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pdfAppendix A: Detailed Explanation of Respondent Burden Estimates and Respondent Universe
Respondents for this information collection include operators of Class I – VI wells and state primacy
agencies. The first part of this Appendix contains EPA’s estimates of respondent burden associated with UIC
paperwork requirements. The second part of this Appendix provides EPA’s assumptions about the number of
respondents subject to each information collection activity.
A.1 Estimating Respondent Burden
EPA has calculated respondent burden hours for each information collection, reporting, and
recordkeeping activity required of well operators and state primacy agencies. Because required data items vary
by well class, separate operator and state burden estimates have been prepared for each class. Tables A-1
through A-7 contain detailed estimates of the number of respondents and unit burden hours for required
paperwork-related activities.
EPA recognizes that many UIC information collection activities are performed by contractors. The
operator unit burdens reported in this appendix represent a composite of the operator time needed to both
perform an information collection activity and to supervise a contractor when the contractor performs the
activity. The mix of operator versus contractor labor varies by activity and by well class. Contractor costs are
included in the estimates of operator unit costs.
Burden Associated with Class I Wells
EPA’s estimate of the annual paperwork burden on operators for permitting, monitoring and testing,
reporting and recordkeeping, and closing their facilities and state burden for administering Class I hazardous
and Class I nonhazardous programs are presented in Tables A-1A and Table A-1B, respectively. Legal,
managerial, technical, and clerical staff hours are shown; Column A presents the total unit burden for each
activity.
Class I facility operators rely on contractors to assist them with most information collection activities,
including initial/start-up activities (e.g., permit applications, completion reports, and no-migration petitions);
monitoring and testing (e.g., ambient monitoring, pressure fall-off tests, and MITs); closure-related reporting;
and other paperwork activities (e.g., permit and no-migration petition modifications). The operator burdens
presented in Column A of Tables A-1A and A-1B largely reflect the time it takes to oversee and furnish
information to contractors. The costs associated with contractor labor and other contractor services are
presented in Column C of Tables A-1A and A-1B.
EPA estimates that 70 percent of the new Class I permits issued will be for newly constructed wells at
existing facilities, and that much of the information these applicants are required to submit is likely to have been
developed in connection with permitting other wells and, therefore, already exists for the facility. EPA assumes
the remaining 30 percent of permits will be issued for wells at new facilities, and the burden associated with
applying for a permit will be greater. Thus, the unit burdens presented in this ICR are a composite of the
burdens for permitting new wells at both new and existing facilities.
Underground Injection Control Program – Information Collection Request
Page A-1
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications
Read permit application directions.
One-time
Gather and submit description of activities
One-time
requiring a permit, facility name and address,
SIC codes, ownership and facility status,
facility location, listing of relevant permits or
construction approvals, description of the
business.
In DI programs, gather and submit a list of
landowners within one-quarter mile of the
facility boundary.
One-time
Prepare and submit a map and tabulation of
all wells within the AoR.
Prepare and submit AoR protocol.
One-time
Legal
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year
Total Cost/Year
0.0
0.25
0.25
0.0
0.5
$33
$0
8
4
$266
3.0
2.0
9.0
6.0
20.0
$1,051
$0
8
160
$8,408
4.0
0.0
0.0
1.2
5.2
$399
$0
3
13
$1,016
0.0
1.5
5.5
0.0
7.0
$394
$23,082
8
56
$187,810
0.0
0.0
1.3
0.0
1.3
$63
$894
8
10
$7,661
0.0
1.5
16.0
0.0
17.5
$906
$47,922
8
140
$390,623
0.0
2.0
5.0
1.0
8.0
$440
$6,879
8
64
$58,553
0.0
3.0
10.0
2.0
15.0
$797
$268
8
120
$8,514
0.0
3.0
0.0
0.0
3.0
$248
$4,509
8
24
$38,061
0.0
2.0
3.0
2.3
7.3
$380
$11,426
8
58
$94,449
0.0
2.0
8.0
5.0
15.0
$700
$5,732
8
120
$51,460
0.0
1.0
3.0
2.6
6.6
$304
$1,689
8
53
$15,947
0.0
1.4
2.0
1.4
4.8
$254
$2,079
8
38
$18,663
0.0
2.5
17.0
0.5
20.0
$1,053
$2,079
1.4
27
$4,260
One-time
Prepare and submit maps/cross sections of
local and regional geology, USDWs.
Develop formation testing and stimulation
programs and injection procedures.
Prepare and submit contingency plans for
shut-ins or well failures.
Prepare and submit ambient monitoring plan.
One-time
One-time
Prepare and submit Corrective Action Plan.
One-time
Prepare and submit descriptions of logs and
tests, construction schematics & operating
data.
Prepare and submit closure plan, including
demonstration of financial responsibility.
One-time
Prepare and submit post-closure care plan.
One-time
One-time
One-time
One-time
Prepare and submit information to support an One-time
aquifer exemption request.
Underground Injection Control Program -- Information Collection Request
Page A-2
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Requirements for active hazardous waste facilities
Gather and submit dates of well operation
One-time
and specific waste information.
Gather and submit hazardous waste release
information.
Develop waste analysis plan.
Legal
Clerical
Unit
Burden
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year
Total Cost/Year
0.0
0.0
26.6
11.4
38.0
$1,620
$8,713
8
304
$82,667
0.0
1.9
30.4
22.8
55.1
$2,289
$4,357
0
0
$0
0.0
1.9
15.2
1.9
19.0
$955
$2,904
8
152
$30,873
0.0
0.0
0.5
0.5
1.0
$39
$0
8
8
$309
0.0
0.0
1.5
2.5
4.0
$144
$0
8
32
$1,153
0.0
0.0
6.0
1.0
7.0
$321
$35,158
8
56
$283,829
0.0
2.0
18.0
0.0
20.0
$1,046
$22,929
8
160
$191,798
0.0
0.0
2.0
0.0
2.0
$97
$153
8
16
$2,003
0.0
0.0
1.0
0.0
4.0
1.0
0.0
0.0
5.0
1.0
$279
$49
$38,215
$153
8
8
40
8
$307,953
$1,613
0.0
2.0
6.0
0.0
8.0
$461
$7,643
8
64
$64,830
2.0
0.0
2.0
$97
$3,057
8
16
$25,238
120.0
30.0
174.0
$8,721
$802,515
8
1,392
$6,489,891
41.5
21.0
71.5
$3,377
$11,312
12
858
$176,261
One-time
One-time
0.0
0.0
No-migration petition requirements
Gather and submit waste information and
One-time
present modeling data to demonstrate that
wastes will not migrate from injection zone.
0.0
24.0
Requirements associated with permit renewals/modifications and petition modifications
Submit updated components of permit
Occasional
application attachments.
0.0
9.0
Prepare and submit request for Permit
One-time
Modification.
Prepare and submit Petition Modification.
Technical
F
One-time
Prepare and submit schedule of construction One-time
logs and tests.
Requirements associated with completion reports
Prepare and submit completion report.
One-time
Submit results of deviation checks, other logs One-time
and tests; sample formation fluids; test
injection and confining zones.
Demonstrate mechanical integrity (i.e., casing One-time
pressure test, radioactive tracer survey of
bottom-hole cement, and noise/temperature
logs to check for movement along the
borehole).
Submit information on the anticipated
One-time
maximum pressure and flow rate.
Submit results of the injection zone and
One-time
confining zone testing programs.
Submit actual injection procedure.
One-time
Demonstrate hydrogeologic compatibility/
One-time
compatability of well materials.
Prepare and submit information on the
calculated AoR.
