24 hours;

(4) Restoring and demonstrating 

mechanical integrity prior to 

resuming injection; and

(5) Notification to the Director 

including the date/time of 

resuming injection. 

•

•

•

•

A 24-hour notification of the incident;

A description of the determination if a release of

carbon dioxide into an unauthorized zone occurred;

A description of activities to restore and 

demonstrate mechanical integrity, including raw data

for logging/testing as described under 40 CFR 146.87; 

and

A notification of planned schedule for resuming 

injection activities.

• A combination

of PDF and/or

tabular data

•

•

•

•

Notification of incident submitted 

within 24 hours under 40 CFR146.91(c)

Notification for any planned testing of 

the injection well submitted 30 days 

prior to the testing under 40 CFR 

146.91(b)

Reports of any planned testing 

submitted within 30 days of conducting 

the testing under 40 CFR 146.91(d)

All retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.89 Mechanical integrity

40 CFR 146.89(b) See 40 CFR 149.88(e) above. • A combination • Continuous measurements, submitted
Draft UIC Program Class VI Well Recordkeeping, A-42 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

Continuous monitoring following an of PDF and as part of the semi-annual reports as 

initial pressure test as specified in 40 tabular data required under 40 CFR 146.90(b) and 

CFR 146.88(e) for: 146.91(a)

• injection pressure; • Retained 10 years after collection as

• injection rate; required under 40 CFR 146.91(f)(3)

• injected volumes;

• pressure on the annulus between

tubing and long string casing; and

• annulus fluid volume

40 CFR 146.89(c)

At least once per year, one of the 

following methods will be used:

• An approved tracer survey, or

• A temperature or noise log

See 40 CFR 149.87(a)(4)(iii) above. •

•

A combination 

of PDF and 

tabular data 

Log results may 

also be

submitted in 

LAS format

•

•

•

Conducted after drilling, construction, 

and completion of the well and 

interpretations submitted as part of the 

well log analyst’s report in the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)(4), 

(7), and (8)

Information submitted in the permit 

application is to be retained throughout 

the life of the GS project and 10 years 

following site closure as required under 

40 CFR 146.91(f)(1)

During the injection phase, conducted, 

40 CFR 146.89(d)

If required by the Director, at a 

frequency specified in the testing and 

monitoring plan required at 40 CFR 

146.90, a casing inspection log must 

be run 

See 40 CFR 149.87(a)(4)(iv) above. • A combination

of PDF and

tabular data

40 CFR 146.89(e) To be determined by the UIC Program Director. • A combination

Any other test to evaluate mechanical of PDF and if required by the UIC Program Director, 

integrity required by the Director and tabular data at a frequency specified in the Testing 

approved by the Administrator and Monitoring Plan (at least once per 

year as required under 40 CFR 

146.90(e)). Resulting reports to be 

submitted within 30 days of conducting

the testing as required under 40 CFR 

146.91(b) and in the semi-annual 

40 CFR 146.89(f)

The results of mechanical integrity 

tests including a description of the 

test(s) and the method(s) used

See 40 CFR 146.87(a) above •

•

A combination 

of PDF and 

tabular data

Log results may 

also be
Draft UIC Program Class VI Well Recordkeeping, A-43 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

submitted in 

LAS format

•

report as required under 40 CFR 

146.91(a).A notification to be 

submitted 30 days prior to the planned 

testing as required under 40 CFR 

146.91(d) 

Information submitted in the semiannual report and notifications to be 

retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.89(g)

Any additional or alternative tests 

required by the Director

To be determined by the UIC Program Director. • A combination

of PDF and

tabular data

40 CFR 146.90 Testing and monitoring requirements

40 CFR 146.90(a) • A list of chemical parameters to be analyzed, • A combination • Submitted as part of the permit

Analysis of carbon dioxide stream with including constituents of the injectate, such as of PDF and application prior to the well

sufficient frequency to yield data carbon dioxide and other impurities (e.g., sulfur tabular data construction as required under 40 CFR

representative of its chemical and dioxide, hydrogen sulfide, nitrous oxides); and/or GIS- 146.82(a)(7)

physical characteristics •

•

•

•

•

•

•

A list of physical parameters to be

analyzed/measured, including temperature and

pressure;

A description of the sampling methodology, including

schematics of the monitoring equipment if

applicable;

Any analytical methods used and the name of the

certified laboratory performing analysis;

All sample dates and times;

All data resulting from carbon dioxide stream

analyses, including dates and any quality

assurance/quality control (QA/QC) samples;

Interpretation of the results with respect to

regulatory requirements and past results (if

applicable); and

Identification of data gaps.

compatible

format

•

•

•

•

Update submitted as part of the permit

application prior to authorization for

injection as required under 40 CFR

146.82(c)(2)

Information submitted in the permit

application to be retained throughout

the life of the GS project and 10 years

following site closure as required under

40 CFR 146.91(f)(1)

Conducted during the injection

operation at a frequency specified in

the approved Testing and Monitoring

Plan, any changes in the results to be

submitted in the semi-annual report as

required under 40 CFR 146.91(a)(1)

Information submitted in the semiannual report to be retained until 10

years after site closure as required
Draft UIC Program Class VI Well Recordkeeping, A-44 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

under 146.91(f)(2)

40 CFR 146.90(b) 

Installation and use of continuous 

recording devices to monitor (as 

defined at 40 CFR 146.88(e)):

• Injection pressure

• Injection rate

• Injection volume

• Annulus pressure between the

tubing and the long string

casing

• Annulus fluid volume added

See 40 CFR 146.88(e) above. • A combination

of PDF and

tabular data

•

•

Continuous measurements, submitted 

as part of the semi-annual reports as 

required under 40 CFR 146.91(a)

Retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.90(c)

Corrosion monitoring of well materials 

for loss of mass, thickness, cracking, 

pitting and other signs of corrosion to 

meet the minimum standards set forth 

in 40 CFR 146.86(b)

•

•

•

•

Method of sampling (e.g., method for retrieval of 

coupons), including material from which coupons or 

loops are made. 

