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pdfSUPPLEMENTARY INFORMATION:
INFORMATION COLLECTION REQUEST
FOR THE
UNDERGROUND INJECTION CONTROL PROGRAM
OMB Control No. 2040-0042
EPA ICR No. 0370.21
Draft
August 16, 2007
TABLE OF CONTENTS
1. Identification of the Information Collection ............................................................................ 1
1(a) Title and Number of the Information Collection............................................................... 1
1(b) Short Characterization ....................................................................................................... 1
2. Need For and Use of the Collection ......................................................................................... 2
2(a) Need/Authority for the Collection..................................................................................... 2
2(b) Practical Utility/Users of the Data..................................................................................... 6
3. Nonduplication, Consultations, and Other Collection Criteria .............................................. 10
3(a) Nonduplication ................................................................................................................ 10
3(b) Public Notice ................................................................................................................... 10
3(c) Consultations ................................................................................................................... 10
3(d) Effects of Less Frequent Collection ................................................................................ 11
3(e) General Guidelines .......................................................................................................... 12
3(f) Confidentiality ................................................................................................................. 12
3(g) Sensitive Questions ......................................................................................................... 12
4. Respondents and Information Requested............................................................................... 13
4(a) Respondents/NAICS Codes............................................................................................. 13
4(b) Information Requested .................................................................................................... 13
5. Information Collected: EPA Activities, Collection Methodology, and Information
Management .............................................................................................................................. 22
5(a) State and Agency Activities ............................................................................................ 22
5(b) Collection Methodology and Management ..................................................................... 23
5(c) Small Entity Flexibility ................................................................................................... 25
5(d) Collection Schedule......................................................................................................... 28
6. Estimating the Burden and Cost of the Collection................................................................. 31
6(a) Respondent Burden.......................................................................................................... 31
6(b) Respondent Costs ............................................................................................................ 36
6(c) Agency Burden and Costs ............................................................................................... 37
6(d) Estimating Respondent Universe and Total Burden and Costs....................................... 38
6(e) Bottom Line Burden Hours and Costs............................................................................. 38
6(g) Burden Statement ............................................................................................................ 43
LIST OF EXHIBITS
2-1
2-2
4-1
4-2
4-3
5-1
5-2
6-1A
6-1B
6-1C
6-1D
6-1E
6-1F
6-2
6-3
6-4
6-5
6-6
6-7
Classification of Underground Injection Wells
Flow of Information in the UIC Program
Respondents’ SIC/NAICS Codes
Operator Paperwork Requirements
State Reporting Forms
Comparison of State Costs: Current Reporting Process vs. Database Transfer
Revised State Reporting Frequency
Annual Burden and Costs Associated with Class I Wells
Annual Burden and Costs Associated with Class II Wells
Annual Burden and Costs Associated with Class III Wells
Annual Burden and Costs Associated with Class IV/Endangering Class V Wells
Annual Burden and Costs Associated with Class V Wells
Summary of Annual Operator Burden and Costs
Annual Primacy Agency Burden and Cost
Annual Agency Burden and Cost
Bottom Line Annual Burden and Cost
Reasons for Change in Annual Operator Burden
Reasons for Change in Annual Primacy Agency Burden
Annual Burden and Costs Associated with all Well Classes
Underground Injection Control Program – Information Collection Request
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LIST OF APPENDICES
APPENDIX A: Detailed Explanation of Respondent Burden Estimates and Respondent Universe
APPENDIX B: The National UIC Database
APPENDIX C: Federal Register Notice on UIC Program Reporting Requirements
APPENDIX D: UIC Program Burden Reduction Efforts
APPENDIX E: UIC Reporting Forms
APPENDIX F: EPA Response to Terms of OMB Clearance
Underground Injection Control Program – Information Collection Request
Page iii
1.
Identification of the Information Collection
1(a) Title and Number of the Information Collection
Underground Injection Control Program Information
OMB #2040-0042
1(b) Short Characterization
The information collected upon extension of the approval of this Information Collection
Request (ICR) will be used by the U.S. Environmental Protection Agency (EPA) for the
monitoring and enforcement of the Underground Injection Control (UIC) Program, authorized by
the Safe Drinking Water Act (SDWA). The purpose of the UIC Program is to establish a
federal-state regulatory system to ensure that actual or potential underground sources of drinking
water (USDWs) are not endangered by the underground injection of fluids.
Monitoring and enforcement are primarily achieved through initial, quarterly, and annual
reporting requirements. Information is gathered both at the state program level and at the
regional level. Each Region has the role of implementing UIC programs for states that do not
have UIC programs.1 In addition, each Region must compile and submit information to EPA
Headquarters from all respective UIC programs. This information is submitted in summary
reports to EPA Headquarters.
Section 144.6 of 40 CFR describes the five injection well types (see Exhibit 2-1). EPA
collects monitoring data and test results from operators of Class I, II, and III injection wells.
Class IV wells are banned—except for wells used to re-inject treated contaminated ground water
into the same formation from which it was drawn as part of a clean-up authorized by the
Resource Conservation and Recovery Act (RCRA) or Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA); operators of these wells must submit plugging and
abandonment reports as they are closed. EPA requires operators of existing Class V motor
vehicle waste disposal wells (MVWDWs) in ground water protection areas or other state-defined
sensitive ground water areas to close these wells or apply for a permit to continue injecting. (If a
state or Region fails to identify these areas within the time frames specified in the Rule, these
requirements apply to all wells state-wide.) In general, Class V operators submit only a small
subset of the information required of Class I, II, and III well operators.
Primacy agencies are also respondents in this information collection. EPA collects
summary information on permits, compliance and enforcement, inspections, mechanical integrity
testing, and inventory for all well classes from permitting authorities in primacy states.
1
Primary enforcement responsibility (primacy) is vested in states that have UIC programs approved by EPA's
Administrator. “Direct Implementation” (DI) refers to programs in states that are administered directly by EPA
regional offices. In some states, more than one agency may oversee injection wells of various classes.
Underground Injection Control Program – Information Collection Request
Page 1
EPA estimates that, over the 3 years covered by this request, the total burden on
underground injection well operators and Primacy agencies associated with UIC requirements
will be 3,001,944 hours (an average of 1,000,648 hours per year), and the present value cost will
be $418,896,572 (an average of $139,632,191 per year). The public reporting and recordkeeping
burden for this collection of information is estimated to average 2.35 hours, or $328.04 per
response annually. The burden per respondent is 25.77 hours; the cost per respondent is
$3,596.54.
2.
Need For and Use of the Collection
This Section describes EPA’s need for the information collected pursuant to this ICR and
the EPA Regions’ and Headquarters’ use of the collected data. Section 2(a) demonstrates both
the need and legal authority for information collection. Need is demonstrated by describing the
potential for contamination of USDWs and the statutory requirements that justify information
collection to prevent contamination. Legal authority is demonstrated by identifying laws and
regulations related to waste disposal, injection wells, and the UIC Program. Section 2(b)
describes the practical utility and the users of the information; it focuses on how data are used to
accomplish program objectives and manage programs at each level of implementation.
2(a) Need/Authority for the Collection
Potential for Contamination
The fundamental purpose of the UIC Program is to prevent the contamination of current
and potential USDWs by keeping injected fluids within the well and the intended injection zone.
There are five major pathways by which injected fluids can migrate into USDWs. The following
discussion describes each pathway and summarizes information collection requirements to
monitor for migration through the pathway.
Pathway 1: Faulty Well Construction. Contamination through this pathway is caused
by leaks in the well casing or fluid forced upward between the well's outer casing and the
well bore. For this reason, the absence of significant leaks and fluid movement in the
well bore must be demonstrated in the initial permit application, and every 5 years
thereafter.
Pathway 2: Nearby Wells. Fluids from the pressurized area in the injection zone may
be forced upward through wells in the area of injection. Wells that penetrate the injection
area in the zone affected by this pressure must be properly constructed or plugged. For
this reason, plans for plugging and abandonment are submitted with the permit
application. In addition, DI programs require that plugging and abandonment reports be
submitted if the operator abandons any well.
Underground Injection Control Program – Information Collection Request
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Pathway 3: Faults or Fractures in Confining Strata. Fluids may be forced upward
out of the pressurized area through faults or fractures in the confining beds. Activities to
address this contamination pathway are tracked using two information collection
requirements. First, permit information is reviewed to ensure that wells are sited such
that they inject below a confining bed that is free of known open faults or fractures.
Second, injection pressures are monitored so that fractures are not propagated in the
injection zone or initiated in the confining bed zone.
Pathway 4: Direct Injection. Class IV wells, which inject into or above USDWs and
have a high potential to endanger human health, are illegal. The exception is wells that
are used in a RCRA/CERCLA-authorized ground water remediation project. Most Class
V wells inject nonhazardous fluids into or above formations that contain USDWs. These
include, but are not limited to, motor vehicle waste disposal wells, cesspools, agricultural
drainage wells, storm water drainage wells, industrial drainage wells, and untreated
sewage waste disposal wells. In a regulatory effort to address the Class V wells that pose
the greatest threat, EPA has banned the construction of new large-capacity cesspools and
requires operators of existing large-capacity cesspools to close their wells. EPA also
banned new motor vehicle waste disposal wells and is requiring operators of existing
motor vehicle waste disposal wells in defined ground water protection areas or other
sensitive ground water areas to close these wells or apply for a permit to continue
injecting.
Pathway 5: Lateral Displacement. Fluid may be displaced from the injection zone into
hydraulically connected USDWs. Permit information regarding the proximity of
underground injection wells to USDWs is considered by the permitting authority in
making a determination of whether the wells are properly sited. Well operators are
required to control injection pressure and conduct monitoring and testing to track any
lateral migration of fluids.
Legal Authority
Injection wells are regulated by EPA's Office of Ground Water and Drinking Water
(OGWDW), as mandated by Sections 1421, 1422, 1423, 1425, 1431, 1445, and 1450 of the
SDWA of 1974, as amended. The regulation of hazardous waste injection is jointly authorized
by the SDWA and the Resource Conservation and Recovery Act (RCRA) of 1976. The
Hazardous and Solid Waste Amendments (HSWA) of 1984 amended RCRA to prohibit the land
disposal of hazardous waste unless it can be demonstrated that there will be no migration from
the disposal unit for as long as the waste remains hazardous. Underground injection of
hazardous wastes is included in Section 3004(k) of HSWA as a land disposal technique.
Under Section 1445 of the SDWA, persons subject to federal or state UIC programs must
“establish and maintain such records, make such reports, conduct such monitoring, and provide
Underground Injection Control Program – Information Collection Request
Page 3
such information as the Administrator may reasonably require by regulation to assist him in
establishing regulations under this title . . .”
The specific requirements for the UIC Program are established in the Code of Federal
Regulations (CFR), Title 40, Sections 144 through 148 as follows:
Section 144 - Underground Injection Control Program. This section describes the
general requirements of the Program, authorizes certain types of wells, defines permitting
procedures, and establishes procedures for ensuring financial responsibility for proper
closure of wells.
Section 145 - State UIC Program Requirements. This section describes the
requirements that state programs must meet to gain primacy and the method for obtaining
program approval.
Section 146 - UIC Program: Criteria and Standards. This section contains the
technical criteria and standards that various classes of underground injection wells must
meet. Monitoring and reporting criteria are outlined for each well class.
Section 147- State UIC Programs. This section describes the provisions of the UIC
programs of individual states’ and territories’ primacy programs.
Section 148 - Hazardous Waste Injection Restrictions. This section identifies
hazardous wastes that are restricted from disposal into Class I hazardous waste injection
wells. It outlines the standards and procedures by which Class I hazardous waste facility
operators may petition to dispose of restricted hazardous wastes.
These CFR Sections contain information collection requirements that are applicable to
operators of underground injection wells and to administrators of primacy and DI programs.
Exhibit 2-1 describes the five classes of injections wells. A summary of the specific
requirements for operators is given in Exhibit 4-2, Operator Paperwork Requirements; the
paperwork requirements for states as respondents are presented in Exhibit 4-3, State Reporting
Forms.
Underground Injection Control Program – Information Collection Request
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Exhibit 2-1
Classification of Underground Injection Wells
Class I
Wells that inject industrial and municipal waste, including hazardous
waste, beneath the lowermost formation containing a USDW.
Class II
Wells used to dispose of fluids which are brought to the surface in
connection with oil or natural gas production; to inject fluids for
enhanced recovery of oil or natural gas; or to store hydrocarbons.
Class III
Wells that inject fluids for the extraction of minerals including: mining of
sulfur by the Frasch process; in situ production of uranium or other
metals such as ore bodies that are not conventionally mined; and
solution mining of salts or potash.
Class IV
Wells used by generators of hazardous waste or of radioactive waste,
or by owners or operators of hazardous waste management facilities, to
inject into or above strata that contain a USDW. These wells are
banned, unless they are used to re-inject treated contaminated ground
water into the formation from which it was drawn in a RCRA/CERCLA
authorized cleanup.
Class V
Injection wells not included in Classes I, II, III, or IV. Typical examples
include, but are not limited to: agricultural drainage wells, storm water
drainage wells, industrial drainage wells, untreated sewage waste
disposal wells, motor vehicle waste disposal wells, and cesspools.
Statutory Requirements
Section 1421(b) of the SDWA specifies that regulations for state UIC programs must
contain minimum requirements for effective programs that prevent underground injection which
endangers USDWs. Therefore, EPA must:
•
Publish minimum national requirements for effective state UIC programs;
•
List states that need UIC programs;
•
Review proposed state programs and approve or disapprove them;
•
Promulgate and enforce UIC programs in those states that choose not to
participate in or do not develop and operate approved programs; and
•
Evaluate state/regional UIC programs for effectiveness in meeting statutory and
regulatory requirements.
In addition to these regulations, other rules are aimed at providing EPA with the
information it needs to administer its program and to determine what new measures, if any, are
necessary to achieve its statutory mandate.
Underground Injection Control Program – Information Collection Request
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2(b) Practical Utility/Users of the Data
EPA information users include regional and Headquarters staff/managers who make
decisions regarding UIC regulations, compliance and enforcement actions, funding for state and
regional UIC programs, and strategic and policy issues related to the mission of OGWDW and
EPA. Primacy agents in states use the summary information reported on the 7520 forms2 or an
equivalent form to target inspection and enforcement activity, to establish permit terms and
conditions, to track performance against demands, and to identify violations and assess their
significance. In addition, the primacy agent can use the summary reports it supplies to EPA
Headquarters to evaluate its own program activities, such as the number of mechanical integrity
tests (MITs) witnessed, the number of inspections conducted, and the number of permits
reviewed.
Exhibit 2-2 charts the flow of information from operators, states, and Regions to EPA
Headquarters. Operators submit data to states (in primacy states), or to EPA regional offices (in
DI states). Each primacy state in turn submits the data to its respective EPA regional office,
which reviews the information and forwards it, along with data from its own DI states, to EPA
Headquarters. All information in the quarterly, semi-annual, and annual reports received at EPA
Headquarters is analyzed and stored. These reports are the only data available to EPA
Headquarters to fulfill the UIC Program’s needs and responsibilities. The following sections
give a more detailed analysis of the uses made of the collected information.
Headquarters' Management of the National Program
EPA Headquarters uses reported information to respond to information requests and
perform analyses for EPA management, the Office of Management and Budget (OMB), the
General Accounting Office (GAO), Congress, and the public. Headquarters oversees primacy
agents by using the reports to track, evaluate, and report on program performance. Performance
targets and measures for EPA regional programs are established by EPA and tracked against
Government Performance and Results Act (GPRA) goals. EPA tracks high priority activities
that guide the Regions in carrying out UIC Program objectives. EPA negotiates with the
Regions to obtain commitments for performance based on these guidelines.
2
The 7520 forms are described in Exhibit 4-3.
Underground Injection Control Program – Information Collection Request
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Exhibit 2-2 UIC Program Information Flowchart
-
EPA Headquarters Use for Regional Submissions
National budget and program planning activities
Resource allocation and state grant allotments
Annual UIC Program report
Tracking program performance against expectations and commitments of the Regions
Management information for policy and program activities, briefing of Agency management
Assessing progress toward meeting Strategic measures
Responses to congressional, OMB, GAO, public (FOIA) information requests
EPA Regions’ Use of Primacy State Submissions
-
Establish budget and planning target
Negotiate State work plans and track State
performance against commitments
Evaluate States against expectations and overall
Regional performance
DI Program Submission
-
Injection well inventory
Permit review and issuance
Inspections/MIT testing
-
Compliance evaluation
Significant noncompliance evaluation
-
Exceptions list report
Annually
SemiAnnually
Quarterly
Primacy State Submission
-
Injection well inventory
Permit review and issuance
Inspections/MIT testing
-
Compliance evaluation
Significant noncompliance evaluation
-
Exceptions list report
Annually
Quarterly
State/ DI Programs’ Use of Operator Submission
SemiAnnually
- Target inspection and enforcement activity
- Establish permit terms and conditions
- Track performance
- Identify violations and assess their significant for
enforcement
Owner/Operator Submission
-
Underground Injection Control Program – Information Collection Request
Permit information
Annual or quarterly report
Notification of:
o Abandonment
o Change of well
ownership
Page 7
Additionally, EPA’s 2003-2008 Strategic Plan contains a key Strategic Target that, “by
2008, 50% of source water areas (both surface and ground water) for community water systems,
will achieve minimized risk to public health.” EPA developed associated Program Activity
Measures (PAMs) to assess progress toward the strategic goal, including four related to UIC:
C
C
C
C
Percent of Class I, II, III, and V wells identified in violation or significant violation that
are addressed by the UIC Program.
Percent of identified Class V motor vehicle waste disposal wells that are closed or
permitted.
Percentage of Class I, II, and III wells that maintain mechanical integrity.
Percent of ground water-based source water areas for community water systems with a
completed Class V survey.
EPA has initiated an effort to collect data on the UIC Program that supports the PAMs through a
new Web-based reporting process. This is described in Section 5(b).
EPA has also begun the development of a national UIC database. This effort is necessary
because the Agency currently has no national well-level database that holds UIC inventory,
compliance monitoring, violation, and enforcement information. A national database will serve
the needs of Headquarters and various supporting programs in need of crucial UIC data. The
database development effort is described in Section 5(b) and Appendix B.
In addition to its use for regional oversight purposes, state and regional information is
also used to justify future program modifications. For example, the information collected may
be used to determine if the requirements that pertain to rule-authorized wells or mechanical
integrity testing are effective. State and regional data are used to support or inform these types
of decisions.
Regional Oversight of Primacy Programs
The primary use of quarterly, semi-annual, and annual reports submitted to the Regions is
to help the Regions oversee the performance of the primacy agents. The information is used to
track individual state progress against commitments, and to ensure that state programs have the
ability to take timely and appropriate action in response to direct threats to the public health due
to contamination of USDWs.
Regions also have enforcement responsibilities and must use well specific information to
track state enforcement response actions for all significant noncompliers (SNCs), i.e., operators
of those injection wells that are most likely to contaminate USDWs. The statutory responsibility
to initiate federal enforcement actions may be delegated to a Region if a primacy state does not
fulfill its responsibilities.
Underground Injection Control Program – Information Collection Request
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Like EPA Headquarters, the Regions use the data to develop regional operating budgets
and program plans, allocate resources, track state-by-state performance, and respond to inquiries.
The Regions are responsible for reviewing and verifying the information on the quarterly reports
before sending them to EPA Headquarters.
Direct Implementation of State Programs
In addition to their oversight responsibilities, EPA regional offices must implement the
UIC Program in states without primacy. As administrators of UIC programs in DI states, EPA
regional offices use information from operators in several ways.
First, initial permit application materials provide the information regional offices need to
determine if proposed underground injection wells will be properly designed and sited to
minimize the possibility of USDW contamination. The primary responsibility of a regional
office is to use well information submitted prior to construction and during completion to ensure
that injected fluids will remain in the selected injection zone and will not leak into areas that
could result in contaminated USDWs.
Following permit approval and completion work, the permitting authority uses
monitoring and testing reports submitted by operators to determine if (l) there is a leak in the
casing, tubing, or packer, or (2) there is significant fluid movement into a USDW through
vertical channels adjacent to the well bore.
Regional offices with DI authority also use information required of operators to focus
efforts on injection wells in need of enforcement attention. Operators who have been out of
compliance for at least two consecutive quarters are identified on the exceptions list.
Underground Injection Control Program – Information Collection Request
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3.
Nonduplication, Consultations, and Other Collection
Criteria
This Section discusses that EPA has no other means available to gather the requested
information. It also describes EPA’s solicitation of public comments in the Federal Register and
Agency consultations in developing the burden and cost estimates; describes how less frequent
reporting may endanger USDWs; and discusses Paperwork Reduction Act (PRA) general
guidelines and provisions for confidentiality.
3(a) Nonduplication
Well-specific data obtained from operators of injection wells and the state reports that
rely on such data comprise virtually all of the information covered by this ICR. To the best of
the Agency’s knowledge, this information is not required or collected by any other agency or
regulation. The Department of Energy does collect information relating to production for
enhanced recovery wells in its “Annual Report for Enhanced Oil Recovery (EOR) Incentive”
(OMB Clearance No. 19054135). This information pertains only to oil production, and is related
to but different from the information EPA uses to evaluate injection well operators. However, on
a case-by-case basis, permitting authorities may use this information to supplement existing
information on enhanced recovery wells.
Since both Class I hazardous and Class IV wells (now banned) involve the injection of
hazardous wastes, there is potential overlap between UIC programs under the SDWA and
hazardous waste regulations promulgated under RCRA. Historically, the regulations established
provisions for RCRA interim status (Part A permit) [40 CFR 270.64] for Class I hazardous wells
in states in which no UIC program had been approved or promulgated. The regulations allow the
UIC permit to be issued in lieu of a Part B RCRA permit if the Class I hazardous waste well
meets certain conditions specified in 40 CFR 270.64(c). Thus, although Class I hazardous waste
wells are co-regulated under RCRA and the SDWA, there is no duplication of information
collection between RCRA and the UIC Program.
3(b) Public Notice
EPA published a notice requesting comment on the burden and cost associated with the
UIC Program reporting requirements in the Federal Register on February 28, 2007 (72 FR 8983).
EPA received no comments on the burden and cost estimates. A copy of the Federal Register
notice of this information collection is attached to this ICR as Appendix C.
3(c) Consultations
In developing burden and cost estimates and underlying assumptions, EPA consulted
knowledgeable staff in the most active EPA regional offices and states in the UIC Program.
Collectively, these offices are the permitting authorities for the majority of injection wells in
Underground Injection Control Program – Information Collection Request
Page 10
each well class. In some cases, these officials contacted operators or consultants in the states and
regions to solicit input on operator burden and costs. These staff reviewed the burden and cost
tables and recommended adjustments to some unit burden and non-labor costs. Their input is
reflected in the burden and cost estimates in Section 6.
3(d) Effects of Less Frequent Collection
There are two types of respondents for whom efforts could be made to minimize burden:
(1) operators of injection wells; and (2) primacy state agencies.
Operators
All Class I, II, and III operators are required to observe pressure, flow, and cumulative
volume of injected wastes, and demonstrate mechanical integrity. Some operators must sample
and analyze their injectate and conduct ambient monitoring. These requirements provide DI and
state primacy programs with crucial information to assess whether injection wells pose a
potential threat to USDWs. In developing the current monitoring and testing frequencies, EPA
attempted to strike a balance between ensuring protection of USDWs and placing an excessive
burden on operators.
The frequency at which operators must conduct various monitoring and testing activities
varies with the potential for a particular well class to endanger USDWs. Less frequent
monitoring and testing might allow injection wells to operate in a manner that could threaten or
cause considerable damage to USDWs if evidence of such a situation were undiscovered for a
long time. EPA has determined that the specified monitoring frequencies for each operators of
well class are at the minimum protective frequency for the following reasons:
•
State and DI programs use injectate pressure and volume data to ensure that the
pressures caused by injection activities do not cause fractures to initiate in the
confining zone. Less frequent monitoring would not provide the necessary data to
ensure that injection does not initiate fractures in the confining zone or that
injectate or formation fluids are not displaced into USDWs.
•
MITs can reduce the amount of damage a well failure can cause to USDWs by
detecting those failures. The degree to which this damage can be reduced
depends on the frequency of MITs. Less frequent MITs would raise the potential
for contamination of USDWs.
•
Permitting authorities require that operators keep timely data on the chemical
composition of operators’ injectate to ensure that potentially incompatible
injected substances will not come into contact with each other.
Injection well operating permits are renewed or reviewed at varying intervals (typically
every 5 to 10 years, depending on the well class). This is necessary to provide permitting
Underground Injection Control Program – Information Collection Request
Page 11
authorities an opportunity to review facility operations to ensure that injection operations will not
endanger USDWs.
State Primacy Agencies
EPA solicited input from state UIC Directors, operators, and other interested parties on
revising the UIC Program to reduce burden. State officials suggested combining, simplifying, or
eliminating some of the 7520 forms, or reducing the frequency at which primacy agents report
this information to EPA.
3(e) General Guidelines
Two provisions of the UIC regulations exceed the PRA guideline for response time.
Pursuant to 40 CFR 144.51(l) and 144.28(b), operators are required to report by phone within 24
hours and in writing within 5 days “any noncompliance which may endanger health or the
environment.” This is an emergency provision necessary to enable permitting authorities to take
timely and appropriate steps to reduce or eliminate any potential threat to public health.
3(f)
Confidentiality
Operators of injection wells may claim confidentiality, as provided in 40 CFR 144.5
Confidentiality of Information. If confidentiality is requested, the information is treated in
accordance with the provisions of 40 CFR Part 2, Public Information. Any confidentiality claim
must be made at the time of submission in the manner prescribed by the application form or its
instructions. In the case of other submissions, respondents may claim confidentiality by
stamping the words “confidential business information” on each page containing such
information. Claims of confidentiality for the following information will be denied: the name
and address of any permit applicant or permittee; and information regarding the existence,
absence, or level of contaminants in drinking water.
If no claim of confidentiality is made at the time of submission, EPA may make the
information available to the public without further notice. However, the information is collected
for the Agency’s internal use and there are no plans to routinely release or publish any of the
data.
3(g) Sensitive Questions
There are no sensitive questions pertaining to this ICR.
Underground Injection Control Program – Information Collection Request
Page 12
4.
Respondents and Information Requested
This Section identifies respondents affected by this information collection and describes
the data items and activities required of operators, states, and DI programs.
4(a) Respondents/NAICS Codes
Operators of injection wells are identified by Standard Industrial Classification (SIC) and
North American Industry Classification System (NAICS) codes. Operator respondents for
underground injection wells are categorized by the industries that produce fluid wastes and the
type of fluid injected into each well class. The SIC and NAICS codes for the operator
respondents associated with each well class are listed in Exhibit 4-1.
The NAICS code for State agencies that include drinking water programs is 92411
(Administration of Air and Water Resources and Solid Waste Management Programs) or 92312
(Administration of Public Health Programs).
4(b) Information Requested
4(b)(1) Data Items, Including Recordkeeping, Required from Operators
Required data items vary according to well class and authorization category (permitted
well vs. rule-authorized well). The information required of operators is listed in Exhibit 4-2.3
Initial Reporting Requirements
Two methods are available for obtaining approval for underground injection: rule
authorization and permitting. Class II enhanced recovery (II-R) and hydrocarbon storage wells
(II-H) in existence before the promulgation of specific permitting regulations are authorized by
rule for life and do not require permits. All new Class I, II, and III wells require permits. New
Class V wells may be rule-authorized, although some operators of Class V wells may be required
to obtain permits. Operators of Class V MVWDWs in state-designated ground water protection
areas or other sensitive areas that wish to continue operating must obtain a permit.
3
The reporting requirements are based on existing UIC regulations as of October 2006. No specific UIC
requirements or policies exist for operators of carbon dioxide geosequestration projects or drinking water treatment
residuals disposal operations. If any such requirements are developed, future ICRs will include appropriate burden
estimates.
Underground Injection Control Program – Information Collection Request
Page 13
Exhibit 4-1
Respondents’ SIC/NAICS Codes*
UIC
Class
SIC Code
NAICS Code (2002)
Description
I
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#
#
#
#
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#
#
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#
#
#
#
#
#
#
#
II
# 1311
# 1321
# 1381
# 211111
# 211112
# 213111
# Crude Petroleum and Natural Gas Extraction
# Natural Gas Liquid Extraction
# Drilling Oil and Gas Wells
III
# Major Group 10
# Major Group 14
# 212
# Mining (except Oil and Gas)
IV
# 4953
# 562
# Waste Management and Remediation Services
V
# 01, 02, 074, 075
# 111, 112, 54194,
11521
# 488999, 562213,
562219, 92411
# 811192
# 7212, 92111
# Agricultural or storm drainage wells
Major Group 13
Major Group 28
Major Group 26
Major Group 29
Major Group 32
Major Group 33
Major Group 36
Major Group 37
Major Group 45
Major Group 49
Major Group 89
Major Group 99
# 4789, 4953, 9511
# 7542
# 7033, 9111
# 4142, 4212, 4213,
4581, 5015, 5511,
5521, 5531, 5541,
7514, 7515, 7532,
7533, 7537, 7538,
7539, 7549, 9111
211
325
322
324
327
331
335
336
481
221
54162
54169
# 441, 484, 485, 488,
562, 811, 44711,
44719, 45299,
48841, 92111,
532111, 532112
Oil and Gas Extraction
Chemical Manufacturing
Paper Manufacturing
Petroleum and Coal Products Manufacturing
Nonmetallic Mineral Product Manufacturing
Primary Metal Manufacturing
Electrical Equipment, Appliance, & Component Mfg.
Transportation Equipment Manufacturing
Air Transportation
Utilities
Environmental Consulting Services
Other Scientific and Technical Consulting Services
# Domestic wastewater disposal wells
# Car washes
# Recreational vehicle parks and campsites, executive
offices (e.g., state parks and campgrounds)
# Bus charter services, trucking, airports, flying fields, and
airport terminal services; motor vehicle parts; motor
vehicle dealers; auto and home supply stores; gasoline
service stations; passenger car rental or leasing;
automotive repair and services; executive offices (e.g.,
town garages)
* Note: this list is not totally inclusive, but represents a large portion of the industries that operate injection wells.
Rule-Authorized Wells
Wells in existence before the promulgation of specific permitting regulations are
authorized by rule until regulations require them to be permitted. To meet initial reporting
requirements, operators of rule-authorized wells are required to submit inventory information
(i.e., facility name; name and address of the facility’s legal contact; ownership status; and
operating status of the injection well) to the permitting authority using Form 7520-16 (or a statedeveloped equivalent form). Operators must also submit a plugging and abandonment plan and
information regarding financial responsibility (this requirement does not apply to rule-authorized
Underground Injection Control Program – Information Collection Request
Page 14
Class V wells). Authorization terminates if the operator fails to supply any required information,
or if the well loses mechanical integrity or contaminates a USDW.
Permitted Wells4
Operators of permitted wells must follow a two-step permit application procedure. The
operator must submit a permit application prior to construction, and a completion report before
commencing injection. Operators must include the following information with their permit
applications:
•
Inventory Information: name of the facility, name and address of legal contact,
ownership of facility, SIC code(s), and a description of the activities requiring a
permit, [all well Classes];
C
List of Landowners: a list of landowners within one-quarter mile of the facility
(in DI programs) [all well Classes];5
•
Area of Review Methods: methods and calculations used to determine the area of
review (AoR) [Classes I, II, and III];
•
Maps of Wells/Area of Review: a tabulation of all wells within the AoR (within
1/4 mile of the well, or within 2 miles of a Class I hazardous well) that penetrate
the injection zone or the confining zone [Classes I, II, and III];
•
Corrective Action Plan: a plan for corrective action for wells within the AoR that
are not properly plugged [Classes I, II, and III];
•
Geological and Hydrogeological Data: maps and cross sections of USDWs, and
data (including maps and cross sections) on the local and regional geology of the
confining zone [Classes I and III]; names and depths of USDWs [Class II];
•
Operating Data: a description of the proposed operation, including rates and
volumes of fluids to be injected, injection pressures, and sources and constituent
analyses of injection fluids [Classes I, II, and III];
4
Permits may be issued on an area basis as well as on an individual basis, except for hazardous waste injection
wells. Refer to Section 5(b) for a description of how the permitting process minimizes the information burden on
owners and operators.
5
This requirement may be waived if the Regional Administrator determines that it is too burdensome (e.g., if the
well is located in a populated area). Some regions may also require operators to notify all landowners of their intent
to construct the well.
Underground Injection Control Program – Information Collection Request
Page 15
Exhibit 4-2
Operator Paperwork Requirements
Activity
Provide Inventory Information
Permit Application
List of Landowners
Area of Review Methods
Maps of Wells/Area of Review
Corrective Action Plan
Maps and Cross Sections of USDWs
Names and Depths of USDWs
Maps and Cross Sections of Local Geology
Maps and Cross Sections of Regional Geology
Geological Data on Injection and Confining Zones
Operating Data
Formation Testing Program
Stimulation Program
Injection Procedures
Construction Details
Changes in Injected Fluid
Plans for Well Failures
Ambient Monitoring Program
Plugging and Abandonment Plan
Financial Assurance
Completion Report
Results of Logs and Tests Performed During Construction
MIT Results
Anticipated Maximum Injection Pressure & Flow Rate
Formation Testing Results
Actual Injection Procedure
Hydrogeological Compatibility/ Compatibility of Well Materials
Status of Corrective Action
Monitoring and Reporting
Analyze and Report on Chemical Composition of Injectate
Record and Report Injection Pressure, Volume, & Flow Rate
Perform and Report on MIT
Conduct and Report on Ambient Monitoring
Conduct and Report on Pressure Fall-Off Test
Recordkeeping
Retain Monitoring, Testing, Permitting Records
Closure
Closure Report (DI only)
Class
II
I-H
I-N
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
III
V*
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
* Operators of rule-authorized Class V wells will submit inventory information only; Class V wells that are issued
permits will be subject to the other paperwork requirements listed.
Underground Injection Control Program – Information Collection Request
Page 16
•
Formation Testing Program: a description of the proposed formation testing
program [Classes I and III, optional for Class II];
•
Stimulation Program: a description of the proposed stimulation program
[Classes I and III, optional for Class II];
•
Injection Procedures: a description of the proposed injection procedure [Classes
I and III, optional for Class II];
•
Construction Details: construction plans, including schematic drawings of the
surface and subsurface details of the system [Classes I and II];
•
Changes in Injected Fluid: expected changes in pressure, native fluid
displacement, and direction of movement of injected fluid [Classes I and III];
•
Plans for Well Failures: plans for contingency action in the case of shut-ins or
well failures [Classes I and III, optional for Class II];
•
Ambient Monitoring Program: planned ambient monitoring program, including
the location of monitoring wells and monitoring devices, and the proposed
sampling frequency [Classes I and III, optional for Class II];
•
Plugging and Abandonment Plan: plans for closing the well, including type and
placement of plugs to be used [Classes I, II, and III]; and
•
Financial Assurance: evidence of financial responsibility for closure, such as
surety bonds or financial statements [Classes I, II, and III].
Upon approval of the permit application, the operator may begin construction of the well.
Following construction, the operator of a new well must submit a completion report prior to
being authorized to inject. Completion reports must include the following elements:
•
The results of deviation checks, other logs and tests [Classes I, II, and III];
•
Demonstration of mechanical integrity (i.e., the results of a casing pressure test;
radioactive tracer survey of the bottom-hole cement; and/or temperature, noise, or
other logs to check for movement along the borehole) [Classes I, II, and III];
•
Anticipated maximum injection pressure and flow rate [Classes I, II, and III];
•
The results of formation fluid sampling, and testing of the injection and confining
zones [Classes I, II, and III];
Underground Injection Control Program – Information Collection Request
Page 17
•
Actual injection procedure [Classes I, II, and III];
•
Report on hydrogeological compatibility and the compatibility of well materials
[Classes I and III]; and
•
The status of corrective action at improperly abandoned wells within the AoR
[Classes I, II, and III].
Operators of Class I hazardous waste wells must adhere to more stringent permit
application requirements than those required of other classes of wells. Operators seeking an
exemption from the prohibition from injecting any of the Class I listed hazardous wastes must
submit the following information in addition to the information described above:
•
No Migration Petition. Operators of Class I hazardous waste injection wells
must demonstrate, usually by computer modeling, that their wastes will not
endanger USDWs. The operator must provide sufficient information to
demonstrate that the hazardous constituents of wastes will not migrate from the
disposal site. In particular, the petition must prove that the waste will not reach
the roof of the injection zone or a conduit within the injection zone within 10,000
years. This is known as the Fluid Flow Petition.
•
Hydrogeological Compatibility/Compatibility of Well Material Report.
Operators of Class I hazardous waste wells must demonstrate hydrogeological
compatibility (i.e., determine that the waste stream and its anticipated reaction
products will be compatible with both the geologic material of the injection zone
and any previously injected fluids), and compatibility of well materials (i.e.,
demonstrate that the waste stream will be compatible with the well materials that
come in contact with the waste).
•
Waste Analysis Plan. Class I hazardous waste well operators must develop and
follow an approved written waste analysis plan that describes procedures for
obtaining a detailed chemical and physical analysis of a representative sample of
their waste. The waste analysis plan must specify (1) the parameters within which
the waste will be analyzed and the rationale for selecting these parameters; (2) the
test methods that will be used to test for these parameters; and (3) the sampling
method that will be used to obtain a representative sample of the waste to be
analyzed.
