2309ss01

INFORMATION COLLECTION REQUEST
FOR THE
FEDERAL REQUIREMENTS UNDER THE UNDERGROUND INJECTION CONTROL
PROGRAM FOR CARBON DIOXIDE GEOLOGIC SEQUESTRATION WELLS–
PROPOSED RULE

OMB Control No. 2040-NEW
EPA ICR No. 2309.01

July, 2008

TABLE OF CONTENTS
1.

Identification of the Information Collection ............................................................................ 1
1(a) Title of the Information Collection ................................................................................. 1
1(b) Short Characterization/Abstract...................................................................................... 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 .................................................................................. 3
3. Nonduplication, Consultations, and Other Collection Criteria................................................. 4
3(a) Nonduplication................................................................................................................ 4
3(b) Public Notice Required Prior to ICR Submission to OMB ............................................ 4
3(c) Consultations................................................................................................................... 5
3(d) Effects of Less Frequent Collection................................................................................ 5
3(e) General Guidelines.......................................................................................................... 5
3(f)
Confidentiality ................................................................................................................ 5
3(g) Sensitive Questions......................................................................................................... 6
4. The Respondents and the Information Requested .................................................................... 6
4(a) Respondent NAICS/ SIC Codes ..................................................................................... 6
4(b) Information Requested.................................................................................................... 6
4(b)(i) Data Items ............................................................................................................... 6
4(b)(ii) Respondent Activities ............................................................................................. 9
5. The Information Collected—Agency Activities, Collection Methodology, and Information
Management............................................................................................................................ 11
5(a) Agency Activities.......................................................................................................... 11
5(b) Collection Methodology and Management................................................................... 11
5(c) Small Entity Flexibility................................................................................................. 12
5(d) Collection Schedule ...................................................................................................... 13
6. Estimating the Burden and Cost of the Collection.................................................................. 14
6(a) Respondent Burden....................................................................................................... 14
6(a)(i) Burden to Owners and Operators of CO2 GS Wells ............................................. 14
6(a)(ii)
Burden to Primacy Agencies ............................................................................ 18
6(b) Respondent Costs.......................................................................................................... 20
6(b)(i)
Cost to Operators .............................................................................................. 20
6(b)(ii)
Cost to Primacy Agencies................................................................................. 20
6(c) Agency Burden and Costs............................................................................................. 21
6(d) Respondent Universe and Total Burden and Costs....................................................... 21
6(d)(i) Total Burden and Costs......................................................................................... 22
6(e) Bottom Line Annual Burden Hours and Costs ............................................................. 23
6(e)(i)
Variations in the Annual Bottom Line................................................................. 23
6(f)
Burden Statement......................................................................................................... 24

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LIST OF EXHIBITS
5-1
6-1
6-2
6-3
6-4
6-5

Schedule of Activities Under this Information Collection
Annual Paperwork Burden and Costs Associated with Class VI CO2 GS Wells:
Operators
Annual Paperwork Burden and Costs Associated with Class VI CO2 GS Wells: Primacy
Agencies
Summary of Annual Operator, Primacy Agency, and EPA Regional/Headquarters Burden
and Cost Associated with Class VI Wells
Annual Burden and Cost Associated with Class VI Wells
Bottom Line Annual Burden and Cost

LIST OF APPENDICES
APPENDIX A: Detailed Explanation of the Derivation of Respondent Burden and Cost
Estimates

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Information Collection Request for the Underground Injection Control (UIC) Program:
Federal Requirements Under the Underground Injection Control Program for Carbon
Dioxide Geologic Sequestration Wells – Proposed Rule

1

Identification of the Information Collection

1(a)

Title of the Information Collection

TITLE: Underground Injection Control (UIC) Program: Federal Requirements for Injection of
Carbon Dioxide for Geologic Sequestration – Proposed Rule
OMB Control Number: 2040-NEW
1(b)

Short Characterization/Abstract

EPA is proposing federal requirements for underground injection of carbon dioxide
(CO2) for the purpose of geologic sequestration (GS). GS is the process of injecting CO2
captured from an emission source (e.g., a power plant or industrial facility) into deep subsurface
rock formations for long-term storage. It is part of a portfolio of options that could help to reduce
CO2 emissions to the atmosphere and mitigate climate change. The U.S. Environmental
Protection Agency (EPA or Agency) Office of Ground Water and Drinking Water (OGWDW) is
proposing a regulation that, if finalized, will require the collection of information as part of the
permit application and monitoring requirements for all CO2 GS wells.
The proposed regulation establishes a new class of injection well – Class VI – for GS
projects based on the unique challenges of preventing potential endangerment to underground
sources of drinking water (USDWs) from these operations. The GS regulation proposes
technical criteria for geological characterization; determination of the area of review (AoR) and
corrective action; well construction and operation; mechanical integrity testing (MIT) and
monitoring; and well plugging, post-injection site care, and site closure. The proposal is based on
the existing UIC regulatory framework found at 40 CFR Parts 144 through 148, with new
requirements added to address the unique nature of CO2 injection for GS. The proposal will
protect USDWs from contamination. It will also help ensure consistent approaches to permitting
GS operations across the United States.
Under the proposed regulation, operators of GS wells must submit UIC permit
applications, which contain extensive geological data and other information to demonstrate that a
site is suitable for GS. Operators must also model the extent of the AoR, report on the status of
corrective action on wells in the AoR, and report on pre-operational logging and testing before
obtaining an injection permit. Throughout the injection project, operators will monitor the well
and the site and submit data to the permitting authority on a semi-annual basis. At the end of
injection activities, permit holders will be required to plug their injection well(s) and monitor the
site for 50 years after injection has ended. Following the post-injection monitoring, operators

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would be required to demonstrate non-endangerment to USDWs. When closure of the site is
authorized, operators must close the site and submit a closure report.
States (including Tribes) applying for primacy to oversee Class VI wells will need to
submit a primacy application as described in 40 CFR 145. States and Tribes that obtain primacy
(and in some cases the Agency) will collect and review permit applications and geological data
from operators; receive and review testing and monitoring data and updates to AoR and
corrective action plans throughout the injection phase; and review plugging reports and postinjection monitoring reports, and eventually authorize site closure.
EPA assumes that the proposed GS Regulation will be promulgated in 2012; this
Information Collection Request (ICR) covers the 3-year period from 2012 through 2014. EPA
assumes that 31 States and territories will apply for primacy during that time. Only five owners
or operators of Class VI wells are assumed to apply for permits during the three-year ICR
clearance period. Four of these sites are assumed to be located in States with primacy; one is
assumed to be in a State where EPA directly implements the UIC Program (this assumption is
based on the distribution of States that have primacy for other well classes, as described in
Chapter 5 of the Cost Analysis).
EPA estimates that the operators of GS wells will incur an average of 4,387 hours of
burden annually responding to this information request, amounting to an annual average labor
cost of $325,262. Annual non-labor costs for operators are estimated at $1.4 million. Overall, the
average annual total cost for operators is expected to be $1.7 million. In order to perform the
activities associated with this ICR, EPA estimates that Primacy Agencies will incur 11,094 hours
of burden annually. The estimated average annual total cost for Primacy Agencies is $467,785,
which is entirely labor cost. The estimated EPA burden is 5,225 hours annually. EPA estimates
that its average annual total cost will be $255,568, which is all labor cost. A summary of burden
and cost associated with this ICR can be found in Exhibit 6-3.

2

Need for and Use of the Collection

The following section describes the need for this information collection and the legal
authority under which this information will be collected.
2(a)

Need/Authority for the Collection

The Agency is proposing the GS Regulation to provide federal requirements for owners
and operators of CO2 GS wells to protect USDWs from potential contamination. EPA has
authority to regulate the injection of fluids, including CO2, into the subsurface under the Safe
Drinking Water Act (SDWA) of 1974, as amended in 1986 and in 1996. The UIC Program, to
which this proposed regulation adds a sixth class of well, was promulgated under Part C of the
SDWA. The information collected under this regulation is required by EPA to carry out its
monitoring and enforcement responsibilities pertaining to UIC under the SDWA.

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The proposed GS regulation is based on the existing UIC regulatory framework found at
40 CFR Parts 144 through 148, with additional new requirements to address the unique nature of
CO2 injection for GS, including the large injection volumes and its corrosivity and buoyancy.
The requirements are anticipated to be codified in a new Subpart H of 40 CFR Part 146. The
proposed GS Regulation is also meant to provide regulatory certainty and permitting consistency
for CO2 GS projects.
The chief goal of any Federally approved UIC Program is the protection of USDWs. This
includes not only those aquifers that are presently being used for drinking water, but also those
that can reasonably be expected to be used in the future. EPA has established through its UIC
regulations that underground aquifers with less than 10,000 mg/L total dissolved solids (TDS)
and which contain a sufficient quantity of ground water to supply a public water system are
USDWs.
Section 1421 of the Act requires EPA to propose and promulgate regulations specifying
minimum requirements for effective State programs to prevent underground injection that
endangers drinking water sources. Section 1421(b) (3)(A) of the Act also provides that EPA’s
UIC regulations shall “permit or provide for consideration of varying geologic, hydrological, or
historical conditions in different states and in different areas within a state.” EPA promulgated
administrative and permitting regulations, now codified in 40 CFR parts 144 and 146, on May
19, 1980 (45 FR 33290), and technical requirements, in 40 CFR part 146, on June 24, 1980 (45
FR 42472). The regulations were subsequently amended on August 27, 1981 (46 FR 43156),
February 3, 1982 (47 FR 4992), January 21, 1983 (48 FR 2938), April 1, 1983 (48 FR 14146),
May 11, 1984 (49 FR 20138), July 26, 1988 (53 FR 28118), December 3, 1993 (58 FR 63890),
June 10, 1994 (59 FR 29958), December 14, 1994 (59 FR 64339), June 29, 1995 (60 FR 33926),
December 7, 1999 (64 FR 68546), May 15, 2000 (65 FR 30886), June 7, 2002 (67 FR 39583),
and November 22, 2005 (70 FR 70513).
2(b)

Practical Utility/Users of the Data

Well owners and operators will use information collected in preparing their permit
applications and associated plans and reports (including the testing and monitoring plan, AoR
and corrective action plan, injection well plugging plan, post-injection site care and site closure
plan, and emergency and remedial response plan) to construct, operate, and close their injection
well sites. They will use the data they collect to determine whether they are complying with
permit conditions and to determine whether corrective action or operational adjustments are
needed. They will also use ambient monitoring data to track the CO2 plume.
Primacy States/Tribes and EPA Regions directly implementing Class VI programs use
the operator-submitted permit applications and associated plans and reports (including the testing
and monitoring plan, AoR and corrective action plan, injection well plugging plan, post-injection
site care and site closure plan, and emergency and remedial response plan) to determine whether
a proposed site is suitable for CO2 GS, whether the proposed well meets the criteria specified in
the GS Regulation, and whether a permit should be granted. Permitting authorities will review
testing and monitoring reports and periodic AoR reevaluations to make sure that wells are in
compliance and that no fluid movement into USDWs has occurred. Permitting authorities will

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use reports submitted during post-injection testing and monitoring to assure that the CO2 plume
is moving as predicted and not endangering USDWs, and to ensure that before site closure is
authorized, the CO2 plume has stabilized and poses no threat to USDWs.
EPA will use the primacy applications submitted by States and Tribes to assure that
States and Tribes desiring to oversee Class VI wells will do so in a manner that protects USDWs.
3

Nonduplication, Consultations, and Other Collection Criteria

3(a)

Nonduplication

EPA has searched the Federal Information Locator System (FILS) in an effort to ensure
nonduplication of the data collection efforts. To the best of the Agency’s knowledge, data
currently required by this regulation are not available from any other source.
3(b)

Public Notice Required Prior to ICR Submission to OMB

As part of the Federal Register notice on the proposed regulation, EPA is also soliciting
comments on this information collection and the estimates in this ICR. EPA will solicit
comments on specific aspects of the proposed information collection, as described below:
1)

2)
3)
4)

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;
Whether the Agency’s burden estimate is accurate including the validity of the
methodology and assumptions used;
How to enhance the quality, utility, and clarity of the information to be collected; and
How to minimize the burden on respondents, including use of appropriate automated
electronic, mechanical, or other technological collection techniques or other forms of
information technology.