When coupon testing is performed, information on 

loss of mass, evidence for pitting corrosion, and 

corrosion rate in mils per year. 

When loops of pipe material are tested, loss of mass 

and any other information on corrosion (e.g., pitting) 

should be provided. 

If the UIC Program Director has required casing 

inspection logs to be run, the owner or operator 

should report the thickness of the casing, referencing 

the original casing thickness, as well as the locations 

of anomalies such as pits, scratches, and splits. Any 

changes from previous measurements should be 

noted. 

• A combination

of PDF and

tabular data

•

•

Conducted quarterly, submitted as part 

of the semi-annual reports as required 

under 40 CFR 146.91(a)

Retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.90(d)

Periodic monitoring data of the 

ground water quality and geochemical 

• A map showing the injection well and all monitoring

wells tested. The names or numbers of the

• A combination

of PDF and

• Conducted during the injection

operation at a frequency specified in
Draft UIC Program Class VI Well Recordkeeping, A-45 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

changes above the confining zone(s) 

or additional identified zones •

•

•

•

•

monitoring wells should be clearly indicated.

Records of calibration of field equipment where 

appropriate.

Notes on field procedures and values for parameters 

measured in the field (e.g., fluid pressure in the well, 

notes on well purging, temperature measurement, 

redox potential, pH, and specific conductivity).

Analytical data, including results, methods used, and 

data for QA/QC samples (matrix spikes, duplicates, 

field blanks, equipment rinsate).

Interpretive analysis (e.g., using piper or stiff 

diagrams, time series graphs, isopleth maps).

Any information specific to ground water monitoring 

in the first USDW below the injection zone for 

owners or operators operating under injection depth 

waivers. 

•

tabular data 

and/or GIScompatible 

format

•

the approved Testing and Monitoring 

Plan, and results to be submitted in the 

semi-annual report as required under 

40 CFR 146.91(a)(1) 

Information submitted in the semiannual report to be retained 10 years 

after collection as required under 40 

CFR 146.91(f)(3)

(1) The location and number of 

monitoring wells based on 

injection rate and volume, 

geology, the presence of artificial 

penetrations and other factors 

(2) The monitoring frequency and 

spatial distribution of monitoring 

wells based on baseline 

geochemical data collected under 

40 CFR 146.86(a)(6) and any 

modeling results in the AoR 

required by 40 CFR 146.84(c) 

40 CFR 146.90(e) See 40 CFR 89(c) and (d) above. • A combination • Conducted after drilling, construction,

A demonstration of external of PDF and and completion of the well and

mechanical integrity (as defined at 40 tabular data interpretations submitted as part of the

CFR 146.89(c)) at least once per year • Log results may well log analyst’s report in the permit

until the injection well is plugged, and also be application following the issuance of

if required by the Director, a casing submitted in the construction permit and prior to

inspection log pursuant to 40 CFR LAS format authorization of the injection operation

146.89(d) as required under 40 CFR 146.82(c)(4),

(7), and (8)

• Information submitted in the permit

application is to be retained throughout

the life of the GS project and 10 years

following site closure as required under

40 CFR 146.91(f)(1)

• During the injection phase, conducted,

if required by the UIC Program Director,

at a frequency specified in the Testing
Draft UIC Program Class VI Well Recordkeeping, A-46 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

and Monitoring Plan (at least once per 

year). Resulting reports to be submitted 

within 30 days of conducting the 

testing as required under 40 CFR 

146.91(b) and in the semi-annual 

report as required under 40 CFR 

146.91(a).A notification to be 

submitted 30 days prior to the planned 

testing as required under 40 CFR 

146.91(d)

Information submitted in the semiannual report and notifications to be 

retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.90(f)

A pressure fall-off test at least once 

every five years unless more frequent 

testing is required by the Director.

See 40 CFR 87(e)(1) above. • A combination

of PDF and

tabular data

•

•

•

•

Submitted as part of the permit 

application following the issuance of 

the construction permit and prior to 

authorization of the injection operation 

as required under 40 CFR 146.82(c)(4) 

and (c)(7)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

Pressure fall-off test to be conducted at 

least once every five years or at a 

frequency determined by the UIC 

Program Director as required under 40 

CFR 146.90(f), and results to be 

submitted in the semi-annual report as 

required under 40 CFR 146.91(a)

Data collected and submitted in the 

semi-annual report to be retained 10 
Draft UIC Program Class VI Well Recordkeeping, A-47 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

years after collection as required under 

40 CFR 146.91(f)(3)

40 CFR 146.90(g)

Testing and monitoring results for 

tracking extent of carbon dioxide

plume and presence or absence of 

elevated pressure (e.g., the pressure 

front):

(1) Direct methods in the injection 

zone

(2) Indirect methods unless 

Director determines, based on 

site-specific geology, that these 

methods are inappropriate

Direct methods in the injection zone for pressure front 

tracking:

• A map showing the injection well and all monitoring

wells tested. The names or numbers of the 

monitoring wells should be clearly indicated.

• Wellhead and measuring point elevations.

• The dates and times of pressure measurements and

pressure values.