Managerial
E
Total Hours and Costs
0.0
2.0
6.0
2.0
10.0
$518
$6,573
5
50
$35,453
0.0
24.0
120.0
30.0
174.0
$8,721
$759,679
6
1,044
$4,610,403
One-time
Underground Injection Control Program -- Information Collection Request
Page A-3
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Monitoring/Testing Requirements (Per Facility)
Use continuous recording devices to monitor Continuous
injection pressure, flow rate, volume, and
temperature.
Conduct chemical monitoring of injected
As specified in
wastes as prescribed in waste analysis plan. WAP
Conduct additional chemical monitoring as
specified by the Director.
Legal
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year
Total Cost/Year
0.0
0.0
5.7
0.0
5.7
$278
$0
74
420
$20,474
0.0
0.0
38.0
0.0
38.0
$1,852
$4,586
295
11,200
$1,897,589
0.0
0.0
7.6
0.0
7.6
$370
$917
29
224
$37,952
0.0
3.8
5.2
0.0
9.0
$573
$6,331
59
531
$406,969
0.0
1.0
7.0
0.0
8.0
$425
$43,565
15
118
$648,281
0.0
3.8
8.0
0.0
11.8
$710
$7,597
4
43
$30,603
0.0
6.0
18.0
0.0
24.0
$1,382
$17,726
74
1,768
$1,407,975
0.0
0.4
1.9
0.0
2.3
$125
$6,114
74
168
$459,716
0.0
4.0
15.0
6.0
25.0
$1,627
$0
295
7,368
$479,572
0.0
1.0
2.0
1.0
4.0
$260
$1,376
74
295
$120,492
0.0
1.0
2.0
3.0
6.0
$260
$0
1
4
$191
0.0
1.0
0.0
0.0
1.0
$91
$0
74
74
$6,720
0.0
1.0
1.0
1.0
3.0
$161
$0
4
11
$594
Varies
Conduct casing pressure test and radioactive Annual
tracer survey of bottom-hole cement.
Conduct casing pressure test, radioactive
tracer of bottom-hole cement, and
noise/temperature logs to check for
movement along the borehole.
Conduct casing inspection log at workover.
Occasional
Conduct pressure fall-off test.
Annual
Conduct ambient monitoring.
Annual
Every 5 years
Reporting Requirements (Per Facility)
Prepare and submit report on maximum
Quarterly
injection pressure, total injectate volume, and
monitoring and testing results.
Prepare and submit report on mechanical
Annual
integrity testing.
Notify Director within 24 hours of: planned
Occasional
physical changes to facility, changes that may
result in noncompliance, compliance or
noncompliance with a compliance schedule,
any indication of possible endangerment of a
USDW, or all other noncompliance.
Prepare and submit revised plugging and
Annual
abandonment cost estimate.
Occasional
Prepare and submit report on: events
exceeding operating parameters or triggering
alarms; changes in annular fluid volume;
workovers or other testing.
Underground Injection Control Program -- Information Collection Request
Page A-4
Table A-1A
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Recordkeeping Requirements (Per Facility)
Maintain monitoring information, calibration
3 years
and maintenance records, required reports,
application data, monitoring results, and most
recent plugging and abandonment cost
estimate.
Closure Requirements (Per Well)
Prepare and submit notice of intent to close. One-time
Prepare and submit closure report.
Conduct pressure fall-off test prior to well
closure.
Legal
One-time
One-time
Demonstrate mechanical integrity (i.e., casing One-time
pressure test, radioactive tracer of bottomhole cement, and noise/temperature logs to
check for movement along the borehole) prior
to closure.
Notify state or local zoning or drilling
One-time
authorities and Regional Administrator
following closure.
TOTAL
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor
Unit NonNo. of
Total
Cost
labor Cost (B) Responses Hours/Year
Total Cost/Year
0.0
0.0
0.0
5.0
5.0
$142
$0
74
368
$10,461
0.0
0.0
0.5
2.0
0.0
8.0
1.0
0.0
1.5
10.0
$70
$558
$0
$3,057
1
1
2
10
$70
$3,615
0.0
1.0
5.0
0.0
6.0
$328
$17,726
1
6
$18,054
0.0
2.0
18.0
0.0
20.0
$1,046
$28,615
1
20
$29,660
0.0
0.5
1.0
3.0
4.5
$176
$0
1
1,375
5
27,723
$
$176
18,769,130
Notes:
(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.
(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.
EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-5
Table A-1A (continued)
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Initial/Start-up
Permit Applications
Consider the permit application, AoR, relevant maps and
cross sections, fluid injection rate and volume, proposed
contingency plans, monitoring plans, and construction
procedures as required at 146.70 and prepare draft permit.
Frequency (A)
Unit Burden
(B)
Unit Labor
Cost
Unit Nonlabor
Cost
E
F
Total Hours and Costs
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
One-time
Provide public notice of issuance of a draft permit or intent to
deny.
One-time
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review notice of completion of construction.
One-time
Review information related to aquifer exemption requests and One-time
forward to EPA region.
No-Migration Petitions
Review and respond to petition request.
One-time
Public notice/public comment.
One-time
Review and respond to petition modification request.
One-time
Permit renewals/modifications
Review and respond to requests for permit modifications or re- Occasional
issuance.
Underground Injection Control Program -- Information Collection Request
40.0
$1,657
$0
5
218
$9,036
1.0
$41
$0
5
5
$226
6.0
$249
$0
5
33
$1,355
2.0
$83
$0
5
11
$452
7.0
$290
$0
5
38
$1,581
2.0
$83
$0
5
11
$452
1.0
$41
$0
1
1
$38
18.0
$746
$0
5
98
$4,066
10.0
$414
$0
5
55
$2,259
10.0
$414
$0
4
41
$1,694
30.0
$1,243
$0
8
245
$10,165
Page A-6
Table A-1A (continued)
Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Monitoring/Testing
Review quarterly monitoring and testing results.
Review casing pressure test and radioactive tracer survey of
bottom-hole cement.
Review casing pressure test, radioactive tracer survey of
bottom-hole cement, and logs.
Review pressure fall-off test.
Other Reporting
Respond to periodic notifications by owners and operators.
Closure
Review closure and post-closure plans prior to approving
plugging and abandonment.
Witness and review pressure fall-off test prior to authorizing
closure.
TOTAL
Frequency (A)
Quarterly
Annual
Unit Burden
(B)
Unit Labor
Cost
Unit Nonlabor
Cost
E
F
Total Hours and Costs
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
1.5
$62
$0
201
301
$12,484
4.0
$166
$0
40
161
$6,658
Annual
4.0
2.0
$166
$83
$0
$0
10
39
40
77
$1,664
$3,204
Occasional
2.0
$83
$0
4
8
$339
2.0
$83
$0
1
2
$83
24.0
$994
$0
1
398
24
1,371
$994
$56,793
Every 5 years
One-time
One-time
Notes:
(A) For quarterly activities, the number of responses = number of facilities X 4.
(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.
Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-7
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications
Read permit application directions.
One-time
One-time
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
In DI programs, gather and submit a list of
One-time
landowners within one-quarter mile of the
facility boundary.
Prepare and submit a map and tabulation of One-time
all wells within the AoR.
Prepare and submit maps/cross sections of One-time
local and regional geology, USDWs.
Prepare and submit descriptions of logs and One-time
tests, construction schematics and operating
data.
Develop formation testing and stimulation
One-time
programs and injection procedures.
Prepare and submit contingency plans for
One-time
shut-ins or well failures.
Prepare and submit ambient monitoring plan. One-time
Prepare and submit Corrective Action Plan.