•
Other Information. Operators of Class I hazardous waste wells must also submit
a description of the hydrogeological and geochemical conditions at the site; the
physicochemical nature of the waste stream; and proof of conformance with AoR
requirements.
Underground Injection Control Program – Information Collection Request
Page 18
Class V facilities generally are rule-authorized. However, under the 1999 Class V rule,
operators of Class V motor vehicle waste disposal wells in ground water protection areas or other
sensitive ground water areas must apply for a permit to continue injecting. Permitting authorities
may also require other Class V operators to apply for a permit to commence or to continue
injecting. Typically, the permit application process for Class V operators is less complex than
for other well classes—operators are typically required to submit a description of the activities
requiring a permit, inventory information, topographic maps, and a plugging and abandonment
plan which includes a demonstration of financial responsibility for closure.
Monitoring and Testing Requirements
All Class I, II, and III operators must observe injection pressure, rate, and cumulative
volume and demonstrate mechanical integrity. Requirements for other monitoring and testing
activities vary by class. The following are specific monitoring and testing activities for each well
class:
C
Monitor injection pressure, flow rate, and cumulative volume of injected fluids
[continuously for Class I, weekly for Class II disposal wells (II-D), monthly for
Class II-R, and semi-monthly for Class III]; temperature of injected fluids and
annulus pressure between the tubing and the long string casing [Class I];
C
Conduct chemical monitoring of injectate as described in a waste analysis plan or
as specified by the permitting authority [Classes I, II, and permitted Class V
MVWDWs];
C
Conduct annual sludge monitoring [permitted Class V MVWDWs];
C
Test for internal and external mechanical integrity of the well casing, via:
— casing pressure test [annually for Class I hazardous; every 5 years for Class I
nonhazardous, Class II, and Class III salt solution mining]
— radioactive racer survey of the bottom-hole cement [annually for Class I
hazardous];
— temperature, noise, or other logs to test for movement of fluid along the
borehole [every 5 years for Class I and Class III (salt solution mining)];6
6
C
Conduct ambient monitoring, including a pressure fall-off test [annually for Class
I]; and
C
Monitor wells completed in the injection zone and in overlying USDWs [semimonthly for active Class III wells, monthly for Class III facilities in restoration].
Substitute MIT methods (e.g., review of cementing record) may be approved by the Director.
Underground Injection Control Program – Information Collection Request
Page 19
Reporting and Recordkeeping Requirements
All permitted and rule-authorized wells must report to state or DI agencies on the results
of required monitoring and testing.7 In addition, operators must notify the permitting authority
of any planned changes to the facility; changes that may result in noncompliance; progress in
meeting the milestones of a compliance schedule; any loss of mechanical integrity or other
indication of possible endangerment of a USDW within 24 hours; or any noncompliance with
permit conditions.
Scheduled reporting requirements include the following:
•
Class I hazardous well operators report quarterly on monitoring results; and
annually on MITs and to update their plugging and abandonment cost estimates.
•
Class I nonhazardous well operators are required to report quarterly on injectate
monitoring; annually on ambient monitoring; and on MITs every 5 years.
•
Class II operators must report monitoring data annually; and on MITs every 5
years.
•
Class III operators report quarterly on monitoring and on MITs every 5 years.
•
Class V motor vehicle waste disposal well operators that obtain a permit must
report annually on injectate and sludge monitoring.
For rule-authorized wells in DI states, the Regional Administrator may require operators
to submit additional information, as needed, to determine if a well poses a hazard to USDWs.
Such information may include evidence of ground-water monitoring, including periodic reports
of such monitoring; periodic reports on analysis of injected fluids; and a description of the
geologic strata through and into which injection is taking place.
Operators must maintain monitoring information, calibration and maintenance records,
required reports, application data, and monitoring results for 3 years; and keep their most recent
plugging and abandonment cost estimate for 1 year.
Closure Requirements
When closing their wells, operators must submit to the permitting authority a plugging
and abandonment report which indicates that the well was plugged in accordance with the
plugging and abandonment plan (this requirement does not apply to rule-authorized Class V
7
In accordance with the Paperwork Reduction Act of 1995, the reporting requirements covered by this information
collection are consistent with the reporting and recordkeeping activities currently in practice by the respondents. For
example, respondents generally may report required information in either electronic or hard-copy format, whichever
is compatible with their facility practices.
Underground Injection Control Program – Information Collection Request
Page 20
wells). Operators who choose to plug in a manner different from the one specified in their
plugging and abandonment plan must first submit and obtain approval for a revised plugging and
abandonment plan.
Class I hazardous waste well operators must also conduct a pressure fall-off test and
demonstrate mechanical integrity before plugging the well and report the results of these tests
with their closure reports.
4(b)(2) Data Items Including Recordkeeping, Required from States
Primacy and DI agencies submit information on wells within their jurisdiction to
Headquarters via the 7520 forms. (Primacy agencies are not required to report on the 7520
forms, but must supply all of the information on the federal forms; many states opt to use the
7520 forms, however.) Each of the forms that agencies must submit as respondents, the
reporting frequency, and the data items reported are listed in Exhibit 4-3 and are addressed in
Section 2(b). Copies of the forms are provided in Appendix E.
Exhibit 4-3
State Reporting Forms
Form
Frequency
Information Collected
Permit Review and Issuance
(7520-1)
Annual
Information on permit determinations (i.e., the number of
permits issued and not issued, and permit modifications),
permit file reviews, the number of rule-authorized wells
reviewed, AoR reviews, and corrective action performed.
Compliance Evaluation
(7520-2A)
Semi-annual
Enforcement actions, including administrative actions and
civil and criminal actions.
Compliance Evaluation Significant Noncompliance
(7520-2B)
Semi-annual
Operators of injection wells identified as being in
significant noncompliance (SNC) with statutory
requirements and enforcement actions against SNCs and
returns of wells to compliance; contamination of USDWs;
and closures.
Mechanical Integrity
Test/Remedial Actions
(7520-3)
Annual
Results of inspections and MITs and remedial actions
conducted for any test failures.
Quarterly Exceptions List
(7520-4)
Quarterly
Wells that have remained in SNC for 2 or more
consecutive quarters and have not been returned to
compliance or been subject to a formal enforcement
action.
Inventory of Wells Information
Form (7520-16)
Annual
Inventory information, including the facility name; the
legal contact of the facility; and well information, including
type, number, and operating status of injection wells.
Underground Injection Control Program – Information Collection Request
Page 21
5.
Information Collected: EPA Activities, Collection
Methodology, and Information Management
Section 5(a) describes state oversight of operators and EPA activities with respect to
program management. Section 5(b) describes how EPA will manage the information collected;
Section 5(c) discusses how this information collection addresses the needs of small businesses;
and Section 5(d) presents EPA’s justification for the collection schedule.
5(a) State and Agency Activities
5(a)(1) State Activities
Under Section 1422 of the SDWA, states that adopt UIC regulations that are at least as
stringent as the federal requirements may be granted primacy for the UIC Program. Under
Section 1425, state programs that regulate oil and gas-related injection must demonstrate that
their program “represents an effective program to prevent underground injection which
endangers drinking water sources” in order to be granted primacy.
In addition to the reporting activities described in Section 4(b)(2), state primacy agencies
are responsible for overseeing the permitting of wells within their states. Primacy agents receive
and review permit applications from operators, solicit and respond to public comments, and issue
final decisions on permit applications. States also review completion reports and associated
testing results to verify that new wells have been constructed in accordance with construction
standards.
State agencies review injectate and ambient monitoring data submitted by operators; they
also review MITs and pressure fall-off tests. Many states witness some or all MITs and plugging
and abandonments. State primacy agencies also respond to occasional reporting submitted by
operators, conduct periodic permit reviews, and respond to operators’ requests for permit
modifications.
State agencies also report to EPA on the status of their programs. The two mechanisms
by which states report are the 7520 forms (or equivalent reporting) and a newly-developed Web
site to report on UIC Program Strategic Measures.
5(a)(2) Agency Activities
EPA regions oversee injection wells in those states that do not have approved primacy
programs. The regions perform the same activities as state primacy agents. In addition, regional
offices review no-migration petitions submitted by Class I hazardous facility operators in both
primacy and DI states. Regional staff review reports on MITs and pressure fall-off tests
Underground Injection Control Program – Information Collection Request
Page 22
performed in the DI programs, and in some cases, tests on wells in primacy states. DI programs
also review closure reports required of operators when they abandon their wells.
EPA Headquarters activities consist of compiling the regional summary information on
permit reviews and issuance; compliance evaluation, enforcement and inspections information,
and inventory data reported on the 7520 forms; and measures data.
5(b) Collection Methodology and Management
Current reporting from operators to states/DI programs and from states and DI programs
to Headquarters is primarily accomplished by completing the UIC Program’s 7520 reporting
forms. The complete set of PDF-format 7520 reporting forms is available to be downloaded on
OGWDW’s Web site (www.epa.gov/safewater/uic/7520s.html), as well as on GSA’s Web site.
(Appendix E of this ICR contains copies of all the UIC reporting forms.)
State and DI programs maintain detailed data about each well regulated by the UIC
Program. Collection of data from individual operators and quality assurance is the responsibility
of the individual state and DI programs. These data are the source of summary information
submitted to the Regions and EPA Headquarters for oversight and program management. Most
use some type of electronic data management system to maintain this data—EPA estimates,
based on a recent database cataloging effort, that approximately 100 state and DI UIC program
databases are in use. However, at present, all summary reporting to Headquarters is via paper
forms.
One exception to the paper-based reporting to Headquarters is an effort to support
collection of information on the UIC Program Activity Measures. EPA has developed an online
reporting mechanism, by which states and DI programs will log on to a secure Web site to
provide measures data.
Electronic reporting involves transmitting UIC data in a standard electronic format that
can be readily incorporated into Headquarters UIC databases without manual data entry.
Electronic reporting supports the Agency’s effort to streamline the UIC Program by reducing the
reporting burden on the states and improving EPA’s data collection methods. Electronic
reporting offers an opportunity to:
•
•
•
•
•
Reduce data entry;
Reduce mailing costs;
Reduce the routine process of handling paperwork;,
Reduce or eliminate the need to store large quantities of paper documents; and
Increase the accuracy of reports submitted to OGWDW and the Office of Enforcement
and Compliance Assurance.
EPA has begun to develop a well-specific database to collect and store data to support
UIC programmatic data needs. The national UIC database will include a mechanism to
Underground Injection Control Program – Information Collection Request
Page 23
electronically transfer data between existing state and DI databases and Headquarters’ database,
eventually eliminating the need for state UIC Program Directors to complete paper reporting
forms.
EPA Headquarters plans to deploy the national UIC database in 2007. Before
deployment, states will incur a “start up” cost to initiate the transfer of their data to the national
database. Once the data flow is in place, states will incur minimal cost to transfer data to
Headquarters quarterly; this cost will be lower than the current annual reporting costs to states
associated with gathering data and completing the reporting forms.
Under the current, paper-based system, each state spends about $18,000 annually to
accomplish the required reporting. Following the investment in the data transfer, states will
incur lower annual costs: an estimated cost of about $11,000 to enter data and transfer it to
Headquarters quarterly.
Even taking into account the costs of the initial phase-in, EPA estimates that the
cumulative costs to states for data development and data management via the database
(represented by the solid line in the graph in Exhibit 5-1) are lower than they would have been to
report by paper during the same time frame (the dashed line).
Appendix B describes the data transfer activities in detail, the schedule by which states
are expected to begin the data transfer, and the eventual burden and cost savings to states
associated with the national UIC database.
Underground Injection Control Program – Information Collection Request
Page 24
Exhibit 5-1
Comparison of State Costs:
Current Reporting Process vs. Database Transfer
$14.0
Cost (millions)
$12.0
$10.0
$8.0
$6.0
$4.0
$2.0
$0.0
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Paper-based
Automated transfer
Year
5(c) Small Entity Flexibility
Few, if any, small businesses are operators of Class I or Class III injection wells. In
contrast, many Class II and Class V operators affected by this collection are small entities. This
collection reduces to the extent practicable and appropriate the burden on persons that provide
information to or for EPA, including with respect to small entities, as defined by the Regulatory
Flexibility Act [5 USC 601(6)], the use of such techniques as:
C
C
C
Establishing differing compliance or reporting requirements or timetables that
take into account the resources available to those who are to respond;
The clarification, consolidation, or simplification of compliance and reporting
requirements; or
An exemption from coverage of the collection of information, or any part thereof.
Class I
The size standard the Small Business Administration uses to define “small business”
varies by SIC code. Class I wells typically involve the following SIC codes:
Underground Injection Control Program – Information Collection Request
Page 25
C
C
C
C
C
C
C
C
C
C
C
C
Major Group 13:
Major Group 28:
Major Group 26:
Major Group 29:
Major Group 32:
Major Group 33:
Major Group 36:
Major Group 37:
Major Group 45:
Major Group 49:
Major Group 89:
Major Group 99:
Oil and gas extraction
Chemicals and allied products
Paper and allied products
Petroleum and coal products
Stone, clay and glass products
Primary metal industries
Electrical and electronic machinery
Transportation equipment
Transportation by air
Electric, gas, and sanitary services
Services not elsewhere classified
Non-classifiable establishments
The small business size standards for firms in these SIC code groups vary from 500 to
1,500 employees, except for SIC code 4953, for which the size standard is $3.5 million or less in
revenues. Most of the firms that own or operate Class I injection wells clearly exceed both the
500-employee and the 1,500-employee standard. Examples include Allied Chemical, Bethlehem
Steel, Dow Chemical, DuPont, Exxon, General Electric, Monsanto, Shell, and USX. The
hazardous waste disposal firms that own and operate Class I wells (SIC code 4953) are believed
to exceed the $3.5 million revenue standard.
Class II
Oil and gas extraction firms fall into three SIC categories:
•
•
•
SIC code 1311 (crude petroleum and natural gas);
SIC code 1321 (natural gas liquids); and
SIC code 1381 (drilling oil and gas wells).
All of these categories have small business size standards of 500 employees. According
to Dun and Bradstreet Market Analysis Profile, more than 90 percent of the firms in these SIC
codes are small businesses, using the 500-employee standard. Even though many of the operable
Class II injection wells are owned and operated by large businesses, industry observers believe
that as many as half of the Class II wells are owned and operated by firms that are well below the
500-employee size standard.
Section 1421 of the SDWA states that regulation of Class II wells must be kept to a
minimum, while at the same time assuring that USDWs will not be endangered. Recognizing
this intent, EPA has minimized reporting requirements for Class II wells in the following ways.
First, while operators of Class I and Class III wells report injection fluid characteristics quarterly,
Class II operators report that information annually. Second, Class I monitoring requirements
include the installation and use of continuous recording devices to monitor injection pressure,
flow rate, volume, and annulus pressure [40 CFR 146.13]. In contrast, Class II operators are
Underground Injection Control Program – Information Collection Request
Page 26
only required to observe injection pressure, flow rate, and cumulative volume and to record these
measurements at least monthly [40 CFR 146.23].
The UIC regulations [40 CFR 146.14, 146.24, 146.34] define the information the UIC
Program Director must consider in authorizing Class I, II, and III wells, respectively. Less
information is required of Class II wells than other types of wells. For permitting of Class I and
Class III wells, maps and cross sections detailing geologic structure may be required, whereas
Class II well operators must provide only a description of geologic conditions. Finally, while the
permitting authority may require Class I operators to provide detailed construction procedures,
including a cementing program; logging procedures; deviation checks; and a drilling, testing, and
coring program, Class II well operators need not submit this information.
EPA has also recognized the needs of operators of Class II wells in other ways. For
example, oil and gas wells are often temporarily abandoned, especially by small businesses that
operate at marginal production rates. To accommodate this situation, the regulations specify that
cessation of operation does not require plugging (and associated information collection) until two
years have elapsed.
Class III
Operators of this class of wells fall into the following categories:
•
•
SIC Major Group 10 (metal mining) and
SIC Major Group 14 (mining and quarrying of non-metallic minerals).
The applicable size standard for both groups is 500 or fewer employees. According to
the preamble to the 1980 UIC regulations (45 FR 42472), the operators of these wells are large,
diversified corporations, well above the size standard of 500 employees. There is no reason to
believe that there has been any material change in the size of the firms since that analysis was
done.
Underground Injection Control Program – Information Collection Request
Page 27
Class V
EPA estimates that the majority of facilities affected by the Class V Rule will be small
businesses. To reduce the impact of the rule on small entities, EPA has attempted to keep
recordkeeping, reporting, and other administrative requirements for these operators to a
minimum in order to provide regulatory relief to small entities while protecting drinking water
supplies. Most Class V facilities do not have collection requirements other than to provide
inventory information. EPA also convened a Small Business Advocacy Review Panel, as
required by the Small Business Regulatory Enforcement Fairness Act (SBREFA), to explore
options for minimizing economic impacts on small entities.
The economic analysis prepared for the 1999 final Class V rule includes a complete, final
Regulatory Flexibility Analysis addressing all activities, including reporting and recordkeeping
activities, required of small entities.
5(d) Collection Schedule
EPA developed the schedule for information collection and reporting to minimize the
amount of information collected while ensuring that enough information is given for appropriate
and timely oversight, evaluation, and enforcement. The rationale for operator and state reporting
frequencies is described below. A complete description of the collection requirements can be
found in Section 4.
5(d)(1) Operator Reporting
In determining the reporting schedule for each class of wells, EPA considered the
potential for each class to contaminate USDWs. Operators of Class I, III, and some Class V
wells must report monitoring results quarterly; Class II operators report annually. The regular
reporting of these data is essential to protecting USDWs. Specific operator reporting schedules
for each well class are presented in Tables A-1 through A-6 of Appendix A.
5(d)(2) State Reporting
Exhibit 5-2 summarizes the frequencies at which state primacy agencies must report UIC
data, including the 7520 forms and Program Activity Measures (PAMs). The paragraphs
following the Exhibit present the justification for the reporting frequencies.
In response to President Clinton’s April 24, 1995, directive to reduce regularly scheduled
reporting frequencies by one-half, except in cases where such action would not adequately
protect the environment, in FY 1996 EPA reduced the frequency of certain state UIC reporting.
EPA has also discontinued the requirement that states submit the grant utilization form (7520-5).
As Section 5(b) discusses, upon implementation of the national UIC database, states UIC
flowing data to Headquarters will no longer be required to submit the 7520 forms and PAM data.
Underground Injection Control Program – Information Collection Request
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Exhibit 5-2
State Reporting Frequencies
Reporting Activity
Frequency
Form 7520-1: Permit Review and Issuance
Annual
Form 7520-2A: Compliance Evaluation
Semi-annual
Form 7520-2B: Compliance Evaluation for Significant Noncompliance
Semi-annual
Form 7520-3: Mechanical Integrity Test/Remedial Actions
Annual
Form 7520-4: Quarterly Exceptions List
Quarterly
Form 7520-16: Inventory of Injection Wells
Annual
Program Activity Measures
Semi-annual
7520-1: Permit Review and Issuance. Permits are the core of the UIC Program, and annual
permit information is used for program management purposes. The Program uses permit
information to evaluate events that delay or accelerate the permitting process. Delays in the
permitting process may result in the states' inability to meet program objectives and prevent
states from meeting schedules. A permitting process that is too lengthy could have a detrimental
impact on industry. Conversely, favorable developments may occur that enable the states to
meet time schedules and goals sooner than anticipated. Both occurrences have a potential for
shifts in workload and resource distribution.
7520-2A: Compliance Evaluation; 7520-2B: Significant Non-compliance. The justification for
semi-annual reporting of compliance information is based on EPA efforts to be routinely and
frequently informed of violations to regulations in effect under Section 1421 of the SDWA. EPA
must be kept informed in order to (a) oversee and encourage states' actions on resolving
violations or enforcing against violators, and (b) to take direct federal action where appropriate
state actions have not occurred in a timely manner or have not been successful.
EPA would be unable to effectively carry out the Congressional direction for federal
enforcement on violators if it only had access to data annually. Prior to 1987, states provided
EPA with the above information on an annual basis. States then agreed to voluntarily supply the
data on a quarterly basis when it became obvious that EPA Headquarters could not direct an
effective federal enforcement program using data received only once a year. EPA later
determined that semi-annual reporting of this information is sufficiently frequent to track
compliance information.
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7520-3: Inspections/Mechanical Integrity Testing. Inspections are the principal method of
identifying instances of noncompliance. Annual inspection information is used to monitor
states’ performance on inspections. Inspections have resulted in criminal indictment and
imprisonment of well owners. Annual inspection information assures that inspections are being
performed on a continual basis throughout the year. The MIT is the principal method used to
determine whether a well is operating in a protective manner. Annual MIT information is used
to evaluate the MIT program. Operators must record and submit information on the types,
frequencies, results, and remedial actions taken on a series of MIT tests.
7520-4: Quarterly Exceptions List. EPA needs quarterly information on SNCs that have been
out of compliance for two or more consecutive quarters. The Agency uses this information to
determine whether timely and appropriate actions have been taken by primacy authorities and to
track enforcement activities, as these wells pose the greatest threat to USDWs.
7520-16: Inventory of Injection Wells. Annual reporting on inventory data, as required by 40
CFR 144.8, is necessary for effective oversight of the UIC Program. Primacy states, Regions,
and EPA Headquarters need to be routinely and frequently informed of changes in the number
and operating characteristics of injection wells to monitor and regulate underground injection
effectively and to continue protecting USDWs from contamination.
PAM Data. EPA Headquarters needs to collect PAM data semi-annually to meet the Office of
Water's reporting schedules to assess progress toward meeting Agency Strategic Targets for
achieving minimized risk to public health. Mid-year and end-of- year reporting on progress
toward environmental and public health goal and program commitments supports national
assessments of Water Program performance and recommendations for management actions to
strengthen performance.
Underground Injection Control Program – Information Collection Request
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6. Estimating the Burden and Cost of the Collection
This section contains EPA’s estimates of the burden and costs to respondents (i.e.,
well owner/operators and state primacy agencies) associated with UIC paperwork
requirements, and federal burden hours and costs for reviewing respondent submissions.
Section 6(a) provides estimates of burden hours for all respondent types. Section 6(b)
contains estimates of respondent costs for the information collection. Section 6(c)
summarizes federal burden and costs as users of respondent data. Section 6(d) describes the
respondent universe and the total burden and cost of this collection to respondents. Section
6(e) covers aggregate burden hours and costs for all respondents, and Section 6(f) explains
the reasons for the change in estimated respondent burden hours and costs from the approved
ICR burden. The burden statement for this information collection is in Section 6(g).
6(a)
Respondent Burden
6(a)(i)
Burden to Owners and Operators of Injection Wells
Operators of injection wells incur reporting burden associated with the following types of
activities: permitting and startup of operations, ground water and injectate monitoring and
well testing during well operation, reporting of monitoring results and other events,
recordkeeping, and well closure.
EPA estimates that the annual burden on the 38,768 owner/operators of injection wells will
be 840,985 hours over the 3 years covered by this ICR. This is summarized in Exhibits 61A-E. See Appendix A for detail on the assumptions used to calculate the owner/operator
burden and detailed burden and cost calculations.
1)
Class I Well Operators
The total annual burden on the 289 operators of Class I wells nation-wide is estimated to
be 88,434 hours. See Exhibit 6-1A. EPA estimates the annual burden for the 63 operators of
Class I hazardous wells to be 24,304 hours, and the burden for 226 operators of Class I nonhazardous wells to be 64,130 hours annually.
The requirements for Class I operators are the most stringent in the UIC Program.
Operator activities associated with Class I facilities include permitting and start-up related
reporting, permit renewals and modifications of permits or petitions, monitoring, reporting
and recordkeeping, and closure-related paperwork. Operators of Class I hazardous wells
must also perform an extensive no-migration demonstration that their wastes will not
endanger USDWs.
Appendix A summarizes the assumptions used to calculate the owner/operator burden
and provides detailed burden and cost calculations. Table A-1 of Appendix A presents cost
and burden estimates specific to Class I wells.
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Exhibit 6-1A
Annual Burden and Cost Associated with Class I Wells
2007-2010
Respondent
Type
Burden
(hours)
Operators
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
88,434
$3,360,646
$25,041,790
$28,402,436
4,581
19.30
$6,199.82
Primacy States
4,854
$181,312
$0
$181,312
1,383
3.51
$131.14
DI Programs
5,827
$221,705
$0
$221,705
544
10.72
$407.79
99,115
$3,763,663
$25,041,790
$28,805,453
6,507
15.23
$4,426.56
TOTAL
2)
Class II Well Operators
As shown in Exhibit 6-1B, EPA estimates the total annual burden on the 14,395
operators of Class II wells (associated with the oil and natural gas industry) to be 593,332
hours. Class II well operators perform many of the same types of activities as Class I
wells, including submitting permit applications and completion reports, monitoring and
mechanical integrity testing (MIT), reporting and recordkeeping, and closure-related
paperwork.
See Appendix A (particularly Table A-2) for details on the assumptions used to
calculate the owner/operator burden and cost associated with the requirements for Class
II wells.
Exhibit 6-1B
Annual Burden and Cost Associated with Class II Wells
2007-2010
Respondent
Type
Burden
(hours)
Operators
Primacy States
DI Programs
TOTAL
3)
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
593,332
$21,338,786
$56,001,210
$77,339,997
313,913
1.89
$246.37
45,761
$1,741,103
$0
$1,741,103
29,722
1.54
$58.58
3,095
$117,743
$0
$117,743
2,283
1.36
$51.58
642,187
$23,197,632
$56,001,210
$79,198,842
345,918
1.86
$228.95
Class III Well Operators
The estimated total annual burden on the 165 operators of Class III facilities is
55,387 hours. See Exhibit 6-1C. Operators of these wells associated with mining
operations incur burden associated with permit applications and completion reports,
monitoring, reporting and recordkeeping, and closure-related paperwork.
See Appendix A (particularly Table A-3) for details on the assumptions used to
calculate the owner/operator burden and cost associated with the requirements for Class
III wells.
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Exhibit 6-1C
Annual Burden and Cost Associated with Class III Wells
2007-2010
Respondent
Type
Burden
(hours)
Operators
Primacy States
DI Programs
TOTAL
4)
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
55,387
$1,892,313
$716,333
$2,608,646
5,996
9.24
$435.04
3,367
$128,122
$0
$128,122
594
5.67
$215.74
282
$10,741
$0
$10,741
430
0.66
$24.97
59,037
$2,031,176
$716,333
$2,747,509
7,020
8.41
$391.36
Class IV/Endangering Class V Well Operators
Class IV wells and Class V wells that are found to be endangering USDWs are
banned from injection, and owners of these wells are required to close them and submit
plugging and abandonment reports to states or DI programs. The exception to the ban is
for those Class IV wells used to inject contaminated ground water that has been treated
and re-injected into the same formation from which it was drawn. These wells are
authorized by rule for the life of the well if such subsurface emplacement of fluid is
approved by EPA or a state pursuant to the provisions for the cleanup of releases under
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
or RCRA.
EPA estimates that the burden on the 990 operators of these wells that are subject
to this information collection will be 9,900 hours annually. See Exhibit 6-1D and
Appendix A.
Exhibit 6-1D
Annual Burden and Cost Associated with Class IV Wells
2007-2010
Respondent
Type
Burden
(hours)
Operators
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
9,900
$213,662
$0
$213,662
990
10.00
$215.82
Primacy States
758
$28,840
$0
$28,840
758
1.00
$38.05
DI Programs
232
$8,827
$0
$8,827
232
1.00
$38.05
10,890
$251,329
$0
$251,329
1,980
5.50
$126.93
TOTAL
5)
Class V Well Operators
The total annual burden on the 22,929 operators of Class V wells with reporting
requirements under this information collection is estimated to be 93,933 hours. See
Exhibit 6-1E and Appendix A.
All operators of Class V wells must submit inventory information before they
may begin operating their wells. In addition, the 1999 Class V Rule provided additional
Underground Injection Control Program – Information Collection Request
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requirements for owners of MVWDWs and large-capacity cesspools. Facilities that wish
to continue operating MVWDWs must apply for permits. MVWDWs and large-capacity
cesspools that close are required to submit pre-closure notifications.
Although the Class V Rule required that all of these facilities be closed or apply
for a permit by January 2007 (the latest date by which operators with state-granted
extensions would be required to close their well or apply for a permit), EPA assumes that
some of these activities may not be complete. Thus, some permitting/closure burden is
included in this ICR. In addition, operators of MVWDWs that opted to apply for (and
received) permits must monitor their injectate and sludge and submit annual monitoring
reports.
Exhibit 6-1E
Annual Burden and Cost Associated with Class V Wells
2007-2010
Respondent
Type
Burden
(hours)
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
Operators
93,933
$2,057,461
$22,489,574
$24,547,035
50,273
1.87
$488.27
Primacy States
16,216
$616,973
$0
$616,973
16,433
0.99
$37.55
8,871
$337,505
$0
$337,505
8,999
0.99
$37.50
119,019
$3,011,938
$22,489,574
$25,501,512
75,705
1.57
$336.85
DI Programs
TOTAL
Exhibit 6-1F summarizes the operator burden and costs, by well type (from
Exhibits 6-1A through E). Exhibit 6-2, in the next section, provides a similar summary
for primacy agencies.
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Exhibit 6-1F
Summary of Annual Operator Burden and Cost (based on above exhibits)
2007-2010
Respondent Type
Burden
(hours)
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
Class I Operators
88,434
$3,360,646
$25,041,790
$28,402,436
4,581
19.30
$6,199.82
Class II Operators
593,332
$21,338,786
$56,001,210
$77,339,997
313,913
1.89
$246.37
Class III Operators
55,387
$1,892,313
$716,333
$2,608,646
5,996
9.24
$435.04
Class IV Operators
9,900
$213,662
$0
$213,662
990
10.00
$215.82
Class V Operators
93,933
$2,057,461
$22,489,574
$24,547,035
50,273
1.87
$488.27
840,985
$28,862,868
$104,248,907
$133,111,775
375,754
2.24
$354.25
TOTAL
6(a)(ii) Burden to Primacy Agencies
EPA estimates that the annual burden on the 56 state primacy agencies that
oversee the various classes of injection wells is 159,663 hours for the years 2007 through
2010. Exhibit 6-2 shows the annual Primacy agency burden hours associated with
oversight of each class of injection well. Appendix A describes the bases for the burden
estimates.
State primacy agencies’ burden as users or reviewers of operator-submitted data
associated with implementing Class I through Class V UIC programs arise from
processing permit applications and completion reports, reviewing monitoring and testing
data, and responding to closure reports submitted by operators within their states.
The burden to states as respondents is associated with compiling and reporting
data using the 7520 forms and the UIC measures reporting process. During the clearance
period, EPA estimates that up to 36 states will also begin to transfer data to EPA
Headquarters to populate the national UIC database. Appendix B describes the costs to
states associated with this effort.
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Exhibit 6-2
Annual Primacy Agency Burden and Cost
2007-2010
Respondent Type
Burden
(hours)
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
Class I Programs
4,854
$181,312
$0
$181,312
1,383
3.51
$131.14
Class II Programs
45,761
$1,741,103
$0
$1,741,103
29,722
1.54
$58.58
Class III Programs
3,367
$128,122
$0
$128,122
594
5.67
$215.74
Class IV Programs
758
$28,840
$0
$28,840
758
1.00
$38.05
Class V Programs
16,216
$616,973
$0
$616,973
16,433
0.99
$37.55
Subtotal -Operator
Oversight
70,955
$2,696,350
$0
$2,696,350
48,889
1.45
$55.15
States as
Respondents
88,708
$3,375,144
$448,922
$3,824,066
1,008
88.00
$3,793.72
159,663
$6,071,494
$448,922
$6,520,416
49,897
3.20
$130.68
TOTAL
6(b) Respondent Costs
6(b)(i) Cost to Operators
Exhibits 6-1A through E and 6-1F show the total costs for owners and operators
of various classes of injection wells over the 3-year ICR clearance period. Annual costs
are estimated at approximately $133.1 million, which consists of $104.2 million in nonlabor costs and $28.9 million in labor costs.
EPA determined operator labor cost by estimating the mix of legal, managerial,
technical, and clerical time needed to perform each collection activity. For Classes I, II,
and III, the labor cost estimate is based on average hourly estimates for salary and
overhead of $80 for legal staff, $70 for managerial staff, $39 for technical staff, and $24
for clerical staff. For Classes IV and V, hourly salary and overhead rates are estimated to
be slightly less: $53 for managerial staff, $23 for technical staff, and $17 for clerical staff
(no legal staff labor is assumed for these operators). Contractor time (which is included
in the non-labor costs in this ICR) was estimated to be approximately $80 per hour.
EPA estimated non-labor costs from data provided by staff in EPA Regions and
state primacy agencies, and from operators and other sources. This ICR assumes there
are no capital costs to operators–large capital expenditures associated with underground
injection (e.g., construction costs and monitoring equipment) are considered to be
customary business practice. All non-labor costs to operators associated with this
collection are operating and maintenance (O&M) costs, such as the cost of contractor
services or laboratory fees associated with injectate, sludge, or ground water monitoring.
6(b)(ii) Cost to Primacy Agencies
Exhibit 6-2 shows that the annual cost to primacy agencies is estimated at
Underground Injection Control Program – Information Collection Request
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approximately $6.5 million, of which most ($6.1 million) is labor cost. For this ICR,
EPA assumed that the average hourly labor rate for a state employee is $38.05. This
estimate is based on a federal GS-9, Step 10 salary on the 2006 federal pay scale,
increased by 60 percent to account for overhead costs. (This is the inflation factor
recommended in EPA’s ICR Handbook.)
The non-labor costs (capital and O&M) to states in this ICR are estimated to be
$448,922. These costs are associated with data development and transfer to the national
UIC database. The capital/start-up costs attributable to this information collection
include purchases of computer hardware to allow data transfer from primacy agencies to
Headquarters to populate the national UIC database. The total capital costs for this ICR
are $252,000, an average of $84,000 per year. The remaining non-labor costs to states
are the cost of contractor support for database development.
6(c) Agency Burden and Costs
EPA’s regional offices implement the UIC Program for all well classes in 10
states and have oversight responsibility for a subset of well classes in 6 states. The
paperwork requirements for DI programs are roughly the same as those for the state
primacy programs. In addition, EPA regions review all no-migration petitions submitted
by Class I hazardous facility operators in both primacy and DI states in their region. The
total annual burden for federal DI programs associated with the above activities is 18,306
hours. In addition, EPA Headquarters spends an estimated 2 FTEs, or 4,160 hours
annually in its oversight responsibilities for the UIC Program activities related to this
information collection. Headquarters activities include gathering and reviewing 7520
forms, analysis of measures data, and development of the national UIC database. See
Exhibit 6-3.
EPA assumes the average hourly labor rate for salary and overhead and benefits
for Agency staff to be $38.05. This estimate is based on a federal GS-9, Step 10 salary
on the 2006 federal pay scale, increased by 60 percent to account for overhead costs. The
annual federal cost associated with this collection is $854,801. The breakdown of
Agency cost associated with each well class is presented in Exhibit 6-3.
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Exhibit 6-3
Annual Agency Burden and Cost
2007-2010
Respondent Type
Burden
(hours)
Labor Cost
Non-Labor
Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
Class I DI
Programs
5,827
$221,705
$0
$221,705
544
10.72
$407.79
Class II DI
Programs
3,095
$117,743
$0
$117,743
2,283
1.36
$51.58
Class III DI
Programs
282
$10,741
$0
$10,741
430
0.66
$24.97
Class IV DI
Programs
232
$8,827
$0
$8,827
232
1.00
$38.05
Class V DI
Programs
8,871
$337,505
$0
$337,505
8,999
0.99
$37.50
Headquarters
Management
4,160
$158,280
$0
$158,280
1
4,160.00
$158,279.68
22,466
$854,801
$0
$854,801
12,489
1.80
$68.45
TOTAL
6(d) Estimating Respondent Universe and Total Burden and Costs
EPA estimates that 38,768 owners or operators of injection wells and 56 state
primacy agencies are subject to the UIC Program’s information collection requirements
outlined in Section 6(a). The number of responses for each well class and activity are
shown in Exhibits 6-1A though 6-1E, and summarized in Exhibit 6-1F. The estimates of
the number of state responses are also shown in Exhibit 6-2. This number, known as the
respondent universe, is based on EPA’s assumptions of the number of permittees subject
to each paperwork requirement, e.g., the number of permit applications or well closures
expected, or the percent of permittees subject to monitoring or reporting requirements
and the frequency with which they must comply with those requirements. Part 2 of
Appendix A provides more detail on EPA’s assumptions about the number of
respondents for each collection activity.
EPA estimates that the total annual respondent burden over the 3 years covered by
this ICR is 3.0 million hours. The total cost to respondents is $419 million.
6(e) Bottom Line Burden Hours and Costs
The bottom line burden hours and costs appear in Exhibit 6-4.