• Records of calibration of pressure transducers.

• Data presented as time series graphs for each well to

show temporal changes.

• An isobar map may be submitted if data are available

from a sufficient number of wells.

• The threshold value for the pressure front should be

referenced to help put pressure readings into

context.

• Comparison of data with modeling predictions.

• Any information specific to pressure monitoring in

the first USDW below the injection zone for owners

or operators operating under injection depth

waivers.

If approved and/or required by the UIC Program 

Director, direct methods in the injection zone for plume 

tracking:

• Geochemical monitoring of the plume by direct

sampling and analyzing for:

o Change in TDS levels;

o Change in signature of major cations and anions,

and leached constituents;

o Increasing carbon dioxide concentrations;

o Change in pH;

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Conducted at a frequency determined 

in the Testing and Monitoring Plan as 

required under 40 CFR 146.90, and 

results to be submitted in the semiannual report as required under 40 CFR 

146.91(a)

Data collected and submitted in the 

semi-annual report to be retained 10 

years after collection as required under 

40 CFR 146.91(f)(3)
Draft UIC Program Class VI Well Recordkeeping, A-48 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o Increasing concentrations of injectate impurities;

and

o Increased reservoir pressure and/or static water

level.

Indirect methods (e.g., seismic surveys):

• A map or diagram showing the locations of the

survey equipment during the test.

• Raw data collected during the survey if required by

the UIC Program Director.

• Estimated pore pressures if data from a seismic

survey were used for pore pressure determination.

• Final images resulting from data processing.

• Data interpretation, including position of the

separate-phase carbon dioxide plume and/or

pressure front, fluid leakage from the injection zone,

and any out-of-zone anomalies that require followup.

• A comparison of the measured position of the

carbon dioxide plume with model predictions or

previous measurements corresponding to the time of

the survey.

• Any information specific to carbon dioxide plume

tracking by owners or operators operating under

injection depth waivers.

40 CFR 146.90(h)

Surface air monitoring and/or soil gas 

monitoring to detect carbon dioxide

movement that could endanger a 

USDW if directed

• Surface air and/or soil gas

monitoring based on potential 

risks to USDWs within AoR

• Monitoring frequency and spatial

•

•

•

•

A map showing the locations of the equipment 

and/or sampling stations.

Notes on field procedures (e.g., vacuum-volume 

purge tests, sample probe purging, and sampling 

rates) and equipment calibration records where 

appropriate.

Raw data, including QA/QC sampling.

Interpretive maps and/or graphs of carbon dioxide 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Conducted at a frequency determined 

in the Testing and Monitoring Plan as 

required under 40 CFR 146.90, and 

results to be submitted in the semiannual report as required under 40 CFR 

146.91(a)

Data collected and submitted in the 

semi-annual report to be retained 10 

years after collection as required under 
Draft UIC Program Class VI Well Recordkeeping, A-49 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

distribution determined by 

baseline data with a description of 

how monitoring will yield useful 

information on AoR delineation 

and/or compliance with 40 

CFR144.12 of this chapter

trends. 40 CFR 146.91(f)(3)

40 CFR 146.90(i)

Any additional monitoring, as required 

by the Director, to support, upgrade, 

and improve computational modeling 

of the AoR (40 CFR 146.84(c)) and to 

determine compliance with standards 

under 40 CFR 144.12

To be determined by the UIC Program Director. • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Conducted at a frequency determined 

in the Testing and Monitoring Plan as 

required under 40 CFR 146.90, and 

results to be submitted in the semiannual report as required under 40 CFR 

146.91(a)

Data collected and submitted in the 

semi-annual report to be retained 10 

years after collection as required under 

40 CFR 146.91(f)(3)

40 CFR 146.90(j)

Periodic reviews of the testing and 

monitoring plan to incorporate 

monitoring data, operational data (40 

CFR 146.88), and the most recent AoR 

reevaluation (40 CFR 146.84(e)); 

submission of an amended testing or 

monitoring plan or demonstration of 

no amendment needed:

(1) within one year of an AoR 

reevaluation

(2) following any significant 

changes to the facility

(3) when required by the Director

•

•

Revised plan; or

A demonstration of no revision need.

• PDF •

•

To be submitted:

o Within one year of AoR reevaluation

o Following significant changes to the

facility, on a schedule determined

by the UIC Program Director

o When required by the UIC Program

Director, as noted under 40 CFR

146.90(j)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.90(k)

A quality assurance and surveillance 

• The quality assurance and surveillance plan. • PDF • Submitted as part of Testing and

Monitoring Plan and updates under 40
Draft UIC Program Class VI Well Recordkeeping, A-50 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

plan for all testing and

requirements

monitoring 

•

CFR 146.90(k)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.91 Reporting requirements

40 CFR 146.91(a)

Semi-annual reports containing:

(1) Any changes to physical, 

chemical and other relevant 

characteristics of carbon dioxide

stream from proposed 

operating data 

(2) Monthly average, maximum and 

minimum values for injection 

pressure, flow rate and volume, 

and annular pressure 

(3) A description of any event that 

exceeds operating parameters 

for annulus pressure or injection 

pressure 

(4) A description of any event 

which triggers a shutdown (as 

defined at 40 CFR 146.88(e))

(5) Monthly volume (mass) of

carbon dioxide stream injected 

over reporting period and 

project cumulatively 

(6) Monthly annulus fluid volume 

added

(7) Results of monitoring (as 

defined at 40 CFR 146.90) 

See 40 CFR 146.90 above. • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted semi-annually as required 

under 40 CFR 146.91(a)