Legal
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor Unit Non-Labor
Cost
Cost (B)
No. of
Total
Responses Hours/Year Total Cost/Year
Managerial
Technical
0.0
0.25
0.25
0.0
0.5
$33
$0
14
7
$465
3.0
2.0
9.0
6.0
20.0
$1,051
$0
14
280
$14,714
4.0
0.0
0.0
1.2
5.2
$399
$0
4
23
$1,778
0.0
1.5
5.5
0.0
7.0
$394
$18,465
14
98
$264,038
0.0
1.5
16.0
0.0
17.5
$906
$47,922
14
245
$683,589
0.0
2.0
8.0
2.5
12.5
$629
$5,732
14
175
$89,061
0.0
2.0
7.0
1.0
10.0
$538
$6,879
14
140
$103,833
0.0
3.0
10.0
2.0
15.0
$797
$268
14
210
$14,899
0.0
3.0
3.0
3.0
9.0
$484
$4,509
14
126
$69,906
0.0
2.0
3.0
2.3
7.3
$380
$8,789
14
102
$128,370
0.0
1.0
3.0
2.6
6.6
$304
$1,689
14
92
$27,907
0.0
2.5
17.0
0.5
20.0
$0
$0
2.4
48
$0
0.0
0.0
1.5
2.5
4.0
$144
$0
14
56
$2,018
0.0
0.0
6.0
1.0
7.0
$321
$35,158
14
98
$496,702
0.0
2.0
3.5
0.0
5.5
$339
$9,936
14
77
$143,848
One-time
Prepare and submit closure plan, including
One-time
demonstration of financial responsibility.
Prepare and submit information to support an One-time
aquifer exemption request.
Requirements associated with completion reports
Prepare and submit completion report.
One-time
Prepare and submit a report of deviation
One-time
checks and other logs and tests during
Demonstrate mechanical integrity (i.e., casing One-time
pressure test and noise/temperature logs to
Underground Injection Control Program -- Information Collection Request
Page A-8
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Submit information on the anticipated
maximum pressure and flow rate.
Submit results of the formation testing
program.
Submit actual injection procedure.
Frequency (A)
One-time
Clerical
F
Unit
Burden
Unit Labor Unit Non-Labor
Cost
Cost (B)
No. of
Total
Responses Hours/Year Total Cost/Year
Managerial
Technical
0.0
0.0
2.0
0.0
2.0
$97
$153
14
28
$3,505
0.0
1.0
4.0
0.0
5.0
$279
$38,215
14
70
$538,918
0.0
0.0
1.0
0.0
1.0
$49
$153
14
14
$2,823
0.0
2.0
6.0
0.0
8.0
$461
$7,643
14
112
$113,453
0.0
8.0
11.0
2.0
21.0
$1,266
$5,350
20
420
$132,327
0.0
2.0
6.0
0.0
8.0
$461
$3,822
9
72
$38,541
0.0
0.0
38.0
0.0
38.0
$1,852
$3,057
1,484
56,400
$7,286,951
0.0
0.0
5.7
0.0
5.7
$278
$0
371
2,115
$103,103
0.0
1.0
8.0
0.0
9.0
$474
$18,878
74
668
$1,436,148
0.0
8.0
16.0
0.0
24.0
$1,453
$17,726
371
8,905
$7,116,437
0.0
0.4
1.5
0.0
1.9
$106
$6,114
371
705
$2,308,124
0.0
0.0
4.0
12.0
16.0
$536
$0
1,484
23,747
$795,137
0.0
2.0
6.0
4.0
12.0
$574
$1,266
371
4,453
$682,759
One-time
One-time
Demonstrate hydrogeologic compatibility/
One-time
compatibility of well materials.
Requirements associated with permit renewals/modifications
Submit updated components of permit
Occasional
application attachments.
Prepare and submit request for permit
modification.
Legal
E
Total Hours and Costs
Occasional
Monitoring/Testing Requirements (Per Facility)
Analyze injected fluids.
Per permit
Monitor injection pressure, flow rate and
volume, and annulus pressure.
Continuous
Demonstrate mechanical integrity (i.e., casing Every 5 years
pressure test and noise/temperature logs to
check for movement along the borehole).
Conduct pressure fall-off test.
Annual
Conduct ambient monitoring.
Annual
Reporting Requirements (Per Facility)
Report on: physical, chemical, and other
characteristics of injected fluids; injection
pressure, flow rate, and volume; and
monitoring of USDWs.
Report results of ambient monitoring and
pressure fall-off test.
Quarterly
Annual
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Page A-9
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency (A)
Occasional
Notify Director within 24 hours of: planned
physical changes to facility, changes that may
result in noncompliance, compliance or
noncompliance with a compliance schedule,
any indication of possible endangerment of a
Submit periodic updates of financial
Occasional
responsibility for closure that account for
inflation.
Report results of: any required mechanical
integrity tests, other required tests, and well
workovers.
Legal
Clerical
E
F
Total Hours and Costs
Unit
Burden
Unit Labor Unit Non-Labor
Cost
Cost (B)
No. of
Total
Responses Hours/Year Total Cost/Year
Managerial
Technical
0.0
1.0
2.0
3.0
6.0
$267
$0
19
111
$4,951
0.0
1.0
0.0
0.0
1.0
$84
$0
124
124
$10,409
0.0
1.0
2.0
1.0
4.0
$210
$1,376
4
15
$5,884
0.0
0.0
0.0
4.0
4.0
$114
$0
371
1,484
$42,144
0.0
0.5
0.0
1.0
1.5
$70
$0
1
5,319
2
101,222
Occasional
Recordkeeping Requirements (Per Facility)
Maintain monitoring information, calibration
At least 3 years
and maintenance records, required reports,
application data, and monitoring results.
Closure Requirements (Per Well)
Notify the Director before conversion or
abandonment of the well or, in the case of
area permits, before closure of the project.
One-time
TOTAL
$
$70
22,662,812
Notes:
(A) EPA assumes that occasional notification will be included in the next quarterly report except where required within 24 hours.
(B) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.
EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for monitoring, testing and reporting.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-10
Table A-1B (continued)
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Initial/Start-up
Permit applications
Consider the permit application, AoR,
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
construction procedures as required at
146.14 and issue notice of intent to deny.
Frequency (A)
Unit Burden
(B)
Unit Labor
Cost
Unit NonLabor Cost
E
Total Hours and Cost
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
One-time
Consider the permit application, AoR,
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
construction procedures as required at
146.14 and prepare draft permit.
One-time
Provide public notice of issuance of a draft
permit or intent to deny.
One-time
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review notice of completion of construction.
One-time
Review information related to aquifer
exemption requests and forward to EPA
region.
Permit renewals/modifications
Review and respond to requests for permit
modifications or re-issuance.
One-time
20.0
$828
$0
1
19
$791
40.0
$1,657
$0
9
344
$14,231
1.0
$41
$0
10
10
$395
6.0
$249
$0
10
57
$2,372
2.0
$83
$0
10
19
$791
7.0
$290
$0
10
67
$2,767
2.0
$83
$0
10
19
$791
1.0
$41
$0
2
2
$67
30.0
$1,243
$0
14
409
$16,942
Occasional
Underground Injection Control Program -- Information Collection Request
Page A-11
Table A-1B (continued)
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Monitoring/Testing
Review casing pressure test and logs.
Review pressure fall-off test.
Review monitoring data submitted by
operators.
Other Reporting
Respond to periodic notifications by owners
and operators.
Closure
Review plugging and abandonment report.
Frequency (A)
Every 5 years
Annual
Quarterly
Unit Burden
(B)
Unit Labor
Cost
Unit NonLabor Cost
E
Total Hours and Cost
Number of
State
Total State
Responses
Hours/Year
Total State
Cost/Year
4.0
2.0
$166
$83
$0
$0
51
253
202
506
$8,382
$20,955
2.0
$83
$0
1,012
2,023
$83,819
1.0
$41
$0
7
7
$282
1.0
$41
$0
1
1,396
1
3,685
$41
$152,627
Occasional
One-time
TOTAL
Notes:
(A) For quarterly activities, the number of responses = number of facilities X 4.