In compliance with the Paperwork Reduction Act (44 USC 3501 et seq.), EPA will
submit the ICR for the proposed GS Regulation to the Office of Management and Budget (OMB)
for review and approval.

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3(c)

Consultations

The burden and costs estimated in this ICR are based on the Technology and Cost (T&C)
document developed for the proposed GS regulation. The costs in that document were reviewed
by members of the regulatory workgroup that developed the proposed regulation. Members of
the workgroup represent the following EPA Offices and Regions: the Office of Water (OGWDW
and the Office of Wetlands, Oceans, and Watersheds); the Office of Air and Radiation; the
Office of General Counsel; the Office of Research and Development; the Office of Solid Waste
and Emergency Response; the Office of Policy, Economics and Innovation; the Office of
Enforcement and Compliance; and EPA Regions 2, 3, 4, 5, 6, 7, 8, and 10.
Four States, as co-regulators, and the U.S. Department of Energy also sat on the
workgroup and reviewed the T&C document.
3(d)

Effects of Less Frequent Collection

The testing and monitoring frequencies for some requirements under the proposed
regulation will be established as permit conditions; others, including MITs, are established in the
proposed regulation. The GS Regulation will require other parameters to be monitored
continuously. These frequencies are consistent with those in the existing UIC regulations for
other well classes, and EPA believes that the monitoring and reporting frequencies established in
the proposed regulation are the minimum necessary to ensure that any leakage due to the buoyant
and potentially corrosive nature of CO2 would not go undetected.
3(e)

General Guidelines

The GS Regulation complies with the guidelines (5 CFR 1320.5(d)(2)) implemented
under the Paperwork Reduction Act (PRA), with the exception that it requires a response to a
request for information in less than 30 days, in opposition to the PRA guidelines. Specifically,
the GS Regulation requires notification of the Primacy Agency within 24 hours if a well loses
mechanical integrity or if injection may cause endangerment to a USDW. This is consistent with
notification requirements for permitted wells under existing UIC regulations.
3(f)

Confidentiality

Operators of injection wells may claim confidentiality, as provided in existing regulations
in 40 CFR 144.5, Confidentiality of Information. If confidentiality is requested, the information
is treated in accordance with the provisions of 40 CFR 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;

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•

Information regarding the existence, absence, or level of contaminants in drinking
water.

Information collected under this ICR is intended for the Agency’s and/or State/Tribe’s
internal use and there are no plans to routinely release or publish any of the data. However, if no
claim of confidentiality is made at the time of submission, the information can be made available
to the public without further notice. Also, all information that is not deemed to be confidential
would be released to the public if requested under the Freedom of Information Act.
3(g)

Sensitive Questions

The data collection proposed does not ask any sensitive questions concerning sexual
behaviors or attitudes, religious beliefs, or other matters.

4

The Respondents and the Information Requested

The following sections provide information on the respondents and the information they
are requested to provide.
4(a)

Respondent NAICS/ SIC Codes

Under this proposed regulation, respondents to the GS Regulation requirements include
those who desire to inject CO2 in the subsurface for the purpose of long-term storage. They
potentially include the owners and operators of coal-fired electric power plants and ethanol
power plants and the oil and gas extraction industry. The North American Industry Classification
System (NAICS) code for fossil fuel electric power generation is 221112; the code for crude
petroleum and natural gas extraction is 211111; and for petroleum refining is 324110.1 States
(including Tribes) and EPA Regions that provide UIC Program oversight are also respondents.
The NAICS code for Tribes is 921150. The code for administration of air and water resource and
solid waste management programs is 924110.
4(b)

Information Requested

The following sections provide details on data items requested and associated activities
respondents will be required to undertake to provide this information.
4(b)(i) Data Items
Owners and Operators
EPA will require those seeking permits to own and operate CO2 GS wells to submit the
following items, as described in more detail in 40 CFR 146.82:
•
1

Information required in 40 CFR 144.31 (e)(1) through (6);

2007 NAICS Codes. http://www.census.gov/naics/2007/NAICOD07.HTM

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•

A map showing the injection well(s) and the applicable AoR;

•

The AoR based on modeling, using data obtained during logging and testing of the
well and the formation;

•

Information on the geologic structure and hydrogeologic properties of the proposed
storage site and overlying formations;

•

A tabulation of all wells within the AoR which penetrate the injection or confining
zone(s);

•

Maps and stratigraphic cross sections indicating the general vertical and lateral limits
of all USDWs, water wells and springs within the AoR, their positions relative to the
injection zone(s) and the direction of water movement, where known;

•

Baseline geochemical data on subsurface formations, including all USDWs in the
area of review;

•

Proposed operating data;

•

The compatibility of the CO2 stream with fluids in the injection zone and minerals in
both the injection and the confining zone(s);

•

Proposed formation testing program;

•

Proposed stimulation program;

•

The results of the formation testing program;

•

Proposed procedure to outline steps necessary to conduct injection operation;

•

Schematic or other appropriate drawings of the surface and subsurface construction
details of the well;

•

Injection well construction procedures;

•

Proposed AoR and corrective action plan;

•

The status of corrective action on wells in the AoR;

•

All available logging and testing program data on the well;

•

A demonstration of mechanical integrity prior to commencing injection;

•

A demonstration that the applicant has met financial responsibility requirements;

•

Proposed testing and monitoring plan;

•

Proposed injection well plugging plan;

•

Proposed post-injection site care and site closure plan;

•

Proposed emergency and remedial response plan; and

•

Any other information requested by the Director.

Once an operating permit has been issued, EPA will require semi-annual reports of the
following (40 CFR 146.91):
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•

The characteristics of injection fluids, injection pressure, flow rate, volume, and
annular pressure.

•

A description of any events that required shutdown or that resulted in an exceedance
of operating parameters specified in the permit.

•

The results any MITs, ground water quality monitoring, plume tracking, soil gas/air
monitoring (if required), well workovers, and any other required test. This should be
submitted within 30 days or with the next semi-annual report, whichever comes later
(40 CFR 146.91(b)).

At least every 10 years (or when changes in operational conditions warrant reevaluation), operators must also re-evaluate the AoR and submit a report, along with the status of
phased corrective action to the permitting authority. (40 CFR 146.92; 40 CFR 146.93) Operators
must also periodically update the cost information supporting their financial responsibility
determinations. (40 CFR 146.85)
Following the injection phase (i.e., during well plugging and post-injection site care) the
owner or operator must submit the following information:
•

A notification of intent to plug injection wells, along with any revisions made to the
original plugging plan submitted with the permit application.

•

A plugging report after plugging is complete.

•

A revised post-injection site care and site closure plan.

•

Periodic reports of the results of post-injection ground water quality monitoring and
the position of the CO2 plume.

•

A non-endangerment demonstration that the CO2 plume has stabilized and there is no
threat to USDWs following the post-injection monitoring.

•

A site closure report and recording of a notation on the deed to the property regarding
the fact that injection occurred.

Primacy States and Tribes
Primacy States/Tribes will be required to review all the items submitted by owners and
operators (see above).
States and Tribes seeking authority to implement a Class VI program will also be
required to apply for primacy. In applying for primacy, under existing regulations, States must
submit to EPA the following (40 CFR 145.22):
•

A letter from the governor requesting program approval.

•

A complete program description (as described in 40 CFR 145.23).

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•

An attorney general’s statement.

•

A memorandum of agreement with the Regional administrator.

•

Copies of all applicable State statutes and regulations.

•

A showing of the State’s public participation activities.

Three copies of the application are required.
4(b)(ii) Respondent Activities
Owners and Operators
In general, owners and operators seeking to obtain permits for CO2 GS wells will be
involved in the following collection activities:
•

Reading and understanding the GS Regulation.

•

Gathering new or existing geological data and other site information required as
part of the permit application, including maps, geological and geochemical data,
and data on existing wells in the AoR.

•

Developing plans and procedures that must be submitted with the permit
application, including the proposed operating data, proposed formation testing
program, proposed stimulation program, proposed injection procedure, schematics
of well construction, testing and monitoring plan, proposed area of review and
corrective action plan, injection well construction procedures, proposed injection
well plugging plan, proposed post-injection site care and site closure plan, and
proposed emergency and remedial response plan.

•

Demonstrating financial responsibility and resources for corrective action,
injection well plugging, post-injection site care and closure, and emergency and
remedial response.

•

Compiling the above information and preparing the permit application.

After submitting the UIC permit application but before beginning operation of a Class VI
well, owners and operators must conduct testing and submit additional information. Activities
include the following:
•

Submit all logging and testing data; results of formation testing; and data on
compatibility of the CO2 stream with fluids and minerals in the injection and
confining zones, and well materials.

•

Demonstrate mechanical integrity of the well.

•

Calculate the AoR using computational models, based on data obtained during
logging and testing.

•

Provide information on status of corrective action on wells in the AoR.

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Once operation commences, owners and operators must monitor the well and submit
semi-annual reports. They must monitor the following:
•

Chemical and physical characteristics of the CO2 stream.

•

Injection pressure, flow rate and volume, and pressure on the annulus (using
continuous recording devices).

•

Corrosion of well materials.