All data to be retained for 10 years after 

collection, except data on changes to 

physical, chemical and other relevant 

characteristics of carbon dioxide that is 

to be retained until 10 years after site 

closure
Draft UIC Program Class VI Well Recordkeeping, A-51 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

40 CFR 146.91(b)

A report, within 30 days the result of

(1) Periodic MITs 

(2) Any well workover 

(3) Any other test of the injection 

well required by the Director

See 40 CFR 146.87, 146.88, and 146.89. • A combination

of PDF and

tabular data

•

•

Within 30 days of results as required 

under 146.91(b)

40 CFR 146.91(c)

A report, within 24 hours of:

(1) Any evidence that the injected

carbon dioxide and associated 

pressure front may cause an 

endangerment to a USDW 

(2) Any noncompliance with a 

permit condition, or malfunction 

of the injection system, which 

may cause fluid migration into or 

between USDWs 

(3) Any triggering of a shut-off 

system

(4) Any failure to maintain 

mechanical integrity 

(5) Pursuant to compliance with the 

requirement at 40 CFR 146.90(h) 

for surface air and/or soil gas 

monitoring or other monitoring 

technologies, any release of 

carbon dioxide to the 

atmosphere or biosphere.

See 40 CFR 146.90. • A combination

of PDF and

tabular data

• Within 24 hours as required under

146.91(c)

40 CFR 146.91(d)

Notifications to the Director 30 days in 

advance of:

(1) Any planned well workover

See 40 CFR 146.88 and 146.89. • A combination

of PDF and

tabular data

• 30 days in advance as required under

40 CFR 146.91(d)
(2) Any planned stimulation 

activities, other than stimulation 

for formation testing under 40 

CFR 146.82

(3) Any other planned test of the 

injection well

Data Element Potential Submittals Anticipated Data

Format Timing & Frequency

40 CFR 146.91(e)

All required reports, submittals, and notifications under subpart H must be submitted to an electronic reporting system

40 CFR 146.91(f)

Records shall be retained by the owner or operator for the time specified until required by the Director

POST-INJECTION ACTIVITIES

40 CFR 146.92 Injection well plugging

40 CFR 146.92(b)

Well plugging plan as a part of the 

permit application, must include:

(1) Bottomhole reservoir pressure

(2) Testing methods and results of 

external mechanical integrity as 

specified in 40 CFR 146.89

(3) Type and number of plugs

(4) The placement of each plug 

including the elevation of the 

top and bottom of each plug

(5) The type, grade and quantity of 

material to be used in plugging

(6) The method of placement of 

the plugs

See 40 CFR 146.82(a)(16). • A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.92(c)

Notice of intent to plug, pursuant to 

40 CFR 146.91(e), at least 60 days 

• Notice of Intent to Plug. • PDF • 60 days before plugging as required

under 40 CFR 146.92(c)

Draft UIC Program Class VI Well Recordkeeping, A-52 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators
Draft UIC Program Class VI Well Recordkeeping, A-53 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

before plugging of a well and revised 

well plugging plan if any changes have 

been made to the original well 

plugging plan

40 CFR 146.92(d)

Certified plugging report, pursuant to 

40 CFR 146.91(e), within 60 days after 

plugging

Plugging Report, including:

• Final pressure reading from downhole pressure

transducer if applicable;

• Notes on any procedures prior to flushing (e.g.,

removal of packers);

• Fluid used to flush the well and fluid volume used

• Flushing procedures (e.g., injection of fluid into

tubing and/or annulus);

• Notes on removal of well components (e.g., injection

tubing) and obstructions after flushing;

• External mechanical integrity test;

o Conditions prior to test including date and time

and time elapsed since flushing;

o The numbers and locations of measurement

stations;

o The results of each log or test and the

interpretation of results provided by the log

analyst; and

o Where the well fails a mechanical integrity test, a

description of remedial actions taken.

Submitted information may include:

• Type and number of plugs installed;

• The placement of the plugs, including top and

bottom elevations and formations opposite which

they are emplaced;

• Cement type used; and

• Method of emplacement.

• PDF •

•

Within 60 days of plugging as required 

under 40 CFR 146.92 (d) 

Retained for 10 years following site 

closure pursuant to 40 CFR 146.91(f)(4)
Draft UIC Program Class VI Well Recordkeeping, A-54 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Data Element

40 CFR 146.93 Post-injection site care and site closure

Anticipated Data Potential Submittals Timing & Frequency Format

40 CFR 146.93(a)(1)

The post-injection site care and site 

closure plan as a part of permit 

application

See 40 CFR 146.82(a)(17) • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a).

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c).

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.93(a)(2)

The post-injection site care and site 

closure plan must include:

(i) The pressure differential between 

pre-injection and predicted postinjection pressures in injection 

zone(s)

(ii) The predicted position of the

carbon dioxide plume and 

associated pressure front at site 

closure as demonstrated in the 

AoR evaluation under 40 CFR 

146.84(c)(1)

(iii)A description of post-injection 

monitoring location, methods, 

and proposed frequency

(iv)A proposed schedule for 

submitting post-injection site care 

monitoring results to the Director 

pursuant to 40 CFR 146.91(e)

40 CFR 146.93(a)(3) • A history of monitoring results for downhole • A combination • Upon cessation of injection as required

Amended post-injection site care and pressures, pressures measured at monitoring wells in of PDF and under 40 CFR 146.93(a)(3)

site closure plan upon cessation of the injection zone and above the confining zone, tabular data

injection, or demonstration of no pressure fall-off tests, and the results of geophysical

amendment need monitoring, and how these support a determination

that changes to the post-injection monitoring is

appropriate. These data are submitted in detail as
Draft UIC Program Class VI Well Recordkeeping, A-55 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data

Format Data Element Potential Submittals Timing & Frequency

•

•

•

•

•

•

part of the monitoring requirements during the 

operational phase. 