(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.
Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
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EPA assumes that some activities required of Class I permit applicants are customary business practices.
The burden presented in this ICR is the incremental time and cost of presenting the information in a format
acceptable to permitting authorities and for using EPA-approved tests.
Knowledge of subsurface geology is necessary to site a well and locate a subsurface zone suitable for
injection. EPA assumes that 50 percent of the geological characterization required of permit applicants
is customary business practice. Most of the incremental ICR burden is attributable to the requirement to
submit detailed maps of local geology.
Operators would customarily develop and conduct formation testing and stimulation programs for the
same reasons they would develop geological data. EPA estimates that 50 percent of the required
program development and testing is customary business practice.
Operators would probably develop and retain contingency plans to reduce potential liability should a
well failure occur and develop closure plans to reduce potential liability when they close their facilities.
EPA assumes that 25 percent of the burden of developing these plans is customary business practice.
Facility engineers would normally prepare construction schematics and operating data during the
planning and design of an injection facility; EPA estimates that 75 percent of the burden associated with
compiling this data is customary business practice.
As part of their overall industrial process, operators would normally develop injectate composition data
and test the compatibility of the waste stream with well materials. EPA assumes that 50 percent of the
time and cost of developing a waste analysis plan and conducting waste compatibility testing is
customary business practice.
During construction, operators would probably conduct deviation checks and other logs to verify that
drilling is progressing within expected parameters. EPA estimates that 50 percent of the requirement to
conduct deviation checks and other logs and tests is customary business practice.
Operators would routinely observe injection pressure, flow rate, volume, and temperature, and analyze
the chemical composition of their wastes to verify the proper operation of their wells; EPA assumes that
nearly all the burden for continuous monitoring and 75 percent of the burden of performing chemical
analyses of injectate is customary business practice.
EPA estimates that owners or operators of Class I wells that apply for an aquifer exemption will submit
geologic and water use-related information to demonstrate that the criteria at 40 CFR 144.7 and 40 CFR 146.4
are met. EPA estimates that much of this information will be gathered as part of the Class I permit application
process, and that applying for an aquifer exemption will require an additional 20 hours for each applicant.
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Page A-13
Class I Hazardous Facilities
Operator activities associated with Class I hazardous facilities include: permitting and start-up-related
reporting; permit renewals and modifications of permits or petitions; monitoring; reporting and recordkeeping;
and closure-related paperwork.
Initial Permitting/Start-up
EPA estimates that, of the new Class I hazardous waste facility operating permits that are issued each
year, most will be for new wells at existing facilities. Thus, in some cases, operators will adapt existing
materials for their permit applications. Note that for permitting activities, the unit burdens are expressed on a
per-application basis.
EPA estimates that the operator burden associated with applying for Class I hazardous waste injection
permits will be 224 hours per permit. (This unit burden incorporates the above assumptions about customary
business practices.) Table A-1A contains burden estimates for specific components of the permit application.
EPA’s calculation of operator burden and contractor labor costs above customary business practices is based on
the following assumptions:
Operators, rather than contractors, will gather the facility description and location information necessary
to complete the permit application form;
Area of review (AoR) studies in support of the application will encompass portions of previous AoR
studies at the facility;
The burden for developing a corrective action plan is based on the assumption that 10 percent of
operators will be required by the permitting authority to revise their corrective action plans; and
The requirement that operators of active hazardous waste facilities gather and submit site investigation
information [40 CFR 144.31(g)(3)] duplicates Resource Conservation and Recovery Act (RCRA)
requirements and is not included in this burden estimate. Other activities that operators of active
hazardous waste facilities must perform (e.g., developing a waste analysis plan) are included in this
estimate.
EPA estimates that the burden on Class I hazardous facility operators associated with preparing and
submitting completion reports will be 49 hours per facility. The burden to perform specific activities related to
completion reports is presented in Table A-1A. As with permitting activities, EPA anticipates that much of the
testing reported in the completion report would normally be performed in the course of business.
In addition to submitting permit applications, operators of newly constructed hazardous Class I wells
will submit no-migration petitions to the EPA Regional Administrator. EPA assumes that no-migration petition
requirements impose an additional 174 burden hours on each operator. EPA anticipates that operators already
have compiled much of the extensive data required to support a no-migration petition in the process of
permitting and preparing petitions for existing wells at their facilities, during the permit application process, or
as a customary business practice.
Permit Renewals and Modifications
Class I operating permits are valid for up to ten years, after which operators must apply to renew their
permits. Additionally, from time to time, operators of Class I hazardous facilities may need to modify their
Underground Injection Control Program – Information Collection Request
Page A-14
permits or their no-migration petitions. Paperwork submittals include: permit renewals, permit modifications,
and petition modifications.
EPA anticipates that the burden associated with renewing permits for a Class I hazardous facility will be
71.5 hours per renewal. Requirements for permit renewals vary among states and regions, ranging from
submitting a letter of intent to continue operating the facility to submitting an application that is similar in scope
to one for a new permit. EPA assumes that, for renewal applications, Class I hazardous facility operators will
be required to submit facility identification information and those attachments that have changed or been
updated since their last application, such as the AoR, corrective action plan, closure plan, waste identification
information, and financial responsibility information. EPA assumes that Class I hazardous facility operators
will not be required to submit no-migration petitions in support of permit renewal applications.
EPA estimates the operator burden for overseeing contractor activities associated with preparing and
submitting a request for a permit modification is 10 hours per facility, and the burden associated with modifying
a no-migration petition is 174 hours.
Monitoring/Testing
As indicated above, EPA assumes that operators of Class I hazardous facilities would routinely observe
injection pressure, flow rate, volume, and temperature in the normal course of business. EPA estimates an
incremental annual burden of 5.7 hours per facility beyond customary business practice to meet UIC reporting
requirements.
Class I hazardous facility operators must also monitor the chemical composition of their wastes
according to the waste analysis plans submitted with their permit applications. As with monitoring of injection
pressure, flow rate, and volume, EPA assumes that operators would perform some chemical monitoring during
the course of business. EPA estimates the additional annual burden for chemical monitoring is 38 hours per
facility per quarter for operators to collect samples and send them to commercial laboratories for analysis. In
addition, EPA assumes that, for various reasons, permitting authorities will require 10 percent of facilities to
conduct additional monitoring under 40 CFR 146.68(a)(3), and that the total burden will be 7.6 hours per
facility per quarter. EPA assumes that all monitoring will be conducted quarterly.
The burden associated with conducting annual MITs (i.e., conducting a casing pressure test and
radioactive tracer survey) is estimated to be 9 hours per facility, and the burden associated with conducting fiveyear MITs, which also include temperature, noise, or other logs to check for movement along the borehole, is
estimated to be 8 hours per facility.
Operators must conduct casing inspection logs when their wells are worked over. EPA estimates the
total annual burden will be 11.8 hours per log.
Class I hazardous facility operators must conduct a pressure fall-off test every year; EPA estimates that
the annual burden associated with this requirement will be 24 hours per facility. EPA estimates that the total
burden associated with required annual ambient monitoring at Class I hazardous facilities will be 2.3 hours per
facility.
Underground Injection Control Program – Information Collection Request
Page A-15
Reporting and Recordkeeping
Operators of each Class I hazardous facility will spend 104 hours per facility reporting the results of
required monitoring and testing each year: this includes 25 hours per report (100 hours annually) for quarterly
monitoring reports, and 4 hours to report on the results of MITs. In addition, EPA assumes that 5 percent of
operators will spend 3 to 6 hours annually submitting various occasional reports (e.g., on changes to the facility;
planned workovers; noncompliance or anticipated noncompliance; or events triggering alarms or shutdown
devices). Operators will also spend one hour submitting revised plugging and abandonment cost estimates.