In addition, at least once per year operators must demonstrate external mechanical
integrity and report the results of testing. Throughout the injection phase, operators must monitor
ground water quality, track the CO2 plume and pressure front, and perform any soil gas/ surface
air monitoring or other required monitoring, as specified in their approved testing and monitoring
plans.
At least every 10 years, the owner or operator must re-evaluate the AoR by re-running the
delineation models to incorporate operational and monitoring data. Based on this, the operator
must revise the AoR and corrective action plan, if needed.
At the end of an injection project, the operator must submit a notice of intent to plug the
injection well and a revised post-injection site care and site closure plan. During the postinjection phase, operators will monitor ground water quality and track the position of the CO2
plume and report to the permitting authority on the results as specified in their approve plan.
Following the post-injection monitoring, operators would perform a non-endangerment
demonstration that there is no threat to USDWs, and that no further monitoring is necessary. At
this point, if closure of the site is authorized, the owner or operator must submit a site closure
report and must record a notation on the deed to the property regarding the fact that injection
occurred (40 CFR 146.93).
Recordkeeping activities include maintaining the AoR and corrective action plan, the
well plugging plan, and the post-injection site care and site closure plan. Operators must also
maintain and adjust cost information associated with their financial responsibility
determinations.
In addition to these new requirements, existing regulations require owners and operators
of Class VI wells to keep records associated with permit application for at least 3 years after the
application is signed. Other regulations require recordkeeping of all reports required by the
permit and records of continuously monitored data for 3 years. Data on the nature and
composition of all injected fluids must be kept until 3 years after completion of plugging and
abandonment procedures.
Primacy States and Tribes
State and Tribal officials may serve in the role of respondents when reviewing and
evaluating information and reports submitted by operators. States and Tribes with primacy will
act as the Agency in ensuring the implementation of the GS Regulation. States are anticipated to
be involved in the following activities:

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•

Review permit applications and prepare permits.

•

Review pre-operational testing and logging data, AoR evaluations, and the status
of corrective action.

•

Review semi-annual and occasional reports from operators.

•

Review AoR re-evaluations and updates to the AoR and corrective action plan.

•

Review notices of intent to plug wells.

•

Review post-injection monitoring data and non-endangerment demonstrations and
determine whether to authorize site closure.

•

Review notices of intent to close GS sites and site closure reports.

•

Maintain records of the above information submitted by operators.

States and Tribes are required to maintain records of verification activities and each
determination made, and report to EPA in accordance with reporting requirements at 40 CFR
144.8 through the UIC Program.
States and Tribes must develop and submit a UIC Program (primacy application) for
Class VI wells if they wish to govern CO2 GS wells in their States/Tribes. The programs are
subject to approval by EPA, and must include the items described in section 4(b)(i) for States
and Tribes.
5

The Information Collected—Agency Activities, Collection Methodology, and
Information Management

The following sections describe the Agency activities related to analyzing, maintaining,
and distributing the information collected.
5(a)

Agency Activities

The Agency will be responsible for promulgating this proposed regulation and overseeing
its implementation. EPA Regions and EPA Headquarters will have different responsibilities.
Where a State does not obtain primacy, EPA Regions conduct the same activities as States (see
section 4b(ii)) to oversee GS wells in the State, except that they do not need to apply for
primacy. Regions also receive and review primacy applications submitted by the States; the
Regions then forward the applications to Headquarters for final approval.
EPA Headquarters (OGWDW) provides technical assistance to Regions, primacy States
and Tribes, and operators in the form of guidance manuals and training. Headquarters will also
evaluate primacy applications submitted by the States for final decisions.
5(b)

Collection Methodology and Management

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EPA proposes to require the reporting of data from owners or operators in an electronic
format acceptable to the Director for site, facility, and monitoring information. At the discretion
of the Director, formats other than electronic may be accepted after a determination has been
made that the entity does not have the capability to use the required format. Long-term retention
of records in an electronic format may also be required at the Director's discretion. If records are
stored in an electronic format, information should be maintained digitally in multiple locations
(i.e., backed-up) in accordance with best practices for electronic 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 EPA.

In 2007, EPA created a national UIC database for well, facility, and compliance data
submitted by Primacy Agencies. The national UIC data model contains approximately 120 data
elements related to various aspects of the UIC Program. At this time, several Primacy Agencies
are actively participating in use of the national UIC database. EPA encourages State and Tribal
primacy agencies to work with EPA Regional offices as much as possible in order to use the new
database system for reporting of information regarding Class VI wells. The database includes a
mechanism to electronically transfer data between existing State and EPA Regional databases
and Headquarters’ database, eliminating the need for State UIC Program Directors to complete
paper reporting forms. (The burden and cost associated with developing and maintaining the
national UIC database is accounted for in the UIC Program ICR; the proposed GS regulation is
assumed to add a negligible cost to this requirement due to the small number of GS sites.)
5(c)

Small Entity Flexibility

In general, a small entity is defined as: (1) a small business with annual revenue less than
$6 million according to Small Business Administration size standards; (2) a small governmental
jurisdiction that is a government of a city, county, town, school district or special district with a
population of less than 50,000; or (3) a small organization that is any not-for-profit enterprise
which is independently owned and operated and is not dominant in its field. In some cases,
however, industries propose different standards for small businesses.

ICR for the Proposed GS Regulation

Page 12

July, 2008

EPA expects that Class VI wells will be owned and operated by fossil fuel power
generators, oil and gas extraction companies, and oil and gas refineries. Because the resources
necessary to construct injection wells that meet the standards of the GS Regulation are
significant, EPA believes that none of the owners or operators of Class VI wells will be small
entities. Therefore, EPA assumes that the GS Regulation will cause no significant impact on
small entities.
5(d)

Collection Schedule

The final GS Regulation is scheduled for promulgation in 2012; this ICR covers the first
three years of implementation (2012 through 2014). At that point, States and Tribes wishing to
obtain primacy will complete and submit primacy applications to EPA.
Because this ICR covers only the first three years of a regulation that will cover injection
operations with potentially long life spans (i.e., up to 20 years of injection and 50 years of postinjection monitoring), EPA assumes that only a limited portion of the paperwork burden for GS
projects will be captured in this ICR. EPA anticipates that the majority of the activities during
the information collection will be associated with States applying for primacy.
Only a handful of GS projects are expected to be deployed during the collection period.
EPA estimates that five operators will submit permit applications and/or monitoring data. EPA
does not predict that any CO2 GS well operators will perform AoR re-evaluations, plug their
injection wells, or perform post-injection site care within the period covered by this ICR.
EPA assumes that one-third of the 31 States (or 10 States) anticipated to apply for
primacy will do so in each year of the collection. EPA assumes that no Tribes will seek primacy
during the information collection period. EPA’s estimates of GS project deployments are based
on Exhibit 3.1 of the Cost Analysis. Exhibit 5-1 presents a schedule of the activities EPA expects
to take place during the collection period.
Exhibit 5-1
Schedule of Activities Under this Information Collection
2012-2014
Activities
Year
10.3 States submit primacy applications
Year 1 (2012)
2.2 Operators in primacy states apply for permits
0.8 Operators in DI states apply for permits
10.3 States submit primacy applications
0.7 Operators in primacy states apply for permits
Year 2 (2013)
0.3 Operators in DI states apply for permits
3.0 Operators begin injection/monitoring
10.3 States submit primacy applications
0.7 Operators in primacy states apply for permits
Year 3 (2014)
0.3 Operators in DI states apply for permits
4.0 Operators begin injection/monitoring
Note:

(1) Detail may not add exactly due to independent rounding.

ICR for the Proposed GS Regulation

Page 13

July, 2008

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 CO2 GS Regulation 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 the burden statement for this information collection is in
Section 6(f).
Many of the burden and cost estimates for this ICR were derived from estimates in the
Technology and Cost document for the proposed GS regulation, and estimates for Class I well
operators in the draft 2007 UIC Program ICR (ICR No. 0370.021), adjusted to account for the
larger scale of CO2 GS sites. The derivation of the burden and cost estimates used in the ICR is
explained in Appendix A.
6(a)

Respondent Burden

6(a)(i) Burden to Owners and Operators of CO2 GS Wells
EPA’s estimate of the annual paperwork burden to operators associated with submitting
permit applications, delineating the AoR and performing corrective action, pre-operational
testing, testing and monitoring, reporting and recordkeeping, injection well plugging, and postinjection site care is presented in Exhibit 6-1. Legal, managerial, technical, and clerical staff
hours are shown; Column A presents the total unit burden for each activity.
The total annual burden on the five operators of Class VI wells nationwide is estimated to
be 4,387 hours for the 3 years covered by this ICR. These costs break down as follows:
•

Permitting and startup operations will require a total of about 3,191 hours annually.
These activities include preparing the permit application, performing geological site
characterization, developing necessary plans, and pre-operational testing and
reporting, including modeling the AoR and performing all pre-operational corrective
action.

•

Compliance with testing and monitoring requirements will impose a total annual
burden of 1,023 hours.

•

Reporting requirements will be associated with 163 burden hours annually for all
operators.

•

Recordkeeping requirements will require 9.3 annually.

ICR for the Proposed GS Regulation

Page 14

July, 2008

EPA does not expect that any operators will conduct activities associated with periodic
AoR re-evaluations, injection well plugging, or post-injection site care during the three years
covered by this ICR. Burden and cost estimates are summarized by response type in Exhibit 6-3.
EPA recognizes that many UIC information collection activities are performed by
contractors. The operator unit burden estimates reported in this section represent a composite of
the 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. Contractor costs are included in the estimates of operator non-labor costs.

ICR for the Proposed GS Regulation

Page 15

July, 2008

Exhibit 6-1 Annual Paperwork Burden and Costs Associated with Class VI CO2 GS Wells: Operators
2012-2014
A

B

Hours and Costs per Response
Managerial Technical Clerical
Unit
Burden
Burden
Burden Burden
(Hours)
(Hours)
(Hours) (Hours)

Legal
Frequen Burden
Description of Requirement
cy
(Hours)
Initial/Startup Requirements (Per Permit Application)
Requirements associated with construction and operating permit applications
Compile all geologic testing data and prepare and
One-time
25.0
66.0
submit permit application.
Gather and submit description of activities requiring
a permit, facility name and address, SIC codes,
ownership and facility status, facility location, listing
of relevant permits or construction approvals,
One-time
relevant maps and cross sections, construction
specifics, description of the business, proposed
injection, formation testing, and stimulation
programs.
0.0
0.0
Prepare and submit map showing the injection
well(s) for which a permit is sought and the
applicable AoR , maps and cross sections of AoR,
One-time
and geologic and topographic maps and cross
sections illustrating regional geology, hydrogeology,
and the geologic structure.
0.0
0.0
Prepare and submit information on the calculated
One-time
0.0
0.0
AoR.
Identify location, orientation, and properties of
known or suspected faults and fractures;
One-time
determination whether they would not interfere with
containment.
0.0
0.0
Obtain and analyze seismic (earthquake) history.

One-time

Obtain data on the depth, areal extent, thickness,
mineralogy, porosity, permeability and capillary
pressure of the injection zone and confining zone.
Obtain geomechanical information on fractures,
stress, ductility, rock strength, and in situ fluid
pressures within the confining zone.