A history of modeling results and how these support 

a determination that changes to the post-injection 

monitoring is appropriate. Interpretive narrative may 

be provided, including a description of any changes 

that may have been made in the modeling approach, 

choice of model, or assumptions.

A discussion of model predictions of pressure with 

time. 

A discussion of historical monitoring and modeling 

results describing how the monitoring results have 

generally tracked with respect to modeling 

predictions. 

A discussion of how the most recent modeling 

predictions compare with model predictions used at 

the time of formulation of the PISC and Site Closure 

Plan. 

The revised predicted timeframe for pressure decline 

within the injection zone.

A comparison of anticipated monitoring frequency 

with predicted rate of movement of plume and 

predicted rate of pressure decay.

146.93(a)(4)

A modified post-injection site care and 

site closure plan must be resubmitted 

for approval by the Director within 30 

days of any changes

• Revised plan. • A combination

of PDF and

tabular data

and/or GIScompatible

format

• Within 30 days of any changes As

required under 40 CFR 146.93(a)(4)

40 CFR 146.93(b)

Monitoring position of carbon dioxide

plume and pressure front

See 40 CFR 146.90 above. • A combination

of PDF and

tabular data

• As specified in the approved postinjection site care plan under 40 CFR

146.93(b)
Draft UIC Program Class VI Well Recordkeeping, A-56 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data

Format Data Element Potential Submittals Timing & Frequency

and/or GIScompatible 

format

• Retained for 10 years following site

closure pursuant to 40 CFR 146.91(f)(4)

40 CFR 146.93(b)(3)

Non-endangerment demonstration

•

•

•

•

A summary of pressure monitoring data. These data 

will be collected and submitted pursuant to the 

approved PISC and Site Closure Plan. 

A summary of ground water quality monitoring data 

that demonstrates that water quality both within the 

injection zone and above the confining zone has 

stabilized and that there are no water quality 

changes above the confining zone that suggest 

leakage of carbon dioxide or brine. 

A summary of indirect monitoring results, including 

images, that shows that migration of the carbon 

dioxide plume has stabilized.

The results of any updated modeling demonstrating 

anticipated continued pressure decline and the 

timeframe in which pressure would no longer be 

able to force fluids into any USDWs. 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

• Prior to authorization for site closure as

required under 40 CFR 146.93(b)(3)

40 CFR 146.93(c)

Demonstration of alternative 

injection site care timeframe

postSee 40 CFR 146.82(a)(18) above. • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

•

Submitted as part of the permit 

application prior to the well 

construction under 40 CFR 146.82(a).

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c).

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.93(d)

Notice of intent for site closure and if 

any changes have been made to the 

• Notice of intent for site closure • PDF • 120 days before site closure as required

under 40 CFR 146.93(d)
Draft UIC Program Class VI Well Recordkeeping, A-57 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

original post-injection site care and 

site closure plan, a revised plan will be 

submitted. 

40 CFR 146.93(f)

Site closure report 

(1) Documentation of injection 

and monitoring well plugging 

as specified in 40 CFR 146.92 

including a survey plat

(2) Documentation of 

appropriate notification and 

information to State, local, 

and Tribal authorities

(3) Records reflecting nature, 

composition and volume of

carbon dioxide stream 

•

•

•

•

•

•

•

•

•

•

•

•

•

Documentation of appropriate injection and 

monitoring well preparation and plugging, required 

at 40 CFR 146.93(f)(1). 

A copy of a survey plat that has been submitted to 

the local zoning authority designated by the UIC 

Program Director is required [40 CFR 146.93(f)(1)]. A 

copy must also be submitted to the Regional 

Administrator of the appropriate EPA Regional 

Office. The plat must indicate the location of the 

injection well relative to permanently surveyed 

benchmarks. 

Notification of authorities is required at 40 CFR 

146.93(f)(2), relevant information may include:

Names of entities being informed (i.e., State, local, 

Tribal agency or authority) 

Copies of letters sent to accompany information. 

Contact information for owner or operator.

Dates of operation of the project and dates of postinjection phase.

Maps of area of review and the locations of injection 

and monitoring wells.

Depth of injection well.

Name and depth interval of formation containing the 

injection zone.

Names and depth intervals of upper (and lower) 

primary confining zones.

Pressure in confining zones and monitored zones 

above the confining layer at the time of site closure.

Fluid composition in the injection zone and above 

• A combination

of PDF and

tabular data

•

•

Within 90 days of site closure as 

required under 40 CFR 146.93(f)

Retained for 10 years following site 

closure pursuant to 40 CFR 146.91(f)(4)
Draft UIC Program Class VI Well Recordkeeping, A-58 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

•

•

the injection zone at the time of site closure.

If available, an image and map of the most recent 

geophysical survey indicating the extent of the 

carbon dioxide plume. 

Records reflecting the nature, composition, and 

volume of the carbon dioxide stream, as required at 

40 CFR 146.93(f)(3). 

Historical graphs or tabular results of injectate 

analyses.

Historical graphs or tabular data showing the total 

volume of injectate at the time of cessation of 

injection.