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Exhibit 6-4
Bottom Line Annual Burden and Cost
2007-2010
Number of Respondents
38,824 =
Total Annual Responses
425,652 =
Number of Responses
per Respondent
Total Respondent Hours
Hours per Response
10.96 =
1,000,648 =
2.35 =
38,768 Operators (from EPA inventory) +
56 Primacy agencies
375,754 Operator responses (from Exhibit 6-1F) +
49,897 Primacy agency responses (from Exhibit 6-2)
425,652 Total annual responses from above ÷
38,824 Total respondents from above
840,985 Operator burden (from Exhibit 6-1F) +
159,663 Primacy agency burden (from Exhibit 6-2)
1,000,648 Total annual hours from above ÷
425,652 Total responses from above
Annual O&M and Capital
Cost
$104,697,829 =
$104,248,907 Operator non-labor cost (from Exhibit 6-1F) +
$448,922 Primacy agency non-labor cost (from Exhibit 6-2)
Total Respondent Cost
$139,632,191 =
$133,111,775 Operator cost (from Exhibit 6-1F) +
$6,520,416 Primacy agency cost (from Exhibit 6-2)
Total Hours
(Respondents plus
Agency)
Total Cost (Respondents
plus Agency)
1,023,114 =
$140,486,991 =
1,000,648 Total respondent hours from above +
22,466 Total EPA hours (from Exhibit 6-3)
$139,632,191 Total respondent cost from above +
$854,801 Total EPA cost (from Exhibit 6-3)
Note: Detail may not add exactly to total due to independent rounding.
6(f)
Reasons for Change in Burden
The total annual approved burden on operators and states associated with the UIC
Program is 1,336,057 hours. This ICR requests total annual respondent burden of
1,000,648 hours. Thus, there is a net reduction in burden of 335,409 hours between the
approved and requested amounts. Of this, about 283,000 hours is reduced operator
burden and 52,400 is reduced primacy agency burden.
Note that the approved burden cited above differs from the burden in the 2004
UIC Program ICR. The 2004 ICR (ICR No. 370.17) estimated a total annual burden on
operators and states of 1,334,054 hours. The current approved burden reflects the
addition of activities associated with the Revision to Federal UIC Requirements for Class
I Municipal Wells in Florida, estimated in EPA ICR No. 370.20. That ICR added 1,472
operator hours and 531 primacy agency hours to the approved UIC Program burden.
This section discusses the change in burden to operators of injection wells and
primacy states between the burden requested in this ICR and the approved burden. The
burden changes are the result of program changes and adjustments and affect well
operators and the agencies that oversee them to varying degrees.
Underground Injection Control Program – Information Collection Request
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The paragraphs below describe these changes. Exhibits 6-5 and 6-6 summarize
the burden impacts of these changes to operators and primacy agencies, respectively.
Program Changes
Program changes that affect the UIC reporting burden in this ICR include the following:
•
Activities associated with the Class V Rule should abate in this ICR period. All
well closures and permitting activities should have been completed by January
2007. However, based on information from some states and regions, there is
evidence that not all of these activities are complete, and some permitting
activities will carry over to this ICR clearance period. The burden associated with
injectate and sludge sampling by MVWDW operators will continue. This change
reduces the operator burden by 71,669 hours and primacy agency burden by 4,762
hours.
•
UIC Measures reporting—EPA Headquarters is now requiring mid-year reporting
of target measures by states. This change adds 2,240 hours to the primacy agency
burden.
•
National UIC database—EPA Headquarters is implementing a new database to
streamline reporting from states and DI programs to Headquarters. The state
burden and cost during the clearance period will increase by an estimated 3,576
hours, as the first states to populate the national UIC database do their initial data
mapping. However, as more and more states complete database development
activities and begin to automate the reporting process, the total reporting burden
will decrease. Appendix B describes the planned development and
implementation of the UIC database, and compares the reporting costs to states
with and without a national database.
Adjustments
Adjustments that affect the UIC reporting burden in this ICR include the following:
•
Inventory changes and adjustments–Between 2004 and 2006, the national
injection well inventory increased by 195,000 wells—the majority of the increase
is in the Class V inventory. Another adjustment relates to assumptions about the
number of Class II operators that will be submitting permit applications—EPA
estimates a significant decrease in permit applications between the 2004 and 2007
ICRs; this adjustment accounts for most of the change in burden between the two
clearance periods. The net effect of these adjustments is a 211,000 hour decrease
in operator burden and a 53,000 hour decrease in state burden.
Underground Injection Control Program – Information Collection Request
Page 40
Exhibit 6-5
Reasons for Change in Annual Operator Burden (Hours)
Type of Change
Change
Approved operator
burden
Abatement of activities
related to the Class V
Rule
Running Total
1,123,994
Carry-over from approved burden.
-71,669
1,052,325
Program change. Burden associated with
permitting and closure of MVWDWs and
closure of large capacity cesspools is
largely complete. Most activities in this
clearance period are associated with
sampling by MVWDW operators who opted
to apply for a permit.
-211,339
840,985
Inventory adjustments
Total change
Comment
Adjustment. Most of the change is
associated with fewer Class II operators
applying for permits.
Total change in operator burden between
approved and requested.
-283,009
Note: Detail may not add exactly to totals due to independent rounding.
Exhibit 6-6
Reasons for Change in Annual Primacy Agency Burden (Hours)
Type of Change
Change
Approved primacy agency
burden
Abatement of activities
related to the Class V
Rule
Running Total
212,063
Carry-over from approved burden.
207,301
Program change. Burden associated with
reviewing permit applications and pre-closure
notification forms from operators of MVWDWs
and large capacity cesspools is largely
complete. Most of burden is associated with
reviewing monitoring data submitted by
operators of MVWDWs that obtained a permit.
3,576
210,877
Program change. Short-term increase in
burden associated with mapping of data from
state databases to the national UIC database.
See Appendix B.
2,240
213,117
Program change. Addition of mid-year
reporting of target measures.
-53,454
159,663
Adjustment. Most of the change is associated
with reduced Class II permit application
reviews.
-4,762
National UIC database
UIC Measures reporting
Inventory adjustments
Total change
Comment
-52,400
Total change in state burden between
approved and requested.
Note: Detail may not add exactly to totals due to independent rounding.
Underground Injection Control Program – Information Collection Request
Page 41
UIC Program Burden Reduction Efforts
EPA is exploring several options to reduce the reporting burden and cost to respondents,
while maintaining the protective components of the UIC Program. These are briefly
described below and are discussed in further detail in Appendix D.
Combining/Revising the Reporting Forms: EPA is exploring whether redesigning
some of the UIC Program’s forms would reduce data collection burden, eliminate
confusion, and facilitate completion of the forms. Potential targets for this redesign
include forms 7520-9 (Completion Form for Injection Wells); 7520-10 (Completion
Report for Brine Disposal, Hydrocarbon Storage, or Enhanced Recovery Wells); 7520-12
(Well Rework Record); and 7520-14 (Plugging and Abandonment Plan). EPA is also
assessing the potential for combining several of the reporting forms, including the
Completion forms (7520-9 and 7520-10), the Well Rework form (7520-12), and the
Plugging and Abandonment Plan (7520-14) into a single multi-purpose form. EPA is
also reviewing required reporting from injection well operators to states or DI programs
to identify whether any of the information reported can be eliminated.
Increasing use of Electronic Reporting Methods: Taking advantage of electronic tools
may help reduce reporting burden and recordkeeping costs. EPA is exploring avenues to
increase the electronic reporting options available through the UIC Program.
•
EPA is developing a National UIC database, which will allow electronic
transfer of data between existing state and DI databases and Headquarters’
database. When fully deployed, the national UIC database will eliminate the
need for state UIC Program Directors to complete paper reporting forms,
because Headquarters would be able to collect data for and prepare national
annual reports using the information in the database. See additional
discussion of the UIC database in Section 5(b) of this ICR and in Appendix B.
•
EPA is also exploring a Web-based system through which Class V well
operators could submit inventory and well closure information. This system,
if implemented, will make two existing UIC reporting forms (Form 7520-16,
Well Inventory form and 7520-17, Class V Well Pre-Closure Notification
form) available online. The Web entry option would offer many benefits to
operators and oversight agencies, including: reducing burden and cost to
operators (e.g., no need to mail the hardcopy form); eliminating physical data
entry for States and any potential transcription errors; and facilitating the
notification process associated with the submissions.
Reducing Reporting Frequency: EPA is reviewing the UIC requirements to determine
whether it is possible to reduce reporting frequency (and therefore reporting burden).
EPA found that monitoring and testing activities account for nearly half of the total
operator burden, and has examined these areas for possible burden reduction and
identified some follow-up activities to determine whether burden reduction is possible.
Underground Injection Control Program – Information Collection Request
Page 42
6(g) Burden Statement
EPA estimates that, over the 3 years covered by this request, the total annual burden
on underground injection well owners/operators and primacy agencies associated with
UIC requirements will be 1,000,648 hours and the present value cost will be $139.6
million per year.
Exhibit 6-7
Annual Burden and Cost Associated with All Well Classes
2007-2010
Respondent
Type
Burden
(hours)
Labor Cost
Non-Labor Cost
Total Cost
Responses
Burden/
Response
Cost/
Response
Operators
840,985
$28,862,868
$104,248,907
$133,111,775
375,754
2.24
$354.25
Primacy States
159,663
$6,071,494
$448,922
$6,520,416
49,897
3.20
$130.68
Respondent
total
1,000,648
$34,934,361
$104,697,829
$139,632,191
425,652
2.35
$328.04
22,466
$854,801
$0
$854,801
12,489
1.80
$68.45
1,023,114
$35,789,162
$104,697,829
$140,486,991
438,140
2.34
$320.64
EPA
TOTAL
The annual public reporting and recordkeeping burden for this collection of
information is estimated to average 2.35 hours per response. Burden means the total
time, effort, or financial resources expended by persons to generate, maintain, retain, or
disclose or provide information to or for a Federal agency. This includes the time needed
to review instructions; develop, acquire, install, and utilize technology and systems for
the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing
ways to comply with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or otherwise disclose the
information. An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently valid OMB control
number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9
and 48 CFR chapter 15.
To comment on the Agency's need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent
burden, including the use of automated collection techniques, EPA has established a
public docket for this ICR under Docket ID No. EPA-HQ-OW-2003-0017, which is
available for public viewing at the Water Docket in the EPA Docket Center (EPA/DC),
EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays. The telephone number for the Reading Room
is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426.
An electronic version of the public docket is available through
http://www.regulations.gov. Use www.regulations.gov to submit or view public
comments, access the index listing of the contents of the public docket, and to access
Underground Injection Control Program – Information Collection Request
Page 43
those documents in the public docket that are available electronically. Once in the
system, select “search,” then key in the docket ID number identified above. Also, you
can send comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OW-2003-0017, and
OMB control number 2040-0042 in any correspondence.
Underground Injection Control Program – Information Collection Request
Page 44
Appendix A: Detailed Explanation of Respondent Burden Estimates and
Respondent Universe
Respondents for this information collection include operators of Class I – V wells
and state primacy agencies. The first part of this Appendix contains EPA’s estimates of
respondent burden associated with UIC paperwork requirements. The second part of this
Appendix provides EPA’s assumptions about the number of respondents subject to each
information collection activity.
A.1 Estimating Respondent Burden
EPA has calculated respondent burden hours for each information collection,
reporting, and recordkeeping activity required of well operators and state primacy
agencies. Because required data items vary by well class, separate operator and state
burden estimates have been prepared for each class. Tables A-1 through A-6 contain
detailed estimates of the number of respondents and unit burden hours for required
paperwork-related activities.
EPA recognizes that many UIC information collection activities are performed by
contractors. The operator unit burdens reported in this section represent a composite of
operator time to both perform an information collection activity, and to supervise a
contractor when the contractor performs the activity. The mix of operator versus
contractor labor varies by activity and by well class. Contractor costs are included in the
estimates of operator unit costs.
Burden Associated with Class I Wells
EPA’s estimate of the annual paperwork burden on operators for permitting,
monitoring and testing, reporting and recordkeeping, and closing their facilities and state
burden for administering Class I hazardous and Class I nonhazardous programs are
presented in Tables A-1A and Table A-1B, respectively. Legal, managerial, technical,
and clerical staff hours are shown; Column A presents the total unit burden for each
activity.
Underground Injection Control Program – Information Collection Request
Page A-1
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
Hours and Costs per Response
Description of Requirement
Frequency (A)
Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications
Read permit application directions.
One-time
Gather and submit description of activities
One-time
requiring a permit, facility name and address,
SIC codes, ownership and facility status,
facility location, listing of relevant permits or
construction approvals, description of the
business.
One-time
In DI programs, gather and submit a list of
landowners within one-quarter mile of the
facility boundary.
Prepare and submit a map and tabulation of One-time
all wells within the AoR.
Prepare and submit AoR protocol.
One-time
Prepare and submit maps/cross sections of
local and regional geology, USDWs.
Develop formation testing and stimulation
programs and injection procedures.
Prepare and submit contingency plans for
shut-ins or well failures.
Prepare and submit ambient monitoring plan.
One-time
Prepare and submit Corrective Action Plan.
One-time
Prepare and submit descriptions of logs and
tests, construction schematics & operating
data.
Prepare and submit closure plan, including
demonstration of financial responsibility.
One-time
Prepare and submit post-closure care plan.
One-time
Managerial
Technical
Clerical
Unit
Burden
D
E
F
Total Hours and Costs
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year Total Cost/Year
0.0
0.25
0.25
0.0
0.5
$27
$0
8
4
$217
3.0
2.0
9.0
6.0
20.0
$875
$0
8
160
$7,003
4.0
0.0
0.0
1.2
5.2
$350
$0
2
10
$682
0.0
1.5
5.5
0.0
7.0
$319
$20,163
8
56
$163,855
0.0
0.0
1.3
0.0
1.3
$51
$781
8
10
$6,654
0.0
1.5
16.0
0.0
17.5
$728
$41,862
8
140
$340,714
0.0
2.0
5.0
1.0
8.0
$358
$6,009
8
64
$50,938
0.0
3.0
10.0
2.0
15.0
$647
$234
8
120
$7,046
0.0
3.0
0.0
0.0
3.0
$206
$3,939
8
24
$33,161
0.0
2.0
3.0
2.3
7.3
$312
$9,981
8
58
$82,347
0.0
2.0
8.0
5.0
15.0
$572
$5,007
8
120
$44,634
0.0
1.0
3.0
2.6
6.6
$249
$1,476
8
53
$13,800
0.0
1.4
2.0
1.4
4.8
$208
$1,816
8
38
$16,196
0.0
0.0
26.6
11.4
38.0
$1,311
$7,611
8
304
$71,378
0.0
1.9
30.4
22.8
55.1
$1,867
$3,806
0
0
$0
0.0
1.9
15.2
1.9
19.0
$770
$2,537
8
152
$26,459
One-time
One-time
One-time
One-time
Requirements for active hazardous waste facilities
Gather and submit dates of well operation
One-time
and specific waste information.
Gather and submit hazardous waste release
information.
Develop waste analysis plan.
Legal
C
One-time
One-time
Underground Injection Control Program -- Information Collection Request
Page A-2
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
Hours and Costs per Response
Description of Requirement
Frequency (A)
Prepare and submit schedule of construction One-time
logs and tests.
Requirements associated with completion reports
Prepare and submit completion report.
One-time
Submit results of deviation checks, other logs One-time
and tests; sample formation fluids; test
injection and confining zones.
Demonstrate mechanical integrity (i.e.,
One-time
casing pressure test, radioactive tracer
survey of bottom-hole cement, and
noise/temperature logs to check for
movement along the borehole).
One-time
Submit information on the anticipated
maximum pressure and flow rate.
Submit results of the injection zone and
One-time
confining zone testing programs.
Submit actual injection procedure.
One-time
Demonstrate hydrogeologic compatibility/
One-time
compatability of well materials.
Prepare and submit information on the
calculated AoR.
Legal
Managerial
Clerical
Unit
Burden
D
E
F
Total Hours and Costs
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year Total Cost/Year
0.0
0.0
0.5
0.5
1.0
$32
$0
8
8
$252
0.0
0.0
1.5
2.5
4.0
$119
$0
8
32
$951
0.0
0.0
6.0
1.0
7.0
$258
$30,712
8
56
$247,757
0.0
2.0
18.0
0.0
20.0
$840
$20,030
8
160
$166,958
0.0
0.0
2.0
0.0
2.0
$78
$134
8
16
$1,691
0.0
0.0
1.0
0.0
4.0
1.0
0.0
0.0
5.0
1.0
$226
$39
$33,383
$134
8
8
40
8
$268,864
$1,380
0.0
2.0
6.0
0.0
8.0
$373
$6,677
8
64
$56,398
2.0
0.0
2.0
$78
$2,671
8
16
$21,988
120.0
30.0
174.0
$7,072
$701,033
8
1,392
$5,664,836
41.5
21.0
71.5
$2,751
$9,881
12
858
$151,592
One-time
0.0
0.0
No-migration petition requirements
Gather and submit waste information and
One-time
present modeling data to demonstrate that
0.0
24.0
wastes will not migrate from injection zone.
Requirements associated with permit renewals/modifications and petition modifications
Submit updated components of permit
Occasional
0.0
9.0
application attachments.
Prepare and submit request for Permit
One-time
Modification.
Prepare and submit Petition Modification.
Technical
C
0.0
2.0
6.0
2.0
10.0
$422
$5,742
5
50
$30,817
0.0
24.0
120.0
30.0
174.0
$7,072
$663,613
6
1,044
$4,024,112
0.0
0.0
5.7
0.0
5.7
$222
$0
63
357
$13,897
0.0
0.0
38.0
0.0
38.0
$1,479
$4,006
251
9,520
$1,374,164
One-time
Monitoring/Testing Requirements (Per Facility)
Use continuous recording devices to monitor Continuous
injection pressure, flow rate, volume, and
temperature.
Conduct chemical monitoring of injected
As specified in
wastes as prescribed in waste analysis plan. WAP
Underground Injection Control Program -- Information Collection Request
Page A-3
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
Hours and Costs per Response
Description of Requirement
Conduct additional chemical monitoring as
specified by the Director.
Frequency (A)
Varies
Legal
Managerial
Technical
Clerical
Unit
Burden
C
D
E
F
Total Hours and Costs
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year Total Cost/Year
0.0
0.0
7.6
0.0
7.6
$296
$801
25
190
$27,483
0.0
3.8
5.2
0.0
9.0
$468
$5,530
50
451
$300,523
0.0
1.0
7.0
0.0
8.0
$342
$38,056
13
100
$480,990
0.0
3.8
8.0
0.0
11.8
$577
$6,636
3
37
$22,588
0.0
6.0
18.0
0.0
24.0
$1,120
$15,484
63
1,503
$1,039,927
0.0
0.4
1.9
0.0
2.3
$100
$5,341
63
143
$340,822
0.0
4.0
15.0
6.0
25.0
$1,008
$0
251
6,263
$252,581
0.0
1.0
2.0
1.0
4.0
$172
$1,202
63
251
$86,032
0.0
1.0
2.0
3.0
6.0
$220
$0
1
4
$138
0.0
1.0
0.0
0.0
1.0
$70
$0
63
63
$4,373
0.0
1.0
1.0
1.0
3.0
$133
$0
3
9
$416
0.0
0.0
0.0
5.0
5.0
$121
$0
63
313
$7,570
0.0
0.5
0.0
1.0
1.5
$59
$0
1
2
$59
Conduct casing pressure test and radioactive Annual
tracer survey of bottom-hole cement.
Conduct casing pressure test, radioactive
tracer of bottom-hole cement, and
noise/temperature logs to check for
movement along the borehole.
Conduct casing inspection log at workover.
Occasional
Conduct pressure fall-off test.
Annual
Conduct ambient monitoring.
Annual
Every 5 years
Reporting Requirements (Per Facility)
Prepare and submit report on maximum
Quarterly
injection pressure, total injectate volume, and
monitoring and testing results.
Annual
Prepare and submit report on mechanical
integrity testing.
Notify Director within 24 hours of: planned
Occasional
physical changes to facility, changes that
may result in noncompliance, compliance or
noncompliance with a compliance schedule,
any indication of possible endangerment of a
USDW, or all other noncompliance.
Prepare and submit revised plugging and
Annual
abandonment cost estimate.
Prepare and submit report on: events
Occasional
exceeding operating parameters or triggering
alarms; changes in annular fluid volume;
workovers or other testing.
Recordkeeping Requirements (Per Facility)
Maintain monitoring information, calibration
3 years
and maintenance records, required reports,
application data, monitoring results, and
most recent plugging and abandonment cost
estimate.
Closure Requirements (Per Well)
Prepare and submit notice of intent to close. One-time
Underground Injection Control Program -- Information Collection Request
Page A-4
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
Hours and Costs per Response
Description of Requirement
Prepare and submit closure report.
Conduct pressure fall-off test prior to well
closure.
Demonstrate mechanical integrity (i.e.,
casing pressure test, radioactive tracer of
bottom-hole cement, and noise/temperature
logs to check for movement along the
borehole) prior to closure.
Notify state or local zoning or drilling
authorities and Regional Administrator
following closure.
TOTAL
Frequency (A)
One-time
One-time
Legal
B
C
D
E
F
Total Hours and Costs
Unit
Unit Labor
Unit NonNo. of
Total
Burden
Cost
labor Cost (B) Responses Hours/Year Total Cost/Year
10.0
$451
$2,671
1
10
$3,122
0.0
Managerial
2.0
Technical
8.0
Clerical
0.0
0.0
1.0
5.0
0.0
6.0
$264
$15,484
1
6
$15,749
0.0
2.0
18.0
0.0
20.0
$840
$24,996
1
20
$25,836
0.0
0.5
1.0
3.0
4.5
$146
$0
1
1,201
One-time
One-time
5
24,304 $
$146
15,499,094
Notes:
(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.
(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.
EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-5
Table A-1A (continued)
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Initial/Start-up
Permit Applications
Consider the permit application, AoR, relevant maps and
cross sections, fluid injection rate and volume, proposed
contingency plans, monitoring plans, and construction
procedures as required at 146.70 and prepare draft permit.
Frequency (A)
Unit Burden
(B)
Unit Labor
Cost
Unit Nonlabor
Cost
E
F
Total Hours and Costs
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
One-time
Provide public notice of issuance of a draft permit or intent to
deny.
One-time
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review notice of completion of construction.
One-time
No-Migration Petitions
Review and respond to petition request.
One-time
Public notice/public comment.
One-time
Review and respond to petition modification request.
One-time
Permit renewals/modifications
Review and respond to requests for permit modifications or re- Occasional
issuance.
Underground Injection Control Program -- Information Collection Request
40.0
$1,522
$0
6
242
$9,204
1.0
$38
$0
6
6
$230
6.0
$228
$0
6
36
$1,381
2.0
$76
$0
6
12
$460
7.0
$266
$0
6
42
$1,611
2.0
$76
$0
6
12
$460
18.0
$685
$0
6
109
$4,142
10.0
$380
$0
6
60
$2,301
10.0
$380
$0
5
45
$1,726
30.0
$1,141
$0
9
272
$10,354
Page A-6
Table A-1A (continued)
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Monitoring/Testing
Review quarterly monitoring and testing results.
Review casing pressure test and radioactive tracer survey of
bottom-hole cement.
Review casing pressure test, radioactive tracer survey of
bottom-hole cement, and logs.
Review pressure fall-off test.
Other Reporting
Respond to periodic notifications by owners and operators.
Closure
Review closure and post-closure plans prior to approving
plugging and abandonment.
Witness and review pressure fall-off test prior to authorizing
closure.
TOTAL
Frequency (A)
Quarterly
Annual
Unit Burden
(B)
Unit Labor
Cost
Unit Nonlabor
Cost
E
F
Total Hours and Costs
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
1.5
$57
$0
189
284
$10,808
4.0
$152
$0
38
152
$5,764
Annual
4.0
2.0
$152
$76
$0
$0
9
36
38
73
$1,441
$2,774
Occasional
2.0
$76
$0
5
9
$345
2.0
$76
$0
1
2
$76
24.0
$913
$0
1
388
24
1,420
$913
$54,028
Every 5 years
One-time
One-time
Notes:
(A) For quarterly activities, the number of responses = number of facilities X 4.
(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.
Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-7
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications
Read permit application directions.
One-time
Gather and submit description of activities
One-time
requiring a permit, facility name and address,
SIC codes, ownership and facility status,
facility location, listing of relevant permits or
construction approvals, relevant maps and
cross sections, construction specifics,
description of the business, proposed
injection, formation testing, and stimulation
In DI programs, gather and submit a list of
One-time
landowners within one-quarter mile of the
facility boundary.
Prepare and submit a map and tabulation of One-time
all wells within the AoR.
Prepare and submit maps/cross sections of One-time
local and regional geology, USDWs.
Prepare and submit descriptions of logs and One-time
tests, construction schematics and operating
data.
Develop formation testing and stimulation
One-time
programs and injection procedures.
Prepare and submit contingency plans for
One-time
shut-ins or well failures.
Prepare and submit ambient monitoring plan. One-time
Prepare and submit Corrective Action Plan.
Legal
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor Unit Non-Labor
Cost
Cost (B)
No. of
Total
Responses Hours/Year Total Cost/Year
Managerial
Technical
0.0
0.25
0.25
0.0
0.5
$27
$0
14
7
$381
3.0
2.0
9.0
6.0
20.0
$875
$0
14
280
$12,256
4.0
0.0
0.0
1.2
5.2
$350
$0
3
18
$1,194
0.0
1.5
5.5
0.0
7.0
$319
$16,130
14
98
$230,289
0.0
1.5
16.0
0.0
17.5
$728
$41,862
14
245
$596,249
0.0
2.0
8.0
2.5
12.5
$511
$5,007
14
175
$77,264
0.0
2.0
7.0
1.0
10.0
$436
$6,009
14
140
$90,232
0.0
3.0
10.0
2.0
15.0
$647
$234
14
210
$12,330
0.0
3.0
3.0
3.0
9.0
$399
$3,939
14
126
$60,730
0.0
2.0
3.0
2.3
7.3
$312
$7,678
14
102
$111,860
0.0
1.0
3.0
2.6
6.6
$249
$1,476
14
92
$24,149
0.0
0.0
1.5
2.5
4.0
$119
$0
14
56
$1,664
0.0
0.0
6.0
1.0
7.0
$258
$30,712
14
98
$433,575
0.0
2.0
3.5
0.0
5.5
$276
$8,679
14
77
$125,375
0.0
0.0
2.0
0.0
2.0
$78
$134
14
28
$2,959
One-time
Prepare and submit closure plan, including
One-time
demonstration of financial responsibility.
Requirements associated with completion reports
Prepare and submit completion report.
One-time
Prepare and submit a report of deviation
One-time
checks and other logs and tests during
Demonstrate mechanical integrity (i.e., casing One-time
pressure test and noise/temperature logs to
Submit information on the anticipated
One-time
maximum pressure and flow rate.
Underground Injection Control Program -- Information Collection Request
Page A-8
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Submit results of the formation testing
program.
Submit actual injection procedure.
Frequency (A)
One-time
Clerical
F
Unit
Burden
Unit Labor Unit Non-Labor
Cost
Cost (B)
No. of
Total
Responses Hours/Year Total Cost/Year
Managerial
Technical
0.0
1.0
4.0
0.0
5.0
$226
$33,383
14
70
$470,512
0.0
0.0
1.0
0.0
1.0
$39
$134
14
14
$2,414
0.0
2.0
6.0
0.0
8.0
$373
$6,677
14
112
$98,696
0.0
8.0
11.0
2.0
21.0
$1,035
$4,674
20
420
$114,172
0.0
2.0
6.0
0.0
8.0
$373
$3,338
9
72
$33,403
0.0
0.0
6.7
0.0
6.7
$183
$0
16
107
$2,931
0.0
0.0
85.3
0.0
85.3
$2,332
$0
16
1,365
$37,314
0.0
0.0
38.0
0.0
38.0
$1,479
$2,671
905
34,400
$3,756,669
0.0
0.0
5.7
0.0
5.7
$222
$0
226
1,290
$50,215
0.0
1.0
8.0
0.0
9.0
$381
$16,491
45
407
$763,688
0.0
8.0
16.0
0.0
24.0
$1,181
$15,484
226
5,432
$3,771,701
0.0
0.4
1.5
0.0
1.9
$86
$5,341
226
430
$1,228,193
0.0
0.0
4.0
12.0
16.0
$446
$0
905
14,484
$403,554
0.0
2.0
6.0
4.0
12.0
$470
$1,106
226
2,716
$356,563
One-time
Demonstrate hydrogeologic compatibility/
One-time
compatibility of well materials.
Requirements associated with permit renewals/modifications
Submit updated components of permit
Occasional
application attachments.
Prepare and submit request for permit
modification.
Legal
E
Total Hours and Costs
Occasional
Activities Associated with the Florida Rule
Read and understand the rule.
One-time
Prepare and submit revised permit application One-time
to inject effluent.
Monitoring/Testing Requirements (Per Facility)
Analyze injected fluids.
Per permit
Monitor injection pressure, flow rate and
volume, and annulus pressure.
Continuous
Demonstrate mechanical integrity (i.e., casing Every 5 years
pressure test and noise/temperature logs to
check for movement along the borehole).
Conduct pressure fall-off test.
Annual
Conduct ambient monitoring.
Annual
Reporting Requirements (Per Facility)
Report on: physical, chemical, and other
characteristics of injected fluids; injection
pressure, flow rate, and volume; and
monitoring of USDWs.
Report results of ambient monitoring and
pressure fall-off test.
Quarterly
Annual
Underground Injection Control Program -- Information Collection Request
Page A-9
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Occasional
Notify Director within 24 hours of: planned
physical changes to facility, changes that may
result in noncompliance, compliance or
noncompliance with a compliance schedule,
any indication of possible endangerment of a
Submit periodic updates of financial
Occasional
responsibility for closure that account for
inflation.
Report results of: any required mechanical
integrity tests, other required tests, and well
workovers.
Legal
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor Unit Non-Labor
Cost
Cost (B)
No. of
Total
Responses Hours/Year Total Cost/Year
Managerial
Technical
0.0
1.0
2.0
3.0
6.0
$220
$0
11
68
$2,492
0.0
1.0
0.0
0.0
1.0
$70
$0
75
75
$5,267
0.0
1.0
2.0
1.0
4.0
$172
$1,202
2
9
$3,109
0.0
0.0
0.0
4.0
4.0
$97
$0
226
905
$21,883
0.0
0.5
0.0
1.0
1.5
$59
$0
1
3,380
2
64,130
Occasional
Recordkeeping Requirements (Per Facility)
Maintain monitoring information, calibration
At least 3 years
and maintenance records, required reports,
application data, and monitoring results.
Closure Requirements (Per Well)
Notify the Director before conversion or
abandonment of the well or, in the case of
area permits, before closure of the project.
One-time
TOTAL
$
$59
12,903,342
Notes:
(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.
(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.
EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-10
Table A-1B (continued)
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: States
A
B
C
D
Hours and Costs per Response
Frequency (A)
Description of Requirement
Initial/Start-up
Permit applications
One-time
Consider the permit application, AoR,
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
construction procedures as required at 146.14
and issue notice of intent to deny.
Unit Burden
(B)
One-time
Consider the permit application, AoR,
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
construction procedures as required at 146.14
and prepare draft permit.
Provide public notice of issuance of a draft
One-time
permit or intent to deny.
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review notice of completion of construction.
One-time
Permit renewals/modifications
Review and respond to requests for permit
Occasional
modifications or re-issuance.
Activities associated with the Florida Rule
Read and understand rule.
One-time
Revised primacy application.
One-time
Underground Injection Control Program -- Information Collection Request
Unit Labor
Cost
Unit NonLabor Cost
E
Total Hours and Cost
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
20.0
$761
$0
1
21
$805
40.0
$1,522
$0
10
381
$14,496
1.0
$38
$0
11
11
$403
6.0
$228
$0
11
63
$2,416
2.0
$76
$0
11
21
$805
7.0
$266
$0
11
74
$2,819
2.0
$76
$0
11
21
$805
30.0
$1,141
$0
15
454
$17,257
13.3
$422
$0
1
13
$422
346.7
$11,001
$0
1
347
$11,001
Page A-11
Table A-1B (continued)
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Review revised permit applications to inject
effluent.
Monitoring/Testing
Review casing pressure test and logs.
Review pressure fall-off test.
Review monitoring data submitted by
operators.
Other Reporting
Respond to periodic notifications by owners
and operators.
Closure
Review plugging and abandonment report.
Frequency (A)
One-time
Unit Burden
(B)
Every 5 years
Annual
Quarterly
Unit Labor
Cost
Unit NonLabor Cost
E
Total Hours and Cost
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
10.7
$340
$0
16
171
$5,432
4.0
2.0
$152
$76
$0
$0
34
171
137
342
$5,207
$13,018
2.0
$76
$0
684
1,369
$52,073
1.0
$38
$0
8
8
$288
1.0
$38
$0
1
995
1
3,434
$38
$127,285
Occasional
One-time
TOTAL
Notes:
(A) For quarterly activities, the number of responses = number of facilities X 4.
(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.
Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-12
Class I facility operators rely on contractors to assist them with most information
collection activities, including initial/start-up activities (e.g., permit applications,
completion reports, and no-migration petitions); monitoring and testing (e.g., ambient
monitoring, pressure fall-off tests, and MITs); closure-related reporting; and other
paperwork activities (e.g., permit and petition modifications). The operator burdens
presented in Column A of Tables A-1A and A-1B largely reflect the time to provide
contractor oversight and furnish information to contractors. The costs associated with
contractor labor and other contractor services are presented in Column C of Tables A-1A
and A-1B.
EPA estimates that 70 percent of the new Class I permits issued will be for newly
constructed wells at existing facilities, and that much of the information these applicants
are required to submit is likely to have been developed in connection with permitting
other wells and, therefore, already exists for the facility. EPA assumes the remaining 30
percent of permits will be issued for wells at new facilities, and the burden associated
with applying for a permit will be greater. Thus, the unit burdens presented in this ICR
are a composite of the burdens for permitting new wells at both new and existing
facilities.
EPA assumes that some activities required of Class I permit applicants are
customary business practices. The burden presented in this ICR is the incremental time
and cost for presenting the information in a format acceptable to permitting authorities
and for using EPA-approved tests.
•
Knowledge of subsurface geology is necessary to site a well and locate a
subsurface zone suitable for injection. EPA assumes that 50 percent of the
geological characterization required of permit applicants is customary business
practice. Most of the incremental ICR burden is attributable to the requirement
for submitting detailed maps of local geology.
•
Operators would customarily develop and conduct formation testing and
stimulation programs for the same reasons they would develop geological data.
EPA estimates that 50 percent of the required program development and testing is
customary business practice.
•
Operators would probably develop and retain contingency plans to reduce
potential liability should a well failure occur and develop closure plans to reduce
potential liability when they close their facility. EPA assumes that 25 percent of
the burden to develop these plans is customary business practice.
•
Facility engineers would normally prepare construction schematics and operating
data during the planning and design of an injection facility; EPA estimates that 75
percent of the burden associated with compiling this data is customary business
practice.
Underground Injection Control Program – Information Collection Request
Page A-13
•
As part of their overall industrial process, operators would normally develop
injectate composition data and test the compatibility of the waste stream with well
materials. EPA assumes that 50 percent of the time and cost to develop a waste
analysis plan and to conduct waste compatibility testing is customary business
practice.
•
During construction, operators would probably conduct deviation checks and
other logs to verify that drilling is progressing within expected parameters. EPA
estimates that 50 percent of the requirement to conduct deviation checks and other
logs and tests is customary business practice.
•
Operators would routinely observe injection pressure, flow rate, volume, and
temperature, and analyze the chemical composition of their wastes to verify the
proper operation of their wells, EPA assumes that nearly all the burden for
continuous monitoring and 75 percent of the burden to perform chemical analyses
of their injectate is customary business practice.
Class I Hazardous Facilities
Operator activities associated with Class I hazardous facilities include: permitting
and start-up related reporting; permit renewals and modifications of permits or petitions;
monitoring; reporting and recordkeeping; and closure-related paperwork.
Initial Permitting/Start-up
EPA estimates that, of the new Class I hazardous waste facility operating permits
that are issued each year, most will be for new wells at existing facilities. Thus, in some
cases, operators will adapt existing materials for their permit applications. Note that for
permitting activities, the unit burdens are expressed on a per-application basis.
EPA estimates that the operator burden associated with applying for Class I
hazardous waste injection permits will be 224 hours per permit. (This unit burden
incorporates the above assumptions about customary business practices.) Table A-1A
contains burden estimates for specific components of the permit application. EPA’s
calculation of operator burden and contractor labor costs above customary business
practices is based on the following assumptions:
•
Operators, rather than contractors, will gather the facility description and location
information necessary to complete the permit application form;
•
AoR studies in support of the application will encompass portions of previous
AoR studies at the facility;
•
The burden for developing a corrective action plan assumes that 10 percent of
operators will be required to revise their corrective action plan at the request of
the permitting authority; and
Underground Injection Control Program – Information Collection Request
Page A-14
•
The requirement that operators of active hazardous waste facilities gather and
submit site investigation information [40 CFR 144.31(g)(3)] duplicates Resource
Conservation and Recovery Act (RCRA) requirements and is not included in this
burden estimate.
EPA estimates that the burden on Class I hazardous facility operators associated
with preparing and submitting completion reports will be 49 hours per facility. The
burden to perform specific activities related to completion reports is presented in Table
A-1A. As with permitting activities, EPA anticipates that much of the testing reported in
the completion report would normally be performed in the course of business.
In addition to submitting permit applications, operators of newly constructed
hazardous Class I wells will submit no-migration petitions to the EPA Regional
Administrator. EPA assumes that no-migration petition requirements impose an
additional 174 burden hours on each operator. EPA anticipates that operators already
have compiled much of the extensive data required to support a no-migration petition in
the process of permitting and preparing petitions for existing wells at their facilities,
during the permit application process, or as a customary business practice.
Permit Renewals and Modifications
Class I operating permits are valid for up to ten years, after which, operators must
apply to renew their permits. Additionally, from time to time, operators of Class I
hazardous facilities may need to modify their permits or their no-migration petitions.