One-time

Prepare and submit a map and tabulation of all wells
One-time
within the AoR.
Prepare and submit maps/cross sections of local
and regional geology, USDWs.

One-time

Submit baseline geochemical data on subsurface
formations and maps/cross sections of subsurface
aquifers.

One-time

Submit proposed operating data (e.g., anticipated
maximum pressure and flow rate).

One-time

C

Unit
Labor
Cost

D

E

F

Total Hours and Costs
Unit Non- No. of
Total
Labor
Respon Hours/Yea
Cost (6)
ses
r
Total Cost/Year

284.0

199.0

574 $35,385

$

-

1.7

956.7

$

58,974

20.0

0.0

0.0 $ 1,577

$

-

1.7

0.0

$

2,628

20.0

0.0

20.0 $ 1,577

$

4,125

1.7

33.3

$

9,503

324.0

0.0

324.0 $25,546

$

2,415

1.7

540.0

$

46,601

0.0

0.0

$ 281,250

1.7

0.0

$

468,750

$

1.7

50.0

$

3,942

0.0 $

-

0.0

0.0

30.0

0.0

30.0 $ 2,365

0.0

0.0

297.0

0.0

297.0 $23,417

$ 179,813

1.7

495.0

$

338,716

0.0

0.0

165.0

0.0

165.0 $13,010

$ 33,250

1.7

275.0

$

77,099

0.0

0.0

42.0

0.0

42.0 $ 3,312

$

-

1.7

70.0

$

5,519

0.0

0.0

90.0

0.0

90.0 $ 7,096

$

5,700

1.7

150.0

$

21,327

631

$

-

1.7

13.3

$

1,051

0.0

0.0

8.0

0.0

Demonstrate compatibility of CO2 stream with well
materials and fluids and minerals in the injection and One-time

0.0

0.0

96.0

0.0

96.0 $ 7,569

$

6,400

1.7

160.0

$

23,282

Develop formation testing and stimulation programs
and injection procedures and submit results of
One-time
formation testing program.

0.0

0.0

20.0

0.0

20.0 $ 1,577

$

5,433

1.7

33.3

$

11,683

0.0

0.0

8.0

0.0

631

$

4,527

1.7

13.3

$

8,597

0.0

0.0

84.0

0.0

84.0 $ 6,623

$

-

1.7

140.0

$

11,038

0.0

0.0

50.0

0.0

50.0 $ 3,942

$ 202,000

1.7

83.3

$

343,237

0.0

0.0

20.0

0.0

20.0 $ 1,577

$

1.7

33.3

$

2,628

0.0

0.0

7.0

0.0

1.7

11.7

$

47,200

Prepare and submit descriptions of construction
procedures and schematics.

8.0 $

-

One-time

Prepare and submit AoR and corrective action plan. One-time
Submit status of corrective action at wells in the
AoR.

One-time

Prepare and submit completion report.

One-time

Prepare and submit a report of deviation checks and
One-time
other logs and tests during construction.

ICR for the Proposed GS Regulation

Page 16

8.0 $

7.0 $

552

-

$ 27,768

July, 2008

Exhibit 6-1 Annual Paperwork Burden and Costs Associated with Class VI CO2 GS Wells: Operators
2012-2014
A

Description of Requirement

Frequen
cy

Demonstrate mechanical integrity prior to
commencing injection.

One-time

Prepare and submit well plugging plan, postinjection site care and site closure plan, and
demonstration of financial responsibility.

One-time

Prepare and submit testing and monitoring plan.

One-time

Prepare and submit emergency and remedial
One-time
response plan.
Requirements Associated with Periodic AoR Reevaluations
Prepare and submit amended AoR and corrective
action plan or demonstrate that no amendment to
Per plan
the plan is needed.
Testing and Monitoring Requirements
Per
Analyze the CO2 stream.
permit
Demonstrate internal mechanical integrity by
Continuo
monitoring injection pressure, flow rate and volume,
us
Periodic
Conduct corrosion monitoring. (3)
Monitor ground water quality.
Demonstrate external mechanical integrity using
tracer survey, noise/temperature logs or other
approved tests
Conduct pressure fall-off test. (3)
Track CO2 plume and pressure front.

Per plan
Annual
Every 5
years
Per plan

Conduct surface air and soil gas monitoring, if
directed.

Per plan

Conduct casing inspection log at workover.

Every 5
ears

Reporting Requirements
Report semi-annually on: physical, chemical, and
other characteristics of injected fluids; injection
pressure, flow rate, and volume; and monitoring of
USDWs.
Report on most recent MITs and other tests.
Report results of: any required mechanical integrity
tests, other required tests, and well workovers.
Provide periodic adjustments/updates to financial
cost estimates for financial responsibility.
Recordkeeping Requirements
Maintain monitoring information, calibration and
maintenance records, required reports, application
data, and monitoring results. Maintain all required
plans.

Legal
Burden
(Hours)

B

Hours and Costs per Response
Managerial Technical Clerical
Unit
Burden
Burden
Burden Burden
(Hours)
(Hours)
(Hours) (Hours)

0.0

0.0

5.5

0.0

C

Unit
Labor
Cost

5.5 $

434

D

E

F

Total Hours and Costs
Unit Non- No. of
Total
Labor
Respon Hours/Yea
Cost (6)
ses
r
Total Cost/Year
$

-

1.7

9.2

$

723

0.0

0.0

24.0

0.0

24.0 $ 1,892

$

-

1.7

40.0

$

3,154

0.0

0.0

40.0

0.0

40.0 $ 3,154

$

3,562

1.7

66.7

$

11,192

0.0

0.0

10.0

0.0

10.0 $

788

$

-

1.7

16.7

$

1,314

0.0

0.0

324.0

0.0

324.0 $25,546

$

2,415

0.0

0.0

$

-

0.0

0.0

12.0

0.0

12.0 $

946

$

3,200

2.3

28.0

$

9,674

0.0

0.0

0.0
2.5

0.0

0.0 $
2.5 $

197

$
$

7,417
-

2.3
2.3

0.0
5.8

$
$

17,306
460

0.0

0.0

96.0

0.0

$ 38,400

2.3

224.0

$

107,261
736

96.0 $ 7,569

0.0

0.0

4.0

0.0

4.0 $

315

$

-

2.3

9.3

$

0.0

0.0

0.0

0.0

0.0 $

-

$

4,000

0.0

0.0

$

-

0.0

0.0

324.0

0.0

2.3

756.0

$

59,607

324.0 $25,546

0.0

0.0

0.0

0.0

0.0 $

-

$

1,875

2.3

0.0

$

4,375

0.0

0.0

2.0

0.0

2.0 $

158

$ 18,000

0.0

0.0

$

-

Semiannual
0.0

0.0

22.0

2.0

24.0

Annual

0.0

0.0

20.0

2.0

22.0 $ 1,793

Occasion
al

0.0

0.0

12.0

2.0

14.0 $ 1,005

0.0

4.0

0.0

0.0

4.0 $

314

0.0

0.0

0.0

4.0

4.0 $116.90

0.0

0.0

0.0

4.0

4.0 $116.90

0.0

0.5

0.0

1.0

0.0

0.0

40.0

0.0

Per plan

###### $

-

4.7

112.0

$

7,632

$

-

2.3

51.3

$

4,184

$

-

0.0

0.0

$

-

$

-

0.0

0.0

$

-

$

-

2.3

9.3

$

272.78

$

-

0.0

0.0

$

-

At least 3
years

Maintain cost data to support financial responsibility
Annual
determinations.
(Ongoing)
Injection Well Plugging
Prepare and submit notice of intent to plug.

One-time

Prepare and submit plugging report.

One-time

1.5 $

69

$

-

0.0

0.0

$

-

40.0 $ 3,154

$

1,014

0.0

0.0

$

-

Post-Injection Site Care
Conduct post-injection monitoring and report to
Per plan
director on results.
0.0
0.0
40.0
0.0
40.0 $ 3,154 $ 400,000
0.0
0.0 $
Submit non-endangerment demonstration that CO2
One-time
plume and pressure front have stabilized.
0.0
0.0
332.0
0.0
332.0 $26,177 $ 189,915
0.0
0.0 $
0.0
0.0
40.0
0.0
40.0 $ 3,154 $
0.0
0.0 $
Submit site closure report.
One-time
62.3
4,386.7 $
1,709,669
Total
Notes:
(1) Burden and cost estimates are based on T&C document or estimates for Class I Hazardous and Nonhazardous wells in the 2007 UIC Program ICR, adjusted to account for variations
between Class I and Class VI GS wells. See Appendix A.
(2) EPA assumes that the GS projects permitted during the clearance period will be large saline projects, each with 4 injection wells.
(3) Non-labor cost is total for 4 injection wells.
(4) Numbers may not appear to add due to rounding.
(5) EPA assumes that all operator activities during the collection period will be associate with permit applications, monitoring, and reporting. See section 5(e).
(6) All non-labor cost is operating and maintenance (O&M) cost or contractor cost.

ICR for the Proposed GS Regulation

Page 17

July, 2008

6(a)(ii)

Burden to Primacy Agencies

Primacy agencies’ burden as users of data associated with implementing Class VI
programs arise from program oversight, reviewing and responding to permit applications and
pre-operational reports, operator testing and monitoring reports, AoR re-evaluations, and
plugging and post-injection reports submitted by operators within their States. Primacy agency
burden associated with oversight of Class VI programs is presented in Column A of Exhibit 6-2.
EPA estimates that the annual burden to primacy agencies associated with this
information collection will be 11,094 hours. The burden is allocated as follows:
•

The majority of the burden is associated with completing primacy applications, which
will impose an average burden of 10,747 hours annually during the 3 years covered
by this ICR. EPA estimates that applying for primacy will require 0.5 FTEs or 1,040
hours per State.

•

Primacy agencies will spend an average of 347 hours annually overseeing four Class
VI well operators, including:
•

294 hours reviewing permit applications for Class VI wells, writing permits, and
reviewing AoR studies and pre-operational data.

•

52 hours reviewing testing and monitoring data or occasional reports submitted by
operators.

•

Recordkeeping will impose an annual burden of 1.2 hours.

During the ICR clearance period, EPA predicts that primacy agencies will not spend any
time reviewing AoR re-evaluations or plugging and post-injection monitoring reports submitted
by operators of Class VI sites, because no sites are expected to reach that phase during this
period.
Exhibit 6-3 provides a summary of primacy agencies’ burden and cost according to
different response categories.