40 CFR 146.94 Emergency and remedial response

40 CFR 146.94(a)

An emergency and remedial response 

plan 

See 40 CFR 146.82(a)(19). • A combination

of PDF and

tabular data

•

•

•

Submitted as part of the permit 

application prior to the well 

construction Under 40 CFR 146.82(a)

Update submitted as part of the permit 

application prior to authorization for 

injection under 40 CFR 146.82(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.94(b)

In case of a possible endangerment to 

a USDW:

(1) Immediate cease of injection

(2) Identification and 

characterization of any 

release

(3) Notification to the Director 

See 40 CFR 146.91(c) and 146.88(f). • A combination

of PDF and/or

tabular data

and/or GIScompatible

format

•

•

•

Notification of incident submitted 

within 24 hours under 40 CFR146.91(c)

Notification for any planned testing of 

the injection well submitted 30 days 

prior to the testing under 40 CFR 

146.91(b)

Reports of any planned testing 
Draft UIC Program Class VI Well Recordkeeping, A-59 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(4)

within 24 hours

Implementation of the 

emergency and remedial 

response plan

•

•

submitted within 30 days of conducting 

the testing under 40 CFR 146.91(d)

All retained 10 years after collection as 

required under 40 CFR 146.91(f)(3)

40 CFR 146.94(c)

A demonstration that the injection 

operation will not endanger USDWs

40 CFR 146.94(d)

Periodic reviews of the emergency 

and remedial response plan

• Revised plan. • PDF • At least every five years, or as required

by the UIC Program Director under 40

CFR 146.94(d)

40 CFR 146.95 Class VI injection depth waiver requirements

40 CFR 146.95 (a)

A waiver application report for seeking 

a waiver of requirement to inject 

below lowermost USDW, in 

conjunction with information 

submitted under 40 CFR 146.82, 

including:

• The waiver application report 

information outlined below.

including the • PDF •

•

Submitted as a supplement to, and at 

the same time as, the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(1) A demonstration that injection • A demonstration of the suitability of injection • A combination • Submitted in the waiver application

zone is laterally continuous, is not zone(s): of PDF and report at the same time as the permit

a USDW and is not hydraulically o Geologic maps and cross sections showing the tabular data application under 40 CFR 146.95(a)

connected to USDW, does not formations comprising the injection zone(s) and and/or GIS- • Retained throughout the life of the GS

outcrop, and has adequate their position relative to all USDWs that lie below compatible project and 10 years following site

injectivity, volume, sufficient or between those formations; format closure as required under 40 CFR

porosity, and appropriate o Geologic maps and cross sections showing that 146.91(f)(1)

geochemistry the injection zone does not outcrop and is not

hydraulically connected to formations containing

USDWs within the AoR;

o Results of any additional seismic surveys

providing the mechanical, geometric, and

material properties of the injection zone(s);
Draft UIC Program Class VI Well Recordkeeping, A-60 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o Lithology and mineralogy of the formation;

o Petrophysical measurements on core samples

(e.g., porosity, permeability);

o Chemical analyses of formation fluids; and

o Carbon dioxide storage volume calculations and

any supporting data.

• An evaluation of alternative sites:

o Geologic maps and cross sections;

o Lithologic data and descriptions of how any

formations that may appear to be suitable

injection zones would not allow safe injection

and storage of the carbon dioxide.

See 40 CFR 146.82 above.

(2) A demonstration that injection 

zone is bounded by laterally 

continuous, impermeable 

confining units above and below, 

and that confining units are free 

of transmissive faults and 

fractures

•

•

A demonstration of the suitability of confining 

zone(s):

o Cross sections presenting the presence of

continuous confining layers above and below the

injection zone(s), showing the confining layers in

relations to all USDWs, and presenting the

thickness of the confining units;

o A demonstration that there are no transmissive

faults and fractures that transect confining zones

or that any faults or fractures identified are

sealed and do not breach the confining units;

o Petrophysical measurements on core samples

(e.g., porosity, permeability)

o Lithology and mineralogy of the confining units;

and

o Results of any additional seismic surveys

providing the mechanical, geometric, and

material properties of the confining zones.

A demonstration of the regional fracture or fault 

system:

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-61 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

o An evaluation of the sealing properties of any

major faults that penetrate the confining zones,

including an indication of the method used for

making the evaluation;

o Geologic maps and cross sections, or geophysical

imaging data that identify regional fracture and

fault system; and

o Any additional data used to characterize the site

in permit application that supports the

evaluation of regional faults and fractures, and

their transmissivity.

See 40 CFR 146.82 above.

(3) A demonstration, using 

computational modeling, that 

USDWs above and below 

injection zone will not be 

endangered as a result of fluid 

movement, conducted in 

conjunction with the AoR 

determination (40 CFR 146.84) 

and is subject to requirements 

under 40 CFR 146.84(c) and 40 

CFR 146.84(e)

•

•

•

•

•

Attributes of the code used to create the 

computational model (e.g., code name, name of the 

developing organization, governing equations 

employed, simplifying assumptions);

Additional input parameters beyond other Class VI 

AoR delineations (e.g., parameters, such as 

formation elevation and thickness, intrinsic 

permeability, porosity, and characteristic curve 

parameters, pertaining to describing the lower 

confining zone, lowermost USDW, and any zones 

intermediary to the lower confining zone and 

lowermost USDW);

The conceptual model accounting for additional 

formations above and below the injection zone(s) 

and all supporting data (e.g., structural geology 

including folding and fracture and fault systems);

Modeling results showing the vertical fluid migration 

and pressure changes above and below the injection 

zone as well as the lateral extent of the AoR;

A description of model’s initial and boundary 

(vertical and lateral) conditions and layers as 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-62 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

•

•

•

•

•

presented on maps and cross sections;

A description of any additional information on 

numerical space discretization, solution 

methods/options employed, computational 

parameters, and time-stepping information;

Additional constitutive relationships of the 

permeable medium (e.g., relative permeabilitysaturation relationship) and a description of how 

they were determined;

Values of additional model parameters and a 

description of how model parameters were 

determined based on site characterization; and

If requested by the UIC Program Director, raw model 

input and output files. 