Paperwork submittals include: permit renewals, permit modifications, and petition
modifications.
EPA anticipates that the burden associated with renewing permits for a Class I
hazardous facility will be 71.5 hours per renewal. Requirements for permit renewals vary
among states and regions, ranging from submitting a letter of intent to continue operating
the facility to an application similar in scope to one for a new permit. EPA assumes that,
for renewal applications, Class I hazardous facility operators will be required to submit
facility identification information and those attachments that have changed or been
updated since their last application, such as the AoR, corrective action plan, closure plan,
waste identification information, and financial responsibility information. EPA assumes
that Class I hazardous facility operators will not be required to submit no-migration
petitions in support of permit renewal applications.
EPA estimates the operator burden for overseeing contractor activities associated
with preparing and submitting a request for a permit modification is 10 hours per facility,
and the burden associated with modifying a no-migration petition is 174 hours.
Underground Injection Control Program – Information Collection Request
Page A-15
Monitoring/Testing
As indicated above, EPA assumes that operators of Class I hazardous facilities
would routinely observe injection pressure, flow rate, volume, and temperature in the
normal course of business. EPA estimates an incremental annual burden of 5.7 hours per
facility beyond customary business practice.
Class I hazardous facility operators must also monitor the chemical composition
of their wastes according to the waste analysis plan submitted with their permit
application. As with monitoring of injection pressure, flow rate, and volume, EPA
assumes that operators would perform some chemical monitoring during the course of
business. EPA estimates the additional annual burden for chemical monitoring is 38
hours per facility per quarter for operators to collect samples and send them to
commercial laboratories for analysis. In addition, EPA assumes that, for various reasons,
permitting authorities will require 10 percent of facilities to conduct additional
monitoring under 40 CFR 146.68(a)(3), and that the total burden will be 7.6 hours per
facility per quarter. EPA assumes that all monitoring will be conducted quarterly.
The burden associated conducting annual MITs (i.e., conducting a casing pressure
test and radioactive tracer survey), and five-year MITs, which also include temperature,
noise, or other logs to check for movement along the borehole is estimated to be 8 hours
per facility.
Operators must conduct casing inspection logs when their wells are worked over.
EPA estimates the total annual burden will be 12 hours per log.
Class I hazardous facility operators must conduct a pressure fall-off test every
year; EPA estimates that the annual burden associated with this requirement will be 24
hours per facility. EPA estimates that the total burden associated with required annual
ambient monitoring at Class I hazardous facilities will be 2.3 hours per facility.
Reporting and Recordkeeping
Operators of Class I hazardous facilities will spend 104 hours per facility
reporting the results of required monitoring and testing each year: this includes 25 hours
per report (100 hours annually) for quarterly monitoring reports, and 4 hours to report on
the results of MITs. In addition, EPA assumes that 5 percent of operators will spend 3 to
6 hours annually submitting occasional reports (e.g., on changes to the facility; planned
workovers; noncompliance or anticipated noncompliance; or events triggering alarms or
shutdown devices). Operators will also spend one hour submitting revised plugging and
abandonment cost estimates.
EPA estimates the annual recordkeeping burden for Class I hazardous facilities to
be 5 hours. Operators must maintain monitoring information, calibration and
maintenance records, required reports, application data, and monitoring results for three
years; and keep their most recent plugging and abandonment cost estimate for one year.
Underground Injection Control Program – Information Collection Request
Page A-16
Closure
EPA estimates that the total annual burden associated with closure of a Class I
hazardous well is 42 hours. This includes 1.5 hours to notify the Regional Administrator
prior to closing, 6 hours to perform pressure fall-off tests, 20 hours for MITs, and 10
hours for a closure report. EPA assumes that the operator will not revise the closure plan
or the post-closure care plan. The operator will also spend 4.5 hours on third-party
notification activities, such as notifying state or local zoning or drilling authorities and
the Regional Administrator following closure.
Class I Nonhazardous Facilities
Paperwork requirements for operators of Class I nonhazardous facilities include
permitting and start-up related reporting, permit renewals and modifications, monitoring
and testing, reporting and recordkeeping, and closure-related paperwork activities.
Initial Permitting/Start-up
As was the case for Class I hazardous facilities, EPA estimates that the majority
of the new nonhazardous waste injection permits issued each year will be for new wells
at existing facilities. Unit burdens are reported on a per-application basis.
Requirements associated with permit applications add 110 hours to the customary
business activities of Class I nonhazardous facility operators. Column A of Table A-1B
presents EPA’s estimates of burdens for specific components of a permit application.
Class I nonhazardous waste permit applicants must submit much of the same information
as operators of hazardous facilities. EPA assumes that the burden on nonhazardous
facilities is the same as that for Class I hazardous waste facilities, with the exception of
the following:
•
Class I nonhazardous facility operators will study a smaller AoR. Consequently,
the burden for the AoR study and for developing a corrective action plan for wells
in the AoR will be lower for these operators.
•
Nonhazardous facility operators are not required to develop waste analysis plans
or plans to reduce the quantity or toxicity of their injectate; nor are they required
to gather and submit hazardous waste release information.
EPA estimates that the unit burden on Class I nonhazardous facility operators for
preparing and submitting completion reports is 32.5 hours. This unit burden varies from
that for Class I hazardous facilities, as Class I nonhazardous facility operators are not
required to submit information on the calculated AoR. Burden estimates for specific
activities associated with completion of new wells are presented in Column A of Table
A-1B.
Underground Injection Control Program – Information Collection Request
Page A-17
Permit Renewals/Modifications
As with hazardous facility operators, EPA assumes that applicants for
nonhazardous injection permit renewals will submit only those attachments to the
application form that have changed since the original application. Each renewal
application will take an estimated 21 hours. EPA estimates the operator burden
associated with contractor oversight to prepare and submit a request for a permit
modification to be 8 hours.
Permitting Activities for Class I Municipal Disposal Facilities in Florida
Class I municipal well operators in Florida whose facilities have caused or may
cause fluid movement and wish to continue injecting will submit applications to modify
their permits to meet the requirements of the Florida Class I rule. EPA estimates that the
average burden incurred by each Class I municipal well operator to meet the new
requirements will be 276 hours (or 92 hours per year for the period covered by this ICR).
Affected operators will undertake two information collection activities, as described
below:
•
Read and understand the rule. It is estimated that each Class I municipal well
operator will require 20 hours (an average of 6.7 hours per year) to read the
rule and understand its implications for future operations.
•
Prepare and submit revised permit application. Because permits are already
required under existing UIC regulations, the new permit is expected to be a
one-time resubmission of an updated permit application. The operator burden
for preparation and submission of a revised injection permit is estimated to be
256 hours (an average of 85.3 hours per year).
These burden estimates are consistent with the estimates in the ICR for the Class I
Rule (EPA ICR number 370.17).
Monitoring/Testing
EPA assumes that operator staff will observe and record injection pressure, flow
rate, volume and temperature and sample their injectate periodically as normal business
activities; however to comply with UIC requirements, operators spend more time on
these activities than they otherwise would. Class I nonhazardous facility operators will
spend 38 hours per quarter to monitor their injectate; 5.7 hours to monitor injection
pressure, flow rate, and volume; 1.9 hours to conduct ambient monitoring; and 24 hours
to conduct an annual pressure fall-off test. In addition, approximately 20 percent of
operators will spend 9 hours to demonstrate mechanical integrity (i.e., five-year MIT).
Underground Injection Control Program – Information Collection Request
Page A-18
Reporting and Recordkeeping
Operators will spend 16 hours per facility reporting quarterly on the chemical and
physical characteristics of injectate, flow rate, and volume. Class I nonhazardous facility
operators will spend 12 hours per facility to report on the results of ambient monitoring
and the pressure fall-off test.
EPA assumes that Class I nonhazardous facility operators will spend one hour
each year to update and submit revised plugging and abandonment cost estimates. EPA
also assumes that operators will spend 4 to 6 hours submitting additional reports (e.g., of
changes to the facility; planned workovers; noncompliance or anticipated noncompliance;
or events triggering an alarm or shutdown).
EPA estimates the annual recordkeeping burden on Class I nonhazardous facilities
to maintain monitoring information, calibration and maintenance records, required
reports, application data, and monitoring results for three years will be 4 hours per
facility.
Closure
EPA estimates the annual burden on operators of Class I nonhazardous facilities
associated with closure is 1.5 hours for notifying the Director.
Burden on Primacy Agencies Associated with Class I Wells
State primacy agencies’ burden as users of data associated with implementing
Class I programs arise from program oversight, reviewing and responding to permit
applications and completion reports, monitoring and testing data, and closure reports
submitted by operators within their states. State burden associated with oversight of
Class I programs is presented in Column A of Tables A-1A and A-1B.
EPA estimates that states will spend from 20 to 62 hours per permit application
reviewing applications for hazardous or nonhazardous Class I wells (depending on
whether the permit is issued or denied), and 30 hours reviewing requests for permit
modifications or renewals. EPA regional offices review all no-migration petitions and
petition modification requests submitted by operators of Class I hazardous waste
injection facilities; however, state primacy agencies assist the regions with this review.
States spend 28 hours per no-migration petition application and 10 hours per petition
modification request on this assistance.
The State of Florida will incur burden associated with the requirements of the rule
for Class I municipal wells in Florida. Three information collection activities will be
required:
•
Reading and understanding the Rule: state regulators will require 40 hours (or
13.3 hours per year) for this activity.
Underground Injection Control Program – Information Collection Request
Page A-19
•
Revised primacy application: the State will reapply for primacy status in order to
administer the new regulation. The burden for this application revision is
estimated to be 1,040 hours (346.7 hours per year).
•
Review of revised permits to inject effluent under the Rule: Florida, as the
primacy agent, is expected to review and approve permit applications to inject
wastewater under the rule. State burden for review and approval of revised permit
applications is estimated to be approximately 32 hours (or 10.7 hours annually)
per permit.
State primacy agencies spend from 2 to 4 hours per report reviewing monitoring
and MIT data or occasional reports submitted by operators (details are presented in
Tables A-1A and A-1B). States spend one hour reviewing plugging and abandonment
reports submitted by operators of Class I nonhazardous waste facilities, and 26 hours
reviewing reports and testing results associated with closure of hazardous waste facilities.
Burden Associated with Class II Wells
EPA’s estimate of the annual paperwork burden on operators for permitting,
monitoring and testing, reporting and recordkeeping, and closing wells, and state burden
for administering Class II programs, are presented in Table A-2.
Class II Operators
Initial Permitting/Start-up
EPA anticipates that 28 percent of Class II permit applications will be for area
permits and 73 percent will be for individual permits. On average, each area permit
application will cover 3.1 wells. EPA estimates that 85 percent of the applications will
be approved. EPA or state primacy agencies will deny applications that do not meet
construction standards and others will be withdrawn by owners.
Underground Injection Control Program – Information Collection Request
Page A-20
Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Legal
Managerial
Initial/Start-up Requirements
Requirements associated with permit applications (Per Permit Application)
Read permit application directions.
One-time
0.0
0.0
Gather and submit: a description of activities One-time
requiring a permit, facility name and address,
SIC codes, ownership and facility status,
facility location, listing of relevant permits or
construction approvals, topographic maps,
description of the business.
Technical
F
Total Hours and Costs
Clerical
Unit Burden
Unit Labor
Cost
Unit Non- No. of
Labor Cost Responses
Total
Hours/Year
Total Cost/Year
0.5
0.5
1.0
$32
$0
1,411
1,411
$44,517
0.1
0.0
1.0
0.4
1.5
$57
$0
1,411
2,117
$79,875
For DI programs, gather and submit a list of One-time
all land owners within one quarter mile of the
facility boundary.
0.2
0.0
0.0
1.0
1.2
$40
$168
71
85
$14,717
Prepare and submit plugging and
abandonment plan.
One-time
0.0
0.6
4.8
0.6
6.0
$243
$0
1,411
8,466
$343,213
Show evidence of financial responsibility for
closure.
One-time
0.0
5.0
5.0
10.0
20.0
$785
$0
1,411
28,220
$1,108,264
Prepare and submit proposed Corrective
Action Plan.
One-time
0.0
0.3
2.9
0.2
3.4
$139
$0
141
480
$19,566
0.0
1.0
9.6
0.7
11.3
$460
$0
28
319
$12,993
0.0
0.0
1.0
0.0
1.0
$39
$33
314
314
$22,682
0.0
0.1
2.9
2.0
5.0
$168
$182
266
1,337
$93,163
0.0
0.1
1.8
0.1
2.0
$79
$0
1,411
2,822
$112,128
0.0
0.5
8.0
1.0
9.5
$370
$0
1,411
13,405
$522,767
0.0
0.1
2.3
0.1
2.5
$99
$200
1,411
3,528
$422,206
0.0
0.0
2.8
0.2
3.0
$114
$0
1,411
4,233
$160,613
Prepare and submit revised Corrective Action One-time
Plan.
Prepare and submit Area of Review map.
(State/DI Program performs study)
One-time
Prepare and submit Area of Review map and One-time
study.
Prepare and submit proposed operating data. One-time
Prepare and submit geological data on the
injection and confining zone.
One-time
Prepare and submit name and depth to
bottom of USDWs.
One-time
Prepare and submit schematic of the well.
One-time
Underground Injection Control Program -- Information Collection Request
Page A-21
Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Requirements associated with completion reports (Per Well)
Prepare and submit completion report.
One-time
Legal
Managerial
Technical
F
Total Hours and Costs
Clerical
Unit Burden
Unit Labor
Cost
Unit Non- No. of
Labor Cost Responses
Total
Hours/Year
Total Cost/Year
0.0
0.0
1.5
2.5
4.0
$119
$0
1,830
7,322
$217,494
0.0
0.2
1.9
0.2
2.4
$97
$4,006
275
659
$1,126,577
0.0
0.0
Requirements associated with permit reviews/modifications (Per Permit/Per Operator)
Respond to issues raised during permit
Every 5 years
review.
0.0
0.5
Prepare and submit request for permit
Occasional
modification.
0.0
0.4
7.0
0.0
7.0
$272
$180
1,830
12,813
$828,718
2.0
0.5
3.0
$125
$0
1,440
4,319
$179,720
2.8
0.8
4.0
$156
$0
3,599
14,395
$562,342
Perform and report on appropriate logs and
other tests during construction.
One-time
Demonstrate mechanical integrity.
One-time
Monitoring/Testing Requirements (Per Operator)
Monitor the nature of injected fluids.
As necessary
to obtain
representative
Record injection pressure, flow rate, and
At least every
cumulative volume.
30 days.
Demonstrate mechanical integrity.
Reporting Requirements (Per Operator)
In DI programs, gather and submit
groundwater monitoring data, analyses of
injected fluids, a description of geologic
strata, and other items as requested.
0.0
0.0
2.0
0.0
2.0
$78
$40
57,580
115,161
$6,789,425
0.0
0.0
0.6
0.3
0.8
$29
$0
172,741
145,103
$4,934,767
0.0
0.0
3.0
0.0
3.0
$117
$1,803
28,790
86,371
$55,260,907
0.0
3.0
22.0
5.0
30.0
$1,187
$0
3
96
$3,782
0.0
0.0
0.5
0.5
1.0
$32
$0
15
15
$482
0.0
1.0
1.5
2.5
5.0
$189
$0
864
4,319
$162,929
Every 5 years
Occasional
In DI programs, notify Regional Administrator Every 5 years
30 days prior to MIT.
Occasional
Notify Director of (1) any planned physical
changes to facility; (2) changes that may
result in noncompliance, (3) permit transfers,
(4) compliance or noncompliance with
compliance schedules, (5) possible
endangerment to a USDW.
Report monitoring data, including monthly
records of injected fluids, any changes in
characteristics or sources of injected fluids.
Annual
Report MIT results.
Annual
0.0
0.0
3.3
1.7
5.0
$170
$0
14,395
71,976
$2,447,093
0.0
0.0
1.0
0.0
1.0
$39
$0
2,879
2,879
$112,070
Underground Injection Control Program -- Information Collection Request
Page A-22
Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Recordkeeping Requirements (Per Operator)
Retain records of permitting data, nature and At least 3 years
composition of injected fluids, and all
monitoring results.
Closure Requirements (Per Operator)
In DI programs, notify director of revisions to
plugging and abandonment plan.
Legal
Managerial
Technical
F
Total Hours and Costs
Clerical
Unit Burden
Unit Labor
Cost
Unit Non- No. of
Labor Cost Responses
Total
Hours/Year
Total Cost/Year
0.0
0.0
1.0
3.0
4.0
$111
$0
14,395
57,580
$1,604,284
0.0
0.5
2.5
1.0
4.0
$156
$0
1
2
$82
0.0
1.0
0.0
2.0
3.0
$118
$0
1,044
3,132
$123,362
0.0
0.0
4.5
1.5
6.0
$211
$240
52
313
$23,601
0.0
0.5
0.5
1.0
2.0
$79
$0
72
313,913
144
593,332
One-time
Notify the Director before conversion or
abandonment of the well, or in the case of
area permits, before closure of the project.
One-time
In DI programs, submit a plugging and
abandonment report within 60 days after
plugging a well.
One-time
Other Requirements (Per Operator)
In DI programs, submit revised demonstration Occasional
of financial responsibility.
TOTALS
$
$5,658
77,339,997
Note: Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-23
Table A-2 (continued)
Annual Paperwork Burden and Costs Associated with Class II Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency
Initial/Start-up
Permit applications (Per Permit Application)
Review permit application and supporting
One-time
documentation and prepare draft permit.
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review operator's AoR map and study.
One-time
One-time
Review operator's AoR map and perform
AoR study.
Review completion report.
One-time
E
F
Total Hours and Cost
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
Number of
Responses
Total
Hours/Year
6.0
2.0
2.0
4.0
5.0
$228
$76
$76
$152
$190
$0
$0
$0
$0
$0
1,340
1,340
1,340
1,340
253
8,042
2,681
2,681
5,362
1,264
$305,996
$101,999
$101,999
$203,998
$48,087
2.5
2.0
$95
$76
$0
$0
314
1,739
784
3,478
$29,838
$132,317
1.0
$38
$0
1,367
1,367
$52,030
4.0
$152
$0
3,419
13,675
$520,299
0.5
$19
$0
2,735
1,367
$52,030
0.3
$10
$0
13,675
3,419
$130,075
1.0
$38
$0
0
0
$0
Permit reviews/modifications (Per Operator)
Review each permit to determine whether it Every 5 years
should be modified, revoked and reissued, or
terminated.
Review request for permit modification or re- Occasional
issuance.
Monitoring/Testing (Per Operator)
Every 5 years
Review mechanical integrity test data
submitted by operators.
Review monitoring data submitted by
Annual
operators.
Recordkeeping
One-time
Maintain administrative record in DI
programs.
Underground Injection Control Program - Information Collection Request
Total
Cost/Year
Page A-24
Table A-2 (continued)
Annual Paperwork Burden and Costs Associated with Class II Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency
Other Reporting (Per Operator)
Respond to periodic notifications by owners Occasional
and operators.
Closure (Per Operator)
For DI programs, review plugging and
One-time
abandonment report.
E
F
Total Hours and Cost
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
Number of
Responses
Total
Hours/Year
2.0
$76
$0
820
1,641
$62,436
1.0
$38
$0
0
29,722
0
45,761
$0
$1,741,103
TOTAL
Total
Cost/Year
Note: Numbers may not add due to rounding
Underground Injection Control Program - Information Collection Request
Page A-25
The average burden for preparing permit application forms and the supporting
documentation is approximately 67 hours per application. The time that a particular
operator will spend on a permit application will likely vary, depending on the specific
state submission requirements, the operator’s level of experience, whether the application
is for an individual or an area permit, the use of contractors, and other factors. The
following paragraphs summarize the burdens for various components of a Class II permit
application.
EPA estimates that operators will spend 2.5 hours per applicant to read the
application directions and fill out the permit application form. With respect to the
supporting documentation, EPA assumes that operators would normally prepare a well
schematic and some geological, hydrogeological, and operating data in the course of
business, and/or utilize existing data for the project. For area permits, the operator
generally submits supporting data for a representative well. Table A-2 provides estimates
of the time beyond customary business practice required to prepare the attachments to a
Class II permit application. EPA estimates that permit applicants will spend an average
of:
•
9.5 hours to prepare geological data on injection and confining zones;
•
6 hours to prepare plugging and abandonment plans;
•
2.5 hours to determine the name and depth to the bottom of USDWs;
•
3 hours to prepare schematics of the wells;
•
2 hours to prepare proposed operating data; and
•
20 hours to prepare financial responsibility information.
Based on previous studies of state AoR practices and requirements, EPA projects
that state primacy agencies and EPA Regions will determine that a complete AoR is not
necessary for approximately 60 percent of Class II permit applicants.1 A complete AoR
study may not be performed because the:
•
AoR is entirely overlapped by the AoRs of wells previously studied.
•
State primacy agency has cross-referenced AoR studies, ensuring AoR coverage.
•
Operator has been granted a state variance based on factors relating to geologic
setting, and/or well conditions.
1
The Cadmus Group, Inc., Technical Issues Paper for Developing Area of Review Guidance (Draft),
Contract No. 68-C4-0011, Work Assignment No. 1-38 (September 8, 1995).
Underground Injection Control Program – Information Collection Request
Page A-26
•
Well is located in a unitized project, and many of the elements of AoR studies
were previously performed during unitization.
Previous EPA studies also have shown that many state primacy agencies perform
all or most of the tasks involved in the AoR study. In these cases, the operator typically
submits only a map of the AoR and a list of wells in the AoR. EPA projects that
approximately 19 percent of applicants will submit an AoR map and an AoR study as
part of the permit application. Each AoR map and study will require an average of 5
hours of operator time.2 Another 22 percent of applicants will submit an AoR map and a
listing of the wells in the AoR, and the state primacy agency will perform most or all of
the tasks involved in the AoR study. The operator time to prepare the map and listing of
wells is about one hour.
Based on the historical incidence of corrective action, EPA estimates that 90
percent of permit applicants will submit brief corrective action plans demonstrating that
corrective action is not necessary to address potential conduits to USDWs in the AoR.
Each of these plans will require one hour to prepare. The remaining 10 percent of
applicants will submit more complex corrective action plans to address specific problems
identified by the AoR study. Each comprehensive corrective action plan will take
approximately 25 hours to prepare. Thus, the average time to prepare a corrective action
plan is 3.4 hours. EPA regional or state primacy staff will require 20 percent of
applicants to revise their complex corrective action plans. Each revised plan will take
about 11.3 hours to prepare.
Unless exempted by the Director, operators in DI programs are required to submit
a list of landowners within ¼ mile of the facility boundary. EPA estimates that these
applicants will each take 1.2 hours to research property ownership records and prepare
the list. This unit burden assumes that operators will supply about 30 percent of the
effort, and the remaining 70 percent will be performed by contractors.
Prior to obtaining approval to begin injection, operators must submit completion
reports for each new Class II well. With the completion report, operators must submit
results of MITs and any well logs and tests required by the Director. Operators will take
approximately 4 hours per well to fill out the completion form and gather the supporting
documentation. The MIT will require approximately 7 hours of operator time, given
current MIT practices for various completion types.
Most operators will submit logs for offset wells in their projects. EPA projects
that Directors will require some permit applicants to perform and report on new well logs
and tests, such as cement bond, temperature, or density logs. Directors are more likely to
require additional logs and tests for II-D wells than for II-R wells. EPA assumes that
operators will perform additional logs and tests for 50 percent of new II-D wells and 5
2
EPA estimates that some operators will utilize contract AoR services. The unit burden for operators
assumes that operators will perform about 67 percent of the AoR burden themselves and contract out for
the remaining 33 percent.
Underground Injection Control Program – Information Collection Request
Page A-27
percent of new II-R wells. Each of the logs and tests will take approximately 2.4 hours of
operator time, primarily to supervise contractors.
Permit Reviews/Modifications
Class II permits are valid “up to the operating life of the facility” [40 CFR
144.36]. While the regulations do not require permit renewals, most permits are reviewed
every five years. These reviews may be formal compliance reviews or informal reviews,
usually conducted in conjunction with reviews of MIT results. Operators may be
required to respond to any issues raised during the permit review. For purposes of
calculating operator burden, EPA assumes that each operator will take 3 hours to respond
to issues raised during the review.
Operators occasionally submit requests for permit modifications in response to
changes in well ownership or injection practices, to add wells to existing area permits,
and for other reasons. EPA expects that the average time to prepare each request is 4
hours.
Monitoring/Testing
For purposes of estimating the number of respondents for monitoring and testing,
EPA assumes that the typical Class II operator has approximately 10 wells. An operator
with wells in multiple states is treated as separate operators, since the operator would
have to submit separate reports to each state primacy agency or EPA regional office.
In general, all operators located in DI programs and operators of commercial II-D
wells in primacy states are required to submit annual injectate analyses. EPA estimates
that approximately 40 percent of Class II operators submit annual injectate analyses each
year. EPA assumes that operators submit samples for approximately 20 percent of their
wells. Each operator takes 2 hours (1 hour per well) per year to sample and analyze their
injectate. This includes the time for operators to analyze their injectate or, in some cases,
send it to a commercial laboratory for analysis.
Most operators are required to observe injection pressure, flow rate, and
cumulative volume weekly for II-D wells and monthly for II-R wells. EPA anticipates
that operators, especially operators of II-R wells, perform periodic observations of
pressure, flow rate, and cumulative volume as a customary business practice. Thus, the
incremental time to perform these observations is about 0.83 hours per operator (0.08
hours, or 5 minutes, per well) per month. This represents the time to record the data on a
field report.
EPA assumes that 20 percent of operators will perform MITs on their wells each
year. Each operator will spend 3.0 hours (0.3 hours per well) performing MITs. The unit
burden assumes that contractors perform many of the tasks involved in an MIT.
Underground Injection Control Program – Information Collection Request
Page A-28
Reporting and Recordkeeping
Each year, Class II operators spend about 5 hours to prepare annual monitoring
reports. These reports include summaries of monthly or weekly observations of flow,
pressure, and cumulative volume. In addition, 20 percent of operators will spend 1 hour
per operator to prepare reports on MITs performed.
From time to time, operators submit other reports or notify UIC staff of various
events. These include notifications of planned changes to the injection facility, permit
transfers, progress in achieving compliance milestones, and noncompliance or
malfunctions which may endanger a USDW. EPA estimates that approximately 6
percent of operators submit one of these occasional reports each year. Operators will
spend an average of 5 hours to prepare each report.
Operators of rule-authorized wells in DI states may be required to gather and
submit groundwater monitoring data, analyses of injected fluids, a description of geologic
strata, and other items as requested. EPA projects that each request will take 30 hours to
prepare. In addition, operators of rule-authorized wells will spend one hour per operator
to notify the Region prior to performing MITs.
Each operator will spend about 4 hours annually to maintain records on
permitting, monitoring, and testing.
Closure
Each operator that closes a well will spend about 3.0 hours (0.3 hours per well) to
notify UIC officials prior to abandoning the wells.
In addition, EPA assumes that operators in DI programs who elect to plug their
wells in a manner different from the one specified in their plugging and abandonment
plans will spend 4 hours to prepare revised plugging and abandonment plans. In addition,
operators who plug wells in DI programs will spend 6 hours to prepare and submit
plugging and abandonment reports.
Other Activities
DI programs may require some operators of wells with lifetime permits to submit
revised financial responsibility demonstrations. EPA estimates that 10 percent of
operators in DI programs will each take 2 hours to prepare and submit revised financial
data.
Underground Injection Control Program – Information Collection Request
Page A-29
Burden on Primacy Agencies Associated with Class II Wells
Class II primacy agencies review and respond to permit applications and permit
reviews/modifications, and monitoring and testing data submitted by operators within
their states. State burden associated with each activity involved in the oversight of Class
II programs is presented in Column A of Table A-2.
EPA estimates that states will spend 23.5 hours per permit application reviewing
Class II injection well applications. Primacy agency staff spend one hour to determine
whether to reissue, modify, or revoke each permit during the five-year review process.
Primacy agencies spend four hours reviewing each request for a permit modification or
renewal.
State primacy agencies spend from ¼ to ½ hour per report reviewing monitoring
and MIT data or occasional reports submitted by Class II operators (see details in Table
A-2).
Burden Associated with Class III Wells
Table A-3 contains EPA’s estimate of the annual paperwork burden on operators
for permitting, monitoring and testing, reporting and recordkeeping, and closing their
facilities, and state burden for administering Class III programs.
Class III Operators
Permitting/Start-up
A Class III operator will spend an average of 132 hours to prepare a new permit
application form and the required attachments. Reading the directions and filling out the
application form account for 11 hours of the total. Table A-3 provides estimates of the
operator time, in addition to customary business practice, required to prepare each
component of the permit application. EPA estimates that permit applicants will spend an
average of:
•
32 hours to prepare AoR maps and studies;
•
22 hours to prepare maps and cross sections of USDWs within the AoR, and of
local and regional geology;
•
16 hours to prepare monitoring plans;
•
14 hours to prepare proposed corrective action plans;
•
9 hours to prepare proposed operating data, formation testing and stimulation
programs, and injection procedures;
Underground Injection Control Program – Information Collection Request
Page A-30
Table A-3
Annual Paperwork Burden and Costs Associated with Class III Wells: Operators
A
B
C
D
E
F
Hours and Costs per Response
Description of Requirement
Frequency
Initial/Start-up Requirements
Requirements associated with permit applications (Per Permit Application)
Read permit application directions.
One-time
Gather and submit the following information: (1) a description One-time
of activities requiring a permit, (2) facility name and address,
(3) SIC codes, (4) ownership and facility status, (5) facility
location, (6) listing of relevant permits or construction appro
For DI programs, gather and submit a list of all land owners
within one quarter mile of the facility boundary.
Prepare and submit plugging and abandonment plan.
Show evidence of financial responsibility for closure.
Prepare and submit proposed Corrective Action Plan.
Prepare and submit revised Corrective Action Plan.
Prepare and submit AoR map and study.
Prepare and submit maps and cross-sections of USDWs within
AoR, local geology, and regional geology.
Prepare and submit proposed operating data, formation testing
program, stimulation program, and injection procedure.
Prepare and submit schematic of the well.
Prepare and submit monitoring plan.
Legal
Managerial
0.0
Technical
Clerical
Total Hours
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
No of
Responses
Total
Hours/Year Total Cost/Year
0.0
0.5
0.5
1.0
$32
$0
32
32
$1,010
0.5
2.0
4.7
2.8
10.0
$430
$0
32
320
$13,771
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
2.0
1.0
3.2
0.0
6.4
1.0
10.0
8.0
25.5
1.0
1.6
2.0
2.0
1.0
3.4
1.2
8.0
3.5
14.0
10.0
32.0
$40
$288
$122
$577
$405
$1,295
$168
$0
$0
$0
$0
$995
27
32
32
32
6
32
32
256
112
448
64
1,024
$5,629
$9,210
$3,910
$18,472
$2,595
$73,288
0.0
0.0
18.0
4.0
22.0
$797
$200
32
704
$31,925
0.0
0.0
0.0
2.0
0.0
0.0
6.0
4.2
12.0
1.0
0.8
4.0
9.0
5.0
16.0
$397
$183
$564
$0
$0
$0
32
32
32
288
160
512
$12,716
$5,851
$18,042
0.0
0.0
1.5
2.5
4.0
$119
$0
21
84
$2,495
0.2
1.0
1.9
8.0
0.2
1.0
2.4
10.0
$97
$405
$4,583
$4,006
1
21
3
210
$6,012
$92,637
3.0
2.0
1.0
22.0
0.0
4.0
4.0
28.0
$248
$1,093
$0
$0
33
24
132
672
$8,196
$26,225
0.0
6.0
2.0
8.0
$282
$0
45
362
$12,764
0.0
16.1
3.3
128.7
1.3
16.1
4.6
160.9
$161
$6,522
$0
$64,442
4,290
9
19,884
1,457
$690,195
$642,591
0.0
27.5
3.0
30.5
$1,143
$0
262
7,982
$299,112
One-time
One-time
One-time
One-time
One-time
One-time
One-time
One-time
One-time
One-time
Requirements associated with completion reports (Per Well)
Prepare and submit completion form and supporting
One-time
documentation (7520-9).
Prepare and submit appropriate logs and tests during
One-time
construction.
Demonstrate mechanical integrity.
One-time
0.0
0.0
Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)
Respond to issues raised during permit review.
Every 5 years
0.0
Prepare and submit request for permit modification.
Occasional
0.0
Monitoring/Testing Requirements (Per Facility)
Monitor the nature of injected fluids.
As necessary
to obtain
representative
0.0
data
Monitor injection pressure and flow rate or volume of injected
Semi-monthly/
0.0
fluids, or meter and record injected and produced fluid
Continuous
Demonstrate mechanical integrity.
Every 5 years
0.0
Monitor the fluid level in the injection zone where appropriate
Semi-monthly
and monitor parameters chosen to measure water quality in the
monitoring wells.
0.0
Underground Injection Control Program -- Information Collection Request
Page A-31
Table A-3
Annual Paperwork Burden and Costs Associated with Class III Wells: Operators
A
B
C
D
E
F
Hours and Costs per Response
Description of Requirement
Reporting Requirements (Per Facility)
Notify Director of (1) planned physical changes to the facility,
(2) anticipated noncompliance, (3) permit transfers, (4)
progress in meeting compliance schedule in permit, (5)
possible endangerment to a USDW.
Report to the Director on required monitoring, mechanical
integrity tests, and other required tests.
Recordkeeping Requirements (Per Facility)
Retain records of permitting data, calibration and maintenance
data, and monitoring results.
Closure Requirements (Per Facility)
Notify the Director before conversion or abandonment of the
well or in the case of area permits before closure of the project.
In DI programs, submit a plugging and abandonment report
within 60 days after plugging a well or at the time of the next
quarterly report.
Other Requirements (Per Facility)
In DI programs, submit revised demonstration of financial
responsibility.
Frequency
Legal
Managerial
Technical
Clerical
Total Hours
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
No of
Responses
Total
Hours/Year Total Cost/Year
Occasional
0.0
1.0
3.0
2.0
6.0
$235
$0
17
99
$3,877
0.0
1.0
10.0
19.0
30.0
$918
$0
660
19,800
$606,127
0.0
0.0
0.4
3.0
3.4
$88
$0
165
561
$14,535
0.0
1.0
0.5
0.5
2.0
$101
$0
2
4
$203
0.0
0.0
0.8
0.3
1.0
$35
$0
1
1
$40
0.0
0.5
0.5
1.0
2.0
$79
$0
92
184
55,387
$7,220
2,608,646
Quarterly
At least 3
years
One-time
One-time
Occasional
TOTALS
5,996
Note: Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-32
Table A-3 (continued)
Annual Paperwork Burden and Costs Associated with Class III Wells: States
A
Program Oversight Activities
Frequency
Initial/Start-up
Permit applications (Per Permit Application)
Consider the permit application, area of review, One-time
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
t tithe permit
d application,
d i area of
ti review,
f
One-time
Consider
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
t public
ti
d of issuance
d
ft
Provide
notice
of a ddraft
One-time
permit or intent to deny.
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review completion report.
One-time
Underground Injection Control Program -- Information Collection Request
B
C
D
Hours and Costs per Response
Unit Labor
Unit NonUnit Burden
Cost
Labor Cost
E
F
Total Hours and Cost
Number of
Total
Total
Responses Hours/Year
Cost/Year
20.0
$761
$0
13
260
$9,892
40.0
$1,522
$0
18
720
$27,395
2.0
$76
$0
48
96
$3,653
8.0
$304
$0
48
384
$14,610
10.0
$380
$0
48
480
$18,263
15.0
$571
$0
48
720
$27,395
2.0
$76
$0
21
42
$1,598
Page A-33
Table A-3 (continued)
Annual Paperwork Burden and Costs Associated with Class III Wells: States
A
Program Oversight Activities
Permit reviews/modifications (Per Facility)
Review each permit to determine whether it
should be modified, revoked and reissued, or
terminated.
Frequency
C
D
E
F
Total Hours and Cost
Number of
Total
Total
Responses Hours/Year
Cost/Year
Every 5 years
Review request for permit modification or reOccasional
issuance.
Monitoring/Testing (Per Facility)
Review mechanical integrity test data submitted Every 5 years
by operators.
Review monitoring data submitted by operators. Quarterly
Other Reporting (Per Facility)
Respond to periodic notifications by owners and Occasional
operators.
Recordkeeping (Per Facility)
Maintain administrative record (DI).
One-time
Closure (Per Facility)
Review plugging and abandonment report (DI
only).
B
Hours and Costs per Response
Unit Labor
Unit NonUnit Burden
Cost
Labor Cost
4.0
$152
$0
14
56
$2,137
20.0
$761
$0
23
460
$17,502
0.5
$19
$0
14
7
$267
0.25
$10
$0
281
70
$2,671
4.0
$152
$0
18
72
$2,739
4.0
$152
$0
0
0
$0
4.0
$152
$0
0
594
0
3,367
One-time
TOTAL
$
$0
128,122
Note: Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-34
•
8 hours to prepare plugging and abandonment plans;
•
5 hours to prepare schematics of the wells; and
•
3.5 hours to demonstrate financial responsibility.
In addition, EPA estimates that, when requested by the Director, revised
corrective action plans will take 10 hours each. Two applicants in DI programs will
spend 1.2 hours each to gather a list of landowners adjacent to the facility.