ICR for the Proposed GS Regulation

Page 18

July, 2008

Exhibit 6-2 Annual Paperwork Burden and Costs Associated with Class VI CO2 GS Wells: Primacy Agencies

A

B

C

D

Hours and Costs per Response
Unit Burden
Description of Requirement
Frequency
(Hours)
Requirements Associated with Obtaining Primacy
Prepare primacy application for oversight of Class
One-time
1,040.0
VI wells.
Initial/Start-up
Requirements Associated with Review of GS Permit Applications
Review permit application, geological data, and
proposed construction and operating procedures
to determine geologic suitability of proposed site. One-time
100.0
Review proposed testing and monitoring plan.
One-time
20.0
Review proposed AoR and corrective action plan. One-time
20.0
Review proposed well plugging and post-injection
One-time
5.0
site care and site closure plans.
Requirements Associated with Public Notices for GS Permits
One-time
20.0
Issue notice of intent to deny.
One-time
40.0
Prepare draft permit.
Provide public notice of issuance of a draft permit
One-time
1.0
or intent to deny.
One-time
6.0
Consider public comments.
One-time
Issue final permit decision.
2.0
One-time
Respond to comments.
7.0
Pre-operational Reporting
Review initial AoR model and report of status of
corrective action on wells in the AoR.
One-time
40.0
Review report of pre-construction logs and tests. One-time
4.0
One-time
Witness logging and testing.
3.0
AoR Reevaluation
Occasional
30.0
Review operator reports on AoR reevaluation.
Operator Reporting
Semi-annual
10.0
Review operator reports.
Review monitoring and other test data submitted
Annual
5.0
since previous evaluation.
Respond to periodic notifications by owners and
Occasional
4.0
operators.
Per plan
2.0
Review updated financial cost estimates.
Recordkeeping
1.0
Maintain administrative record of permit decision. One-time
Injection Well Plugging
One-time
4.0
Review well plugging plan.
Review amended post-injection site care and
One-time
4.0
closure plan upon cessation of injection.
Post-injection Site Care
Review periodic monitoring reports during postPer plan
4.0
injection site care.
Review non-endangerment demonstrations.
One-time
24.0
Prepare and publish notice of permanent record
One time
8.0
on the GS project.
Total

Unit Labor
Cost

Unit Non-labor
Cost

E

F

Total Hours and Costs
Number of
State
Total State
Responses
Burden/Year

$43,852

-

10.3

$4,217

-

$843
$843

-

$211

10,746.7

Total State
Cost/Year

$

453,141

1.2

120.0 $

5,060

1.2
1.2

24.0 $
24.0 $

1,012
1,012

-

1.2

6.0 $

253

$843
$1,687

-

0.0
1.2

0.0 $
48.0 $

2,024

$42
$253
$84
$295

-

1.2
1.2
1.2
1.2

$1,687
$169
$126

-

$1,265

1.2
7.2
2.4
8.4

$
$
$
$

51
304
101
354

1.2
1.2
0.0

48.0 $
4.8 $
0.0 $

2,024
202
-

-

0.0

0.0 $

-

$422

-

3.4

33.6 $

1,417

$211

-

1.7

8.4 $

354

$169
$84

-

1.7
1.7

6.7 $
3.4 $

283
142

$42

-

1.2

1.2 $

$169

-

0.0

0.0 $

-

51

$169

-

0.0

0.0 $

-

$169
$1,012

-

0.0
0.0

0.0 $
0.0 $

-

$337

-

0.0
33.1

0.0 $
11093.9 $

467,785

Notes:
(1) Numbers may not appear to add due to rounding.
(2) EPA assumes that all operator activities during the collection period will be associate with permit applications, monitoring, and reporting. See section 5(e).

ICR for the Proposed GS Regulation

Page 19

July, 2008

6(b)

Respondent Costs

6(b)(i) Cost to Operators
Exhibit 6-1 shows the annual total costs for owners and operators of Class VI injection
wells over the 3-year ICR clearance period. The annual costs are estimated at approximately
$1.7 million, which consists of $1.4 million in non-labor costs and $325,262 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. The labor cost estimate is based on
average hourly estimates for salary and overhead of $76 for legal staff, $75 for managerial staff,
$62 for technical staff, and $28 for clerical staff. The legal, managerial, and clerical rates are
based on Bureau of Labor Statistics Occupational Employment Statistics, 2006, median hourly
wage estimates for NAICS code 221100 (electric power generation, transmission and
distribution). The technical labor rate is an average of estimates for geoscientists and mining and
geological engineers from the Technology & Cost document. Each hourly wage estimate was
increased by 60 percent to account for overhead costs (the inflation factor recommended in
EPA’s ICR Handbook). EPA assumes that contractor time (which is embedded in the non-labor
costs in this ICR) would be approximately $78 per hour; this is based on a mean hourly wage
estimate for management, scientific, and technical consulting services for NAICS code 221100
and was inflated to account for overhead (60 percent) and contractor profit (5 percent).
EPA derived non-labor costs from the T&C document and the 2007 programmatic ICR.
This ICR assumes there are no capital costs to operators–large capital expenditures associated
with CO2 GS (e.g., construction costs and monitoring equipment) are considered to be customary
business practice, not incremental costs associated with the information collection. 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 CO2 or ground water
monitoring. Appendix A describes the derivation of non-labor costs.
6(b)(ii)

Cost to Primacy Agencies

Exhibit 6-2 shows that the annual cost to Primacy Agencies is estimated at approximately
$467,785, all of which is labor cost. For this ICR, EPA assumed that the average hourly labor
rate for a State employee is $38.69. This estimate is based on a federal GS-9, Step 10 salary on
the 2007 federal pay scale, increased by 60 percent to account for overhead cost (the inflation
factor recommended in EPA’s ICR Handbook).
The incremental non-labor costs (capital and O&M) to primacy agencies associated with
the Class VI program are estimated to be negligible.

ICR for the Proposed GS Regulation

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July, 2008

6(c)

Agency Burden and Costs

EPA estimates that its Regional offices will implement the UIC Program for Class VI
wells in the 12 States and territories that EPA anticipates may seek Class VI permits but will not
obtain Class VI primacy, and in the Tribes. The paperwork requirements for Regional direct
implementation (DI) programs are roughly the same as those for the State and Tribal primacy
programs. EPA estimates that only one DI program will have to meet the paperwork
requirements during the 3-year clearance period because only one CO2 GS project is assumed to
be under the authority of a DI program. The total annual burden for Regional DI programs
associated with the paperwork requirements and oversight of Class VI activities is 135 hours. In
addition, Regions will spend an average of 517 hours annually reviewing primacy applications
submitted by the States.
EPA estimates that Headquarters will spend approximately 2 FTEs, or 4,160 hours
annually in its oversight responsibilities for the GS regulation. Headquarters activities will
include providing technical assistance to the Regions and States as they begin to oversee Class
VI wells. Headquarters staff will also spend 413 hours annually reviewing and making final
determinations on State and Tribal primacy applications.
EPA assumes the average hourly labor rate for salary and overhead and benefits for
Agency staff to be $48.91. This estimate is based on a federal GS-12, Step 5 salary on the 2007
federal pay scale, increased by 60 percent to account for overhead costs. The annual federal cost
associated with this collection is $265,018. A summary of Agency cost is presented in Exhibit 63.
6(d)

Respondent Universe and Total Burden and Costs

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 Exhibits
6-1 and 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 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.
EPA estimates that 31 States will apply for and gain primacy within the 3 year clearance
period, an average of 10.3 States per year. This number represents 72 percent of the 43 States
currently active in the UIC program, as described in the Cost Analysis document (Chapter 5).
EPA assumes that no Tribes will seek primacy for Class VI wells during the information
collection period.
EPA estimates that five GS projects will be deployed over the three years covered by this
ICR. This is based on the deployment schedule in the T&C document. EPA predicts that, of
these five projects, four (or 72 percent) will be located in States with primacy, thus four Primacy
Agencies will incur paperwork burden associated with operator submittals. EPA assumes that the
remaining CO2 GS project site will be permitted under the authority of a DI program.
ICR for the Proposed GS Regulation

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July, 2008

During the three years covered by this ICR, each of the five operators will apply for a
permit; this equals an average of 1.7 operators submitting permit applications per year over the
three years of the information collection. EPA estimates that no operators will perform
monitoring in Year 1, three will monitor in Year 2, and 4 in Year 3 (see Exhibit 5-1). This
equals an average of 2.3 monitoring responses annually.
6(d)(i) Total Burden and Costs
EPA estimates that the total annual respondent burden (i.e., to operators and primacy
agencies) for the 3 years covered by this ICR is 15,481 hours. The total respondent burden over
the ICR clearance period is estimate to be 46,442 hours. EPA estimates that the total cost to
respondents is $2.2 million per year. The total cost estimate associated with this ICR is $7.3
million from 2012 through 2014. See Exhibit 6-3 for a summary of annual costs by respondent
and response type and see Exhibit 6-4 for total burden and cost incurred by respondents.
Exhibit 6-3
Summary of Annual Operator, Primacy Agency, and EPA Regional/Headquarters Burden and Cost Associated with Class VI Wells
2012-2014
Burden
Burden/
Response Type
Labor Cost
Non-Labor Cost
Total Cost
Responses
(Hours)
Response
Operator Burden and Cost
Initial/Startup Requirements
3,190.8 $
232,501 $
1,254,467 $
1,498,160
36.7
87.0
Requirements Associated with Periodic
AoR Reevaluations
0.0 $
$
$
0.0
0.0
Monitoring/Testing Requirements
1023.2 $
80,672 $
118,748 $
199,420
16.3
62.6
Reporting Requirements
163.3 $
11,816 $
$
11,816
7.0
23.3
Recordkeeping Requirements
9.3 $
273 $
$
273
2.3
4.0
Injection Well Plugging Requirements
0.0 $
$
$
0.0
0.0
Post-injection Site Care Requirements
0.0 $
$
$
0.0
0.0
Total
4,386.7 $
325,262 $
1,373,215 $
1,709,669
62.3
70.4
Primacy Agency
Requirements Associated with Obtaining
Primacy
10,746.7 $
453,141 $
$
453,141
10.3
1040.0
Initial/Start-up Requirements
294.0 $
12,397 $
$
12,397
13.2
22.3
AoR Reevaluation Requirements
0.0 $
$
$
0.0
0.0
Operator Reporting
52.1 $
2,196 $
$
2,196
8.4
6.2
Recordkeeping Requirements
1.2 $
51 $
$
51
1.2
1.0
Injection Well Plugging Requirements
0.0 $
$
$
0.0
0.0
Post-injection Site Care Requirements
0.0 $
$
$
0.0
0.0
Total
11,093.9 $
467,785 $
$
467,785
33.1
334.8
EPA Regional/Headquarters
Regional
Review of Primacy Packages
516.7 $
25,271 $
$
25,271
10.3
50.0
Initial/Start-up Requirements
114.3 $
5,592 $
$
5,592
5.1
22.3
AoR Reevaluation Requirements
0.0 $
$
$
0.0
0.0
Operator Reporting
20.3 $
991 $
$
991
3.3
6.2
Recordkeeping Requirements
0.5 $
23 $
$
23
0.5
1.0
Injection Well Plugging Requirements
0.0 $
$
$
0.0
0.0
Post-injection Site Care Requirements
0.0 $
$
$
0.0
0.0
Subtotal
651.7 $
31,877 $
$
31,877
19.2
33.9
EPA Headquarters
Review of Primacy Packages
413.3 $
20,217 $
$
20,217
10.3
40.0
Oversight and Technical Assistance
4160.0 $
203,474 $
$
203,474
1.0
4160.0
Subtotal
4573.3 $
223,691 $
$
223,691
11.3
403.5
EPA Total
5225.1 $
255,568 $
$
255,568
30.5
171.1
Note: Detail may not add exactly due to independent rounding.