EPA estimates the annual recordkeeping burden for Class I hazardous facilities to be 5 hours.
Operators must maintain monitoring information, calibration and maintenance records, required reports,
application data, and monitoring results for three years; and keep their most recent plugging and abandonment
cost estimate for one year.
Closure
EPA estimates that the total annual burden associated with closure of a Class I hazardous well is 42
hours. This includes 1.5 hours to notify the permitting authority prior to closing, 6 hours to perform pressure
fall-off tests, 20 hours for MITs, and 10 hours for a closure report. EPA assumes that the operator will not
revise the closure plan or the post-closure care plan. The operator will also spend 4.5 hours on third-party
notification activities, such as notifying state or local zoning or drilling authorities and the permitting authority
following closure.
Class I Nonhazardous Facilities
Paperwork requirements for operators of Class I nonhazardous facilities include permitting and start-uprelated reporting, permit renewals and modifications, monitoring and testing, reporting and recordkeeping, and
closure-related paperwork activities.
Initial Permitting/Start-up
As is the case for Class I hazardous facilities, EPA estimates that the majority of the new nonhazardous
waste injection permits issued each year will be for new wells at existing facilities. Unit burdens are reported
on a per-application basis.
Requirements associated with permit applications add 110.6 hours to the customary business activities
of Class I nonhazardous facility operators. Column A of Table A-1B presents EPA’s estimates of burdens for
specific components of a permit application. Class I nonhazardous waste injection well permit applicants must
submit much of the same information as operators of hazardous facilities. EPA assumes that the burden on
nonhazardous facilities is the same as that for Class I hazardous waste facilities, with the exception of the
following:
Class I nonhazardous facility operators will study a smaller AoR. Consequently, the burden for the AoR
study and for developing a corrective action plan for wells in the AoR will be lower for these operators.
Nonhazardous facility operators are not required to develop waste analysis plans or plans to reduce the
quantity or toxicity of their injectate; nor are they required to gather and submit hazardous waste release
information.
EPA estimates that the unit burden on Class I nonhazardous facility operators for preparing and
submitting completion reports is 32.5 hours. This unit burden varies from that for Class I hazardous facilities,
Underground Injection Control Program – Information Collection Request
Page A-16
as Class I nonhazardous facility operators are not required to submit information on the calculated AoR.
Burden estimates for specific activities associated with completion of new wells are presented in Column A of
Table A-1B.
Permit Renewals/Modifications
As with hazardous facility operators, EPA assumes that applicants for nonhazardous injection permit
renewals will submit only those attachments to the application form that have changed since the original permit
application. Preparing and submitting the updated materials needed for a permit renewal application will take
an estimated 21 hours. EPA estimates the operator burden associated with contractor oversight to gather the
necessary information for a permit modification to be 8 hours.
Monitoring/Testing
EPA assumes that operator staff will observe and record injection pressure, flow rate, volume, and
temperature and sample their injectate periodically as normal business activities. However, to comply with UIC
requirements, operators spend more time on these activities than they otherwise would. Class I nonhazardous
facility operators will spend 38 hours to monitor their injectate; 5.7 hours to monitor injection pressure, flow
rate, and volume; 1.9 hours to conduct ambient monitoring; and 24 hours to conduct an annual pressure fall-off
test. In addition, approximately 20 percent of operators will spend 9 hours to demonstrate mechanical integrity
(i.e., five-year MIT).
Reporting and Recordkeeping
Operators will spend 16 hours per facility reporting quarterly on the chemical and physical
characteristics of injectate, flow rate, and volume. Class I nonhazardous facility operators will spend 12 hours
per facility reporting on the results of ambient monitoring and the pressure fall-off test.
EPA assumes that Class I nonhazardous facility operators will spend one hour each year to update and
submit revised plugging and abandonment cost estimates. EPA also assumes that operators will spend 4 to 6
hours submitting additional reports (e.g., of changes to the facility, planned workovers, noncompliance or
anticipated noncompliance, or events triggering an alarm or shutdown).
EPA estimates the annual recordkeeping burden on Class I nonhazardous facilities to maintain
monitoring information, calibration and maintenance records, required reports, application data, and monitoring
results for three years will be 4 hours per facility.
Closure
EPA estimates the annual burden on operators of Class I nonhazardous facilities associated with closure
is 1.5 hours, for notifying the Director.
Burden on Primacy Agencies Associated with Class I Wells
State primacy agencies’ burden associated with implementing Class I programs arises from program
oversight and reviewing and responding to permit applications, completion reports, monitoring and testing data,
and closure reports submitted by operators within their states. State burden associated with oversight of Class I
programs is presented in Column A of Tables A-1A and A-1B.
EPA estimates that states will spend from 20 to 58 hours per permit application reviewing applications
for hazardous or nonhazardous Class I wells (depending on whether the permit is issued or denied), and 30
Underground Injection Control Program – Information Collection Request
Page A-17
hours reviewing requests for permit modifications or renewals. EPA regional offices review all no-migration
petitions and petition modification requests submitted by operators of Class I hazardous waste injection
facilities; however, state primacy agencies assist the regions with this review. States spend 28 hours per nomigration petition application and 10 hours per petition modification request on this assistance.
State primacy agencies spend from 1 to 4 hours per report reviewing monitoring and MIT data or
occasional reports submitted by operators (details are presented in Tables A-1A and A-1B). States spend one
hour reviewing plugging and abandonment reports submitted by operators of Class I nonhazardous waste
facilities, and 26 hours reviewing reports and testing results associated with closure of hazardous waste
facilities. EPA estimates that state staff will spend 1 hour per request reviewing aquifer exemption requests for
Class I owners or operators in their state and forwarding these requests to the EPA Region for a determination.
Burden Associated with Class II Wells
EPA’s estimates of the annual paperwork burden on operators for permitting, monitoring and testing,
reporting and recordkeeping, and closing wells, and state burden for administering Class II programs, are
presented in Table A-2.
Class II Operators
Initial Permitting/Start-up
EPA anticipates that 28 percent of Class II permit applications will be for area permits and 73 percent
will be for individual permits. On average, each area permit application will cover 3.1 wells. EPA or state
primacy agencies will deny applications that do not meet construction standards, and others will be withdrawn
by owners.
The average burden for preparing permit application forms and the supporting documentation is
approximately 67 hours per application. The time that a particular operator will spend on a permit application
will likely vary, depending on the specific state submission requirements, the operator’s level of experience,
whether the application is for an individual or an area permit, the use of contractors, and other factors. The
following paragraphs summarize the burdens for various components of a Class II permit application.
EPA estimates that operators will spend 2.5 hours to read the application directions and fill out the
permit application form. With respect to the supporting documentation, EPA assumes that operators would
normally prepare a well schematic and some geological, hydrogeological, and operating data in the course of
business, and/or utilize existing data for the project. For area permits, the operator generally submits supporting
data for a representative well. Table A-2 provides estimates of the time required, beyond what is considered
customary business practice, to prepare the attachments to a Class II permit application. EPA estimates that
permit applicants will spend an average of:
9.5 hours to prepare geological data on injection and confining zones;
6 hours to prepare plugging and abandonment plans;
2.5 hours to identify and determine depth to the bottom of USDWs;
3 hours to prepare schematics of the wells;
2 hours to prepare proposed operating data; and
20 hours to prepare financial responsibility information.
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Page A-18
Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Legal
Managerial
Initial/Start-up Requirements
Requirements associated with permit applications (Per Permit Application)
Read permit application directions.
One-time
0.0
0.0
Gather and submit: description of activities
One-time
requiring a permit, facility name & address,
SIC codes, ownership and facility status,
facility location, listing of relevant permits or
construction approvals, topographic maps,
description of the business.
0.1
0.0
For DI programs, gather and submit a list of One-time
all land owners within one quarter mile of the
facility boundary.