Operators completing wells must perform a two-part MIT and submit a
completion form. The burden associated with preparing completion reports is difficult to
determine. Operators of Class III facilities, especially uranium mining facilities, typically
develop their projects in multiple phases under the same area permit. Based on
conversations with operators and states, EPA estimates that operators of Class III wells
will spend an average of 4 hours to prepare a completion report, 10 hours to demonstrate
mechanical integrity, and 2.4 hours to perform and submit the results of required logs and
tests during construction.
Permit Renewals, Reviews, and Modifications
EPA estimates that 20 percent of operators each year will have a formal or
informal review of their permits. Each operator will take 4 hours to respond to any issues
raised during the review. In addition, Class III operators will take an average of 28 hours
to prepare requests for permit modifications.
Monitoring/Testing
EPA anticipates that operators of salt solution mining facilities will submit annual
analyses of their injectate. On average, each operator will take 8 hours per year to sample
and analyze their injectate in-house.
Operators of Class III facilities will monitor injection pressure, flow rate, or
volume of injected fluids semi-monthly, or meter injected and produced fluid volumes
continuously. EPA expects that operators perform this activity periodically as a
customary business practice to ensure the efficient operation of their facilities, and that
the incremental collection burden is approximately 4.6 hours per operator over a twoweek period. This represents the time needed to fill out field reports.
EPA estimates that operators of salt solution mining facilities will perform twopart MITs on all of their wells each year.3 The burden is estimated to be 161 hours per
operator.
3
Some operators may be allowed to submit cementing records in lieu of performing temperature or noise
logs.
Underground Injection Control Program – Information Collection Request
Page A-35
All uranium operators monitor water quality at selected monitoring wells
completed in the injection zone and overlying freshwater aquifers. Approximately 3
active facilities monitor semi-monthly; approximately 7 facilities which are performing
aquifer restoration monitor monthly. EPA estimates that the typical uranium facility has
about 110 monitoring wells. As with pressure, flow, and volume monitoring, operators
will perform about two-thirds of this monitoring as a customary business practice to
identify potential excursions from the injection zone. EPA assumes that UIC
requirements increase the monitoring burden to these operators by about 30.5 hours per
monitoring period.
Reporting and Recordkeeping
Operators of Class III facilities will incur a burden of 30 hours per facility per
quarter for quarterly reporting on monitoring and any MITs performed. Finally, about 10
percent of operators will spend 6 hours per year on occasional reporting activities. EPA
estimates that each Class III operator spends approximately 3.4 hours on recordkeeping
annually.
Closure
EPA estimates that Class III operators who close their projects will take 2 hours to
prepare written notifications to the Director. Operators in DI programs will spend one
hour to submit a plugging and abandonment report.
Burden on Primacy Agencies Associated with Class III Wells
For the Class III Program, primacy agency staff review and respond to permit
applications, permit reviews/modifications, and monitoring and testing data submitted by
operators. State burden associated with each activity involved in the oversight of Class
III programs is presented in Column A of Table A-3.
Depending on whether the permit is issued or denied, EPA estimates that states
will spend between 20 and 77 hours reviewing each application for a permit to inject
waste into a Class III well. Primacy agency staff spend 4 hours determining whether to
reissue, modify, or revoke each permit during the five-year review process, and 20 hours
reviewing each request for a permit modification or re-issuance. Class III primacy
agencies spend from ¼ to ½ hour per report reviewing monitoring and MIT data or
occasional reports submitted by operators (see details in Table A-3).
Burden Associated with Class IV and Endangering Class V Wells
Paperwork burden on operators of Class IV/endangering Class V wells and on
states for administering these wells is presented Table A-4.
Underground Injection Control Program – Information Collection Request
Page A-36
Class IV and Endangering Class V Well Operators
Class IV wells and Class V wells that are found to be endangering USDWs are
banned from injection, and owners of these wells are required to close them and submit
plugging and abandonment reports to states or DI programs. The exception to the ban is
for those Class IV wells used to inject contaminated ground water that has been treated
and re-injected into the same formation from which it was drawn. These wells are
authorized by rule for the life of the well if such subsurface emplacement of fluid is
approved by EPA or a State pursuant to the provisions for the cleanup of releases under
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
or RCRA. EPA estimates that the burden associated with this one-time requirement will
be 10 hours per well (See Table A-4). Because these wells are banned, there are no
permitting or monitoring requirements.
Burden on Primacy Agencies Associated with Class IV and Endangering Class V
Wells
State burden associated with Class IV and endangering Class V wells involves
review by primacy agency staff of closure plans submitted by operators. EPA estimates
the state burden to be one hour per review.
Burden Associated with Class V Wells
EPA’s estimate of the annual paperwork burden on operators and states associated
with Class V wells is presented in Column A of Table A-5.
Class V Operators
Activities for Class V well operators include submitting inventory information
and compliance with the Class V Rule by owners of motor vehicle waste disposal wells
(MVWDWs) and large-capacity cesspools.
Inventory Activities
Recent efforts by the Regions and state primacy agencies to address the potential
threats to USDWs posed by Class V wells will likely increase compliance with the
inventory requirement. Each Class V well operator will take 0.5 hours to prepare and
submit inventory information to the appropriate Regional or state primacy agency.
Underground Injection Control Program – Information Collection Request
Page A-37
Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: Operators
A
Description of Requirement
Closure Requirements (Per Well)
Submit a plugging and abandonment report
within 60 days after plugging a well
TOTAL
Questions
Frequency
Managerial
Technical
Clerical
B
C
Unit Burden
Unit Labor
Cost
10.0
$216
D
Unit Nonlabor Cost
E
F
Total Hours and Costs
No. of
Total
Total
Responses Hours/Year Cost/Year
One-time
0
7.5
2.5
$0
990
990
9,900
9,900
$213,662
$213,662
Note:
Numbers may not add due to rounding.
Underground Injection Control Program - Information Collection Request
Page A-38
Table A-4 (continued)
Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: States
A
Description of Requirement
Closure
Review closure plan.
Frequency
B
C
D
Hours and Costs per Response
Unit
Unit Burden Unit Labor
Nonlabor
(A)
Cost
Cost
One-time
TOTAL
1.0
$38
$0
E
F
Total Hours and Cost
Number of
Responses
Total
Hours/Year
758
758
758
758
Total
Cost/Year
$28,840
$28,840
Note:
Numbers may not add due to rounding.
Underground Injection Control Program - Information Collection Request
Page A-39
Table A-5
Annual Paperwork Burden and Costs Associated with Class V Wells: Operators
A
B
C
D
E
F
No. of
Responses
Total
Hours/Year
Total
Cost/Year
Hours and Costs per Response
Description of Requirement
Frequency
Legal
Managerial
Technical
Inventory Requirements
In DI programs, submit inventory information prior to One-time
0.0
0.0
0.0
commencing injection.
Class V Rule Requirements for Owners/Operators of Large-Capacity Cesspools
Read regulations.
One-time
0.0
0.0
3.0
Prepare and submit pre-closure notification (Form
One-time
0.0
0.5
0.8
7520-17).
Class V Rule - Startup Requirements for Owners / Operators of Motor Vehicle Waste Disposal Wells
Contact state or local agency to determine
One-time
requirements.
0.0
0.0
1.0
Read regulations.
One-time
For wells that will close, sample injectate and
One-time
maintain record.
One-time
Prepare and submit pre-closure notification (Form
7520-17).
For wells obtaining a waiver, conduct initial sampling. One-time
Unit Burden
Unit Labor
Cost
Unit Non-labor
Cost (A)
0.5
0.5
$9
$0
15,000
7,500
$128,700
0.0
3.0
$69
$0
333
1,000
$23,056
0.3
1.5
$48
$0
333
500
$16,109
Clerical
0.0
0.0
3.0
0.0
0.0
1.0
3.0
$23
$69
$0
$0
498
498
498
1,493
$11,474
$34,423
0.0
0.0
1.0
0.5
1.5
$32
$617
137
206
$88,851
0.0
0.5
0.8
0.3
1.5
$48
$0
137
206
$6,621
1.0
0.5
1.5
$32
$617
361
541
$233,908
25.0
21.0
54.0
$1,365
$0
361
19,476
$492,189
1.0
0.5
1.5
$32
$617
21,744
32,616
$14,101,954
1.0
0.5
1.5
$32
$1,613
5,436
8,154
$8,940,472
3.0
1.0
4.0
$86
$0
5,436
50,273
21,744
93,933
$469,279
$24,547,035
0.0
0.0
One-time
For wells obtaining a waiver, prepare and submit
0.0
8.0
permit application.
Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal Wells
Conduct quarterly injectate sampling.
Quarterly
0.0
0.0
Annual
Conduct annual sludge sampling (concurrent with
0.0
0.0
injectate sampling).
Annual reporting and recordkeeping of all monitoring Annual
0.0
0.0
results.
TOTAL
Notes:
(A) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-40
Table A-5 (continued)
Annual Paperwork Burden and Costs Associated with Class V Wells: States
A
Description of Requirement
Initial/Startup
Frequency
B
C
D
Hours and Costs per Response
Unit Nonlabor
Unit Burden (A) Unit Labor Cost
Cost
E
F
Total Hours and Cost
Number of
Responses
Total Hours/Year
Total Cost/Year
Review inventory information.
Primacy State Activities Associated With the Class V Rule
One-time
0.5
$19
$0
9,696
4,848
$184,456
Provide technical assistance to owners/operators (at start-up).
One-time
1.0
$38
$0
1,611
1,611
$61,313
Review and file pre-closure notifications.
One-time
1.3
$48
$0
912
1,140
$43,378
Review, approve, and file waivers/permit applications.
One-time
8.3
$316
$0
699
5,805
$220,870
Annual
0.8
$30
$0
3,514
16,433
2,811
16,216
Review and file annual monitoring reports.
TOTAL
$
$106,955
616,973
Notes:
(A) Unit burdens for initial/start-up activities reported on a per-permit basis. Unit burden for other activities reported on a per-operator basis.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-41
Activities Required Under the Class V Rule
Under the Class V Rule, facilities that wish to continue operating motor vehicle
waste disposal wells must seek waivers from the ban on existing motor vehicle waste
disposal wells and apply for permits. As a condition of the permit, facilities must submit
all monitoring reports to the UIC Director. Owners of MVWDWs and large-capacity
cesspools that close are required to submit pre-closure notifications.
Note: While the Class V Rule required that all closure or permitting activities be
completed by January 2007 (the latest date by which operators with state-granted
extensions would be required to have closed or applied for a permit), EPA assumes that
some of these activities may not be complete. Thus, some permitting/closure burden is
included in this ICR.
Operators of Large-Capacity Cesspools
Operators of facilities with large-capacity cesspools will need to become familiar
with the Class V requirements and prepare and submit a pre-closure notification to their
primacy agency. EPA assumes that each facility will require a total of 4.5 hours to
complete these activities.
Operators of Motor Vehicle Waste Disposal Wells
All owner/operators of facilities with MVWDWs must contact their primacy
agency to determine if their wells are located in a source water protection area (SWPA)
or other sensitive ground water area. These activities will require 4 hours. If a well is
located within one of these areas, the owner/operator will either close the well or seek a
waiver and apply for a permit.
•
If they choose to close their wells, owners of MVWDWs must notify the UIC
Program Director at least 30 days prior to well closure, sample their injectate, and
submit a pre-closure notification form (Form 7520-17 or a state equivalent).
These operators would incur a burden of 3 hours.
•
The specific information required in a permit application will be defined by the
appropriate Primacy States or EPA regions. For purposes of this analysis, EPA
has assumed that the permit requirements will be similar to those required in
existing UIC permit applications (40 CFR 144.31) including: a description of
activities requiring a permit, inventory information, topographic maps, and a brief
description of the business. These operators will also sample their injectate. The
burden for these activities is estimated to be 55.5 hours, the majority of which is
to prepare the permit application.
Owner/operators of MVWDWs that opted to seek a waiver and apply for a permit
(and were granted one) will be required to sample their injectate quarterly and sludge
Underground Injection Control Program – Information Collection Request
Page A-42
annually and submit these results once per year. These operators will incur an annual
burden of 7 hours.
Burden on Primacy Agencies Associated with Class V Wells
State primacy agencies’ burden associated with Class V wells includes reviewing
inventory information, processing permit applications and pre-closure notifications, and
reviewing and responding to monitoring data submitted by operators within their states.
State burden associated with oversight of Class V programs is presented in Column A of
Table A-5.
EPA estimates that states will spend 0.5 hours per Class V facility reviewing
inventory information. EPA estimates that states will review permit applications and preclosure notifications submitted by operators of facilities with motor vehicle waste
disposal wells and large-capacity cesspools. State primacy agencies will also review
annual monitoring reports submitted by operators (details are presented in Table A-5).
States as Respondents
State burden associated with program oversight and compiling and reporting data
using the 7520 forms and the UIC measures reporting process is presented in Column A
of Table A-6. The burden on states associated with completing the 7520 forms ranges
from 2 to 280 hours per form. States will also report quarterly to EPA on the UIC
program measures via a new online reporting system. EPA estimates the annual burden
associated with this effort will be 120 hours per state primacy agency, or 60 hours semiannually.
The bulk of the states’ burden associated with operator reporting will be for
compiling data on an estimated 15,000 newly inventoried facilities on the Inventory of
Injection Wells form (7520-16). Most of these are new facilities added to the Class V
inventory each year.
EPA estimates that the annual recordkeeping burden on state primacy agencies
associated with the 7520 forms and the inventory form will be 40 hours per agency. EPA
estimates that maintenance of inventory data will account for the bulk of the
recordkeeping burden.
EPA estimates that, in each primacy program, one-half of an FTE (1,040 hours) is
devoted to implementing their state UIC Program. Implementation activities states may
perform include updating state regulations as needed to reflect new federal rules or
providing guidance, training, or other information to well operators.
Underground Injection Control Program – Information Collection Request
Page A-43
Table A-6
Annual State Burden and Cost for Program Oversight and Reporting
A
B
C
D
Hours and Costs per Response
Description of Requirement
Program Oversight
Oversee and implement UIC program in the State, for
example, update regulations or guidances as needed.
7520 Forms Reporting
Permit Review and Issuance Form (7520-1)
Frequency
Annual
Compliance Evaluation Form (7520-2A)
Semi-annual
Compliance Evaluation for Significant Non-Compliance
Form (7520-2B)
Semi-annual
Mechanical Integrity Tests/Remedial Action Form (75203)
Annual
Quarterly Exceptions List Form (7520-4)
Quarterly
Inventory of Injection Wells Form (7520-16)
Annual
Measures Reporting
Report on UIC Measures to Headquarters
Semi-annual
E
F
Total Hours and Cost
Unit Labor
Cost
Unit Nonlabor
Cost
Total
Hours/Year
Total Cost/Year
1,040
$39,570
$0
56
58,240
$2,215,916
4.5
$171
$0
56
252
$9,588
6.0
$228
$0
112
672
$25,568
5.5
$209
$0
112
616
$23,438
5.0
$190
$0
56
280
$10,653
2.0
$76
$0
224
448
$17,046
280
$10,642
$0
56
15,664
$595,978
60
$2,283
$0
112
6,720
$255,683
10
$393
$
3,304
36
372
$133,071
25
$951
$
9,166
36
900
$364,235
8
$317
$
3,833
0
0
$0
200
24
$7,610
$913
$0
$0
0
96
0
2,304
$0
$87,663
40
$1,522
$0
56
1,008
2,240
88,708
$85,228
$3,824,066
Unit Burden
Number of
Responses
Ongoing
Activities related to populating the National UIC Database
Start-up activities (per program)
One-time
Develop data to meet UIC database needs (programs
with UIC databases)
Build data flow through data node (programs with UIC
One-time
databases)
Build data flow through data node (programs without
One-time
databases)
Ongoing activities (per program)
Enter UIC data into state database
Ongoing
Data flow and QA checks
Quarterly
Recordkeeping
Maintain records of 7520 forms
Ongoing
Notes:
For program oversight and forms and measures reporting, the number of respondents reflects the number of primacy agencies.
There may be more than one agency per state with Primacy authority.
EPA assumes that states with high and medium data coverage will initiate data flow to the UIC database during the clearance period. See Appendix B.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
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State Activities Associated with the National UIC Database
EPA Headquarters plans to deploy the national UIC database in 2007. Once they
initiate a data transfer process, States will be able to automatically transfer the data
needed to generate the information they currently report via the 7520 forms and the
measures data to Headquarters. (Once they set up this data transfer process, States will no
longer be required to complete the 7520 forms, report on the UIC measures, or retain
records. Appendix B describes the data transfer activities in detail, EPA’s burden and
cost estimates, and the eventual burden and cost savings to states associated with the
national UIC database.)
To initiate the data transfer, states will need to develop data to transfer to the
national database and set up the automated data flow. These burdens will vary depending
on the status of a state’s existing UIC database. On average, EPA estimates that each
program will require 310 hours to develop the data and 750 hours to set up the data flow.
Annualized over the planned six-year database development schedule, this equates to 52
hours per program to develop the data and 125 hours to set up the data flow. EPA
assumes that most of this work (80 percent) will be performed by contractors.
Once the data transfer process is in place, states will place their data on a data
node quarterly, notify Headquarters that the data are available, and respond to QA and
data validation issues as needed. EPA estimates these tasks will require 24 hours, and be
incurred 4 times per year (96 hours total).
A.2 Estimating the Respondent Universe
In this section, EPA describes the number of respondents subject to each
paperwork activity in this ICR. The number of responses for each activity is shown in
Column D of Tables A-1 through A-6. This number, known as the respondent universe,
is based on EPA’s assumptions on the number of permittees subject to each paperwork
requirement, e.g., the number of permit applications or well closures expected, or the
percent of permittees subject to monitoring or reporting requirements and the frequency
with which they must comply with those requirements. The frequency at which each
activity is performed is presented in the burden and cost tables along with EPA’s
description of each activity. Specific assumptions about the respondent universe for each
well class are described below.
Class I
EPA inventory data indicate that there are 549 Class I wells, of which 119 inject
hazardous waste, and 430 inject nonhazardous waste.
Class I Hazardous
According to EPA’s inventory, there are 119 Class I hazardous waste wells, with
an average of 1.9 wells at each facility. EPA estimates that 8 new Class I hazardous
Underground Injection Control Program – Information Collection Request
Page A-45
waste facility operating permits will be issued each year (6 for one new well at an
existing facility, and the remaining two for newly constructed facilities). EPA further
anticipates that 12 Class I hazardous facility operators will renew their permits each year;
5 will modify their permits each year; and 6 operators will modify their petitions each
year. All operators of Class I hazardous waste facilities must monitor and report at
various frequencies (see Table A-1A). EPA expects that one Class I hazardous well will
close during each year of the life of this ICR.
Class I Nonhazardous
EPA estimates that there are 430 Class I nonhazardous waste wells at 226
facilities, an average of 1.9 wells per facility. The Agency estimates that 14 new
nonhazardous waste injection permits will be issued each year, of which 10 will be for
one new well at an existing facility. EPA anticipates that 20 Class I nonhazardous
facility operators will renew their permits each year, and 9 Class I nonhazardous facility
operators will modify their permits each year. EPA also estimates that operators of 16
municipal wastewater disposal facilities in South Florida will submit permit applications
to meet the requirements of the Class I Florida rule. Every operator of a Class I
nonhazardous waste facility must monitor and report at various frequencies, as shown in
Table A-1B. Based on past data, EPA anticipates that one Class I nonhazardous well in a
primacy state will close each year.
Class II
The 2006 UIC inventory includes 143,951 Class II wells. EPA assumes that the
typical Class II facility has approximately 10 wells, thus there are approximately 14,400
Class II facilities.
EPA anticipates that, collectively, EPA regional offices and primacy states will
receive approximately 1,411 applications for Class II wells each year during the life of
this ICR. Details of the numbers of Class II operators subject to each paperwork
requirement are presented in Column D of Table A-2.
Based on previous studies of state AoR practices and requirements, EPA projects
that state primacy agencies and EPA Regions will determine that a complete AoR is not
necessary for approximately 831 of the 1,411 permit applicants. Of the remaining
applicants, EPA projects that approximately 266 applicants will submit an AoR map and
an AoR study as part of the permit application. Another 314 applicants will submit an
AoR map and a listing of the wells in the AoR, and the state primacy agency will perform
most or all of the tasks involved in the AoR study.
EPA estimates that 141 applicants will submit corrective action plans to address
specific problems identified by the AoR study. EPA regional or state primacy staff will
require 28 operators (20 percent) to revise their corrective action plans.
Underground Injection Control Program – Information Collection Request
Page A-46
Prior to obtaining approval to begin injection, operators must demonstrate
mechanical integrity and submit completion reports for an estimated 1,830 new Class II
wells each year. Most operators will submit logs for offset wells in their projects. EPA
assumes that operators will perform additional logs and tests for 275 new II-D and II-R
wells.
EPA estimates that approximately 71,975 Class II wells (50 percent of the
inventory) are permitted, and that the 1,440 operators of 14,395 wells (20 percent) will
undergo permit reviews each year. In addition, EPA expects that 3,599 operators will
submit requests for permit modifications.
From time to time, operators submit reports or notify UIC staff of various events
such as planned changes to the injection facility, permit transfers, progress in achieving
compliance milestones, and noncompliance or malfunctions which may endanger a
USDW. EPA estimates that approximately 864 operators submit one of these occasional
reports each year.
EPA projects that approximately three operators of rule-authorized wells in DI
states may be required to gather and submit groundwater monitoring data, analyses of
injected fluids, a description of geologic strata, and other items as requested.
EPA projects that, each year, approximately 1,044 operators will plug and
abandon all of their wells. In addition, EPA assumes that approximately 1 operator in a
DI program will elect to plug its wells in a manner different from the one specified in its
plugging and abandonment plan.
Class III
EPA estimates that there are approximately 165 facilities with Class III wells (10
uranium mining, 45 salt solution mining, and 110 brine mining/other sites). A typical
uranium facility has approximately 1,581 Class III wells, a typical salt mining facility has
11 wells, and a typical brine mining/other facility has 3 wells.
EPA regional offices and state primacy agencies expect to receive 32 permit
applications from Class III operators each year. EPA estimates that approximately 2
Class III operators will close their projects annually.
Operators of all 165 Class III facilities will monitor injection pressure, flow rate,
or volume of injected fluids semi-monthly, or meter injected and produced fluid volumes
continuously. EPA anticipates that operators of salt solution mining facilities will submit
analyses of their injectate once each year, and operators of salt solution mining facilities
will perform two-part MITs on all of their wells every five years. All uranium well
operators monitor water quality in the injection zone and overlying freshwater aquifers
either semi-monthly or monthly.
Underground Injection Control Program – Information Collection Request
Page A-47
Class IV/Endangering Class V
Based on UIC measures data reported by the states in 2003, EPA anticipates that
990 Class IV wells and endangering Class V wells will close each year. EPA estimates
23 percent of Class IV and endangering Class V wells are in DI states.
Class V
The current EPA inventory of Class V wells includes approximately 402,000
wells. This number is imprecise, and it is estimated that perhaps 3 to 5 times as many
Class V wells actually exist. EPA anticipates that approximately 15,000 operators of
Class V facilities will submit inventory information each year over the life of this ICR,
based on trends in the UIC program inventory.
Facilities Subject to the Class V Rule
The Class V rule required that all large capacity cesspools be closed and that all
motor vehicle waste disposal wells (MVWDWs) either close or obtain a permit by 2007
(the burden associated with these activities was estimated in the 2004 UIC Program ICR).
However, based on consultations with regional and state staff, there is reason to believe
that these activities are incomplete. Thus, this ICR assumes that some permitting and
closure activities associated with Class V Rule requirements will continue into this
clearance period.
EPA estimates that 1,000 large-capacity cesspools (an average of 333 per year)
will close during the clearance period. In addition, EPA estimates that operators of 411
MVWDWs (137/year) will close and 1,082 MVWDW operators (361/year) will apply for
a permit during the clearance period.
In addition, operators of 5,436 MVWDWs that have opted to obtain a permit will
conduct quarterly injectate sampling and annual sludge sampling, as required under the
Class V rule.
States as Respondents
EPA assumes that 56 primacy agencies in 40 states will prepare and submit 7520
forms and report on the UIC measures. This number reflects the fact that, in some states,
more than one agency oversees UIC activities (e.g., states typically regulate Class II wells
through agencies other than those overseeing other classes of wells for which they have
primacy). The frequency at which Primacy agencies complete each 7520 form is
presented in Table A-6. Measures reporting will take place semi-annually (mid-year and
end of year).
Because of the effort involved in initiating data transfer to the national UIC
database, EPA assumes that states will accomplish this at varying paces, resulting in a
phased-in schedule for populating the national UIC database. EPA assumes that about 36
Underground Injection Control Program – Information Collection Request
Page A-48
state programs will begin to flow data during the three year clearance period covered by
this ICR. These same 36 programs will begin to do quarterly data flow and QA checks;
EPA assumes that on average, 12 programs will begin data transfer each year, an average
of 24 programs per year over the three-year clearance period. (EPA assumes that, in the
initial years, the “early deployers” will continue to complete 7520 forms and report
measures data, while testing of the database continues.) See Appendix B for additional
detail about the schedule and EPA’s assumptions.
Underground Injection Control Program – Information Collection Request
Page A-49
Appendix B: The National UIC Database
EPA Headquarters is developing the National UIC Database, a well-specific database that will
collect and store state and DI program data to support UIC Programmatic data needs. The
national UIC data model contains approximately 120 data elements related to various aspects of
the UIC Program (e.g., permit information and enforcement and compliance data). The database
will include a mechanism to electronically transfer data between existing state databases and
Headquarters’ database.
Headquarters plans to deploy the national UIC database in mid-2007. Over the next several
years, states will map their data to the national database and begin to transfer data. EPA assumes
that data transfer activities would be “phased in” over about six years; this schedule would allow
states with existing and well-developed databases to complete the data transfer early on (and
begin to build up content in the national database), while giving additional time to states with
less electronically available data to accomplish the data transfer.
Once they initiate a data transfer process, States would no longer be required to complete the
7520 forms and do measures reporting, eventually eliminating the current burden associated with
gathering and compiling data, completing the reporting forms, and maintaining records.
This Appendix describes the current status of UIC data management by primacy states, the
burden and cost associated with data transfer, and the eventual cost savings to states associated
with the national UIC database.
B1. Status of State Data Management Activities
As a prelude to the national database development effort, EPA Headquarters conducted a
cataloging effort to assess the current status of data management by 63 state UIC programs
(some states have more than one UIC program). EPA’s findings are presented in the UIC
Program Databases Cataloging Report (December 2, 2005).
Data coverage is a measure of how closely the data elements in a state’s database match those in
the national data model. EPA assessed data coverage by determining how many of the national
data elements reside in each state’s database. Arbitrary cutoffs of 66 percent, 34-66 percent, and
33 percent and below are used to distinguish high, medium, and low data coverage, respectively.
The effort required to map state data to the national database is assumed to be related to this
coverage level.
Based on the cataloging effort, 36 state programs have high (7 programs) or medium data
coverage (29 programs). Seven programs have low data coverage, and two programs have no
electronic database. Eighteen (18) programs did not respond to the request for information; EPA
conservatively assumes these programs do not have UIC databases. See Table B-1.
Underground Injection Control Program – Information Collection Request
Page B-1
Table B-1: Summary of State UIC Data Coverage
Data Coverage Level
Programs
High coverage
7
Medium coverage
29
Low coverage
7
No database
2
Unknown (assume no database)
18
B2. Burden and Cost Associated With Data Transfer
State UIC programs will incur burden and cost associated with the necessary start-up activities to
prepare their databases and data for transfer to Headquarters and ongoing activities associated
with quarterly data transfers to Headquarters. (Note: the cost estimates in this appendix are
preliminary. At present, the first states are beginning to set up their data transfer; it is possible
that the cost estimates may be revised in future ICRs.)
Burden associated with start-up activities
Prior to initiating data transfer, states will need to prepare their databases to flow data to the
national database and initially populate the database. The effort (and associated cost) will vary
depending on the current status of the state’s database. That is, states with existing databases
that currently contain most or all of the Headquarters data elements would need to do less work
than states with fewer data elements in their database and states with no UIC database.
States with existing UIC databases (high or medium data coverage)
Start-up costs include the costs associated with developing the data to transfer to the national
database and setting up the data flow process. The following activities are included:
Data Development: these activities include adding new data fields and new data tables (if
needed) to align the state’s UIC data to the national data model. The effort involved is
estimated to range from 150 to 300 hours per program, depending on current coverage.
Input Historic Data: in addition, EPA assumes some programs have at least partial data
in hard copy only and would need to input some data from paper files. EPA estimates
that seven programs will require 200 hours to do this.
On average, the total “data development” cost to these programs is about 310 hours (11,150
hours divided by 36 programs). See Table B-2. Annualizing the effort over the estimated 6-year
phase-in schedule, this equals 51.6 hours, per program, annually.
Underground Injection Control Program – Information Collection Request
Page B-2
Table B-2: Data Development Burden
Hours/ program Programs
Data development – states
150
7
with high coverage
Data development – states
300
29
with medium coverage
Input historic data
200
7*
Total burden – all programs
Average (36 programs)
Total
1,050
8,700
1,400
11,150
310
* These 7 programs are a subset of the 36 above.
Setting up Data Flow includes the following activities:
C
C
C
Data mapping and data set generation includes mapping data from the state
database to Headquarters and generating data sets with valid records. This is
estimated to take 200 hours per program.
Convert to Extensible Markup Language (XML), including developing a tool for
automatic data conversion to XML. This will require an estimated 150 hours per
program.
Data flow via a Network Node involves setting up/testing automatic data
submission and transfer to EPA’s Central Data Exchange (CDX). This is
estimated to require 400 hours per program.
The total data flow burden is estimated to be 750 hours per program. Annualized over 6 years,
this equates to 125 hours per year per program.
States without databases (or low data coverage)
Headquarters plans to develop an Access database for use by states with no existing UIC
database, or those that do not currently maintain most of the national data elements. EPA
assumes that the 27 states with low or no data coverage would use this Headquarters-developed
database. Because the database would be designed to the needs of the national UIC database and
Headquarters would perform the basic programming, this effort is assumed to be less intensive,
and is estimated to be one-third of the burden for those states that already have a database, as
described above. EPA estimates the start-up burden to these state programs is 250 hours/
program (or 20.8 hours per year, annualized over 6 years).
Cost associated with start-up activities
Start-up non-labor costs for this ICR include contractor support and one-time hardware costs to
set up a state “data node.” EPA assumes that most start-up activities (estimated at 80 percent of
the burden cited above), will be performed by contractors at an estimated labor rate of $80 hour.
In addition, programs will incur $7,000/program ($1,167/year, annualized over 6 years) for
hardware costs associated with setting up a data flow via the network node.
Underground Injection Control Program – Information Collection Request
Page B-3
Ongoing activities
Annual activities include the incremental data entry burden for those states that currently do not
enter UIC data into a state database. (States that already have a database are already incurring a
data entry burden; thus, this ICR assume no additional paperwork burden for these states as a
result of the new database.) The annual data entry burden is estimated to be 200 hours.
All programs will place their data on the node quarterly, notify Headquarters the data are
available, and respond to quality assurance (QA) and data validation issues. EPA estimates these
tasks will require 24 hours per quarter, or 96 hours per year.
B3. Burden Reduction and Cost Savings
Over the long run, the national UIC database will reduce the states’ reporting burden. Once the
data transfer process is initiated, States will no longer need to complete the 7520 forms and
report on the measures. This will eventually eliminate the current burden associated with
gathering and compiling UIC data, completing the reporting forms, and maintaining records.
As described above, states will need to make a time and hardware investment to develop the
automated data transfer process. However, when the data transfer is complete, the current annual
burden associated with completing the 7520 forms and reporting on the PAMs will be replaced
with a lower burden associated with placing data on a network node to transfer it to Headquarters
and providing QA to assure data accuracy, as described below:
•
Under the current, paper-based system, states collectively incur $1.02 million annually in
reporting and recordkeeping costs; this equals about $18,271 per state.
•
Over the next three years (2007-2009), each state that currently has a database will incur
$82,884 in start-up costs (as described above), and in the three years following that
(2010-2012), each state without a database will incur $24,902 in start-up costs.
•
When their initial data transfer is complete, each state will incur lower annual costs: an
estimated cost of about $11,000 to enter data and transfer it to Headquarters quarterly.
Table B-3 presents the annual and cumulative costs to states under the current reporting system
and using the national database.
Underground Injection Control Program – Information Collection Request
Page B-4
Table B-3: Comparison of Costs –
Current Reporting Process vs. Automatic Data Transfer
Paper-Based Reporting
Year
Annual cost
Cumulative cost
Data Transfer
Annual cost
Cumulative cost
2007
$1,023,181
$1,023,181
$1,129,760
$1,129,760
2008
$1,023,181
$2,046,362
$1,264,906
$2,394,666
2009
$1,023,181
$3,069,543
$1,400,053
$3,794,719
2010
$1,023,181
$4,092,724
$730,917
$4,525,636
2011
$1,023,181
$5,115,905
$832,277
$5,357,913
2012
$1,023,181
$6,139,087
$933,637
$6,291,550
2013
$1,023,181
$7,162,268
$709,519
$7,001,069
2014
$1,023,181
$8,185,449
$709,519
$7,710,588
2015
$1,023,181
$9,208,630
$709,519
$8,420,107
2016
$1,023,181
$10,231,811
$709,519
$9,129,626
2017
$1,023,181
$11,254,992
$709,519
$9,839,145
2018
$1,023,181
$12,278,173
$709,519
$10,548,664
2019
$1,023,181
$13,301,354
$709,519
$11,258,183
2020
$1,023,181
$14,324,535
$709,519
$11,967,702
2021
$1,023,181
$15,347,716
$709,519
$12,677,221
2022
$1,023,181
$16,370,897
$709,519
$13,386,741
2023
$1,023,181
$17,394,079
$709,519
$14,096,260
2024
$1,023,181
$18,417,260
$709,519
$14,805,779
2025
$1,023,181
$19,440,441
$709,519
$15,515,298
2026
$1,023,181
$20,463,622
$709,519
$16,224,817
Annual costs are higher in the initial phase-in years, and level off as states’ only activities are
data entry and transfer. When the initial data population and transfer are complete, states will
collectively save about $300,000 annually. As Table B-3 and the figure below show, after 2012,
the cumulative costs for data development and data management via the database (represented by
the solid line in the graph) are lower than they would have been to report by paper during the
same time frame (the dashed line).
Underground Injection Control Program – Information Collection Request
Page B-5
Cost (millions)
Comparison of State Costs:
Current Reporting Process vs. Database Transfer
$14.0
$12.0
$10.0
$8.0
$6.0
$4.0
$2.0
$0.0
2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Paper-based
Automated transfer
Year
Underground Injection Control Program – Information Collection Request
Page B-6
APPENDIX C
Federal Register Notice on UIC Program Reporting Requirements
sroberts on PROD1PC70 with NOTICES
Federal Register / Vol. 72, No. 39 / Wednesday, February 28, 2007 / Notices
to the proceedings for this project
should, on or before the comment date
stated below, file with the Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC 20426,
a motion to intervene in accordance
with the requirements of the
Commission’s Rules of Practice and
Procedure (18 CFR 385.214 or 385.211)
and the Regulations under the NGA (18
CFR 157.10). A person obtaining party
status will be placed on the service list
maintained by the Secretary of the
Commission and will receive copies of
all documents filed by the applicant and
by all other parties. A party must submit
14 copies of filings made with the
Commission and must mail a copy to
the applicant and to every other party in
the proceeding. Only parties to the
proceeding can ask for court review of
Commission orders in the proceeding.
However, a person does not have to
intervene in order to have comments
considered. The second way to
participate is by filing with the
Secretary of the Commission, as soon as
possible, an original and two copies of
comments in support of or in opposition
to this project. The Commission will
consider these comments in
determining the appropriate action to be
taken, but the filing of a comment alone
will not serve to make the filer a party
to the proceeding. The Commission’s
rules require that persons filing
comments in opposition to the project
provide copies of their protests only to
the party or parties directly involved in
the protest.
Persons who wish to comment only
on the environmental review of this
project should submit an original and
two copies of their comments to the
Secretary of the Commission.
Environmental commentors will be
placed on the Commission’s
environmental mailing list, will receive
copies of the environmental documents,
and will be notified of meetings
associated with the Commission’s
environmental review process.
Environmental commentors will not be
required to serve copies of filed
documents on all other parties.
However, the non-party commentors
will not receive copies of all documents
filed by other parties or issued by the
Commission (except for the mailing of
environmental documents issued by the
Commission) and will not have the right
to seek court review of the
Commission’s final order.
The Commission strongly encourages
electronic filings of comments protests
and interventions via the internet in lieu
of paper. See 18 CFR 385.2001(a) (1) (iii)
and the instructions on the
VerDate Aug<31>2005
16:08 Feb 27, 2007
Jkt 211001
Commission’s web (www.ferc.gov) site
under the ‘‘e-Filing’’ link.
Comment Date: March 15, 2007.
Magalie R. Salas,
Secretary.
[FR Doc. E7–3487 Filed 2–27–07; 8:45 am]
BILLING CODE 6717–01–P
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
[Docket No. CP06–421–000]
Transcontinental Gas Pipe Line
Corporation; Notice of Public Meeting
for the Proposed Potomac Expansion
Project
February 22, 2007.