Cost/
Response
$

40,859

$
$
$
$
$
$
$

12,209
1,688
117
27,428

$
$
$
$
$
$
$
$

43,852
939
261
42
14,118

$
$
$
$
$
$
$
$

2,446
1,089
303
49
1,660

$
$
$
$

1,956
203,474
19,737
8,370

Exhibit 6-4
Annual Burden and Cost Associated with Class VI Wells
2012-2014
Burden
Respondent Type
(hours)
Labor Cost
Non-Labor Cost
Operators
4,386.7 $
325,262 $
1,373,215
Primacy States
11,093.9 $
467,785 $
Respondent Total
15,480.6 $
793,047 $
1,373,215
EPA Regional/Headquarters
5,225.1 $
255,568
Total
20,705.7 $
1,048,614 $
1,373,215
Note: Detail may not add exactly due to independent rounding.

ICR for the Proposed GS Regulation

Page 22

$
$
$
$
$

Total Cost
1,709,669
467,785
2,177,453
255,568
2,433,021

Responses
62.3
33.1
95.5
30.5
126.0

Burden/
Response
70.4
334.8
162.2
171.1
164.3

Cost/
Response
$
27,428
$
14,118
$
13,428
$
8,370
$
19,310

July, 2008

6(e)

Bottom Line Annual Burden Hours and Costs
The bottom line burden hours and costs are presented in Exhibit 6-5.
Exhibit 6-5
Bottom Line Annual Burden and Cost
2012-2014
16.5 =

Number of Respondents

95.5 =

Total Annual Responses

5.8 =

Number of Responses per Respondent

15,480.6 =

Total Respondent Hours

162.2 =

Hours per Response
Annual Non-Labor Cost
Total Respondent Cost
Total Hours (Respondents plus Agency)

$

1,373,215 =
$2,177,453 =
20,705.7 =

$2,600,915 =
Total Cost (Respondents plus Agency)
Note: Detail may not add exactly due to independent rounding.

4
12.5
62.3
33.1
95.5
16.5
4386.7
11093.9
15,480.6
95.5
$1,373,215
$0
1,709,669
467,785
15,480.6
5,225.1
$2,177,453
$255,568

Operators +
Primacy Agencies
Operator responses +
Primacy Agencies responses
Total annual responses from above ÷
Total respondents from above
Operator burden +
Primacy Agency burden
Total annual hours from above ÷
Total responses from above
Operator non-labor cost +
Primacy Agency non-labor cost
Operator cost +
Primacy Agency cost
Total respondent hours from above +
Total EPA hours
Total respondent cost from above +
Total EPA cost

6(e)(i) Variations in the Annual Bottom Line
The burden and costs incurred by respondents to the CO2 GS Regulation differ over each
of the 3 years covered by this ICR. These variations are shown in Exhibit 6-6 below. The
differences are due primarily to the fact that the five operators assumed to apply for Class VI
permits during the three years will apply and begin operation in a staggered fashion. As
described in Exhibit 5-1, three operators are assumed to apply for permits in the first year of the
ICR period (2.2 in States with primacy and 0.8 in DI States). During the second year, those three
operators are assumed to begin injection and monitoring, and an additional operator is assumed
to apply for a permit (0.7 in primacy States and 0.3 in DI States). During the third year, four
operators are assumed to be injecting and monitoring, and one additional operator (again, 0.7 in
primacy States and 0.3 in DI States) will apply for a permit.
State and DI oversight burden during the ICR period will vary accordingly, as States and
DI programs respond to permit applications by reviewing the applications and writing permits. In
addition, as operators begin operational monitoring, States and DI programs will begin reviewing
the monitoring data. Preparing primacy applications will account for the majority of primacy
agency burden. This is a one-time burden to each State or Tribe that seeks primacy and, in
subsequent ICRs, primacy agency burden is expected to decrease by approximately 90 percent as
this activity is completed.

ICR for the Proposed GS Regulation

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July, 2008

Exhibit 6-6
Summary of Operators, Primacy Agency, and EPA Regional/Headquarters Burden and Cost Associated with this ICR
2012-2014
Year 1

Year 2

Year 3

Total (Owners/Operators, Primacy Agencies, and DI Programs/EPA Headquarters)
Burden (in hours)
21,934.2
18,293.7
18,435.2
Respondents
24.3
28.2
29.9
Responses
131.0
113.0
129.0
Costs ($)
$
3,412,795 $
2,428,168 $
2,702,335
Labor ($)
$
1,132,302 $
877,087 $
887,616
Non-Labor ($)
$
2,280,493 $
1,551,081 $
1,814,719
Burden per Response
167.4
161.9
142.9
Cost per Response
$
26,052 $
21,488 $
20,948
Burden per Respondent
901.4
648.4
615.9
Cost per Respondent
$
140,252 $
86,065 $
90,278
Operators/Owners
Burden (in hours)
5,359.5
2,118.0
2,228.5
Respondents
3.0
4.0
5.0
Responses
63.0
54.0
65.0
Costs ($)
$
2,678,179 $
1,711,130 $
1,983,931
Labor ($)
$
397,687 $
160,049 $
169,212
Non-Labor ($)
$
2,280,493 $
1,551,081 $
1,814,719
Avg. Burden per Response
85.1
39.2
34.3
Avg. Cost per Response
$
42,511 $
31,688 $
30,522
Avg. Burden per Respondent
1,786.5
529.5
445.7
Avg. Cost per Respondent
$
892,726 $
427,783 $
396,786
Primacy Agencies
Burden (in hours)
11,278.0
10,990.7
11,013.1
Respondents
10.3
13.2
13.9
Responses
36.3
29.8
33.4
Costs ($)
$
475,547 $
463,433 $
464,374
Labor ($)
$
475,547 $
463,433 $
464,374
Non Labor ($)
$
$
$
Burden per Response
311.1
369.1
330.0
Cost per Response
$
13,117 $
15,565 $
13,915
Burden per Respondent
1,091.4
831.8
790.4
Cost per Respondent
$
46,021 $
35,073 $
33,328
DI Programs/EPA Headquarters
Burden (in hours)
5296.6
5184.9
5193.6
Respondents
11.0
11.0
11.0
Responses
31.7
29.2
30.6
Costs ($)
$
259,069 $
253,605 $
254,029
Labor ($)
$
259,069 $
253,605 $
254,029
Non-Labor Cost ($)
$
$
$
Burden per Response
166.8
177.4
169.6
Cost per Response
$
8,161 $
8,677 $
8,294
Burden per Respondent
481.5
471.4
472.1
Cost per Respondent
$
23,552 $
23,055 $
23,094
Note: Numbers may not appear to add due to rounding.

6(f)

Total

$
$
$
$
$

$
$
$
$
$

$
$
$
$
$

$
$
$
$
$

62,117.0
47.0
378.0
7,299,064
3,145,843
4,119,644
164.3
19,310
1,321.6
155,299
13,160.0
5.0
187.0
5,129,006
975,786
4,119,644
70.4
27,428
2632
1,025,801
33,281.8
31.0
99.4
1,403,354
1,403,354
1010.2
42,597
2,713.6
114,422
15675.2
11.0
91.6
766,703
766,703
171.1
8,370
1425.0
69,700

Annual Average

$
$
$
$
$

$
$
$
$
$

$
$
$
$
$

$
$
$
$
$

20,705.7
27.5
126.0
2,433,021
1,048,614
1,373,215
164.3
19,310
753.1
88,495
4,386.7
4.0
62.3
1,709,669
325,262
1,373,215
70.4
27,428
1096.7
427,417
11,093.9
12.5
33.1
467,785
467,785
336.7
14,199
904.5
38,141
5225.1
11.0
30.5
255,568
255,568
171.1
8,370
475.0
23,233

Burden Statement

EPA estimates that, for the 3 years covered by this request, the total annual burden on
CO2 GS well owners/operators and Primacy Agencies associated with Class VI requirements will
be 15,481 hours and the cost will be $2.2 million per year.

ICR for the Proposed GS Regulation

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July, 2008

The annual public reporting and recordkeeping burden for this collection of information
is estimated to average 162 hours per response, as shown in Exhibit 6-4. 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 the proposed GS
regulations under Docket ID No. EPA-HQ-OW-2008-0390, 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 at
http://www.regulations.gov. This site can be used to submit or view public comments, access the
index listing of the contents of the public docket, and to access those documents in the public
docket that are available electronically. Once in the system, select “search,” then key in the
docket ID number identified above. Also, you can send comments to the Office of Information
and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington,
DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (EPA-HQOW-2008-0390), and OMB control number (2040-NEW) in any correspondence.

ICR for the Proposed GS Regulation

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July, 2008

Appendix A: Detailed Explanation of the Derivation of Respondent Burden and Cost
Estimates

Respondents for this information collection include operators of Class VI wells and State
primacy agencies. This Appendix describes how EPA derived estimates of the respondent burden
and cost associated with CO2 GS Regulation paperwork requirements.
EPA derived the burden and cost estimates based largely on the Technology and Cost
(T&C) document and the 2007 UIC Programmatic ICR. Wherever possible, burden and cost
estimates in this ICR are based on the T&C document, (i.e., for all reporting items for which a
cost was developed in the T&C document). The T&C document is considered to be a reliable
source of burden and cost because it was developed specifically for the GS regulation and is
based on recent research to support the GS regulatory development effort. Other costs are based
on costs and burdens estimated for Class I non-hazardous and hazardous well operators in the
2007 UIC Program ICR. This is because EPA assumes that many of the activities performed by
CO2 GS well operators will be similar in nature to those performed by Class I non-hazardous
well operators. In some cases, estimates were “scaled up” to reflect the larger scope of a GS site,
e.g., larger AoRs for GS wells.
Table A-1 shows the steps EPA took to derive ICR burden and cost estimates from the
T&C document and the 2007 programmatic ICR.
An example of a burden and cost derivation based on T&C document estimates is below.
The example shows the steps which EPA took to estimate burden and cost associated with
§146.82(2) of the GS Regulation, which calls for the submission of maps showing the injection
well(s) for which the permit is sought and the applicable AoR, including: the number, or name
and location of all injection wells, producing wells, plugged wells or dry holes, deep
stratigraphic boreholes, surface bodies of water, springs, mines (surface and subsurface),
quarries, water wells, and other pertinent surface features in the AoR. It requires the submission
of cross sections of the AoR and geologic and topographic maps and cross sections illustrating
regional geology, hydrogeology, and the geologic structure. It also requires the submission of a
list of surface features including structure intended for human occupancy and roads. CFR
citations and descriptions of the regulation reporting requirements can be found in Columns A
and B of Table A-1.
•

To meet the requirements of §146.82(2) of the GS Regulation, EPA determined
that, at a minimum, operators would have to conduct remote aerial surveys of
land, land use, structures, etc. (T&C document, tracking number A-4, as shown in
Column C of table A-1), at a cost of $2,250 per site plus $300 per square mile.
For a large scale project injecting into a saline formation this activity totals
$8,250.