See 40 CFR 146.84 above.

(4) A demonstration that well design 

and construction in conjunction 

with waiver will ensure isolation 

of the injectate in lieu of the 

requirements at 40 CFR 

146.86(a)(1) and will meet all well 

construction requirements in 40 

CFR 146.95(f)

•

•

•

Construction plans and procedures that demonstrate 

that the wellbore will not act as a conduit for fluid 

movement out of the injection zone and indicate the 

placement and location of all casing strings in 

relation to the injection zone, upper and lower 

confining zones, and all USDWs above and below the 

injection zone;

Complete construction schematics, indicating the 

depth, thickness, and materials used in all casings 

and cement; the type of cement used; and the 

placement of cement along the entire lengths of 

both the surface and long string casings;

A demonstration of the effectiveness of the casing 

and cement design along with a description of the 

intended cementing procedures indicating how 

cement will be circulated to the surface and any 

special considerations for weak geologic or overpressured zones; 

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-63 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

• Strength calculations for casing and tubing; and

• Information on the compatibility of materials used

for cement, casing, tubing, and packer with carbon

dioxide and formation fluids.

See 40 CFR 146.86 above.

(5) A description of how monitoring 

and testing and any additional 

plans will be tailored to GS 

project to ensure protection of 

USDWs above and below the 

injection zone(s)

• The description must, at least, include:

o Ground water quality monitoring above and

below the injection zone(s) (e.g., monitoring

parameters, frequency of sampling, depth of

monitoring) and planned locations for testing and

monitoring along with procedures to ensure

zonal isolation;

o Carbon dioxide plume and pressure front tracking

technologies to be employed to obtain data

below the lower confining zone; and

o Pressure monitoring above and below the

injection zone.

See 40 CFR 146.90 above.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(6) Information on location of all the 

public water supplies affected, 

reasonably likely to be affected, 

or served by USDWs in the AoR

•

•

•

•

•

•

•

Names and contact information for drinking water 

utilities within the AoR or that draw from USDWs 

that might be affected by the project;

Population served by drinking water utilities;

Number and locations of production wells and the 

aquifers from which they draw;

Average gallons per day (GPD) withdrawn by each 

drinking water utility;

Average GPD delivered by each drinking water utility;

Locations of private drinking water wells within the 

AoR; and

Maps showing aquifers being used and their 

relationship to the injection and/or storage 

formation.

• A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-64 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(7) Any other information requested 

by the Director to inform a

decision to issue waiver

To be determined by the UIC Program Director. • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1).

40 CFR 146.95 (b) To support the Regional Administrator’s decision on whether to grant a waiver of the injection depth requirements at 40 CFR40 CFR144.6, 

146.5(f), and 146.86(a)(1) of this chapter, the Director must:

40 CFR 146.95 (b)(1)

Consider the following information:

(i) Integrity of upper and lower 

confining units

See 40 CFR 146.95(a) above. • A combination

of PDF and

tabular data

and/or GIScompatible

format

•

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

(ii) Suitability of the injection zone See 40 CFR 146.95(a) above.

(iii) Potential capacity of geologic 

formation, accounting for the 

availability of alternative 

injection sites

See 40 CFR 146.95(a) above.

(iv) All other site characterization 

data, proposed emergency and 

remedial response plan, 

demonstration of financial 

responsibility

• A description of how the proposed Emergency and

Remedial Response Plan will address any

contamination that impacts USDWs above and below

the injection zone and a demonstration of sufficient,

additional financial responsibility to address any

contamination of all USDWs.

See 40 CFR 146.95(a), 146.82(a)(19), and 146.85 

above.

(v) Community needs, demands, 

and supply from drinking water 

resources

See 146.95(a) above.
Draft UIC Program Class VI Well Recordkeeping, A-65 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(vi) Planned needs, potential and/or 

future use of USDWs and nonUSDWs in the area

•

•

•

•

•

Anticipated population growth over the proposed life 

of the GS project in the region;

Anticipated land use changes during the operational 

phase of the project;

Locations of aquifers that are not currently used but 

that may be used in the future;

Future projections of water usage over 5, 10, and 20 

years, if available; and

Potential changes in water supply. 

(vii) Planned or permitted water, • Geologic maps and cross section showing all USDWs

hydrocarbon, or mineral above and below the injection zone;

resource exploitation potential • Names, thicknesses, and depths of all USDWs above

of proposed injection formation and below the injection in the region;

and other formations both • Any available chemical analyses of ground water in

above and below injection zone

•

•

•

•

•

•

USDWs;

Any available information on projected water

use/development of currently unused USDWs or

installation of new wells in currently used USDWs;

A map with the location of economically viable

deposits;

The depths and host formations of deposits;

Geologic maps and cross section of the region

showing information on resources;

Maps and descriptions of any past or current mining

or hydrocarbon recovery activities; including well

locations and API numbers; and

Information on whether future use of minerals and

hydrocarbons has been permitted and/or planned.