The staff of the Federal Energy
Regulatory Commission (FERC or
Commission) is holding a public
meeting for Transcontinental Gas Pipe
Line Corporation’s (Transco’s) proposed
Potomac Expansion Project. The project
would consist of the construction of
about 20 miles of new 42-inch-diameter
pipeline in three loops located in
Campbell, Pittsylvania, and Fairfax
Counties, Virginia; and various
aboveground facilities, including a
proposed pig launcher/receiver facility
at milepost 1,586.17 in Fairfax County,
Virginia.
The meeting will be on Friday, March
2, 2007, at 7 p.m. (EST) in the Virginia
Run Community Center, 15355
Wetherburn Court, Centreville, VA
20120.
This event is posted on the
Commission’s calendar located at http://
www.ferc.gov/EventCalendar/
EventsList.aspx along with other related
information. For additional information,
please contact the Commission’s Office
of External Affairs at 1–866–208–FERC.
Magalie R. Salas,
Secretary.
[FR Doc. E7–3490 Filed 2–27–07; 8:45 am]
BILLING CODE 6717–01–P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ–OW–2003–0017; FRL–8282–3]
Agency Information Collection
Activities; Proposed Collection;
Comment Request; Underground
Injection Control (UIC) Program; EPA
ICR No. 0370.19; OMB Control No.
2040–0042
Environmental Protection
Agency (EPA).
AGENCY:
PO 00000
Frm 00025
Fmt 4703
Sfmt 4703
ACTION:
8983
Notice.
SUMMARY: In compliance with the
Paperwork Reduction Act (PRA) (44
U.S.C. 3501 et seq.), this document
announces that EPA is planning to
submit a request to renew an existing
approved Information Collection
Request (ICR) to the Office of
Management and Budget (OMB). This
ICR is scheduled to expire on April 30,
2007. Before submitting the ICR to OMB
for review and approval, EPA is
soliciting comments on specific aspects
of the proposed information collection
as described below.
DATES: Comments must be submitted on
or before April 30, 2007.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OW–2003–0017, by each item in the
text, by one of the following methods:
• http://www.regulations.gov: Follow
the on-line instructions for submitting
comments.
• E-mail: [email protected].
• Mail: Environmental Protection
Agency, Mailcode: MC 4101T, 1200
Pennsylvania Ave., NW., Washington,
DC 20460.
Instructions: Direct your comments to
Docket ID No. EPA–HQ–OW–2003–0017
identified by the Docket ID. EPA’s
policy is that all comments received
will be included in the public docket
without change and may be made
available online at http://
www.regulations.gov, including any
personal information provided, unless
the comment includes information
claimed to be Confidential Business
Information (CBI) or other information
whose disclosure is restricted by statute.
Do not submit information that you
consider to be CBI or otherwise
protected through http://
www.regulations.gov or e-mail. The
http://www.regulations.gov website is
an ‘‘anonymous access’’ system, which
means EPA will not know your identity
or contact information unless you
provide it in the body of your comment.
If you send an e-mail comment directly
to EPA without going through http://
www.regulations.gov, your e-mail
address will be automatically captured
and included as part of the comment
that is placed in the public docket and
made available on the Internet. If you
submit an electronic comment, EPA
recommends that you include your
name and other contact information in
the body of your comment and with any
disk or CD–ROM you submit. If EPA
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, EPA may not be
able to consider your comment.
Electronic files should avoid the use of
E:\FR\FM\28FEN1.SGM
28FEN1
8984
Federal Register / Vol. 72, No. 39 / Wednesday, February 28, 2007 / Notices
special characters, any form of
encryption, and be free of any defects or
viruses. For additional information
about EPA’s public docket visit the EPA
Docket Center homepage at http://
www.epa.gov/epahome/dockets.htm.
FOR FURTHER INFORMATION CONTACT:
Robert E. Smith, Office of Ground Water
and Drinking Water, Drinking Water
Protection Division/Underground
Injection Control Program, Mailcode:
4606M, Environmental Protection
Agency, 1200 Pennsylvania Ave., NW.,
Washington, DC 20460; telephone
number: 202–564–3895; fax number:
202–564–3756; e-mail address:
[email protected].
SUPPLEMENTARY INFORMATION:
sroberts on PROD1PC70 with NOTICES
How Can I Access the Docket and/or
Submit Comments?
EPA has established a public docket
for this ICR under Docket ID No. EPA–
HQ–OW–2003–0017, which is available
for online viewing at http://
www.regulations.gov, or in person
viewing at the Water Docket, Docket in
the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution
Ave., NW., Washington, DC. The EPA/
DC Public Reading Room is open from
8 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays. The
telephone number for the Reading Room
is 202–566–1744, and the telephone for
the Water Docket is 202–566–2426.
Use http://www.regulations.gov to
obtain a copy of the draft collection of
information, submit or view public
comments, access the index listing of
the contents of the docket, and to access
those documents in the public docket
that are available electronically. Once in
the system, select ‘‘search,’’ then key in
the docket ID number identified in this
document.
What Information Is EPA Particularly
Interested in?
Pursuant to section 3506(c)(2)(A) of
the PRA, EPA specifically solicits
comments and information to enable it
to:
(i) Evaluate whether the proposed
collection of information is necessary
for the proper performance of the
functions of the Agency, including
whether the information will have
practical utility;
(ii) Evaluate the accuracy of the
Agency’s estimate of the burden of the
proposed collection of information,
including the validity of the
methodology and assumptions used;
(iii) Enhance the quality, utility, and
clarity of the information to be
collected; and
(iv) Minimize the burden of the
collection of information on those who
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16:08 Feb 27, 2007
Jkt 211001
are to respond, including through the
use of appropriate automated electronic,
mechanical, or other technological
collection techniques or other forms of
information technology, e.g., permitting
electronic submission of responses. In
particular, EPA is requesting comments
from very small businesses (those that
employ less than 25) on examples of
specific additional efforts that EPA
could make to reduce the paperwork
burden for very small businesses
affected by this collection.
What Should I Consider When I
Prepare My Comments for EPA?
You may find the following
suggestions helpful for preparing your
comments:
1. Explain your views as clearly as
possible and provide specific examples.
2. Describe any assumptions that you
used.
3. Provide copies of any technical
information and/or data you used that
support your views.
4. If you estimate potential burden or
costs, explain how you arrived at the
estimate that you provide.
5. Offer alternative ways to improve
the collection activity.
6. Make sure to submit your
comments by the deadline identified
under DATES.
7. To ensure proper receipt by EPA,
be sure to identify the docket ID number
assigned to this action in the subject
line on the first page of your response.
You may also provide the name, date,
and Federal Register citation.
What Information Collection Activity or
ICR Does This Apply to?
Affected entities: Entities potentially
affected by this action are owners and
operators underground injection wells,
State Underground Injection Control
(UIC) primacy agencies, and in some
instances, U.S. EPA Regional offices and
staff.
Title: Information Collection Request
for the Underground Injection Control
Program.
ICR numbers: EPA ICR No. 0370.19,
OMB Control No. 2040–0042.
ICR status: This ICR is currently
scheduled to expire on April 30, 2007.
An Agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information, unless it
displays a currently valid OMB control
number. The OMB control numbers for
EPA’s regulations in title 40 of the CFR,
after appearing in the Federal Register
when approved, are listed in 40 CFR
part 9, are displayed either by
publication in the Federal Register or
by other appropriate means, such as on
the related collection instrument or
PO 00000
Frm 00026
Fmt 4703
Sfmt 4703
form, if applicable. The display of OMB
control numbers in certain EPA
regulations is consolidated in 40 CFR
part 9.
Abstract: The Underground Injection
Control (UIC) Program under the Safe
Drinking Water Act established a
Federal and State regulatory system to
protect underground sources of drinking
water (USDWs) from contamination by
injected fluids. Injected fluids include
over 9 billion gallons of hazardous
waste per year and over two billion
gallons of brine from oil and gas
operations every day as well as
automotive, industrial, sanitary and
other wastes. Owners/operators of
underground injection wells must
obtain permits, conduct environmental
monitoring, maintain records, and
report results to EPA or the State UIC
primacy agency. States must report to
EPA on permittee compliance and
related information. The mandatory
information is reported using
standardized forms and annual reports,
and the regulations are codified at 40
CFR Parts 144 through 148. The data are
used by UIC authorities to ensure the
protection of underground sources of
drinking water.
Burden Statement: The annual public
reporting and recordkeeping burden for
this collection of information is
estimated to average 2.35 hours per
response. Burden means the total time,
effort, or financial resources expended
by persons to generate, maintain, retain,
or disclose or provide information to or
for a Federal agency. This includes the
time needed to review instructions;
develop, acquire, install, and utilize
technology and systems for the purposes
of collecting, validating, and verifying
information, processing and
maintaining information, and disclosing
and providing information; adjust the
existing ways to comply with any
previously applicable instructions and
requirements which have subsequently
changed; train personnel to be able to
respond to a collection of information;
search data sources; complete and
review the collection of information;
and transmit or otherwise disclose the
information.
The ICR provides a detailed
explanation of the Agency’s estimate,
which is only briefly summarized here:
Estimated total number of potential
respondents: 38,824.
Frequency of response: yearly, semiannually, quarterly, and other.
Estimated total average number of
responses for each respondent: 10.96.
Estimated total annual burden hours:
1,000,648 hours.
Estimated total annual costs:
$117,142,617. This includes an
E:\FR\FM\28FEN1.SGM
28FEN1
Federal Register / Vol. 72, No. 39 / Wednesday, February 28, 2007 / Notices
estimated burden cost of $34,934,361
and an estimated cost of $82,208,255 for
capital investment or maintenance and
operational costs.
In its ‘‘Terms of Clearance’’ for the
current ICR, OMB asked EPA to report
on its efforts to reduce burden on
owners and operators of UIC injection
wells. In response to this request, the
Agency has undertaken an effort to
study where further paperwork burden
reduction is feasible. The UIC Program
is reviewing UIC regulations requiring
paperwork reporting/recordkeeping and
then evaluating potential for burden
reduction. Past efforts to reduce burden
focused on analyzing data needs of the
UIC Program and identifying ways to
reduce burden on State primacy
agencies that submit information to
EPA. This effort resulted in reduced
frequency with which states must
submit several 7520 Federal reporting
forms. Current efforts focus on how to
reduce burden on owners and operators
that submit specific 7520 owner/
operator reporting forms. Areas of
consideration are combining/revising
some 7520 reporting forms, eliminating
certain reporting requirements,
eliminating data elements from the 7520
forms submitted by operators, reducing
frequency and using options such as
electronic data entry and transfer
systems. EPA prepared a report that
summarizes these efforts. This report
can be found in the Water Docket for the
UIC Program ICR under Docket ID No.
EPA–HQ–OW–2003–0017 and is
available for viewing in person at the
EPA/DC Public Reading Room which is
in the EPA Headquarters Library, Room
Number 3334 in the EPA West Building,
located at 1301 Constitution Ave., NW.,
Washington, DC.
sroberts on PROD1PC70 with NOTICES
Are There Changes in the Estimates
From the Last Approval?
There is a decrease of 333,406 hours
in the total estimated respondent
burden compared with that identified in
the ICR currently approved by OMB.
This decrease primarily reflects
abatement of permitting and closure
under the 1999 Class V Rule; reduced
Class V well inventory activities; and a
reduction in the Class II inventory,
particularly the number of Class II
permit applications that operators will
submit during the clearance period.
These changes are adjustments.
What Is the Next Step in the Process for
This ICR?
EPA will consider the comments
received and amend the ICR as
appropriate. The final ICR package will
then be submitted to OMB for review
and approval pursuant to 5 CFR
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16:08 Feb 27, 2007
Jkt 211001
8985
1320.12. At that time, EPA will issue
another Federal Register notice
pursuant to 5 CFR 1320.5(a)(1)(iv) to
announce the submission of the ICR to
OMB and the opportunity to submit
additional comments to OMB. If you
have any questions about this ICR or the
approval process, please contact the
technical person listed under FOR
FURTHER INFORMATION CONTACT.
made under the provisions of 40 CFR
Part 53, as amended on December 18,
2006 (71 FR 61271).
The new equivalent method is an
automated method (analyzer) that
utilizes a measurement principle based
on absorption of ultraviolet light by
ozone at a wavelength of 254 nm. The
newly designated equivalent method is
identified as follows:
Dated: February 23, 2007.
Cynthia C. Dougherty,
Director, Office of Ground Water and Drinking
Water.
[FR Doc. E7–3516 Filed 2–27–07; 8:45 am]
EQSA–0207–164, ‘‘SIR S.A. Model S–5014
Photometric O3 Analyzer,’’ operated on the
0–500 ppb measurement range, within an
ambient temperature range of 20 to 30
degrees C, with a sample inlet particulate
filter, and with or without an optional
PCMCIA card.
BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
[FRL–8282–4]
Office of Research and Development;
Ambient Air Monitoring Reference and
Equivalent Methods: Designation of a
New Equivalent Method
Environmental Protection
Agency.
ACTION: Notice of the designation of a
new equivalent method for monitoring
ambient air quality.
AGENCY:
SUMMARY: Notice is hereby given that
the Environmental Protection Agency
(EPA) has designated, in accordance
with 40 CFR Part 53, a new equivalent
method for measuring concentrations of
ozone (O3) in the ambient air.
FOR FURTHER INFORMATION CONTACT:
Elizabeth Hunike, Human Exposure and
Atmospheric Sciences Division (MD–
D205–03), National Exposure Research
Laboratory, U.S. EPA, Research Triangle
Park, North Carolina 27711. Phone:
(919) 541–3737, e-mail:
[email protected].
SUPPLEMENTARY INFORMATION: In
accordance with regulations at 40 CFR
Part 53, the EPA evaluates various
methods for monitoring the
concentrations of those ambient air
pollutants for which EPA has
established National Ambient Air
Quality Standards (NAAQSs) as set
forth in 40 CFR Part 50. Monitoring
methods that are determined to meet
specific requirements for adequacy are
designated by the EPA as either
reference methods or equivalent
methods (as applicable), thereby
permitting their use under 40 CFR Part
58 by States and other agencies for
determining attainment of the NAAQSs.
The EPA hereby announces the
designation of a new equivalent method
for measuring concentrations of O3 in
the ambient air. This designation is
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Frm 00027
Fmt 4703
Sfmt 4703
An application for an equivalent
method determination for the candidate
method based on this ozone analyzer
was received by the EPA on August 4,
2006. The sampler is commercially
available from the applicant, SIR USA,
1775 Pennsylvania Avenue, NW.,
Washington, DC 20006 or from SIR
Spain, Avda. de la Industria, 3, 28760
Tres Cantos, Spain.
A test analyzer representative of this
method has been tested in accordance
with the applicable test procedures
specified in 40 CFR Part 53 (as amended
on December 18, 2006). After reviewing
the results of those tests and other
information submitted by the applicant
in the application, EPA has determined,
in accordance with Part 53, that this
method should be designated as an
equivalent method. The information
submitted by the applicant in the
application will be kept on file, either
at EPA’s National Exposure Research
Laboratory, Research Triangle Park,
North Carolina 27711 or in an approved
archive storage facility, and will be
available for inspection (with advance
notice) to the extent consistent with 40
CFR Part 2 (EPA’s regulations
implementing the Freedom of
Information Act).
As a designated reference or
equivalent method, this method is
acceptable for use by states and other air
monitoring agencies under the
requirements of 40 CFR Part 58,
Ambient Air Quality Surveillance. For
such purposes, the method must be
used in strict accordance with the
operation or instruction manual
associated with the method and subject
to any specifications and limitations
(e.g., configuration or operational
settings) specified in the applicable
designation method description (see the
identifications of the method above).
Use of the method should also be in
general accordance with the guidance
and recommendations of applicable
sections of the ‘‘Quality Assurance
Handbook for Air Pollution
E:\FR\FM\28FEN1.SGM
28FEN1
APPENDIX D
Report on Underground Injection Control Program
Burden Reduction Efforts
Introduction
EPA’s Office of Ground Water and Drinking Water (OGWDW) is requesting OMB approval to
renew the Underground Injection Control (UIC) Information Collection Request (ICR) to allow
the continued collection of information under the UIC Program.
In its “Terms of Clearance” for the current ICR, the Office of Management and Budget (OMB)
asked OGWDW to report on its efforts to reduce burden on owners and operators of injection
wells.
The following report responds to OMB’s request and describes EPA’s efforts to assess the
burden on well operators associated with the UIC Program’s requirements and the efforts to
identify potential burden reduction opportunities in the UIC Program.
UIC Burden Estimates
There are approximately 38,768 owners and operators of UIC wells who must collect
information and periodically report to the State or EPA on well activities. The total annual
burden on owners and operators of injection wells estimated in the approved ICR (EPA ICR
number 0370.19; January 18, 2005) is 1,122,522 hours.1 EPA has revised these estimates as part
of the process of renewing the UIC ICR and expects the total annual owner/operator burden
between 2007 and 2010 to be approximately 840,985 hours.
EPA expects a net reduction in operator burden of 281,537 hours between 2007 and 2010. This
reduction reflects a combination of programmatic changes and adjustments to the UIC inventory,
rather than changes in the reporting forms or frequency of reporting. Programmatic changes
include activities associated with the Revision to Federal UIC Requirements for Class I
Municipal Wells in Florida (“the Florida Rule”) and reduced activity as a result of the 1999
Revisions to the Underground Injection Control Regulations for Class V Injection Wells (“the
Class V Rule”). In addition, the burden estimate is expected to change to reflect adjustments to
the inventory for Classes II and V.
Table 1 provides additional detail.
1
The UIC Program ICR estimates the burden to primacy states as well; however, that burden is not included in the
estimate of operator burden reduction noted above.
3
Table 1: Change in Annual Well Owner/Operator Burden
Between Approved and Renewal ICRs
Type of Change
Florida Rule
Change
(hours)
1,472
Reason for Change
Additional burden associated with compliance with 2005 Rule.
Operators of certain Class I municipal wells in Florida will apply
to modify their permits in order to be able to continue injecting.
Abatement of
Class V Rule
activities
-71,669
The burden associated with permitting and closure of motor
vehicle waste disposal wells (MVWDWs) and closure of large
capacity cesspools is largely complete. Most activities in the
2007 to 2010 clearance period will be associated with rulerequired sampling by MVWDW operators who opted to apply
for a permit.
Inventory
adjustments
-211,339
For Class V injection wells, the Agency predicted an increase in
the number of Class V wells during the 2004 to 2006 period
because of the significant increase due to requirement to locate
and document large capacity cesspools and motor vehicle
waste disposal wells as part of the 1999 Class V Rule. For the
2007 to 2010 period the Agency expects a decrease in these
activities as most of the wells subject to permitting and closure
should have been identified.
For Class II injection wells during 2004 to 2006, the Agency
predicted an increase in Class II activities based on
consultations with EPA regions and states. Based on
consultations on activities between 2007 and 2010, some wells
are expected to temporarily close and fewer permits are likely
to be received in the future.
Total Change
-281,536
Past Efforts to Address Operator Burden
In 1998, EPA convened a burden reduction workgroup to analyze the data needs of the UIC
Program and identify possible ways to reduce burden. The workgroup consisted of
representatives of 11 states and all 10 EPA regions (see Table 2 below).
4
Table 2: 7520 Workgroup Members
EPA Regions
David Delaney; Region I
John Kushwara; Region II
Roger Reinhart and Maria Conicelli; Region III
Nancy Marsh and Frank Baker; Region IV
Valoria Robinson; Region V
Ray Leissner; Region VI
Kurt Hildebrandt; Region VII
Carol Bowden and Nathan Wiser; Region VIII
Gregg Olson and George Robin; Region IX
Grover Partee; Region X
EPA Headquarters
Richard Lawrence, Al Havinga, and Don Olson;
OECA
James Curtin; OGC
Denny Cruz, (Workgroup Leader), Robyn
Delehanty and Bruce Kobelski; OGWDW
States
Lindsay Taliaferro; Ohio
Richard Ginn, Ben Knape, and Marty Barnes;
Texas
Mike Stettner; California
Dave Watkins; West Virginia
Mark Slifka; Idaho
Richard Deuerling; Florida
Michel Phillips and Bur Filson; Illinois
Stan Belieu; Nebraska
George Hudak; Montana
Bob Lucht; Wyoming
Larry Fiddler; Oklahoma
The workgroup focused its review on the information that primacy agencies submit to EPA and
recommended that EPA reduce state burden by changing the frequency of state submissions.
Based on these recommendations, in [add year] EPA made changes to the program that reduced
the frequency with which states must submit several of the UIC Program’s series 7520 reporting
forms. The work group also recommended allowing Web-based entry of the data on some of the
forms. Finally, the workgroup recommended reformatting the State reporting forms (the
workgroup did not make recommendations about the owner/operator reporting forms).
However, before any action was taken to approve the reformatted 7520 forms, OGWDW
responded to requests to provide electronic reporting and embarked upon development of a
national UIC database. The national database is being developed based on a “hybrid” set of data
elements from both the approved forms and the workgroup’s recommendations. The Agency
expects the UIC database to be available as in 2007, allowing electronic entry and transmission
of data from primacy agencies to EPA.
Current Efforts to Address Operator Burden
In 2006, in response to OMB requests, EPA stepped up its efforts to investigate and assess
possibilities for burden reduction. EPA convened a study group composed of representatives
from EPA headquarters and Regions to assess whether burden could be further reduced. This
study group continues to evaluate burden reduction possibilities and complete recommendations
will be made available in late 2007. A discussion of the areas this group is examining follows.
Combining/Revising the Reporting Forms
It may be possible to combine several of the 7520 reporting forms into a single multi-purpose
form. These forms include the Completion forms (7520-9 and 7520-10), the Well Rework form
5
(7520-12), and the Plugging and Abandonment Plan (7520-14). EPA is evaluating whether
combining the forms would result in any burden reduction.
The study group also discussed whether redesigning some of the data elements on the forms
would reduce the total number of pages associated with UIC data collection, eliminate confusion,
and facilitate completion of the forms. The study group is currently focusing its efforts on forms
7520-9 (Completion Form for Injection Wells), 7520- 10 (Completion Report for Brine Disposal,
Hydrocarbon Storage, or Enhance Recovery Wells), 7520-12 (Well Rework Record), and 752014 (Plugging and Abandonment Plan).
Reducing Frequency of Reporting
It may be possible to reduce reporting burden by reducing reporting frequency. The study group
found that monitoring and testing had a large number of respondents These activities account
for nearly half of the total operator burden. We have examined these areas for possible burden
reduction and have some areas to follow-up on whether burden can be reduced. As a possible
next step, we could talk with states that run the UIC programs and the regulated community.
Table 3 summarizes the percent of total burden by activity.
Table 3: Annual Injection Well Operator Burden
(by Activity Type)
Activity
Hours
Percent
*Permitting, startup, and inventory
151,684
35% of total
Monitoring/ testing
493,093
46% of total
Reporting
123,125
12% of total
Recordkeeping
59,360
6% of total
Well closure
13,396
1% of total
Other
184
0.02% of total
Total
840,842
Source: ICR burden tables, last revised October 24, 2006.
*This is a one-time activity
Eliminating Data Elements from the 7520 Forms
The study group discussed the potential for eliminating some of the reporting elements on the
7520 forms submitted by well owners/operators. Although it is too early to tell the exact number
of elements that could be eliminated, the study group acknowledged that some elements could be
eliminated. The study group believes it is necessary to continue to require many of the existing
data elements to ensure that injection wells are sited, constructed, and operated in an
environmentally protective manner, however, it is working to refine a list of the elements that
could be eliminated. Attachment 1 summarizes the analysis to date of the potential for
eliminating data elements.
6
Additional Burden Reduction Options
Study group members made additional recommendations for burden reduction. The following is
a description of these recommendations and associated activities.
•
Maintain and transfer all operator data electronically. Electronic reporting of
routinely-collected data would eliminate the need to collect, record on paper, and submit
information to the permitting authority. A first step toward this goal is developing a
database for transferring UIC data from regions and states to EPA Headquarters.
Headquarters is currently developing a national UIC database (with plans to deploy it in
2007). Following this, it may be possible to provide well operators the option to report
some information electronically. Headquarters estimates the database will reduce
primacy agency burden. It is likely that electronic reporting may offer significant burden
savings to those operators with electronic data transfer capabilities as well.
•
Create an electronic permitting system. Electronic submission of permit application
data could streamline the application review process. This option needs to be further
explored. EPA must consider the states’ ability to receive all of the required permit
application attachments electronically (e.g., well logs and schematics), whether some
information could be sent electronically, and the actual burden reduction relative to the
cost of setting up such a system (the number of permit applications received each year by
many states is limited and not all applicants would be able to use an electronic system).
•
Allow electronic entry of inventory information. Operators that do not need to apply
for a permit must submit basic inventory information about their wells to the permitting
authority using the Injection Well Inventory form (7520-16) or an equivalent. A webbased data entry system could reduce burden to operators, especially those that submit
multiple inventory forms for similar wells. (Regions and primacy agencies would benefit
as well, since this would eliminate data entry from paper forms). EPA plans to enable
web site entry of inventory information in 2007. States are likely to be the first to use
this technology. Further analysis is needed to assess how web-entered data will be
exported to other databases (e.g., state databases) as needed.
What Else Should the Agency Consider?
Where possible, examine whether operators submitting paperwork to DI programs could
responsibly retain more of their reporting paperwork at their facilities and be made
responsible for assuring that it is accurate, complete and available, at all times for inspection
by UIC agencies. OGWDW recognizes that some of state regulatory requirements could be
more stringent, making the implementation of some burden reduction practices less likely.
7
Attachment 1: Study Group Evaluation of Potential to Eliminate 7520 Form Elements
Element
(Form number)
Members
recommending
Potential
Elimination
FINDS number
10
Existing EPA permits
9
Ownership/ private, federal, other
Formation testing program
6
5
Injection procedures
5
Changes in injection fluid
5
Plans for well failure
5
Stimulation program
4
Corrective action plan
3
Monitoring program
3
Plugging and abandonment
1
Elements on Form 7520-7
Non-lat/long locational data
7
Name and address of permittee
All of form 7520-8 – monitoring
information
Elements on Form 7520-9
Description of surface equipment
Monitoring system
2
7
3
Well design and construction
As-built diagrammatic sketch
8
2
1
Element
(Form number)
Members
recommending
Potential
Elimination
Date drilling completed
6
Injection zone stimulation
4
Lease name
3
Wire line logs, list each type
3
Schematic or other drawing of surface
& subsurface construction
2
Status of corrective action on
defective wells in the area of review
2
Hole
1
Monthly monitoring information
Method of emplacement of cement
plugs
Open hole/or perforated intervals and
intervals where casing will be varied
Transaction type
3
2
1
6
Based on consultations with the regions, Headquarters is working on resolutions for these elements.
9
APPENDIX E
APPENDIX E
Underground Injection Control Program Reporting Forms
Number
Form
7520-1
7520-2A
7520-2B
7520-3
7520-4
7520-6
7520-7
7520-8
7520-9
7520-10
Permit Review and Issuance/Wells in Area of Review
Compliance Evaluation
Compliance Evaluation - Significant Noncompliance
Mechanical Integrity Test/Remedial Actions
Quarterly Exceptions List
UIC Permit Application
Application to Transfer Permit
Injection Well Monitoring report
Completion Form for Injection Wells
Completion Report for Brine Disposal, Hydrocarbon Storage, or Enhanced
Recovery Well
Annual Disposal/Injection Well Monitoring Report
Well Rework Record
Plugging and Abandonment Plan
Inventory of Injection Wells
Pre-Closure Notification Form
7520-11
7520-12
7520-14
7520-16
7520-17
Please type or print all information. Please read instructions.
OMB No. 2040-0042 Form Expires 1/31/05
United States Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington, DC 20460
I. Name and Address of Reporting Agency
United States Environmental Protection Agency
UIC Federal Reporting System
Part I: Permit Review and Issuance/
Wells in Area of Review
(This information is solicited under the
authority of the Safe Drinking Water Act)
II. Date Prepared (month, day, year)
III. State Contact (name, telephone no.)
IV. Reporting Period (month, year)
From
To
October 1, 20
Class and Type of Injection Wells
II
Item
V. Permit
Application
Number of Individual
Permits Issued
B
Existing
Wells
Number of area Permits* Issued
New
Well Field
(Multiple Wells)
(*See instructions on back)
Existing
Well Field
Number of Wells in Area Permits
New
Wells
Issued
C
Permit
Not Issued
D
Modification
Issued
E
2R
2H
III
IV
V
(See B above)
Existing
Wells
Number of Permits Denied/Withdrawn
(after complete technical review)
Number of Major Permit
Modifications Approved
Number of Rule-Authorized
Class II Wells Reviewed
Wells
Reviewed
Number of Wells
A
Wells
VIII.
Area
of
Review
(AOR)
HC
2D
Identified
B
for C/A
New
Wells
(One Well)
Permit
VII.
Permit
File
Review
ER
Number of Permit Applications Received
A
VI.
Permit
Determination
I
SWD
Wells
Reviewed
Wells
Deficient
Abandoned
Wells
in Area of Review
Other
Wells
Number of Wells Identified
Abandoned
Wells
for Corrective Action
Other
Wells
1. Number of Wells in AOR with
Casing Repaired/Recemented C/A
2. Number of Active Wells in AOR
Plugged/Abandoned
Wells
with
C/A
C
3. Number of Abandoned Wells
in AOR Replugged
4. Number of Wells in AOR with
"Other" Corrective Action
IX. Remarks/Ad Hoc Report
(Attach additional sheets if necessary)
Certification
I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any
knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature and Typed or Printed Name and Title of Person Completing Form
EPA Form 7520-1 (Rev. 8-01)
Previous edition is obsolete.
Date
Telephone No.
Instructions and Definitions
All reporting is cumulative, year to date, and begins with October 1.
Section V. Permit Application
Well Reviewed: Enter under the appropriate category of injection wells the
number of rule authorized (existing) Class II wells with permit files reviewed
and compliance status determined this year to date.
Enter under each well class the total number of permit applications that have Well Deficient: Enter under the Class II well class the number of reviewed
been received this year to date. Include all applications: complete and rule authorized Class II wells found deficient (not in compliance) that received
incomplete; individual and municipal well (Area Permit); and applications for corrective or enforcement action as appropriate followup response.
“New” and “Existing” wells.
Section VIII. Area of Review (AOR)
A “New Well” is any well other than an existing well or a plugged/abandoned
well that became operable after the effective date of the State(or EPA) Under- All wells that penetrate the injection zone in the AOR of an injection well/field
ground Injection Control Program.
are reviewed duringpermit determination or duringany AOR analysis of a rule
authorized well file.
An “Existing Well” is any operable (i.e., active, under construction, shut in,
or temporarily abandoned) injection well or a properly plugged and abandoned Item A: Enter under the well class of each permit application or file that has
injection well that was in existence on the effective dateof the State(or EPA) been reviewed this year to date, the number of “Abandoned” and “Other”
UIC Program.
wells reviewed in the AOR.
Section VI. Permit Determination
“Abandoned” includes any well penetratingthe injection zone in theAOR that
has been properly or improperly plugged and/or abandoned. “Other” includes
Permit Determinations include the approval or denial of UIC permit any producing well, operable injection well, dry hole, exploratory well, etc.,
request/actions such as: applications for permits, major modifications to that penetrates the injection zone in the AOR.
issued permits, revocation andreissuanceof permits, or termination of permits
for cause. A complete permit determination includes a thorough technical Corrective Action is required for those wells that penetrate the injection zone
evaluation of the request,public notification or review before issuance, and a in the AOR that are improperly sealed, completed, or abandoned.
final decision document signed by the regulating authority.
Item B: Enter under the well class of each permit applications or file reviewed
Item A: Enter under each well class the number of individual permits issued this year to date, all “Abandoned” and “Other” wells in the AOR that have
required corrective action.
for “New” or “Existing” wells this year to date.
Item B: Enter under each well class the number of area permits that have been
issued for “New” or “Existing” well fields this year to date. (“New” in this
case, describes a nonhazardous injection well field having only new wells or
a mixture of new and existingwells. “Existing” describes a nonhazardous well
field having only existing wells.)
Item C: Enter under the well class of all permit applications or files that have
been reviewed, the number of wells in the AOR which have received corrective
action (be specific) this year to date.
Item C: Enter under each well class the number of “New” and “Existing”
wells covered by the Area Permits entered in Item B.
The public reporting and record keeping burden for this collection of
information is estimated to average 4.5 hours per year. Burden means the total
time, effort, or financial resource expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal Agency. This
includes the time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting, validating, and
verifying information, processingand maintaininginformation, and disclosing
and providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements;trainpersonnel to be able
to respond to the collection of information; search data sources; complete and
review the collection of information; and, transmit or otherwise disclose the
information. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a
currently valid OMB control number. Send comments on the Agency’s need
for this information, the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including the use of
automated collection techniques to Director, Collection Strategies Division,
U.S. EnvironmentalProtectionAgency (2822), 1200 Pennsylvania Ave., NW.,
Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed forms to this address.
Item D: Enter under each well class the number of permits or major modifications denied by the State(or EPA) UIC program and/or permits withdrawn by
applicants this year to date. The denial of a permit or major modification
should be included as a permit determination only after there has been a
complete technical review.
Item E: Enter under each well class the number of major modifications
approved this year to date. An approved major modification requires a
complete technical review, public notification or review, and a final decision
document signed by the regulating authority.
Section VII. Permit File Review
Paperwork Reduction Act Notice
A complete technical review of an existing (rule authorized) Class II well
record may be conducted by the authorized regulating
authority in lieu of a permit determination in accordance with the
UIC 1425 Guidance to determine whether the well is in compliance with UIC
regulatory requirements. The well record (or file) review may include an
evaluation of siting reports, wells in the area of review, construction, operat-
ing, monitoring or other State reports. Existing Class II wells should be
routinely reviewed at least once every five years during the life of the well.
EPA Form 7520-1 (8-01) Revised
Please type or print all information. Please read instructions on reverse.
United States Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington, DC 20460
OMB No. 2040-0042
Approval Expires 1/31/05
I. Name and Address of Reporting Agency
United States Environmental Protection Agency
UIC Federal Reporting System
Part II: Compliance Evaluation
(This information is solicited under the
authority of the Safe Drinking Water Act)
II. Date Prepared (month, day, year)
III. State Contact (name, telephone no.)
IV. Reporting Period (month, year)
From
To
October 1, 20
Class and Type of Injection Wells
II
Item
Total
Wells
A
HC
2D
2R
2H
III
IV
V
Number of Unauthorized
Injection Violations
2. Number of Mechanical Integrity Violations
Summary
of
ER
Number of Wells with Violations
1.
V.
I
SWD
Total
Violations
B
3. Number of Operation and
Maintenance Violations
4. Number of Plugging
and Abandonment Violations
Violations
5. Number of Monitoring and
Reporting Violations
6. Number of Other Violations
(Specify)
Total
Wells
A
Number of Wells with
Enforcement Actions
1. Number of Notices of Violation
2. Number of Consent Agreements
VI.
3. Number of Administrative Orders
Summary
of
Enforcement
Total
Enforcement
4. Number of Civil Referrals
B
Actions
5. Number of Criminal Referrals
6. Number of Well Shut-ins
7. Number of Pipeline Severances
8.
VII.
Summary
of
Compliance
Number of Other Enforcement Actions
(Specify)
A. This Quarter
Number of Wells
Returned to Compliance
B. This Year
VIII.
Number of Cases of Alleged Contamination of a USDW
Contamination
IX.
MIT Resolved
Percent of MIT Violations Resolved in 90 Days
X. Remarks/Ad Hoc Report (Attach additional sheets)
Certification
I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any
knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature and Typed or Printed Name and Title of Person Completing Form
EPA Form 7520-2A (1-88)
Replaces EPA Form 7520-2 which is obsolete
Date
Telephone No.
Definitions and Instructions
All reportingis cumulative, year to date, and begins with October 1.
Section VIII. USDW Contaminations
A Class II, III, or V injection well with a violation of a permit or rule
requirement is said to be in noncompliance. A Class I or IV well with
any violation is said to be in significant noncompliance (SNC). Note:
A Class II, III, or V well with certain types of violations may also be
in significant noncompliance. (See Form 7520-2B (Reverse) for
definitions of SNC violations.)
Enter under each well class the number of times a well in noncompliance has allegedly contaminated an underground source of drinking
water (USDW) this year to date.
Section V. Summary of Violations
Section IX. % MIT Violations Resolved in 90 Days
Enter under each well class the percentage of MIT violations
(identified in Section V., under “Mechanical Integrity”) resolved
within 90 days.
(Includes all noncompliance, significant and non-significant)
In order to calculate the percentage:
Note: Also Report Significant Noncompliance Information on Form
7520-2B.
A. Total Wells: Enter under each well class the number of wells with
a violation(s) identified this year to date, whether or not the well has
been returned to compliance. These totals track the percentage of the
injection well universein noncompliance each year. Enter a well only
once each year.
B. Total Violations:
Item 1-6: Enter under each well class the number of times each
violation (be specific) has been identified this year to date.
Section VI. Summary of Enforcement
A. Total Wells: Enter under each well class the number of wells with
violations that have received an enforcement action(s) this year to
date. These totals track the percentage of the injection well universe
that receives an enforcement action each year. Enter a well only once
each year.
B. Total Enforcement Actions:
Item 1-8: Enter under each well class the number of times wells with
violations have received an enforcement action(s) (be specific) this
year to date.
Section VII. Number of Wells Returned to Compliance
A “Well Returned to Compliance” is a well in violation of UIC
program requirements that has had the violation(s) corrected and the
resolution of the violation(s) has been verified by the regulating
authority. Note: An enforcement action alone (e.g., well shut-in) does
not constitute a “return to compliance.”