Prepare and submit plugging and
abandonment plan.
One-time
Show evidence of financial responsibility for
closure.
One-time
Prepare and submit proposed Corrective
Action Plan.
One-time
Prepare and submit revised Corrective Action One-time
Plan.
Prepare and submit Area of Review map.
(State/DI Program performs study)
Technical
F
Total Hours and Costs
Clerical
Unit Burden
Unit Labor
Cost
Unit Non- No. of
Labor Cost Responses
Total
Hours/Year
Total Cost/Year
0.5
0.5
1.0
$39
$0
8,983
8,983
$346,479
1.0
0.4
1.5
$69
$0
8,983
13,474
$621,844
0.2
0.0
0.0
1.0
1.2
$47
$193
351
421
$83,883
0.0
0.6
4.8
0.6
6.0
$302
$0
8,983
53,897
$2,708,506
0.0
5.0
5.0
10.0
20.0
$948
$0
8,983
179,655
$8,519,807
0.0
0.3
2.9
0.2
3.4
$172
$0
898
3,054
$154,770
0.0
1.0
9.6
0.7
11.3
$572
$0
180
2,030
$102,766
0.0
0.0
1.0
0.0
1.0
$49
$38
1,997
1,997
$173,665
0.0
0.1
2.9
2.0
5.0
$206
$208
1,694
8,512
$702,802
0.0
0.1
1.8
0.1
2.0
$99
$0
8,983
17,966
$889,314
0.0
0.5
8.0
1.0
9.5
$460
$0
8,983
85,336
$4,136,207
One-time
Prepare and submit Area of Review map and One-time
study.
Prepare and submit proposed operating data. One-time
Prepare and submit geological data on the
injection and confining zone.
One-time
Prepare and submit name and depth to
bottom of USDWs.
One-time
Prepare and submit schematic of the well.
One-time
Prepare and submit information to support an One-time
aquifer exemption request.
0.0
0.1
2.3
0.1
2.5
$123
$229
8,983
22,457
$3,167,918
0.0
0.0
2.8
0.2
3.0
$142
$0
8,983
26,948
$1,277,123
0.0
2.5
17.0
0.5
20.0
$1,053
$0
269
5,390
$283,849
0.5
9.5
50.0
20.0
80.0
$3,850
$764
30
2,400
$138,441
For operators in DI states performing HF
One-time
using diesel fuels, prepare and submit
information recommended in DFHF Guidance
(e.g., planned fracture extent, geologic
information, AoR, construction information).
Underground Injection Control Program -- Information Collection Request
Page A-19
Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Requirements associated with completion reports (Per Well)
Prepare and submit completion report.
One-time
Legal
Managerial
Technical
F
Total Hours and Costs
Clerical
Unit Burden
Unit Labor
Cost
Unit Non- No. of
Labor Cost Responses
Total
Hours/Year
Total Cost/Year
0.0
0.0
1.5
2.5
4.0
$144
$0
8,585
34,340
$1,237,181
0.0
0.2
1.9
0.2
2.4
$121
$4,586
1,318
3,163
$6,201,871
0.0
0.0
Requirements associated with permit reviews/modifications (Per Permit/Per Operator)
Respond to issues raised during permit
Every 5 years
review.
0.0
0.5
Prepare and submit request for permit
Occasional
modification.
0.0
0.4
7.0
0.0
7.0
$341
$206
8,585
60,095
$4,701,158
2.0
0.5
3.0
$154
$0
1,765
5,295
$271,432
2.8
0.8
4.0
$193
$0
2,648
10,591
$510,680
Perform and report on appropriate logs and
other tests during construction.
One-time
Demonstrate mechanical integrity.
One-time
Monitoring/Testing Requirements (Per Operator)
Monitor the nature of injected fluids.
As necessary
to obtain
Record injection pressure, flow rate, and
At least every
cumulative volume.
30 days.
Demonstrate mechanical integrity.
Reporting Requirements (Per Operator)
In DI programs, gather and submit
groundwater monitoring data, analyses of
injected fluids, a description of geologic
strata, and other items as requested.
0.0
0.0
2.0
0.0
2.0
$97
$46
70,606
141,213
$10,121,799
0.0
0.0
0.6
0.3
0.8
$35
$0
212,179
178,231
$7,479,262
0.0
0.0
3.0
0.0
3.0
$146
$2,064
47,659
142,978
$105,320,229
0.0
3.0
22.0
5.0
30.0
$1,467
$0
33
991
$48,479
0.0
0.0
0.5
0.5
1.0
$39
$0
79
79
$3,053
0.0
1.0
1.5
2.5
5.0
$228
$0
1,059
5,295
$241,754
0.0
0.0
3.3
1.7
5.0
$210
$0
17,682
88,408
$3,708,752
0.0
0.0
1.0
0.0
1.0
$49
$0
17,682
17,682
$861,954
Every 5 years
Occasional
In DI programs, notify Regional Administrator Every 5 years
30 days prior to MIT.
Notify Director of (1) any planned physical
Occasional
changes to facility; (2) changes that may
result in noncompliance, (3) permit transfers,
(4) compliance or noncompliance with
compliance schedules, (5) possible
endangerment to a USDW.
Report monitoring data, including monthly
records of injected fluids, any changes in
characteristics or sources of injected fluids.
Annual
Report MIT results.
Annual
Underground Injection Control Program -- Information Collection Request
Page A-20
Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Recordkeeping Requirements (Per Operator)
Retain records of permitting data, nature and At least 3
composition of injected fluids, and all
years
monitoring results.
Legal
Managerial
Technical
F
Total Hours and Costs
Clerical
Unit Burden
Unit Labor
Cost
Unit Non- No. of
Labor Cost Responses
Total
Hours/Year
Total Cost/Year
0.0
0.0
1.0
3.0
4.0
$134
$0
17,652
70,606
$2,364,125
0.0
0.5
2.5
1.0
4.0
$192
$0
0
2
$78
0.0
1.0
0.0
2.0
3.0
$141
$0
1,044
3,132
$147,146
0.0
0.0
4.5
1.5
6.0
$262
$275
41
245
$21,888
0.0
0.5
0.5
1.0
2.0
$95
$0
69
485,967
138
1,195,002
Closure Requirements (Per Operator)
In DI programs, notify director of revisions to One-time
plugging and abandonment plan.
Notify the Director before conversion or
abandonment of the well, or in the case of
area permits, before closure of the project.
One-time
In DI programs, submit a plugging and
abandonment report within 60 days after
plugging a well.
One-time
Other Requirements (Per Operator)
In DI programs, submit revised
demonstration of financial responsibility.
Occasional
TOTALS
$
$6,535
166,554,749
Note: Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-21
Table A-2 (continued)
Annual Paperwork Burden and Costs Associated with Class II Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Frequency
E
F
Total Hours and Cost
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
Number of
Responses
Total
Hours/Year
6.0
2.0
2.0
4.0
5.0
$249
$83
$83
$166
$207
$0
$0
$0
$0
$0
8,632
8,632
8,632
8,632
1,628
51,793
17,264
17,264
34,528
8,139
$2,145,463
$715,154
$715,154
$1,430,308
$337,159
2.5
2.0
$104
$83
$0
$0
1,997
8,250
4,992
16,500
$206,807
$683,488
1.0
$41
$0
247
247
$10,252
1.0
$41
$0
1,696
1,696
$70,266
4.0
$166
$0
2,544
10,178
$421,595
0.5
$21
$0
45,799
22,900
$948,589
0.3
$10
$0
16,963
4,241
$175,665
1.0
$41
$0
0
0
$0
Initial/Start-up
Permit applications (Per Permit Application)
Review permit application and supporting
One-time
documentation and prepare draft permit.
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review operator's AoR map and study.