•

EPA assumes that 50% of the cost associated with aerial surveys is attributable to
customary business practices. Operators would conduct aerial survey in the
absence of this ICR in order to gain knowledge of the surface characteristics and

ICR for the Proposed GS Regulation

Page A-1

July, 2008

possible exit points for CO2 within the AoR. EPA estimates that 50% of the cost
incurred by aerial surveys, or $4,125, will be a direct result of this ICR.
[Customary business practice assumptions are discussed in more detail below.] In
Table A-1, a description of the EPA’s burden and cost manipulations can be
found in Column D and cost calculations can be found in Column F.
•

In addition to the $4,125 cost derived from the T&C document, EPA assumes that
the operator will have to invest 20 hours of technical labor to assemble the
information gained from the surveys into a format acceptable to EPA to fulfill the
information collection request. EPA’s calculation of the technical burden can be
found in Column E of Table A-1.

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July, 2008

Table A-1 Annual Operator Paperwork Burden and Cost Estimate Derivations
CFR Citation
A

Description of Requirement
B

Manipulations
D

Source
C

Technical Burden Calculations (Unless
otherwise noted) (1)
E

Non-labor Cost
Calculations (1)
F

Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications

§146.82(a)

Compile all geologic testing data and
prepare and submit permit application.

Technology & Cost
Document: Tracking
Number C-5 (Adjusted)

Non-labor cost estimate from the
Technology & Cost document, tracking
number C-5, was divided among the
labor categories using the distribution
from the 2007 ICR.

§146.82(a)(1)

Gather and submit description of activities
requiring a permit, facility name and
address, SIC codes, ownership and facility
status, facility location, listing of relevant
permits or construction approvals, relevant
maps and cross sections, construction
specifics, description of the business,
proposed injection, formation testing, and
stimulation programs.

2007 Nonhazardous ICR
estimate for 146.14(a)(1, 412) (estimate adjusted to
account for larger scale of
GS projects)

The technical burden estimate for
146.14(a)(1,4-12) from the 2007 UIC
Nonhazardous ICR was increased by
122%.

Prepare and submit map showing the
injection well(s) for which a permit is sought
and the applicable AoR , maps and cross
sections of AoR, and geologic and
§146.82(a)(2),
topographic maps and cross sections
Technology & Cost
§146.82(a)(4)(i) and illustrating regional geology, hydrogeology, Document: Tracking
§146.82(a)(4)(vi)
and the geologic structure.
Number A-4 (Adjusted)

Non-labor cost estimate from the
Technology & Cost document, tracking
number A-4, was multiplied by noncustomary business practices factor of
50%and the technical labor burden was
set at 20 hours.

-

9.0 hours*222%=20.0 hours $

-

+20.0 hours

$8,250*50%=$4,125

0.0 hours

$562,500*50%=$281,250

§146.82(a)(4)(ii)

Identify location, orientation, and properties
of known or suspected faults and fractures; Technology & Cost
determination whether they would not
Document: Tracking
interfere with containment.
Number A-2

§146.82(a)(4)(iii)

Obtain and analyze seismic (earthquake)
history.

Technology & Cost
Document: Tracking
Number A-3

Obtain data on the depth, areal extent,
thickness, mineralogy, porosity,
permeability and capillary pressure of the
injection zone and confining zone. Obtain
geomechanical information on fractures,
stress, ductility, rock strength, and in situ
fluid pressures within the confining zone.

Estimate from Technology and Cost
document, tracking number A-5, was
multiplied by a non-customary business
practices factor of 50%, then increased
by 2000% and summed with A-6, which
was also multiplied by a non-customary
business practices factor of 50% . The
non-labor cost estimate from
Technology & Cost
Technology and Cost document,
Document: Tracking
tracking number A-7, was multiplied by
Numbers A-5, A-6, and A-7 a non-customary business practices
(Adjusted)
factor of 50%.
24.0 hours*50%*2100% + 90*50%=297.0 hours

§146.82(a)(4)(iv)
and (a)(4)(v)

§146.82(a)(5)

§146.82(a)(6)

Technical labor burden estimates from
the Technology and Cost document,
tracking numbers A-11, A-12, and A-13,
were summed and multiplied by a 50%
Technology & Cost
non-customary business practices
Document: Tracking
factor. The non-labor cost estimater
Prepare and submit a map and tabulation of Numbers A-11, A-12, A-13, from the same document for tracking
all wells within the AoR.
and D-4
number D-4 was used.
Estimates from Technology and Cost
document, tracking numbers A-1 and ATechnology & Cost
8, summed and multiplied by a noncustomary business practices factor of
Prepare and submit maps/cross sections of Document: Tracking
Numbers A-1 and A-8
50%.
local and regional geology, USDWs.

§146.82(a)(7)

Submit baseline geochemical data on
subsurface formations and maps/cross
sections of subsurface aquifers.

§146.82(a)(8)

Submit proposed operating data (e.g.,
anticipated maximum pressure and flow
rate).

§146.82(a)(10)

§146.82(a)(11),
§146.82(a)(12) &
§146.82(a)(13)

Estimate from Technology and Cost
document, tracking number A-2, was
multiplied by non-customary business
practices factor of 50%.
Estimate from Technology and Cost
document, tracking number A-3, was
multiplied by non-customary business
practices factor of 50%.

Legal Burden: 25.0 hours
Managerial Burden: 66.0 hours
Technical Burden: 284.0 hours
Clerical Burden: 199.0 hours $

Technology & Cost
Document: Tracking
Numbers: A-9, A-10, B-1
2007 Nonhazardous ICR
estimate for 146.14(b)(3)
(estimate adjusted to
account for larger scale of
GS projects)

Estimates from the Technology and
Cost document, tracking numbers A-9,
A-10, and B-1, were multiplied by their
corresponding non-customary business
practices factors of 50%, 50% and
100%, respectively, then summed.
The technical burden estimate for
146.14(b)(3) from the 2007 UIC
Nonhazardous ICR was increased by
300%, the non-labor estimate was not
used.

The technical and managerial labor
burden estimates for 146.14(b)(6) from
the 2007 UIC Nonhazardous ICR were
Demonstrate compatibility of CO2 stream
combined under technical burden, the
with well materials and fluids and minerals 2007 Nonhazardous ICR
estimate for non-labor cost was also
in the injection and confining zones.
estimate for 146.14(b)(6)
used.
The entire non-labor cost estimate for
2007 Nonhazardous ICR
146.14(a)(8-10) from the 2007 UIC
estimate for 146.14(a)(8-10) Nonhazardous ICR was used, the
Develop formation testing and stimulation
(estimate adjusted to
technical labor burden for the same
programs and injection procedures and
account for larger scale of compliance activity was increased by
submit results of formation testing program. GS projects)
186%.

ICR for the Proposed GS Regulation

Page A-3

60.0 hours*50%=30.0 hours $

330.0 hours*50%=165.0 hours

84.0 hours*50%=42.0 hours $

-

$359,625*50%=$179,813

$8,313

-

180.0 hours*50%=90.0 hours ($5,000*50%) + $3,200=$5,700

2.0 hours*400%=8.0 hours $

-

2.0 hours + 6.0 hours= 8.0 hours

$6,400

7.0 hours*286%=20.0 hours

$5,433

July, 2008

Table A-1 Annual Operator Paperwork Burden and Cost Estimate Derivations
CFR Citation
A
§146.82(a)(14) &
§146.82(a)(15)

Description of Requirement
B
Prepare and submit descriptions of
construction procedures and schematics.

Source
C
2007 Nonhazardous ICR
estimate for
146.14(a)(7,11,15)

§146.82(a)(18) &
§146.82(a)(19)

Technology & Cost
Submit status of corrective action at wells in Document: Tracking
the AoR.
Number D-7 (adjusted)
2007 Nonhazardous ICR
estimate for 146.14(b)
(estimate adjusted to
account for larger scale of
Prepare and submit completion report.
GS projects)

§146.82(a)(18)

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

§146.82(a)(17)

§146.82(a)(19)

§146.82(a)(20) &
§146.82(a)(22)

§146.82(a)(21)

Manipulations
D
The unadjusted non-labor cost and
technical labor burden estimates for
146.14(a)(7,11,15) from the 2007 UIC
Nonhazardous ICR were used.
The non-labor cost estimate from the
Technology and Cost document,
tracking number D-7, was used, 50
hours were added as technical labor
burden.

Demonstrate mechanical integrity prior to
commencing injection.

The technical labor burden for 146.14(b)
from the 2007 UIC Nonhazardous ICR
was increased by 1233%.
The unadjusted non-labor cost for
146.14(b)(1) from the 2007 UIC
Nonhazardous ICR was used, the
technical and clerical labor burden
estimates were combined under
technical burden .
The unadjusted non-labor cost for
146.14(b)(2) from the 2007 UIC
Nonhazardous ICR was used, the
technical and managerial labor burden
estimates were combined under
technical burden.

Prepare and submit testing and monitoring
plan.

Estimates from Technology and Cost
document, tracking numbers H-1 and H2, were summed increased by 100%.
The entire non-labor cost estimate for
146.14(a)(13) from the 2007 UIC
Nonhazardous ICR was used, the
technical labor burden for the same
compliance activity was increased by
1,233%.

2007 Nonhazardous ICR
estimate for 146.14(b)(1)

Technology & Cost
Document: Tracking
Number F-1.
Technology & Cost
Prepare and submit well plugging plan, post- Document: Tracking
injection site care and site closure plan, and Numbers H-1 and H-2
demonstration of financial responsibility.
(Adjusted)

§146.82(a)(24)

Prepare and submit emergency and
remedial response plan.

§146.84(c)(1)

Prepare and submit information on the
calculated AoR.