A. Enter under each well class the number of wells returned to
compliance in the current quarter only.
B. Enter under each well class the number of wells returned to
compliance (as a result of an enforcement action against a violation)
this year to date. These totals track the percentage of the injection
well universe that returned to compliance through an enforcement
action(s) each year. Enter a well only once each year.
1. Add up the total number of MIT violations to date
whether of not they were identified in this reporting
period, e.g., 10.
2. Add up the number of these violations to date that were
resolved in 90 days or less, e.g., 5.
3. Calculatethe percentage of total MIT violations todate
that have been resolved in 90 days or less, e.g., 50%.
Paperwork Reduction Act
The public reportingand record keeping burden for this collection
of information is estimated to average 6 hours per response.
Burden means thetotal time, effort,or financial resource expended
by persons to generate, maintain, retain, or disclose or provide
information to or for a Federal Agency. This includes the time
needed to review instructions;develop,acquire, install, and utilize
technology and systems for the purposes of collecting, validating,
and verifying information, processing and maintaining information, and disclosingand providinginformation; adjust the existing
ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to the
collection of information; search data sources; complete and
review the collection of information; and, transmit or otherwise
disclosethe information. An agency may not conduct or sponsor,
and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control
number. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including
the use of automated collection techniques to Director, Collection
Strategies Division, U.S. Environmental Protection Agency
(2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460.
Include the OMB control number in any correspondence. Do not
send the completed forms to this address.
EPA Form 7520-2A Revised
Please type or print all information. Please read instructions on reverse.
United States Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington, DC 20460
OMB No. 2040-0042
Approval Expires 1/31/05
I. Name and Address of Reporting Agency
United States Environmental Protection Agency
UIC Federal Reporting System
Part II: Compliance Evaluation
Significant Noncompliance
(This information is solicited under the
authority of the Safe Drinking Water Act)
II. Date Prepared (month, day, year)
III. State Contact (name, telephone no.)
IV. Reporting Period (month, year)
From
To
October 1, 20
Class and Type of Injection Wells
II
Item
Total
Wells
A
Number of Wells with SNC Violations
B
1. Number of Unauthorized
Injection SNC Violations
2. Number of Mechanical Integrity
SNC Violations
3. Number of Injection Pressure
SNC Violations
4. Number of Plugging
and Abandonment SNC Violations
5. Number of SNC Violations
of Formal Orders
6. Number of Falsification
SNC Violations
Number
of Other SNC Violations
7.
(Specify)
A
Number of Wells with
Enforcement Actions Against SNC
V.
Summary
of
Significant
Total
Non-
Violations
Compliance
(SNC)
Total
Wells
I
SWD
ER
HC
2D
2R
2H
III
IV
V
1. Number of Notices of Violation
VI.
2. Number of Consent Agreements/Orders
Summary
3. Number of Administrative Orders
of
Enforcement
Total
Enforcement
Actions
Against
4. Number of Civil Referrals
B
5. Number of Criminal Referrals
6. Number of Well Shut-ins
SNC
7. Number of Pipeline Severances
8.
VII.
Summary
of
Compliance
Number of Other Enforcement Actions
Against SNC Violations (Specify)
Number of Wells in SNC
Returned to Compliance
A. This Quarter
B. This Year
VIII.
Number of Cases of Alleged Contamination of a USDW
Contamination
IX.
Well
Closure
Class IV/Endangering Class V
Well Closures
Involuntary Well Closure
Voluntary Well Closure
Certification
I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any
knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature and Typed or Printed Name and Title of Person Completing Form
EPA Form 7520-2B (8-01)
Replaces EPA Form 7520-2 which is obsolete.
Date
Telephone No.
Instructions and Definitions
EPA Form 7520-2B
Section IV. Reporting Period: All reporting is cumulative, year to date,
beginning with October 1.
Definitions of SNC Violations:
Section VII. No. of Wells Returned to Compliance: A “Well Returned to
Compliance” is a well in violation of UIC program requirements which has had
the violation(s) corrected and has had the resolution of the violation(s) verified
by the regulating authority. An enforcement action alone (e.g., well shut-in) does
not constitute a “Return to Compliance.”
1. Violations of any kind pertaining to a Class I or IV well.
2. The followingviolations by the owner/operator of a Class II, III, or V well:
a. Unauthorized Injection – Any unauthorized emplacement of fluids (where
formal authorization is required);
b. Mechanical Integrity – Well operation without mechanical integrity which
causes the movement of fluid outside the authorized zone – if injection of such
fluid may have the potential for endangering a USDW;
Under subsection A, enter under each well class the total number of wells
returned to compliance (as a result of an enforcement action against an SNC
violation) in the current quarter only. Under subsection B, enter under each well
class the total number of wells returned to compliance (as a result of an
enforcement action against an SNC violation) this year to date. These totals
track the percentage of the injection well universe that returned to compliance
through an SNC enforcement action(s) each year. Enter a well only once each
year.
Section VIII. USDW Contaminations
c. Injection Pressure – Well operation at an injection pressure that exceeds the
permitted or authorized injection pressure and causes the movement of fluid
outside the authorized zone of injection – if such movement may have the
potential for endangering a USDW;
d. Pluggingand Abandonment – The pluggingand abandonment of an injection
well in an unauthorized manner. This definition includes the “walking away
from” a responsibility to plug and abandon a well. These wells are in SNC
only when there is endangerment of USDW and there is an identifiable
owner/operator;
e. Violation of a Formal Order – Any violation of a formal enforcement action,
includingan administrative or judicial order, consent agreement,judgement,or
equivalent State action;
f. Falsification – The knowing submission or use of any false information in
a permit application, periodic report or special request for information about
a well.
Section V. Total No. of Wells with SNC Violations:
Significant Noncompliance information is also to be reported on EPA From
7520-2A. Under each well class and type, enter the total number of SNC
violations which have been identified in the year to date, whether or not the
violations(s)havebeen corrected and the well(s) returned to compliance. These
totals track the percentage of the injection well universe in SNC each year.
Enter a well only once each year.
For subsections 1 through 7 enter under each well class the total number of
times, by specific violation, an SNC has been identified this year to date.
Section VI. Total SNC Enforcement Actions: Significant Noncompliance
information is also to be reported on EPA Form 7520-2A. Under each well
class and type, enter the total number of wells with SNC violations that have
received an enforcement action(s) this year to date, whether or not the wells
have been returned to compliance. These totals track the percentage of the
injection well universe that receives an SCN enforcement action each year.
Enter a well only once each year.
For subsections 1 through 8 enter under each well class the total number of
times wells with SNC violations have received the specified enforcement
action this year to date.
Enter under each well class the number of times a well in SNC has allegedly
contaminated an underground source of drinking water (USDW) this year to
date.
Section IX. Number of Class IV/V Endangering Class V Well Closures:
Enter the number of Class IV and Class V well closures either as a voluntary or
involuntary action. Involuntary well closure means wells closed as a result of
enforcement actions or permit call-ins. Voluntary well closure means well
closed as a direct result of outreach activities. Well closure describes a process
to permanently discontinue injection of an unauthorized and en-dangeringfluid
contaminant which is in violation of RCRA or SDWA or applicable regulations.
At the time, closure must include immediate cessation of injection of unauthorized waste stream to satisfy SDWA requirements. To satisfy both SDWA and
RCRA, well closure may require additional actions: remove injection fluids
deposited in well, sludge and any visibly contaminated soil; segregatehazardous
waste streams from sanitary waste streams (septic system) and redirect HW
to holding tank; restrict injection to authorized waste stream; seal floor drain;
obtain authorized sewer hook-up; remove well, injectate and contaminated soil
and dispose in authorized facility. Imminent threat to USDW may require
monitoring and ground-water remediation.
Paperwork Reduction Act
The public reporting and record keeping burden for this collection of information is estimated to average 5.5 hours per response. Burden means the total
time, effort, or financial resource expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal Agency. This
includes the time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and disclosing
and providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements;train personnel to be able
to respond to the collection of information; search data sources;complete and
review the collection of information; and, transmit or otherwise disclose the
information. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a currently
valid OMB control number. Send comments on the Agency’s need for this
information, the accuracy of the provided burden estimates, and any suggested
methods for minimizing respondent burden, including the use of automated
collection techniques to Director, Collection Strategies Division, U.S.
Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW.,
Washington, DC 20460. Include the OMB control number in any correspondence. Do not send the completed forms to this address.
Please type or print all information. Please read instructions on reverse.
United States Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington, DC 20460
OMB No. 2040-0042
Approval Expires 1/31/05
I. Name and Address of Reporting Agency
United States Environmental Protection Agency
UIC Federal Reporting System
Part III: Inspections
Mechanical Integrity Testing
(This information is solicited under the
authority of the Safe Drinking Water Act)
II. Date Prepared (month, day, year)
III. State Contact (name, telephone no.)
IV. Reporting Period (month, year)
From
To
October 1, 20
Class and Type of Injection Wells
II
Item
Total
Wells
A
V.
Summary
Total
of
Inspections
B
Inspections
A
Total
Wells
B
For
Significant
of
Leak
Integrity
For
Fluid
Total
Wells
A
VII.
of
Remedial
Action
2R
2H
III
IV
V
1. Number of Mechanical Integrity Tests
(MIT) Witnessed
2. Number of Emergency Response or
Complaint Response Inspections
3. Number of Well
Constructions Witnessed
4. Number of Well
Pluggings Witnessed
5. Number of Routine/Periodic
Inspections
Number of Wells Tested or Evaluated
for Mechanical Integrity (MI)
No. of Rule-Authorized Wells Passed 2-part test
Tested/Evaluated for MI
Failed 2-part test
Total
Remedial
Actions
VIII. Remarks/Ad Hoc Report
2. No. of Casing/
Tubing Pressure Tests
Well Passed
3. Number of Monitoring
Record Evaluations
Well Passed
4. No. of Other Significant Leak
Tests/Evaluations (Specify)
Well Passed
1. Number of Cement
Record Evaluations
Well Passed
2. Number of Temperature/
Noise Log Tests
Well Passed
3. No. of Radioactive Tracer/
Cement Bond Tests
Well Passed
4. No. of Other Fluid Migration
Tests/Evaluations (Specify)
Well Passed
D
Migration
Summary
HC
2D
Number of Wells Inspected
C
Mechanical
(MI)
ER
Well Passed
1. Number of Annulus Pressure
Monitoring Record Evaluations Well Failed
VI.
Summary
I
SWD
B
Well Failed
Well Failed
Well Failed
Well Failed
Well Failed
Well Failed
Well Failed
Number of Wells with
Remedial Action
1. Number of Casing Repaired/
Squeeze Cement Remedial Actions
2. Number of Tubing/Packer
Remedial Actions
3. Number of Plugging/Abandonment
Remedial Actions
4. Number of Other Remedial Actions
(Specify)
(Attach additional sheets)
Certification
I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any
knowingly false or misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature and Typed or Printed Name and Title of Person Completing Form
EPA Form 7520-3 (Rev. 8-01)
Previous edition is obsolete.
Date
Telephone No.
Instructions and Definitions
(All reporting is cumulative, year to date, and begins with October 1.)
Item D. Fluid Migration Tests: (This year to date)
Section V. Summary of Inspections
Items 1-4: Enter under each well class the number of times wells have
passed or failed a field test/record evaluation for fluid migration (be
specific).
A complete inspection should include an assessment of: the well
head, pressure and flow meters, pipeline connections, and any other
equipment associated with the injection system; an inspection is
complete only when a report has been filed with the regulating
authority.
Item A: Enter under each well class the number of wells that have
been inspected this year to date. These totals track the percentage of
the injection well universe inspected each year. Enter a well only
once each year.
Total Inspections: (This year to date)
Item 1: Enter under each well class the number of inspections to
witness field Mechanical Integrity Tests. (At least 25% of MITs
performed by operators each year should be witnessed.)
Section VII. Summary of Remedial Action
A failure of mechanical integrity (MI) may occur at any time during the
life of an injection well until it is plugged and abandoned in accordance
with a preapproved plan. Failure may be identified duringan inspection,
a field test, an evaluation of well records, or during routine operation of
a well. Remedial actions include additional permit conditions, monitoring
or testing, or one of the actions specified below.
Item A: Enter under each well class the number of wells that have
received remedial actions this year to date. This total tracks the percentage of the injection well universe that have received remedial action each
year. Enter a well only once each year.
Total Remedial Actions: (This year to date)
Item 2: Enter under each well class the number of inspections that
have been in response to a problem reported to the regulating
authority.
Item 3: Enter under each well class the number of inspections of well
constructions or any preoperational activities.
Item 4: Enter under each well class the number of inspections of well
pluggings or pluggings and abandonment.
Item 5: Enter under each well class the number of inspections that
have been routine/periodic.
Section VI. Summary of Mechanical Integrity
A complete MIT is composed of a test for significant leaks in the
casing, tubing or packer and a test for significant fluid migration into
a USDWthrough vertical channels adjacent to the well bore. An MIT
consists of a field test on a well or an evaluation of a well’s monitoring records (i.e., annulus pressure, etc.) or cement records. A t a
minimum, the mechanical integrity of a Class I, II, or III (solution
mining of salt) well should be demonstrated at least once every five
years during the life of the well.
Item A: Enter under each well class the number of wells that have had
a complete MIT this year to date. These totals track the percentage
of the injection well universe tested for MI each year. Enter a well
only once each year.
Item B: Enter under the appropriate well class the number of rule
authorized wells that have passed a complete MIT and the number
that have failed a complete MIT this year to date.
Item 1-4: Enter under each well class the number of times that wells have
received remedial action (be specific).
Paperwork Reduction Act
The public reporting and record keeping burden for this collection of
information is estimated to average 5 hours per response. Burden
means the total time, effort,or financial resource expended by persons
to generate, maintain, retain, or discloseor provide information to or
for a Federal Agency. This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing
and providing information; adjust the existing ways to comply with
any previously applicable instructions and requirements; train
personnel to be able to respond to the collection of information; search data sources; complete and review the collection of information;
and, transmit or otherwise disclose the information. An agency may
not conduct or sponsor, and a person is not required to respond to,
a collection of information unless it displays a currently valid OMB
control number. Send comments on the Agency’s need for this
information, the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including the
use of automated collection techniques to Director, Collection
Strategies Division, U.S. Environmental Protection Agency (2822),
1200 Pennsylvania Ave., NW., Washington, DC 20460. Include the
OMB control number in any correspondence. Do not send the
completed forms to this address.
Item C: Significant Leak Tests: (This year to date)
Item 1-4: Enter under each well class the number of times wells have
passed or failed a field test/record evaluation for significant leaks (be
specific).
EPA Form 7520-3 Reverse
OMB No. 2040-0042
United States Environmental Protection Agency
Office of Ground Water and Drinking Water
Washington, DC 20460
Approval expires 1/31/05
UIC Federal Reporting System
I. Reporting Period
Part IV: Quarterly Exceptions List
From
To
(This information is collected under the authority of the Safe Drinking Water Act)
II.
Well
III.
IV.
Name and Address
Date of
Date
Other (Specify)
Pipeline Severance
Well Shut-in
Criminal Referral
Civil Referral
Administrative Order
Consent Agreement
Notice of Violation
Enforcement
VII.
Mark ('X') Enforcement Type
Date of
Other (Specify)
Falsification
No.)
Formal Order
Type
Violation
Plugging and Abandonment
(Permit
Injection Pressure
and
Well Mechanical Integrity
ID No.
of Owner/Operator
VI. Summary of Enforcement
Mark ('X') Violation Type
Unauthorized Injection
Class
Well
V. Summary of Violations
Compliance
Certification
I certify that the statements I have made on this form and all attachments thereto are true, accurate, and complete. I acknowledge that any knowingly false or misleading statement may be
punishable by fine or imprisonment or both under applicable law.
Signature of Person Completing Form
EPA Form 7520-4 (Rev. 8-01)
Typed or Printed Name and Title
Previous edition is obsolete.
Date
Telephone No.
Achieved
Instructions and Definitions
The quarterly Exceptions list is used to track wells reported
in significant noncompliance (SNC) on EPA Form 7520-2B
for two or more consecutive quarters without being addressed with a formal enforcement action or returned to
compliance. Any SNC reported on Form 7520-4 shall be
reported until the SNC is resolved. Once a SNC is reported
as resolved, it need not appear in subsequent reports.
Section I - Reporting Period
All reporting is cumulative, year to date, beginning with
October 1.
Section II - Well Class and Type
Enter the well class and type of each well in SNC for two or
more consecutive quarters. For Class I wells, specify IH for
hazardous waste, IM of municipal waste, Ii for industrial
waste. For Class II wells, specify IID for saltwater disposal,
IIR for enhanced recovery, IIH for liquid hydrocarbon
storage.
Section III - Name and Address of Owner/Operator
Enter the name and address of the owner/operator of the
injection well. Use multiple lines of the form if needed. (You
may use one form for each owner/operator.)
Section IV - Well ID No. (Permit No.)
Enter the I.D. number of the injection well in SNC. If the well
has a UIC permit number, enter this as the I.D. number.
Section V - Summary of Violations
Enter the date the SNC violation was first identified and
place an “X” in the appropriate column. In the event that
there were multiple SNC violations for a single well, enter
each violation and the date it was identified on a separate
line.
Section VI - Summary of Enforcement
Enter the date an enforcement action was taken against the
SNC violation and place an “X” in the appropriate column.
In the event that there were multiple enforcement actions,
enter each enforcement action and the date it was taken on
a separate line.
EPA Form 7520-4 (8-01) Reverse
Paperwork Reduction Act
The public reporting and record keeping burden for this
collection of information is estimated to average 2 hours
per response. Burden means the total time, effort, or
financial resource expended by persons to generate,
maintain, retain, or disclose or provide information to or
for a Federal Agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting,
validating, and verifying information, processing and
maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any
previously applicable instructions and requirements;
train personnel to be able to respond to the collection of
information; search data sources; complete and review
the collection of information; and, transmit or otherwise
disclose the information. An agency may not conduct or
sponsor, and a person is not required to respond to, a
collection of informat ion unless it displays a currently
valid OMB control number. Send comments on the
Agency’s need for this information, the accuracy of the
provided burden estimates, and any suggested methods
for minimizing respondent burden, including the use of
automated collection techniques to Director, Collection
Strategies Division, U.S. Environmental Protection
Agency (2822), 1200 Pennsylvania Ave., NW., Washington, DC 20460. Include the OMB control number in any
correspondence. Do not send the completed forms to this
address.
OMB No. 2040-0042
United States Environmental Protection Agency
Approval Expires 1/31/05
I. EPA ID Number
Underground Injection Control
T/A
Permit Application
(Collected under the authority of the Safe Drinking
Water Act. Sections 1421, 1422, 40 CFR 144)
U
Read Attached Instructions Before Starting
For Official Use Only
Application approved
mo
day
Date received
year
mo
day
Permit Number
year
Well ID
II. Owner Name and Address
FINDS Number
III. Operator Name and Address
Owner Name
Owner Name
Street Address
City
State
IV. Commercial Facility
Phone Number
Street Address
ZIP CODE
City
V. Ownership
Phone Number
State
VI. Legal Contact
Yes
Private
Owner
No
Federal
Operator
ZIP CODE
VII. SIC Codes
Other
VIII. Well Status
Date Started
A.
mo
day
(Mark "x")
B. Modification/Conversion
C. Proposed
year
Operating
IX. Type of Permit Requested
A. Individual
(Mark "x" and specify if required)
Number of Existing Wells
B. Area
Number of Proposed Wells
X. Class and Type of Well
A. Class(es)
B. Type(s)
(enter code(s))
(enter code(s))
Name(s) of field(s) or project(s)
(see reverse)
C. If class is "other" or type is code 'x,' explain
D. Number of wells per type (if area permit)
XI. Location of Well(s) or Approximate Center of Field or Project
Latitude
Deg
Min
Longitude
Sec
Deg
Min
XII. Indian Lands (Mark 'x')
Township and Range
Sec
Sec
Twp
Range
1/4 Sec
Yes
Feet From
Line
Feet From
Line
No
XIII. Attachments
(Complete the following questions on a separate sheet(s) and number accordingly; see instructions)
For Classes I, II, III, (and other classes) complete and submit on a separate sheet(s) Attachments A--U (pp 2-6) as appropriate. Attach maps where
required. List attachments by letter which are applicable and are included with your application.
XIV. Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments
and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibliity of fine and
imprisonment. (Ref. 40 CFR 144.32)
A. Name and Title
(Type or Print)
C. Signature
EPA Form 7520-6 (Rev. 8-01)
B. Phone No. (Area Code and No.)
D. Date Signed
C
Well Class and Type Codes
Class I
Wells used to inject waste below the deepest underground source of drinking
water.
Type “I”
“M”
“W”
“X”
Nonhazardous industrial disposal well
Nonhazardous municipal disposal well
Hazardous waste disposal well injecting below USDWs
Other Class I wells (not included in Type “I,” “M,” or “W”)
Class II
Oil and gas production and storage related injection wells.
Type “D”
“R”
“H”
“X”
Produced fluid disposal well
Enhanced recovery well
Hydrocarbon storage well (excluding natural gas)
Other Class II wells (not included in Type “D,” “R,” or “H”)
Class III
Special process injection wells.
Type “G”
“S”
“U”
“X”
Solution mining well
Sulfur mining well by Frasch process
Uranium mining well (excluding solution mining of conventional mines)
Other Class III wells (not included in Type “G,” “S,” or “U”)
Other Classes Wells not included in classes above.
Class V wells which may be permitted under §144.12.
Wells not currently classified as Class I, II, III, or V.
Attachments to Permit Application
Class
Attachments
I new well
existing
A, B, C, D, F, H – S, U
A, B, C, D, F, H – U
II new well
existing
A, B, C, E, G, H, M, Q, R; optional – I, J, K, O, P, U
A, E, G, H, M, Q, R, – U; optional – J, K, O, P, Q
III new well
existing
A, B, C, D, F, H, I, J, K, M – S, U
A, B, C, D, F, H, J, K, M – U
Other Classes
EPA Form 7520-6 (8-01)
To be specified by the permitting authority
page 2 of 6
INSTRUCTIONS - Underground Injection Control (UIC) Permit Application
Paperwork Reduction Act: The public reporting and record keeping burden for this collection of information is estimated to average
394 hours for a Class I hazardous well application, 252 hours for a Class I non-hazardous well application, 32 hours for a Class II well
application, and 119 hours for a Class III well application. Burden means the total time, effort, or financial resource expended by
persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating,and verifying
information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with
any previously applicable instructions and requirements; train personnel to be able to respond to the collection of information; search
data sources; complete and review the collection of information; and, transmit or otherwise disclose the information. An agency may
not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB
control number. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any
suggested methods for minimizing respondent burden, including the use of automated collection techniques to Director, Collection
Strategies Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, DC 20460. Include the
OMB control number in any correspondence. Do not send the completed forms to this address.
This form must be completed by all owners or operators of Class I, II, and III injection wells and others who may be directed to
apply for permit by the Director.
I.
EPA I.D. NUMBER - Fill in your EPA Identification Number. If you do not have a number, leave blank.
II.
OWNER NAME AND ADDRESS - Name of well, well field or company and address.
III.
OPERATOR NAME AND ADDRESS - Name and address of operator of well or well field.
IV.
COMMERCIAL FACILITY - Mark the appropriate box to indicate the type of facility.
V.
OWNERSHIP - Mark the appropriate box to indicate the type of ownership.
VI.
LEGAL CONTACT - Mark the appropriate box.
VII.
SIC CODES - List at least one and no more than four Standard Industrial Classification (SIC) Codes that best describe the
nature of the business in order of priority.
VIII.
WELL STATUS - Mark Box A if the well(s) were operating as injection wells on the effective date of the UIC Program for the
State. Mark Box B if wells(s) existed on the effective date of the UIC Program for the State but were not utilized for injection.
Box C should be marked if the application is for an underground injection project not constructed or not completed by the
effective date of the UIC Program for the State.
IX.
TYPE OF PERMIT - Mark “Individual” or “Area” to indicate the type of permit desired. Note that area permits are at the
discretion of the Director and that wells covered by an area permit must be at one site, under the control of one person and
do not inject hazardous waste. If an area permit is requested the number of wells to be included in the permit must be
specified and the wells described and identified by location. If the area has a commonly used name, such as the “Jay
Field,” submit the name in the space provided. In the case of a project or field which crosses State lines, it may be
possible to consider an area permit if EPA has jurisdiction in both States. Each such case will be considered individually, if
the owner/operator elects to seek an area permit.
X.
CLASS AND TYPE OF WELL - Enter in these two positions the Class and type of injection well for which a permit is
requested. Use the most pertinent code selected from the list on the reverse side of the application. When selecting type X
please explain in the space provided.
XI.
LOCATION OF WELL - Enter the latitude and longitude of the existing or proposed well expressed in degrees, minutes, and
seconds or the location by township, and range, and section, as required by 40 CFR Part 146. If an area permit is being
requested, give the latitude and longitude of the approximate center of the area.
XII.
INDIAN LANDS - Place an “X” in the box if any part of the facility is located on Indian lands.
XIII.
ATTACHMENTS - Note that information requirements vary depending on the injection well class and status. Attachments
for Class I, II, III are described on pages 4 and 5 of this document and listed by Class on page 2. Place EPA ID number in
the upper right hand corner of each page of the Attachments.
CERTIFICATION - All permit applications (except Class II) must be signed by a responsible corporate officer for a
corporation, by a general partner for a partnership, by the proprietor of a sole proprietorship, and by a principal executive or
ranking elected official for a public agency. For Class II, the person described above should sign, or a representative duly
authorized in writing.
EPA Form 7520-6
Page 3 of 6
XIV.
INSTRUCTIONS - Attachments
Attachments to be submitted with permit application for Class I, II, III and other wells.
A.
AREA OF REVIEW METHODS - Give the methods and, if appropriate, the calculations used to determine the size of
the area of review (fixed radius or equation). The area of review shall be a fixed radius of 1/4 mile from the well bore
unless the use of an equation is approved in advance by the Director.
B.
MAPS OF WELL/AREA AND AREA OF REVIEW - Submit a topographic map, extending one mile beyond the property
boundaries, showing the injection well(s) or project area for which a permit is sought and the applicable area of
review. The map must show all intake and discharge structures and all hazardous waste treatment, storage, or
disposal facilities. If the application is for an area permit, the map should show the distribution manifold (if applicable)
applying injection fluid to all wells in the area, including all system monitoring points. Within the area of review, the
map must show the following:
Class I
The number, or name, and location of all producing wells, injection wells, abandoned wells, dryholes, surface bodies
of water, springs, mines (surface and subsurface), quarries, and other pertinent surface features, including
residences and roads, and faults, if known or suspected. In addition, the map must identify thosewells, springs, other
surface water bodies, and drinking water wells located within one quarter mile of the facility property boundary. Only
information of public record is required to be included in this map;
Class II
In addition to requirements for Class I, include pertinent information known to the applicant. This requirement
does not apply to existing Class II wells;
Class III
In addition to requirements for Class I, include public water systems and pertinent information known to the
applicant.
C.
CORRECTIVE ACTION PLAN AND WELL DATA - Submit a tabulation of data reasonably available from public records
or otherwise known to the applicant on all wells within the area of review, including those on the map required in B,
which penetrate the proposed injection zone. Such data shall include the following:
Class I
Adescription of each well's types,construction, date drilled, location, depth, record of plugging and/or completion, and
any additional information the Director may require. In the case of new injection wells, include the corrective action
proposed to be taken by the applicant under 40 CFR 144.55.
Class II
In addition to requirement for Class I, in the case of Class II wells operating over the fracture pressure of the injection
formation, all known wells within the area of review which penetrate formations affected by the increase in pressure.
This requirement does not apply to existing Class II wells.
Class III
In addition to requirements for Class I, the corrective action proposed under 40 CFR 144.55 for all Class III wells.
D.
MAPS AND CROSS SECTION OF USDWs - Submit maps and cross sections indicating the vertical limits of all
underground sources of drinking water within the area of review (both vertical and lateral limits for Class I), their
position relative to the injection formation and the direction of water movement, where known, in every underground
source of drinking water which may be affected by the proposed injection. (Does not apply to Class II wells.)
EPA Form 7520-6
Page 4 of 6
E.
NAME AND DEPTH OF USDWs (CLASS II) - For Class II wells, submit geologic name, and depth to bottom of all
underground sources of drinking water which may be affected by the injection.
F.
MAPS AND CROSS SECTIONS OFGEOLOGIC STRUCTURE OF AREA - Submit maps and cross sections detailing the
geologic structure of the local area (including the lithology of injection and confining intervals) and generalized maps
and cross sections illustrating the regional geologic setting. (Does not apply to Class II wells.)
G.
GEOLOGICAL DATA ON INJECTION AND CONFINING ZONES (Class II) - For Class II wells, submit appropriate
geological data on theinjection zone and confining zones including lithologic description, geological name, thickness,
depth and fracture pressure.
H.
OPERATING DATA - Submit the following proposed operating data for each well (including all those to be covered by
area permits): (1) average and maximum daily rate and volume of the fluids to be injected; (2) average and maximum
injection pressure; (3) nature of annulus fluid; (4) for Class I wells, source and analysis of the chemical, physical,
radiological and biological characteristics, including density and corrosiveness, of injection fluids; (5) for Class II
wells, source and analysis of the physical and chemical characteristics of the injection fluid; (6) for Class III wells, a
qualitative analysis and ranges in concentrations of all constituents of injected fluids. If the information is proprietary,
maximum concentrations only may be submitted, but all records must be retained.
I.
FORMATION TESTING PROGRAM - Describe the proposed formation testing program. For Class I wells the program
must be designed to obtain data on fluid pressure, temperature, fracture pressure, other physical, chemical, and
radiological characteristics of the injection matrix and physical and chemical characteristics of the formation fluids.
For Class II wells the testing program must be designed to obtain data on fluid pressure, estimated fracture
pressure, physical and chemical characteristics of the injection zone. (Does not apply to existing Class II wells or
projects.)
For Class III wells the testing must be designed to obtain data on fluid pressure, fracture pressure, and physical and
chemical characteristics of the formation fluids if the formation is naturally water bearing. Only fracture pressure is
required if the program formation is not water bearing. (Does not apply to existing Class III wells or projects.)
J.
STIMULATION PROGRAM - Outline any proposed stimulation program.
K.
INJECTION PROCEDURES - Describe the proposed injection procedures including pump, surge, tank, etc.
L.
CONSTRUCTION PROCEDURES - Discuss the construction procedures (according to §146.12 for Class I, §146.22 for
Class II, and §146.32 for Class III) to be utilized. This should include details of the casing and cementing program,
logging procedures, deviation checks, and the drilling, testing and coring program, and proposed annulus fluid.
(Request and submission of justifying data must be made to use an alternative to packer for Class I.)
M.
CONSTRUCTION DETAILS - Submit schematic or other appropriate drawings of the surface and subsurface
construction details of the well.
N.
CHANGES IN INJECTED FLUID - Discuss expected changes in pressure, native fluid displacement, and direction of
movement of injection fluid. (Class III wells only.)
O.
PLANS FOR WELL FAILURES - Outline contingency plans (proposed plans, if any, for Class II) to cope with all
shut-ins or wells failures, so as to prevent migration of fluids into any USDW.
P.
MONITORING PROGRAM - Discuss the planned monitoring program. This should be thorough, including maps
showing the number and location of monitoring wells as appropriate and discussion of monitoring devices, sampling
frequency, and parameters measured. If a manifold monitoring program is utilized, pursuant to §146.23(b)(5),
describe the program and compare it to individual well monitoring.
Q.
PLUGGING AND ABANDONMENT PLAN - Submit a plan for plugging and abandonment of the well including: (1)
describe the type, number, and placement (including the elevation of the top and bottom) of plugs to be used; (2)
describe the type, grade, and quantity of cement to be used; and (3) describe the method to be used to place plugs,
including the method used to place the well in a state of static equilibrium prior to placement of the plugs. Also for a
Class III well that underlies or is in an exempted aquifer, demonstrate adequate protection of USDWs. Submit this
information on EPA Form 7520-14, Plugging and Abandonment Plan.
EPA Form 7520-6
Page 5 of 6
R.
NECESSARY RESOURCES - Submit evidence such as a surety bond or financial statement to verify that the
resources necessary to close, plug or abandon the well are available.
S.
AQUIFER EXEMPTIONS - If an aquifer exemption is requested, submit data necessary to demonstrate that the aquifer
meets the following criteria:(1) does not serve as a source of drinking water; (2) cannot now and will not in the future
serve as a source of drinking water; and (3) the TDS content of the ground water is more than 3,000 and less than
10,000 mg/l and is not reasonably expected to supply a public water system. Data to demonstrate that the aquifer is
expected to be mineral or hydrocarbon production, such as general description of the mining zone, analysis of the
amenability of the mining zone to the proposed method, and time table for proposed development must also be
included. For additional information on aquifer exemptions, see 40 CFR Sections 144.7 and 146.04.
T.
EXISTING EPA PERMITS - List program and permit number of any existing EPA permits, for example, NPDES,
PSD, RCRA, etc.
U.
DESCRIPTION OF BUSINESS - Give a brief description of the nature of the business.
EPA Form 7520-6
Page 6 of 6
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
Application To Transfer Permit
Name and Address of Existing Permittee
Name and Address of Surface Owner
State
Locate Well and Outline Unit on
Section Plat - 640 Acres
County
Permit Number
Surface Location Description
N
____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of
Section ____ Township ____ Range ____
Locate well in two directions from nearest lines of quarter section and drilling unit
Surface
Location ____ ft. frm (N/S) ____ Line of quarter section
and ____ ft. from (E/W) ____ Line of quarter section.
W
E
Well Activity
Well Status
Type of Permit
____ Class I
____ Operating
____ Individual
____ Class II
____ Modification/Conversion
____ Area
____ Proposed
Number of Wells ____
____ Brine Disposal
____ Enhanced Recovery
____ Hydrocarbon Storage
S
____ Class III
____ Other
Lease Number
Well Number
Name and Address of New Operator
Name(s) and Address(es) of New Owner(s)
Attach to this application a written agreement between the existing and new permittee containing a
specific date for transfer of permit responsibility, coverage, and liability betweend them.
The new permittee must show evidence of financial responsibility by the submission of a surety bond, or
other adequate assurance, such as financial statements or other materials acceptable to the Director.
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in
this document and all attachments and that, based on my inquiry of those individuals immediately responsible for
obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32)
Name and Official Title (Please type or print)
EPA Form 7520-7 (Rev. 8-01)
Signature
Date Signed
PAPERWORK REDUCTION ACT
The public reporting and record keeping burden for this collection of information is estimated to average 5 hours per response.
Burden means the total time, effort, or financial resource expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal Agency. This includes the time needed to review instructions; develop, acquire, install,
and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously
applicable instructions and requirements; train personnel to be able to respond to the collection of information; search data
sources; complete and review the collection of information; and, transmit or otherwise disclose the information. An agency may
not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently
valid OMB control number. Send comments on the Agency’s need for this information, the accuracy of the provided burden
estimates, and any suggested methods for minimizing respondent burden, including the use of automated co l l e c t i o n
techniques to Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave.,
NW., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed forms to
this address.
Well Class and Type Code
Class I
Wells used to inject waste below the deepest underground source of drinking water.
Type “I”
“M”
“W”
“X”
Nonhazardous industrial disposal well
Nonhazardous municipal disposal well
Hazardous waste disposal well injecting below USDWs
Other Class I wells (not included in Type “I,” “M,” or “W”)
Class II
Oil and gas production and storage related injection wells.
Type “D”
“R”
“H”
“X”
Produced fluid disposal well
Enhanced recovery well
Hydrocarbon storage well (excluding natural gas)
Other Class II wells (not included in Type “D,” “R,” or “H”)
Class III
Special process injection wells.
Type “G”
“S”
“U”
“X”
Solution mining well
Sulfur mining well by Frasch process
Uranium mining well
Other Class III wells (not included in Type “G,” “S,” or “U”)
Other Classes
Wells not included in classes above.
Class V wells which may be permitted under § 144.12
Wells not currently classified as Class I, II, III, or V
EPA Form 7520-7 (8-01) Reverse
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
Injection Well Monitoring Report
Year
Month
Month
Month
Injection Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Rate (Gal/Min)
1. Minimum
2. Average
3. Maximum
Annular Pressure (PSI)
1. Minimum
2. Average
3. Maximum
Injection Volume (Gal)
1. Monthly Total
2. Yearly Cumulative
Temperature (F °)
1. Minimum
2. Average
3. Maximum
pH
1. Minimum
2. Average
3. Maximum
Other
Name and Address of Permittee
Name and Official Title (Please type or print)
EPA Form 7520-8 (Rev. 8-01)
Permit Number
Signature
Date Signed
Paperwork Reduction Act
The public reporting and record keeping burden for this collection of information is estimated to average 5.7
hours per year for operators of Class I wells and 30 hours per quarter for operators of Class III wells. Burden
means the total time, effort, or financial resource expended by persons to generate, maintain, retain, or
disclose or provide information to or for a Federal Agency. This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and requirements;
train personnel to be able to respond to the collection of information; search data sources; complete and
review the collection of information; and, transmit or otherwise disclose the information. An agency may not
conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays
a currently valid OMB control number. Send comments on the Agency’s need for this information, the
accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden,
including the use of automated collection techniques to Director, Collection Strategies Division, U.S.
Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include
the OMB control number in any correspondence. Do not send the completed forms to this address.
EPA Form 7520-8 Reverse
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
Completion Form For Injection Wells
Administrative Information
1. Permittee
Address
(Permanent Mailing Address) (Street, City, and ZIP Code)
2. Operator
Address
(Street, City, State and ZIP Code)
3. Facility Name
Address
Telephone Number
(Street, City, State and ZIP Code)
4. Surface Location Description of Injection Well(s)
State
County
Surface Location Description
____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of
Section ____ Township ____ Range ____
Locate well in two directions from nearest lines of quarter section and drilling unit
Surface
Location ____ ft. frm (N/S) ____ Line of quarter section
and ____ ft. from (E/W) ____ Line of quarter section.
Well Activity
Well Status
Type of Permit
____ Class I
____ Operating
____ Individual
____ Class II
____ Modification/Conversion
____ Area : Number of Wells ____
____ Brine Disposal
____ Proposed
____ Enhanced Recovery
____ Hydrocarbon Storage
____ Class III
____ Other
Lease Number _______________
Well Number _______________
Submit with this Completion Form the attachments listed in Attachments for Completion Form.
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in
this document and all attachments and that, based on my inquiry of those individuals immediately responsible for
obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32)
Name and Official Title (Please type or print)
EPA Form 7520-9 (Rev. 8-01)
Signature
Date Signed
PAPERWORK REDUCTION ACT
The public reporting and record keeping burden for this collection of information is estimated to average 49 hours per response for a Class I
hazardous facility, and 47 hours per response for a Class I non-hazardous facility. Burden means the total time, effort, or financial resource
expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time needed
to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to be able to respond to the collection of information; search data sources;
complete and review the collection of information; and, transmit or otherwise disclose the information. An agency may not conduct or sponsor,
and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. Send comments
on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques to Director, Collection Strategies Division, U.S. Environmental Protection
Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send
the completed forms to this address.
Attachments to be submitted with the Completion report:
I. Geologic Information
4. Provide data on centralizers to include number, type
and depth.
1. Lithology and Stratigraphy
5. Provide data on bottom hole completions.
A. Provide a geologic description of the rock units pene-
trated by name, age, depth, thickness, and lithology of
each rock unit penetrated.
6. Provide data on well stimulation used.
III. Description of Surface Equipment
B. Provide a description of the injection unit.
(1) Name
(2) Depth (drilled)
(3) Thickness
(4) Formation fluid pressure
(5) Age of unit
(6) Porosity (avg.)
(7) Permeability
(8) Bottom hole temperature
(9) Lithology
(10) Bottom hold pressure
(11) Fracture pressure
C. Provide chemical characteristics of formation fluid
(attach chemical analysis).
D. Provide a description of freshwater aquifers.
(1) Depth to base of fresh water (less than 10,000 mg/l
TDS).
(2) Provide a geologic description of aquifer units with
name, age, depth, thickness, lithology, and average total
dissolved solids.
1. Provide data and a sketch of holding tanks, flow lines,
filters, and injection pump.
IV. Monitoring Systems
1. Provide data on recording and nonrecording injection
pressure gauges, casing-tubing annulus pressure
gauges, injection rate meters, temperature meters, and
other meters or gauges.
2. Provide data on constructed monitor wells such as
location, depth, casing diameter, method of cementing,
etc.
V. Logging and Testing Results
Provide a descriptive report interpreting the results of
geophysical logs and other tests. Include a description
and data on deviation checks run during drilling.
VI. Provide an as-built diagrammatic sketch of the injection well(s) showing casing, cement, tubing, packer, etc.,
with proper setting depths. The sketch should include
well head and gauges.
II. Well Design and Construction
1. Provide data on surface, intermediate, and long string
casing and tubing. Data must include material, size,
weight, grade, and depth set.
2. Provide data on the well cement, such as type/class,
additives, amount, and method of emplacement.
3. Provide packer data on the packer (if used) such as
type, name and model, setting depth, and type of annular
fluid used.
EPA Form 7520-9 Reverse
VII. Provide data demonstrating mechanical integrity
pursuant to 40 CFR 146.08.
VIII. Report on the compatibility of injected wastes with
fluids and minerals in both the injection zone and the
confining zone.
IX. Report the status of corrective action on defective
wells in the area of review.
X. Include the anticipated maximum pressure and flow
rate at which injection will operate.
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
COMPLETION REPORT FOR BRINE DISPOSAL,
HYDROCARBON STORAGE, OR ENHANCED RECOVERY
Name and Address of Existing Permittee
Name and Address of Surface Owner
State
Locate Well and Outline Unit on
Section Plat - 640 Acres
County
Permit Number
Surface Location Description
N
____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of
Section ____ Township ____ Range ____
Locate well in two directions from nearest lines of quarter section and drilling unit
Surface
Location ____ ft. frm (N/S) ____ Line of quarter section
and ____ ft. from (E/W) ____ Line of quarter section.
W
WELL ACTIVITY
E
TYPE OF PERMIT
Brine Disposal
Individual
Enhanced Recovery
Area
Hydrocarbon Storage
S
Injection Interval
Average
Feet
Maximum
Average
Brackish Water
Liquid Hydrocarbon
Date Drilling Began
Lease Name
Fresh Water
to Feet
Depth to Bottom of Lowermost Freshwater
Formation (Feet)
Maximum
Type of Injection Fluid (Check the appropriate block(s))
Well Number
Name of Injection Zone
Other
Date Well Completed
Permeability of Injection Zone
Date Drilling Completed
Porosity of Injection Zone
CEMENT
CASING AND TUBING
OD Size
Number of Wells ____
Anticipated Daily Injection Volume (Bbls)
Anticipated Daily Injection Pressure (PSI)
Salt Water
Estimated Fracture Pressure
of Injection Zone
Wt/Ft - Grade - New or Used
Depth
Sacks
INJECTION ZONE STIMULATION
Interval Treated
HOLE
Class
Depth
Bit Diameter
WIRE LINE LOGS, LIST EACH TYPE
Materials and Amount Used
Log Types
Logged Intervals
Complete Attachments A -- E listed on the reverse.
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all
attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the
information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the
possibliity of fine and imprisonment. (Ref. 40 CFR 144.32)
Name and Official Title (Please type or print)
EPA Form 7520-10 (Rev. 8-01)
Signature
Date Signed
ATTACHMENTS
A.
Present a schematic or other appropriate drawing of the surface and subsurface
construction details of the well as built.
B.
Describe the method and results of mechanical integrity testing.
C.
Present the results of that portion of those logs, test, and cores which specifically
relate to (1) underground sources of drinking water and the confining zone(s) and
(2) the injection and adjacent formations.
D.
Present the status of corrective action on defective wells in the area of review.
E.
Provide to EPA, with the completion report, one final print of all geophysical logs
run.
PAPERWORK REDUCTION ACT
The public reporting and record keeping burden for this collection of information is estimated to average 4 hours
per well. Burden means the total time, effort, or financial resource expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and requirements;
train personnel to be able to respond to the collection of information; search data sources; complete and review
the collection of information; and, transmit or otherwise disclose the information. An agency may not conduct
or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently
valid OMB control number. Send comments on the Agency’s need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent burden, including the use
of automated collection techniques to Director, Collection Strategies Division, U.S. Environmental Protection
Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the OMB control number in
any correspondence. Do not send the completed forms to this address.
EPA Form 7520-10 Reverse
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
ANNUAL DISPOSAL/INJECTION WELL MONITORING REPORT
Name and Address of Existing Permittee
Name and Address of Surface Owner
State
Locate Well and Outline Unit on
Section Plat - 640 Acres
County
Permit Number
Surface Location Description
N
____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of
Section ____ Township ____ Range ____
Locate well in two directions from nearest lines of quarter section and drilling unit
Surface
Location ____ ft. frm (N/S) ____ Line of quarter section
and ____ ft. from (E/W) ____ Line of quarter section.
W
E
WELL ACTIVITY
Brine Disposal
Enhanced Recovery
Hydrocarbon Storage
TYPE OF PERMIT
Individual
Area
Number of Wells ____
Lease Name
Well Number
S
INJECTION PRESSURE
MONTH
YEAR
AVERAGE PSIG
TOTAL VOLUME INJECTED
MAXIMUM PSIG
BBL
MCF
TUBING -- CASING ANNULUS PRESSURE
(OPTIONAL MONITORING)
MINIMUM PSIG
MAXIMUM PSIG
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all
attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the
information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the
possibliity of fine and imprisonment. (Ref. 40 CFR 144.32)
Name and Official Title (Please type or print)
EPA Form 7520-11 (Rev. 8-01)
Signature
Date Signed
PAPERWORK REDUCTION ACT
The public reporting and record keeping burden for this collection of information is estimated to average 25 hours annually for
operators of Class I wells and 5 hours annually for operators of Class II wells. Burden means the total time, effort, or financial
resource expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes
of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing
information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel
to be able to respond to the collection of information; search data sources; complete and review the collection of information;
and, transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently valid OMB control number. Send comments on the Agency’s
need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent
burden, including the use of automated collection techniques to Director, Collection Strategies Division, U.S. Environmental
Protection Agency (2822), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any
correspondence. Do not send the completed forms to this address.
EPA Form 7520-11 Reverse
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
WELL REWORK RECORD
Name and Address of Permittee
Name and Address of Contractor
State
Locate Well and Outline Unit on
Section Plat - 640 Acres
County
Permit Number
Surface Location Description
N
____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of
Section ____ Township ____ Range ____
Locate well in two directions from nearest lines of quarter section and drilling unit
Surface
Location ____ ft. frm (N/S) ____ Line of quarter section
and ____ ft. from (E/W) ____ Line of quarter section.
W
WELL ACTIVITY
E
Total Depth Before Rework
Brine Disposal
Enhanced Recovery
TYPE OF PERMIT
Individual
Total Depth After Rework
Hydrocarbon Storage
Area
Number of Wells ____
Date Rework Commenced
Lease Name
Well Number
Date Rework Completed
S
WELL CASING RECORD -- BEFORE REWORK
Casing
Size
Cement
Depth
Sacks
Perforations
Type
From
Acid or Fracture
Treatment Record
To
WELL CASING RECORD -- AFTER REWORK (Indicate Additions and Changes Only)
Casing
Size
Cement
Depth
Sacks
Perforations
Type
From
Acid or Fracture
Treatment Record
To
WIRE LINE LOGS, LIST EACH TYPE
DESCRIBE REWORK OPERATIONS IN DETAIL
USE ADDITIONAL SHEETS IF NECESSARY
Log Types
Logged Intervals
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all
attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the
information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the
possibliity of fine and imprisonment. (Ref. 40 CFR 144.32)
Name and Official Title (Please type or print)
EPA Form 7520-12 (Rev. 8-01)
Signature
Date Signed
PAPERWORK REDUCTION ACT
The public reporting and record keeping burden for this collection of information is estimated to average 4 hours per
response annually. Burden means the total time, effort, or financial resource expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal Agency. This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and disclosing and providing information; adjust the
existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to
respond to the collection of information; search data sources; complete and review the collection of information; and,
transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently valid OMB control number. Send comments on the
Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including the use of automated collection techniques to Director, Collection Strategies
Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include
the OMB control number in any correspondence. Do not send the completed forms to this address.
EPA Form 7520-12 Reverse
OMB No. 2040-0042
Approval Expires 1/31/05
United States Environmental Protection Agency
Washington, DC 20460
PLUGGING AND ABANDONMENT PLAN
Name and Address of Facility
Name and Address of Owner/Operator
State
Locate Well and Outline Unit on
Section Plat - 640 Acres
County
Permit Number
Surface Location Description
N
____ 1/4 of ____ 1/4 of ____ 1/4 of ____ 1/4 of
Section ____ Township ____ Range ____
Locate well in two directions from nearest lines of quarter section and drilling unit
Surface
Location ____ ft. frm (N/S) ____ Line of quarter section
and ____ ft. from (E/W) ____ Line of quarter section.
W
TYPE OF AUTHORIZATION
E
WELL ACTIVITY
Individual Permit
CLASS I
Area Permit
CLASS II
Brine Disposal
Rule
Enhanced Recovery
Number of Wells ____
Hydrocarbon Storage
CLASS III
S
Lease Name
Well Number
CASING AND TUBING RECORD AFTER PLUGGING
SIZE
WT (LB/FT)
TO BE PUT IN WELL (FT)
METHOD OF EMPLACEMENT OF CEMENT PLUGS
TO BE LEFT IN WELL (FT)
HOLE SIZE
The Balance Method
The Dump Bailer Method
The Two-Plug Method
Other
CEMENTING TO PLUG AND ABANDON DATA:
PLUG #1
PLUG #2
PLUG #3
PLUG #4
PLUG #5
PLUG #6
Size of Hole or Pipe in which Plug Will Be Placed (inches)
Depth to Bottom of Tubing or Drill Pipe (ft.)
Sacks of Cement To Be Used (each plug)
Slurry Volume To Be Pumped (cu. ft.)
Calculated Top of Plug (ft.)
Measured Top of Plug (if tagged ft.)
Slurry Wt. (Lb./Gal.)
Type Cement or Other Material (Class III)
LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED (if any)
From
To
From
To
Estimated Cost to Plug Wells
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all
attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the
information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the
possibliity of fine and imprisonment. (Ref. 40 CFR 144.32)
Name and Official Title (Please type or print)
EPA Form 7520-14 (Rev. 8-01)
Signature
Date Signed
PLUG #7
Paperwork Reduction Act Notice
The public reporting and record keeping burden for this collection of information is
estimated to average 19.5 hours annually for operators of Class I wells, 6 hours
annually for operators of Class II wells, and 8 hours annually for operators of Class III
wells. Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide information to or for a
Federal agency. This includes the time needed to review instructions; adjust the
existing ways to comply with any previously applicable instructions and requirements;
train personnel to be able to respond to the collection of information; search data
sources; complete and review the collection of information; and, transmit or otherwise
disclose the information. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a currently valid
OMB control number. The OMB control numbers for EPA’s regulations are listed in
40 CFR Part 9 and 48 CFR Chapter 15.
Please send comments on the Agency’s need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent
burden, including the use of automated collection techniques to Director, Office of
Environmental Information, Collection Strategies Division, U.S. Environmental
Protection Agency (2822), Ariel Rios Building, 1200 Pennsylvania Ave., NW.,
Washington, DC 20460; and to the Office of Information and Regulatory Affairs, Office
of Management and Budget, 725 17th Street, NW., Washington, DC 20503, Attention:
Desk Officer for EPA. Please include the EPA ICR number and OMB control number
in any correspondence.
EPA Form 7520-14 Reverse
Type or print all information. See reverse for instructions.
OMB No. 2040-0042
INVENTORY OF INJECTION WELLS
1. DATE PREPARED
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF GROUND WATER AND DRINKING WATER
(Year, Month, Day)
MO
YR
Approval Expires 1/31/05
2. FACILITY ID NUMBER
DY
(This information is collected under the authority of the Safe Drinking Water Act)
PAPERWORK REDUCTION ACT NOTICE
The public reporting burden for this collection of information is estimated at about 0.5 hour per response, including time for reviewing
instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection
of information. Send comments regarding the burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to Chief, Information Policy Branch, 2136, U.S. Environmental Protection Agency, 401 M Street,
SW, Washington, DC 20460, and to the Office of Management and Budget, Paperwork Reduction Project, Washington, DC 20503.
3. TRANSACTION TYPE
(Please mark one of the following)
Deletion
First Time Entry
Entry Change
Replacement
4. FACILITY NAME AND LOCATION
A. NAME (last, first, and middle initial)
C. LATITUDE
DEG
MIN
E. TOWNSHIP/RANGE
SEC
.
B. STREET ADDRESS/ROUTE NUMBER
D. LONGITUDE
DEG
MIN
TOWNSHIP
RANGE
SECT
1/4 SECT
SEC
.
F. CITY/TOWN
G. STATE
H. ZIP CODE
I. NUMERIC
COUNTY CODE
J. INDIAN LAND
(mark "x")
Yes
5. LEGAL CONTACT:
A. TYPE (mark "x")
Owner
B. NAME (last, first, and middle initial)
C. PHONE
(area code
and number)
Operator
D. ORGANIZATION
E. STREET/P.O. BOX
F. CITY/TOWN
G. STATE
I. OWNERSHIP (mark "x")
PRIVATE
PUBLIC
STATE
FEDERAL
SPECIFY OTHER
H. ZIP CODE
6. WELL INFORMATION:
A. CLASS
AND
TYPE
B. NUMBER OF WELLS
COMM
NON-COMM
C. TOTAL
NUMBER
OF WELLS
D. WELL OPERATION STATUS
UC
AC
TA
PA
COMMENTS (Optional):
AN
KEY:
DEG = Degree
MIN = Minute
SEC = Second
SECT = Section
1/4 SECT = Quarter Section
EPA Form 7520-16 (Rev. 8-01)
COMM = Commercial
NON-COMM = Non-Commercial
AC = Active
UC = Under Construction
TA = Temporarily Abandoned
PA = Permanently Abandoned and Approved by State
AN = Permanently Abandoned and not Approved by State
No
INSTRUCTIONS AND DEFINITIONS
SECTION 1. DATE PREPARED: Enter date in order of year, month,
and day.
SECTION 4. FACILITY NAME & LOCATION (CONT’D.):
I.
SECTION 2. FACILITY ID NUMBER: In the first two spaces, insert
the appropriate U.S. Postal Service State Code. In the third space, insert
one of the following one letter alphabetic identifiers:
D - DUNS Number,
G - GSA Number, or
S - State Facility Number.
In the remaining spaces, insert the appropriate nine digit DUNS, GSA, or
State Facility Number. For example, A Federal facility (GSA 123456789) located in Virginia would be entered as : VAG123456789.
J.
SECTION 5. LEGAL CONTACT:
A.
SECTION 3. TRANSACTION TYPE: Place an “x” in the applicable
B.
box. See below for further instructions.
Deletion. Fill in the Facility ID Number.
First Time Entry. Fill in all the appropriate information.
Entry Change.
Fill in the Facility ID Number and the information
that has changed.
Replacement.
C.
D.
SECTION 4. FACILITY NAME AND LOCATION:
A.
B.
C.
D.
E.
F.
G.
H.
Name. Fill in the facility’s official or legal name.
Street Address. Self Explanatory.
Latitude. Enter the facility’s latitude (all latitudes assume
North Except for American Samoa).
Longitude. Enter the facility’s longitude (all longitudes assume
West except Guam).
Township/Range. Fill in the complete township and range.
The first 3 spaces are numerical and the fourth is a letter
(N,S,E,W) specifying a compass direction. A township is North
or South of the baseline, and a range is East or West of the
principal meridian (e.g., 132N, 343W).
City/Town. Self Explanatory.
State. Insert the U.S. Postal Service State abbreviation.
Zip Code. Insert the five digit zip code plus any extension.
Numeric County Code. Insert the numeric county code from
the Federal Information Processing Standards Publication (FIPS
Pub 6-1) June 15, 1970, U.S. Department of Commerce,
National Bureau of Standards. For Alaska, use the Census Division
Code developed by the U.S. Census Bureau.
Indian Land. Mark an “x” in the appropriate box (Yes or No)
to indicate if the facility is located on Indian land.
E.
F.
G.
H.
I.
Type. Mark an “x” in the appropriate box to indicate the type
of legal contact (Owner or Operator). For wells operated by lease,
the operator is the legal contact.
Name. Self Explanatory.
Phone. Self Explanatory.
Organization. If the legal contact is an individual, give the
name of the business organization to expedite mail distribution.
Street/P.O. Box. Self Explanatory.
City/Town. Self Explanatory.
State. Insert the U.S. Postal Service State abbreviation.
Zip Code. Insert the five digit zip code plus any extension.
Ownership. Place an “x” in the appropriate box to indicate
ownership status.
SECTION 6. WELL INFORMATION:
A.
B.
C.
D.
Class and Type. Fill in the Class and Type of injection wells
located at the listed facility. Use the most pertinent code
(specified below) to accurately describe each type of injection
well. For example, 2R for a Class II Enhanced Recovery Well, or
3M for a Class III Solution Mining Well, etc.
Number of Commercial and Non-Commercial Wells.
Enter the total number of commercial and non-commercial wells
for each Class/Type, as applicable.
Total Number of Wells. Enter the total number of injection
wells for each specified Class/Type.
Well Operation Status. Enter the number of wells for each
Class/Type under each operation status (see key on other side).
INJECTION WELL CLASS AND TYPE CODES
CLASS I Industrial, Municipal, and Radioactive Waste Disposal Wells
CLASS III (CONT’D.)
used to inject waste below the lowermost Underground Source of Drinking
Water (USDW).
TYPE
TYPE
1I
1M
Non-Hazardous Industrial Disposal Well.
Non-Hazardous Municipal Disposal Well.
1H
Hazardous Waste Disposal Well injecting below the
lowermost USDW.
Radioactive Waste Disposal Well.
Other Class I Wells.
1R
1X
3S
3T
3U
3X
Sulfur Mining Well by Frasch Process.
Geothermal Well.
Uranium Mining Well.
Other Class III Wells.
CLASS IV Wells that inject hazardous waste into/above USDWs.
TYPE
4H
4R
Hazardous Facility Injection Well.
Remediation Well at RCRA or CERCLA site.
CLASS II Oil and Gas Production and Storage Related Injection Wells.
CLASS V Any Underground Injection Well not included in Classes I
TYPE
2A
2D
2H
2R
2X
Annular Disposal Well.
Produced Fluid Disposal Well.
Hydrocarbon Storage Well.
Enhanced Recovery Well.
Other Class II Wells.
CLASS III Special Process Injection Wells.
TYPE
3G
3M
In Situ Gassification Well
Solution Mining Well.
EPA Form 7520-16 (Revised 8-01)
through IV.
TYPE
5A
5B
5C
5D
5E
5F
5G
5H
5I
5J
Industrial Well.
Beneficial Use Well.
Fluid Return Well.
Sewage Treatment Effluent Well.
Cesspools (non-domestic).
Septic Systems.
Experimental Technology Well.
Drainage Well.
Mine Backfill Well.
Waste Discharge Well.
PAPERWORK REDUCTION ACT The public reporting and record keeping burden for this collection of information is
estimated to average 0.5 hours per response. Burden means the total time, effort, or financial resource expended by
persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. This includes the time
needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust
the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to
respond to the collection of information; search data sources; complete and review the collection of information; and,
transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently valid OMB control number. Send comments on the
Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including the use of automated collection techniques to Director, Collection Strategies
Division, U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW., Washington, D.C. 20460. Include the
OMB control number in any correspondence. Do not send the completed forms to this address.
EPA Form 7520-16 (Revised 8-01)
Type or print all information. See reverse for instructions
Form Approved 12/99 OMB No. 2040-0214
United States Environmental Protection Agency
UIC Federal Reporting System
Class V Well Pre-Closure Notification Form
1. Name of facility:
Address of facility:
City/Town:
State:
Zip Code:
County:
Location:
Lat./Long.:
State:
Zip Code:
2. Name of Owner/Operator:
Address of Owner/Operator:
City/Town:
Legal contact:
Phone number:
3. Type of well(s):
Number of well(s):
4. Well construction (check all that apply):
Drywell
Septic tank
Cesspool
Improved sinkhole
Drainfield/leachfield
Other
5. Type of discharge:
6. Average flow (gallons/day):
7. Year of well construction:
8. Type of well closure (check all that apply):
Sample fluids/sediments
Clean out well
Appropiate disposal of remaining fluids/sediments
Install permanent plug
Remove well & any contaminated soil
Conversion to other well type
Other (describe):
9. Proposed date of well closure:
10.Name of preparer:
Date:
Certification
I certify under the penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40 CFR 144.32).
Name and Official Title (Please type or print)
EPA Form 7520-17
Signature
Date Signed
INSTRUCTIONS FOR EPA FORM 7520-17
This form contains the minimum information that you must provide your UIC Program Director if you intend to close your Class V well. This form
will be used exclusively where the EPA administers the UIC Program: AK, AS, AZ, CA, CO, DC, DE, HI, IA, IN, KY, MI, MN, MT, NY, PA, SD, TN, VA, VI,
and on all Tribal Lands. If you are located in a different State or jurisdiction, ask the agency that administers the UIC Program in your State for
the appropriate form.
If you are closing two or more Class V wells that are of similar construction at your facility (two dry wells, for example) you may use one form. If
you are closing Class V wells of different construction (a septic system and a dry well, for example) use one form per construction type.
The numbers below correspond to the numbers on the form.
1.
Supply the name and street address of the facility where the Class V well(s) is located. Include the City/Town, State (U.S. Postal Service
abbreviation) and Zip Code. If there is no street address for the Class V well, provide the route number or locate the well(s) on a map and
attach it to this form. Under "Location," provide the Latitude/Longitude of the well, if available.
2.
Provide the name and mailing address of the owner of the facility, or if the facility is operated by lease, the operator of the facility. Include
the name and phone number of the legal contact for any questions regarding the information provided on this form.
3.
Indicate the type of Class V well that you intend to close (for example, motor vehicle waste disposal well or cesspool). Provide the number
of wells of this well type at your location that will be closed.
4.
Mark an "X" in the appropriate box to indicate the type of well construction. Mark all that apply to your situation. For example, for a septic tank that drains into a drywell, mark both the "septic tank" and "drywell" boxes. Please provide a generalized sketch or schematic of
the well construction if available.
5.
List or describe the types of fluids that enter the Class V well. If available, attach a copy of the chemical analysis results and/or the
Material Safety Data Sheets for the fluids that enter the well.
6.
Estimate the average daily flow into the well in gallons per day.
7.
Provide the year that the Class V well was constructed. If unknown, provide the length of time that your business has been at this location
and used this well.
8.
Mark an "X" in the appropriate box(s) to indicate briefly how the well closure is expected to proceed. Mark all that apply to your situation.
For example, all boxes except the "Remove well & any contaminated soil" and "Other" would be marked if: the connection of an automotive service bay drain leading to a septic tank and drainfield will be closed, but the septic system will continue to be used for washroom
waste disposal only, and the fluids and sludge throughout the system will be removed for proper disposal, the system cleaned, a cement
plug placed in the service bay drain and the pipe leading to the washroom connection, and the septic tank/drainfield remains open for septic use only. In this example, the motor vehicle waste disposal well is being converted to another well type (a large capacity septic system).
9.
Self explanatory.
10.
Self explanatory.
PLEASE READ . . .
The purpose of this form is to serve as the means for the Class V well owner or operator’s notice to the UIC Director of his/her intent to close the
well in accordance with Title 40 of the Code of Federal Regulations (40 CFR) Section 144.12(a). According to 40 CFR §144.86, you must notify the
UIC Program Director at least 30 days prior to well closure of your intent to close and abandon your well. Upon receipt of this form, if the
Director determines that more specific information is required to be submitted to ensure that the well closure will be conducted in a manner that
will protect underground sources of drinking water (as defined in 40 CFR §144.3), the Director can require the owner/operator to prepare, submit
and comply with a closure plan acceptable to, and approved by the Director.
Please be advised that this form is intended to satisfy Federal UIC requirements regarding pre-closure notification only. Other State, Tribal or
Local requirements may also apply.
Paper Work Reduction Act Notice
The public reporting and record keeping burden for this collection of information is estimated to average 1.5 hours per respondent.
Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency. This includes the time needed to review instructions, develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and
disclosing and providing information, adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a currently valid OMB control number.
Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including thorough the use of automated collection techniques to the Director, Regulatory
information Division, U.S. Environmental Protection Agency (2137), 401 M. Street, S.W., Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.
EPA Form 7520-17
Appendix F: Progress Report on OMB’s Terms of Clearance Dated (October 25, 2005)
Underground Injection Control Program Information Collection Request
OMB # 2040-0042
EPA # 0370.21
Attachment to Supporting Statement
Introduction
This progress report provides specific answers to OMB’s “Terms of Clearance” concerns
raised in two emails to EPA’s Office of Ground Water and Drinking Water (OGWDW) for the
Underground Injection Control (UIC) Program ICR. In a late September 2005, email, the ICR
was given a 2-year clearance. However in a sequent email dated October 25, 2007, OMB
reduced the clearance to 18 months. This report will also briefly highlight efforts being explored
to reduce UIC Program burden, a key OMB concern.
OMB Comments/Concerns and UIC Program Responses
OMB does not believe that concerns raised in the terms of clearance have been
adequately addressed. OMB requested that before the UIC program began preparation of the
next renewal of this ICR, the Agency shall orally brief OMB on its progress to date on
addressing the issues outlined in the terms of clearance. Management and staff have briefed and
discussed orally the issues with OMB’s representative, Jim Laity. Furthermore, through
cooperative early involvement, Program management and staff sent a draft first ICR Federal
Register Notice and a Burden Reduction report to OMB for review. OMB reviewed these drafts
and on January 19, 2007, OMB’s representative sent an email to EPA showing a favorable
response. The first Federal Register Notice was published on February 28, 2007. Both the
Notice and report was placed in the Agency’s docket for public comment and review. No
comments were received on either document. The Program has been steadily working with UIC
regional programs to study areas where burden reduction might be possible. This also included a
review of state burden activities. The Agency will be working diligently throughout the
remainder of the calendar year to find and implement, where possible, Program areas for burden
reduction. Below, the Agency addresses four areas of concern from OMB:
OMB Concern #1
Following the Agency’s effort to develop a National Source Contamination Prevention Strategy
(designed to focus reporting in the Program on a few meaningful measures) modification of the
7520 forms was to be completed. EPA did not report to OMB on the progress of this effort.
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EPA Response:
The National Source Water Contamination Prevention Strategy was designed to measure
program performance. The Strategy focused reporting on a few meaningful measures for both the
Source Water Protection (SWP) and the Underground Injection Control (UIC) programs. A
comprehensive strategy for the SWP and UIC programs was necessary to help accomplish the
Agency’s strategic goals of environmental protection. Management felt that at the time of its
development, it would replace the 7520 Federal Reporting forms.
In early 2000, EPA’s OGWDW’s Drinking Water Protection Division began planning the
development of a national drinking water contamination prevention strategy. Federal statutes
and state laws exist to safeguard public health through the protection of drinking water supplies
from contamination which is also called Source Water Protection. There was no national statute,
regulation, or guidance document that clearly defined what source water protection was, how it
should be implemented, and how to measure performance, therefore the “National Source Water
Contamination Prevention Strategy” was proposed. This strategic document development
became cumbersome and difficult to implement. As a result, the effort to develop the national
strategy evolved into two separate efforts. One was a measures document for the SWP program
and the other was a measures document for the UIC program. Dividing the effort into two
separate strategies allowed EPA to timely complete a few meaningful measures for both
programs. The measures were distributed to the Regions through two separate measures
documents, “State and Federal Source Water Assessment and Protection Program Measures –
Final Reporting Guidance” and “Information to Assist Regions and States to Report on the
Underground Injection Control (UIC) Program’s National Water Program Guidance Program
Activity Measures”.
The process started through the strategy resulted in four measures for each program. The intent
of the measures was to help EPA better understand program performance by creating measures
that support the program priorities.
These performance measures provide a good picture of the program’s current priorities but do
not provide comprehensive enough data to manage a national program. However, the
information on the 7520s does provide the data necessary to manage a national program.
Currently, the information necessary to perform effective program management is captured in
the 7520 summary paper forms (1, 2A, 2B, 3 and 4). Therefore, the 7520 information can not be
replaced by only a few meaningful measures and still ensure public health protection.
To help reduce the burden on primacy states, EPA is developing a more efficient data collection
method, a database. The national data system will contain the information that is critical to
program management. The data contained in the data system represents the data necessary to
ensure public health protection. When developing the data system, EPA evaluated the products
of the revised 7520 workgroup, which was finalized in 2001. The revised forms were part of the
decision-making process when determining what the database will contain. The revised 7520
forms enjoyed both state and EPA Regional support. Recognizing the contribution that the
Agency-state workgroup made, with this in mind, the database will contain only the data
necessary for program management.
11
OMB Concern #2
OMB believes that the Program has lost its focus on ensuring that all data have practical utility
and that burden is reduced to the extent practical and appropriate (both of which are required by
5 CFR 1320.9).
EPA Response:
EPA has evaluated the need for the collected data through the database development process and
the ICR renewal. When developing the database, EPA wanted to ensure that all of the data
collected was necessary for program management. EPA reviewed the recommendations from the
7520 workgroup, consulted with EPA regions and states, checked the authority to collect the data
and evaluated how EPA uses that information. The result of this effort is a database that will
meet the needs of the UIC program to manage the program. EPA feels that the data to be
collected through the database is critical to ensure public health protection by holding
accountable implementing programs.
During the ICR renewal we reviewed all UIC data collected and determined the necessity of the
information. Primacy programs were consulted to determine the use of information submitted by
the owners and operators. EPA regions were also involved to review the necessity of the
information submitted to EPA by primacy agencies.
OMB Concern #3
There has been no modification to the 7520 Forms, and no other actions to reduce burden since
FY 1996, when EPA reduced the frequency of some reporting requirements. There appears to
have been no follow up on recommended changes by the Federal Reporting Forms Workgroup.
While a new Excel Spreadsheet reporting process has been added to track four new Performance
Activity Measures (PAMs), none of the existing reporting requirements have been eliminated or
reduced. The annual burden of this report has increased by 22%. While the agency has
characterized this increase as an adjustment, OMB notes that 127,843 hours reflects new
permitting and closure requirements for operations of certain Class V wells, and has reclassified
this burden.
EPA Response:
EPA has taken no action to modify the 7520 forms because EPA decided to use an alternative
approach to streamlining reporting, developing a database.
Previously, EPA reduced the frequency of reporting to the extent possible without sacrificing the
intent or implementation of the program; EPA has further evaluated the burden imposed on states
and determined the following conclusions:
• EPA previously reduced as much burden as possible without a regulatory change
• The data collected by the 7520s is critical to perform program management
EPA has taken action to consolidate reporting during the development of the national database.
When the database is complete, it will be the mechanism for UIC reporting. This was
12
accomplished by consolidating measures and inventory reporting through web-entry. EPA is
also evaluating other ways to simplify reporting.
The 22% increase in the last ICR renewal was characterized as an adjustment because this
increase was not due to new reporting requirements but additional respondents and increase
activity to close and/or permit certain high-priority Class V wells and increases in required Class
II operations that must be preformed by the operators (consultations).
Respondent
type
Class-II
operators
Class-IV
operators
Class-V
Operators
UIC-Primacy
Agencies
Total
Change in Annual Respondent Burden Hours
Previous
Revised
Net Change Reason of Change
Respondent Respondent
(adjustments)
Burden
Burden
589,384
803,422
214,038
Large increase in
operations that must be
performed based on
consultations
3,700
9,900
6,200
A higher number of
Class IV wells to be
closed during the
clearance period
39,259
167,102
127,843
Significant increase in
activities related to the
1999 Class V Rule
78,412
82,892
4,480
Increase in burden
during clearance period
but < 6 percent
710,755
1,063,316
352,561
OMB Concern #4
OMB is instructing the Program during the next year, prior to beginning the renewal process for
this ICR, to review the recommendations of the Federal Reporting Forms workgroup and
determine whether these or other changes to the forms, with the specific goal of reducing
unnecessary burden, are appropriate. EPA needs to provide OMB a full report on how it has
addressed each of the specific recommendations of the Federal Reporting Forms workgroup.
EPA Response:
EPA has reviewed the revised 7520s through the development of a national database. EPA
determined that some of the recommendations are appropriate and has aligned the data collected
in the database with the recommendations of the workgroup and lessons learn since the
conclusion of the workgroup. The result of this effort is a national database that will contain only
data necessary to complete essential program management.
Several of the workgroup’s recommendations addressed formatting to make the forms easier to
use. These recommendations are not being considered because they will be replaced by the
13
national UIC database which will receive data directly from states’ databases. If there is a need
to develop web-entry of data, EPA will evaluate the format of the revised 7520. In addition,
EPA will be using revised form 7520-16 in this renewal.
We will also continue to explore other means of reducing burden and cost as appropriate. The
Program has submitted a Burden Reduction report that serves at the strategy to address OMB’s
greatest concern, burden reduction.
Burden Reduction Highlights
Electronic reporting is an important initiative for the UIC program. We are currently
getting both inventory and Program Activity Measures (required by OMB) through electronic
data web entry systems. EPA is near the completion of the development a national UIC database
management system that will allow the flow of required state data to the Agency. This effort
will also supplement the needs of other EPA Water and Compliance-Enforcement programs.
This is the first time such an effort of this magnitude has been made to report on all five injection
well classes nationally. Once the database is deployed this Fall, we expect to see some burden
reduction during the next clearance period. We believe it would increase the efficiency of some
record keeping and reporting required of owners/operators and states.
In December 2006, we sent a draft Burden Reduction report to OMB detailing the areas
that we were looking at for burden reduction. As mentioned earlier in this response document,
we will continue to study this matter and implement burden reduction where possible. We
believe that we might be able to mimic some innovated approaches burden reduction in a few
states by encouraging e-permitting. This would include eliminating unnecessary data elements
that will not assure public health and environmental protection.
14
The 7520 Federal Reporting forms will remain in the program as crucial data
collection instrument. They will receive data electronically and where possible
unnecessary data elements will be eliminated.
15
| File Type | application/pdf |
| File Title | Microsoft Word - 0370ss21.doc |
| Author | sring |
| File Modified | 2007-09-17 |
| File Created | 2007-09-17 |