(viii)The proposed plan for securing • Condition of currently used water supply source,

alternative resources or treating including total capacity and existing treatment

USDW formation water in the facilities;

event of contamination related • Condition of currently used water distribution
Draft UIC Program Class VI Well Recordkeeping, A-66 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

to Class VI injection activity

•

•

systems, including contamination problems and 

potential for connection to an alternate water supply 

source; 

Capabilities of other regional water supply systems, 

including available excess capacity and ease of 

connection to the distribution system of the 

contaminated water supply system; and

Hydrogeology and hydrology of water resources 

currently supplying water and those that could 

potentially serve as a water supply.

(ix) Any other applicable 

consideration or information 

requested by the Director

To be determined by the UIC Program Director.

40 CFR 146.95 (b)(2)

Consultation with the PWSS Directors 

of all states and tribes having 

jurisdiction over lands within the AoR

• Any written documentation. • PDF •

•

Submitted in the waiver application 

report at the same time as the permit 

application under 40 CFR 146.95(a)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)

40 CFR 146.95 (b)(3)

Any written waiver-related 

information submitted by PWSS 

Director(s) to the (UIC) Director

40 CFR 146.95 (c)

Pursuant to requirements at 40 

CFR124.10 and as part of permit 

application for Class VI permit, the 

Director shall give public notice that 

waiver application has been 

submitted. The notice shall clearly 

state:

(1) Depth of proposed injection zone

(2) Location of injection well

• A public notice. • PDF •

•

After the waiver application submitted 

as required under 40 CFR 146.95(c)

Retained throughout the life of the GS 

project and 10 years following site 

closure as required under 40 CFR 

146.91(f)(1)
Draft UIC Program Class VI Well Recordkeeping, A-67 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

(3) Name and depth of all USDWs 

within AoR

(4) Map of the AoR

(5) Names of any public water 

supplies affected, reasonably likely to 

be affected, or served by USDWs in 

AoR 

(6) Results of UIC-PWSS consultation 

required under 40 CFR 146.95(b)(2)

40 CFR 146.95 (d)

Following the public notice, the 

Director shall provide information 

received through the waiver 

application process to the Regional 

Administrator

•

•

The waiver application report; and

Any other documentation.

• PDF • Following the public notice as required

under 40 CFR 146.95(d)

40 CFR 146.95 (e)

If a waiver is issued, within 30 days of 

waiver issuance, U.S. EPA 

headquarters shall post the following 

information on the Office of Water’s 

website:

(1) The depth of the proposed 

injection zone(s)

(2) The location of the injection well

(3) The name and depth of all USDWs

within the AoR

(4) A map of the AoR

(5) The names of any public water 

supplies affected, reasonably likely to 

be affected, or served by USDWs in 

the AoR

(6) The date of waiver issuance

• A website communication piece. • PDF • Within 30 days of waiver issuance as

required under 40 CFR 146.95(e)
Draft UIC Program Class VI Well Recordkeeping, A-68 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

40 CFR 146.95 (f) Upon receipt of a waiver, owner or operator must comply with:

(1) All requirements at 40 CFR 

146.84, 40 CFR 146.85, 40 CFR 

146.87, 40 CFR 146.88, 40 CFR 

146.89, 40 CFR 146.91, 40 CFR 

146.92, and 40 CFR 146.94

See 40 CFR 146.84, 40 CFR 146.85, 40 CFR 146.87, 40 CFR 146.88, 40 CFR 

146.89, 40 CFR 146.91, 40 CFR 146.92, and 40 CFR 146.94 above.

• Upon receipt of a waiver as required

under 40 CFR 146.95(f)

(2) Applicable requirements at 40 

CFR 146.86 and the following 

modified requirements:

(i) The owner or operator 

must ensure that Class VI

wells with a waiver are 

constructed and 

completed to prevent 

movement of fluids into 

any unauthorized zones 

including USDWs

(ii) The casing and cementing 

program must be 

designed to prevent the 

movement of fluids into 

any unauthorized zones 

including USDWs

(iii) The surface casing must 

extend through the base 

of the nearest USDW 

directly above the 

injection zone and 

cemented to the surface, 

or, at the Director’s 

discretion another 

formation above the 

See 40 CFR 146.95(a)(4) above. • Upon receipt of a waiver as required

under 40 CFR 146.95(f)
Draft UIC Program Class VI Well Recordkeeping, A-69 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

injection zone and below 

the nearest USDW above 

the injection zone

(3) Applicable requirements at 40 

CFR 146.90 and the following 

modified requirements;

(i) The owner or operator 

shall monitor 

groundwater quality, 

geochemical changes and 

pressure in the first 

USDWs immediately 

above and below 

injection zone

(ii) Testing and monitoring to 

track extent of carbon 

dioxide plume and 

presence or absence of 

elevated pressure

See 40 CFR 146.95(a)(5) above. • Upon receipt of a waiver as required

under 40 CFR 146.95(f)

(4) Applicable requirements at 40 

CFR 146.93 and modified postinjection site care monitoring 

requirements:

(i) The owner or operator 

shall monitor 

groundwater quality, 

geochemical changes, 

and pressure in USDWs 

immediately above and 

below injection zone

(ii) Testing and monitoring to 

track extent of the

See 40 CFR 146.93 above. • Format as

determined at

40 CFR 146.93

• Upon receipt of a waiver as required

under 40 CFR 146.95(f)
Draft UIC Program Class VI Well Recordkeeping, A-70 March 2013 

Reporting, and Data Management Guidance

for Owners and Operators

Anticipated Data 

Format Data Element Potential Submittals Timing & Frequency

carbon dioxide plume 

and presence or absence 

of elevated pressure

(5) Any additional requirements To be determined by the UIC Program Director. • Upon receipt of a waiver as required in

requested by Director 40 CFR 146.95(f)