Prepare and submit AoR and corrective
§146.84(c)(2)
action plan.
Requirements Associated with Periodic AoR Reevaluations

Prepare and submit amended AoR and
corrective action plan or demonstrate that
§146.84(b)(1)
no amendment to the plan is needed.
Testing and Monitoring Requirements

2007 Nonhazardous ICR
estimate for 146.14(a)(13)
(estimate adjusted to
account for larger scale of
GS projects)

The unadjusted technical labor burden
2007 Nonhazardous ICR
estimate for 146.14(a)(12) from the
estimate for 146.14(a)(12) 2007 UIC Nonhazardous ICR was used.
The technical labor burden estimate
2007 Hazardous ICR non- from the Technology and Cost
labor estimate for
document, tracking number B-18, was
146.70(b)(7), Technology & used, as well as the non-labor cost
Cost Document B-18
estimate for 146.70(b)(7) from the 2007
burden estimate
UIC Nonhazardous ICR.
Technology & Cost
Estimate from Technology and Cost
Document: Tracking
document, tracking number D-5, was
Number D-5
used.
The technical labor burden estimate
2007 Hazardous ICR non- from the Technology and Cost
labor estimate for
document, tracking number B-18, was
146.70(b)(7), Technology & used, as well as the non-labor cost
Cost Document B-18
estimate for 146.70(b)(7) from the 2007
burden estimate
UIC Hazardous ICR.

§146.90(a)

Analyze the CO2 stream.

Technology & Cost
Document: Tracking
Number E-2.

§146.90(b)

Demonstrate internal mechanical integrity
by monitoring injection pressure, flow rate
and volume, and annulus pressure.(3)

Technology & Cost
Document: Tracking
Number E-5 and E-6.

§146.90(c)

Conduct corrosion monitoring. (3)

EPA estimate.

§146.90(d)

Monitor ground water quality.

Technology & Cost
Document: Tracking
Number B-12.

§146.90(e)

Demonstrate external mechanical integrity Technology & Cost
using tracer survey, noise/temperature logs Document: Tracking
or other approved tests.
Number F-3 and F-5.

§146.90(e)

Technology & Cost
Document: Tracking
Conduct casing inspection log at workover. Number F-2.

§146.90(f)

Conduct pressure fall-off test. (3)

ICR for the Proposed GS Regulation

Technology & Cost
Document: Tracking
Number F-7

Half of labor (6*0.5=3 hrs quarterly = 12
hrs/yr) is for injectate analysis + lab
costs (assume 4 samples
@$200/sample quarterly = $3200
annually)
Non-labor cost estimates from the
Technology & Cost document, tracking
number E-5 and E-6, was multiplied by
non-customary business practices
factor of 1%.
EPA estimated 2.5 hours of technical
burden.

Non-labor cost estimates from the
Technology and Cost document,
tracking numbers F-3 and F-5, were
summed and multiplied by a noncustomary business practices factor of
50% and 8 hours were used as a
technical labor burden estimate.
The unadjusted non-labor cost and
technical labor burden estimates for
146.68(d)(4) from the 2007 UIC
Hazardous ICR were used.
Non-labor cost estimate from the
Technology & Cost document, tracking
number F-7, was multiplied by noncustomary business practices factor of
50%.

Page A-4

Technical Burden Calculations (Unless
otherwise noted) (1)
E

Non-labor Cost
Calculations (1)
F

8.0 hours

$4,527

+50 hours

$202,000

1.5 hours*1333%=20.0 hours $

-

6.0 hours +1.0 hour = 7.0 hours

$27,768

2.0 hours + 3.5 hours = 5.5 hours

$8,000

12.0 hours*200%=24.0 hours $

-

3.0 hours*1333%=40.0 hours $

3,562

10.0 hours $

324.0 hours

84.0 hours $

-

$2,415

-

324.0 hours

$2,415

12.0 hours

$3,200

0.0 hours
2.5 hours $

$4,020
-

96

$4,829

+8.0 hours

$41,000

2.0 hours

$18,000

0.0 hours

$8,000*50%=$4,000

July, 2008

Table A-1 Annual Operator Paperwork Burden and Cost Estimate Derivations
CFR Citation
A

§146.90(g)

Description of Requirement
B

Track CO2 plume and pressure front.

Conduct surface air and soil gas
§146.90(h)
monitoring, if directed.
Reporting Requirements

Source
C
Technology & Cost
Document: Tracking
Number B-18.

Non-labor cost estimate from the
Technology & Cost document, tracking
number B-17, was used and the
technical labor burden estimate was 8
hours.

Technology & Cost
Document: Tracking
Number B-15 (Adjusted)

The non-labor cost estimate from the
Technology and Cost document,
tracking number B-15, was multiplied by
25% to reflect only the cost of
monitoring.

Report semi-annually on: physical,
chemical, and other characteristics of
Technology & Cost
injected fluids; injection pressure, flow rate, Document: Tracking
§146.91(a)
and volume; and monitoring of USDWs.
Number B-20 (Adjusted)
2007 Nonhazardous ICR
estimate for 146.13(d)
(estimate adjusted to
Report on most recent MITs and other
account for larger scale of
§146.91(b)(1)
tests.
GS projects)
2007 Nonhazardous ICR
estimate for 146.13(c)(2)
Report results of: any required mechanical (estimate adjusted to
§146.91(b)(2) &
integrity tests, other required tests, and well account for larger scale of
§146.91(b)(3)
workovers.
GS projects)
Provide periodic adjustments/updates to
financial cost estimates for financial
§146.85(b)
responsibility.
EPA estimate.
Recordkeeping Requirements
Maintain monitoring information, calibration
and maintenance records, required reports,
application data, and monitoring results.
2007 Nonhazardous ICR
Maintain all required plans.
estimate for 144.51(j)(2)
Injection Well Plugging

§146.92(c)

2007 Hazardous ICR
Prepare and submit notice of intent to plug. estimate for 146.71(b)

§146.92(d)
Prepare and submit plugging report.
Post-Injection Site Care

§146.93(b)

§146.93(b)(3)

Manipulations
D

Technology & Cost
Document: Tracking
Number G-1 and G-2

Conduct post-injection monitoring and
report to director on results.

Technology & Cost
Document: Tracking
Number G-9, G-10, G-11.

Submit non-endangerment demonstration
that CO2 plume and pressure front have
stabilized.

Technology & Cost
Document: Tracking
Numbers B-17 and B-18
2007 Hazardous ICR
estimate for 146.70(b)(7)
(Adjusted)

Technical Burden Calculations (Unless
otherwise noted) (1)
E

The technical labor burden estimate
from Technology and Cost document,
tracking number B-20, was used and 2
hours of clerical burden were added.
The technical burden estimate for
146.13(d) from the 2007 UIC
Nonhazardous ICR was increased by
233%, and the clerical burden was
decrease by 50%.
The technical burden estimate for
146.13(c)(2) from the 2007 UIC
Nonhazardous ICR was increased by
500% and the clerical burden was
increased by 100%.
EPA estimated 4.0 hours of managerial
labor burden.

The clerical burden estimate for
144.51(j)(2) from the 2007 UIC
Nonhazardous ICR was used.
The unadjusted managerial and clerical
labor burden estimates for 146.71(b)
from the 2007 UIC Hazardous ICR were
used.
The non-labor cost estimates from the
Technology and Cost document,
tracking numbers G-1 and G-2, were
summed and multiplied by a noncustomary business practices factor of
1%. The technical labor burden was
estimated to be 40.0 hours.
The technical labor estimate from
Technology and Cost document,
tracking number G-11 was used.
The technical labor burden estimate
from the Technology and Cost
document, tracking number B-18, 8
hours of technical labor burden were
added for plume and pressure front
tracking. The non-labor cost estimate
was the sum of the non-labor cost
estimate for 146.70(b)(7) from the 2007
UIC Hazardous ICR and the estimate
from the Technology & Cost document,
tracking number B-17.
EPA estimated 40.0 hours of technical
labor burden.

§146.93(e)
Submit site closure report.
EPA estimate.
Notes:
(1) Burden and cost associated with customary business practices have already been removed in estimates from the 2007 Programmatic ICR.
(2) Numbers may not appear to add due to rounding.
(3) Non-labor cost is total for 4 injection wells.
(4) All non-labor cost is operating and maintenance (O&M) cost or contractor cost.

ICR for the Proposed GS Regulation

Page A-5

Non-labor Cost
Calculations (1)
F

276.0 hours

$0

0.0 hours

$7,500*25%=$1,875

Technical Burden:
12.0 hours per report * 2 = 24.0 hours/yr.
Technical burden: 22 hours
Clerical Burden: 2.0 hours $
Technical Burden:
6.0 hours*333%=20.0 hours
Clerical Burden:
4.0 hours*50%=2.0 hours $
Technical Burden:
2.0 hours*600%=12.0 hours

-

-

Clerical Burden:
1.0 hour*200%=2.0 hours $

-

Managerial Burden: +4.0 hours $

-

Clerical burden: 4.0 hours $

-

Managerial Burden: 0.5 hours
Clerical Burden: 1.0 hours $

-

+40.0 hours

($5,400+$96,000)*1%=$1,014

40.0 hours $

-

276.0 hours + 8.0 hours = 284.0 hours $2,415 + $187,500 = $189,915
+40.0 hours $

-

July, 2008

In the T&C document, EPA produced burden and cost estimates for injection in 3 types
of geologic formations, including: saline formations, depleted gas fields, and depleted oil fields.
Formation type affects the injection interval, the pore space, the reservoir storage capacity, the
area of the site as well as other site characteristics which ultimately affects the cost of injection
and monitoring. EPA also produced more refined estimates for each geologic formation based
on the size of the injection project, either pilot scale or large scale; pilot scale projects are
assumed to have one injection well, whereas large scale projects would have four wells.
EPA estimates that five GS projects will be deployed over the three years covered by this
ICR. Of these, EPA estimates that four will be pilot projects injecting into saline formations with
one injection well per site, the other will be a large scale project also injecting into saline
formations with four injection wells. EPA used burden and cost estimates for a large scale
project injecting into saline formations from the T&C document to generate the conservative
estimates for this ICR. EPA predicts that saline formations have the largest capacity for CO2 and
that following the initial pilot projects more large scale projects will be launched.
Class VI operators will rely on contractors to assist them with most information
collection activities, including initial/start-up activities (e.g., permit applications and preoperational reports); testing and monitoring (e.g., ground water monitoring, pressure fall-off
tests, and MITs); well plugging and post-injection reporting; and other paperwork activities. The
operator burdens presented in Column A of Exhibit 6-1 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, unit non-labor cost.
EPA assumes that some activities required of Class VI permit applicants are customary
business practices. That is, they are necessary in order to site the well to allow a profitable
business venture or to maintain their injection wells—which represent a substantial investment—
in working order. 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 EPAapproved tests. These estimates are based on consultations with operators and permit writers
involved with Class I non-hazardous wells, as part of the UIC Program ICR development effort.
•

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.

•

Facility engineers would normally prepare construction schematics and operating
data during the planning and design of an injection facility; EPA estimates that 75

ICR for the Proposed GS Regulation

Page A-6

July, 2008

percent of the burden associated with compiling this data 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 injectate 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.

ICR for the Proposed GS Regulation

Page A-7

July, 2008