One-time
Review operator's AoR map and perform
One-time
AoR study.
Review completion report.
One-time
Review information related to aquifer
One-time
exemption requests and forward to EPA
region.
Permit reviews/modifications (Per Operator)
Review each permit to determine whether it Every 5 years
should be modified, revoked and reissued, or
terminated.
Review request for permit modification or re- Occasional
issuance.
Monitoring/Testing (Per Operator)
Review mechanical integrity test data
Every 5 years
submitted by operators.
Review monitoring data submitted by
Annual
operators.
Recordkeeping
Maintain administrative record in DI
One-time
programs.
Underground Injection Control Program - Information Collection Request
Total
Cost/Year
Page A-22
Table A-2 (continued)
Annual Paperwork Burden and Costs Associated with Class II Wells: States
A
B
C
D
Hours and Costs per Response
Description of Requirement
Other Reporting (Per Operator)
Respond to periodic notifications by owners
and operators.
Closure (Per Operator)
For DI programs, review plugging and
abandonment report.
Frequency
E
F
Total Hours and Cost
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
Number of
Responses
Total
Hours/Year
Total
Cost/Year
2.0
$83
$0
1,018
2,036
$84,319
1.0
$41
$0
0
114,710
0
191,778
$0
$7,944,220
Occasional
One-time
TOTAL
Note: Numbers may not add due to rounding
Underground Injection Control Program - Information Collection Request
Page A-23
Based on previous studies of state AoR practices and requirements, EPA projects that state primacy
agencies and EPA Regions will determine that a complete AoR is not necessary for approximately 60 percent of
Class II permit applicants. A complete AoR study may not be performed because:
The AoR is entirely overlapped by the AoRs of wells previously studied;
A State primacy agency has cross-referenced AoR studies, ensuring AoR coverage;
The operator has been granted a state variance based on factors relating to geologic setting and/or well
conditions; or
The well is located in a unitized project, and many of the elements of AoR studies were previously
performed during unitization.
Previous EPA studies also have shown that many state primacy agencies perform all or most of the tasks
involved in the AoR study. In these cases, the operator typically submits only a map of the AoR and a list of
wells in the AoR. EPA projects that approximately 19 percent of applicants will submit an AoR map and an
AoR study as part of the permit application. Each AoR map and study will require an average of 5 hours of
operator time.2 Another 22 percent of applicants will submit an AoR map and a listing of the wells in the AoR,
and the state primacy agency will perform most or all of the tasks involved in the AoR study. The operator time
needed to prepare the map and listing of wells is about one hour.
Based on the historical incidence of corrective action, EPA assumes that operators will incur different
burdens to prepare a corrective action plan. EPA estimates that 90 percent of permit applicants will submit brief
corrective action plans demonstrating that corrective action is not necessary to address potential conduits to
USDWs in the AoR; these plans will require one hour to prepare. The remaining 10 percent of applicants will
submit more complex corrective action plans to address specific problems identified by the AoR study, which
will take approximately 25 hours to prepare. Thus, the weighted average time to prepare a corrective action
plan is 3.4 hours. EPA regional or state primacy staff will require 20 percent of applicants to revise their
complex corrective action plans. Each revised plan will take about 11.3 hours to prepare.
Unless exempted by the Director, operators in DI programs are required to submit a list of landowners
within ¼ mile of the facility boundary. EPA estimates that these applicants will each take 1.2 hours to research
property ownership records and prepare the list. This unit burden assumes that operators will supply about 30
percent of the effort, and the remaining 70 percent will be performed by contractors.
Prior to obtaining approval to begin injection, operators must submit completion reports for each new
Class II well. With the completion report, operators must submit results of MITs and any well logs and tests
required by the Director. Operators will take approximately 2.4 hours to perform and report on logs and tests
and 4 hours per well to fill out the completion form. The MIT will require an additional 7 hours of operator
time, given current MIT practices for various completion types.
Most operators will submit logs for offset wells in their projects. EPA projects that Directors will
require some permit applicants to perform and report on new well logs and tests, such as cement bond,
temperature, or density logs. Directors are more likely to require additional logs and tests for II-D (disposal)
wells than for II-R (recovery) wells. EPA assumes that operators will perform additional logs and tests for 50
percent of new II-D wells and 5 percent of new II-R wells. Each of the logs and tests will take approximately
2.4 hours of operator time, primarily to supervise contractors.
2
EPA estimates that some operators will utilize contract AoR services. The unit burden for operators assumes that operators will
perform about 67 percent of the AoR burden themselves and contract out for the remaining 33 percent.
Underground Injection Control Program – Information Collection Request
Page A-24
EPA estimates that owners or operators of Class II wells that apply for an aquifer exemption will submit
geologic and water use-related information to demonstrate that the criteria at 40 CFR 144.7 and 40 CFR 146.4
are met. EPA estimates that much of this information will be gathered as part of the Class II permit application
process, and that applying for an aquifer exemption will require an additional 20 hours for each applicant.
Additionally, operators of production wells in DI states performing hydraulic fracturing (HF) using
diesel fuels (DF) that are issued permits as recommended in the DFHF Guidance will submit the same types of
information required of Class II well owners or operators, along with additional information to afford an
evaluation of the proposed HF operation, such as information about the formation(s) to be fractured and the
extent and orientation of the planned fracture network, seismic history, and baseline geochemical data. The
guidance also recommends that owners or operators identify a site-specific AoR; demonstrate that the well is
constructed appropriately; perform a pre-HF MIT; and demonstrate financial responsibility. EPA estimates that
each of these operators will incur 80 hours to apply for a UIC permit and provide this information to the EPA
DI Program.
Following permitting, owners or operators of wells following the DFHF Guidance recommendations
will monitor injection pressure, flow rate and cumulative volume during HF operations, perform an MIT if
needed, monitor ground water quality if directed, and perform the same reporting and recordkeeping activities
as other Class II owners or operators, as described below.
Permit Reviews/Modifications
Class II permits are valid “up to the operating life of the facility” [40 CFR 144.36]. While the
regulations do not require permit renewals, most permits are reviewed every five years. These reviews may be
formal compliance reviews or informal reviews, usually conducted in conjunction with reviews of MIT results.
Operators may be required to respond to any issues raised during the permit review. For purposes of calculating
operator burden, EPA assumes that each operator will take 3 hours to respond to issues raised during the review.
Operators occasionally submit requests for permit modifications in response to changes in well
ownership or injection practices, to add wells to existing area permits, and for other reasons. EPA expects that
preparing each request will take an average of 4 hours.
Monitoring/Testing
For purposes of estimating the number of respondents for monitoring and testing, EPA assumes that the
typical Class II operator has approximately 10 wells. An operator with wells in multiple states is treated as a
separate operator in each state, since the operator would have to submit separate reports to each state primacy
agency or EPA regional office.
In general, all operators located in DI programs and operators of commercial II-D wells in primacy
states are required to submit annual injectate analyses. EPA estimates that approximately 40 percent of Class II
operators submit annual injectate analyses each year. EPA assumes that operators submit samples for
approximately 20 percent of their wells. Each operator takes 2 hours (1 hour per well) per year to sample and
analyze its injectate. This includes the time it takes for operators to analyze their injectate or, in some cases,
send it to a commercial laboratory for analysis.
Most operators are required to observe injection pressure, flow rate, and cumulative volume weekly for
II-D wells and monthly for II-R wells. EPA anticipates that operators, especially operators of II-R wells,
perform periodic observations of pressure, flow rate, and cumulative volume as a customary business practice.
Thus, the incremental time needed to perform these observations is about 0.84 hours per operator (0.08 hours,
or 5 minutes, per well) per month. This represents the time required to record the data on a field report.
Underground Injection Control Program – Information Collection Request
Page A-25
Based on information reported on the UIC reporting forms, EPA assumes that 27 percent of operators
will perform MITs on their wells each year. Each operator will spend 3.0 hours (0.3 hours per well) performing
MITs. The unit burden assumes that contractors perform many of the tasks involved in an MIT.
Reporting and Recordkeeping
Each year, Class II operators spend about 5 hours to prepare annual monitoring reports. These reports
include summaries of monthly or weekly observations of flow, pressure, and cumulative volume. In addition,
27 percent of operators will spend 1 hour per operator to prepare reports on MITs performed.
From time to time, operators submit other reports or notify UIC staff of various events. These include
notifications of planned changes to the injection facility, permit transfers, progress in achieving compliance
milestones, and noncompliance or malfunctions which may endanger a USDW. EPA estimates that
approximately 6 percent of operators submit one of these occasional reports each year. Operators will spend an
average of 5 hours to prepare each report.
Operators of rule-authorized wells in DI states may be required to gather and submit groundwater
monitoring data, analyses of injected fluids, a description of geologic strata, and other items as requested. EPA
projects that each request will take 30 hours to prepare. In addition, operators of rule-authorized wells will
spend one hour per operator to notify the Region prior to performing MITs.
Each operator will spend about 4 hours annually to maintain records on permitting, monitoring, and
testing.
Closure
Each operator that closes a well will spend about 3.0 hours (0.3 hours per well) to notify UIC officials
prior to abandoning the wells.
In addition, EPA assumes that operators in DI programs who elect to plug their wells in a manner
different from the one specified in their plugging and abandonment plans will spend 4 hours to prepare revised
plugging and abandonment plans. In addition, operators who plug wells in DI programs will spend 6 hours to
prepare and submit plugging and abandonment reports.
Other Activities
DI programs may require some operators of wells with lifetime permits to submit revised financial
responsibility demonstrations. EPA estimates that 10 percent of operators in DI programs will each take 2
hours to prepare and submit revised financial data.
Burden on Primacy Agencies Associated with Class II Wells
Class II primacy agencies review and respond to permit applications and permit reviews/modifications,
as well as monitoring and testing data submitted by operators within their states. State burden associated with
each activity involved in the oversight of Class II programs is presented in Column A of Table A-2.
EPA estimates that states will spend 23.5 hours per application reviewing Class II injection well permit
applications. Primacy agency staff spend one hour to determine whether to reissue, modify, or revoke each
permit during the five-year review process. Primacy agencies spend four hours reviewing each request for a
permit modification or renewal. EPA estimates that state staff will spend 1 hour per request reviewing aquifer
Underground Injection Control Program – Information Collection Request
Page A-26
exemption requests for Class II owners or operators in their state and forwarding these requests to the EPA
Region for a determination.
State primacy agencies spend from 0.3 to 0.5 hours per report reviewing monitoring and MIT data or
occasional reports submitted by Class II operators (see details in Table A-2).
Burden Associated with Class III Wells
Table A-3 presents EPA’s estimate of the annual paperwork burden on operators for permitting,
monitoring and testing, reporting and recordkeeping, and closing their facilities, as well as state burden for
administering Class III programs.
Class III Operators
Initial Permitting/Start-up
A Class III operator will spend an average of 132 hours to prepare a new permit application form and
the required attachments. Reading the directions and filling out the application form account for 11 hours of the
total. Table A-3 provides estimates of the operator time, incremental to that considered customary business
practice, required to prepare each component of the permit application. EPA estimates that permit applicants
will spend an average of:
32 hours to prepare AoR maps and studies;
22 hours to prepare maps and cross sections of USDWs within the AoR, and of local and regional
geology;
16 hours to prepare monitoring plans;
14 hours to prepare proposed corrective action plans;
9 hours to prepare proposed operating data, formation testing and stimulation programs, and injection
procedures;
8 hours to prepare plugging and abandonment plans;
5 hours to prepare schematics of the wells; and
3.5 hours to demonstrate financial responsibility.
In addition, EPA estimates that, when requested by the Director, revised corrective action plans will take
10 hours each. Applicants in DI programs will spend 1.2 hours each to gather a list of landowners adjacent to
the facility.
Underground Injection Control Program – Information Collection Request
Page A-27
Operators completing wells must perform a two-part MIT and submit a completion form. The burden
associated with preparing completion reports is difficult to determine. Operators of Class III facilities,
especially uranium mining facilities, typically develop their projects in multiple phases under the same area
permit. Based on conversations with operators and states, EPA estimates that operators of Class III wells will
spend an average of 4 hours to prepare a completion report, 10 hours to demonstrate mechanical integrity, and
2.4 hours to perform and submit the results of required logs and tests during construction.
EPA estimates that owners or operators of Class III wells that apply for an aquifer exemption will
submit geologic and water use-related information to demonstrate that the criteria at 40 CFR 144.7 and 40 CFR
146.4 are met. EPA estimates that much of this information will be gathered as part of the Class III permit
application process, and that applying for an aquifer exemption will require an additional 20 hours for each
applicant.
Permit Renewals, Reviews, and Modifications
EPA estimates that, each year, 20 percent of Class III operators will have a formal or informal review of
their permits. Each operator will take 4 hours to respond to any issues raised during the review. In addition,
Class III operators will take an average of 28 hours to prepare requests for permit modifications.
Monitoring/Testing
EPA anticipates that operators of salt solution mining facilities will submit annual analyses of their
injectate. On average, each operator will take 8 hours per year to sample and analyze its injectate in-house.
Operators of Class III facilities will monitor injection pressure, flow rate, or volume of injected fluids
semi-monthly, or meter injected and produced fluid volumes continuously. EPA expects that operators perform
this activity periodically as a customary business practice to ensure the efficient operation of their facilities, and
that the incremental collection burden is approximately 4.6 hours per operator to complete the field reports.
EPA estimates that operators of salt solution mining facilities will perform two-part MITs on all of their
wells each year.3 The burden is estimated to be 161 hours per operator.
All uranium facility operators monitor water quality at selected monitoring wells completed in the
injection zone and overlying freshwater aquifers. Some active facilities monitor semi-monthly, while other
facilities that are performing aquifer restoration monitor monthly. EPA estimates that the typical uranium
facility has about 110 monitoring wells. As with pressure, flow, and volume monitoring, operators will perform
about two-thirds of this monitoring as a customary business practice to identify potential excursions from the
injection zone. EPA assumes that UIC requirements increase the monitoring burden to these operators by about
30.5 hours per monitoring period.
3
Some operators may be allowed to submit cementing records in lieu of performing temperature or noise logs.
Underground Injection Control Program – Information Collection Request
Page A-28
Table A-3
Annual Paperwork Burden and Costs Associated with Class III Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Frequency
Initial/Start-up Requirements
Requirements associated with permit applications (Per Permit Application)
Read permit application directions.
One-time
Gather and submit the following information: (1) a description One-time
of activities requiring a permit, (2) facility name and address,
(3) SIC codes, (4) ownership and facility status, (5) facility
location, (6) listing of relevant permits or construction appro
For DI programs, gather and submit a list of all land owners
within one quarter mile of the facility boundary.
Prepare and submit plugging and abandonment plan.
Show evidence of financial responsibility for closure.
Prepare and submit proposed Corrective Action Plan.
Prepare and submit revised Corrective Action Plan.
Prepare and submit AoR map and study.
Prepare and submit maps and cross-sections of USDWs within
AoR, local geology, and regional geology.
Prepare and submit proposed operating data, formation testing
program, stimulation program, and injection procedure.
Prepare and submit schematic of the well.
Prepare and submit monitoring plan.
Legal
Managerial
0.0
Technical
Clerical
F
Total Hours and Costs
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
No of
Responses
Total
Hours/Year Total Cost/Year
0.0
0.5
0.5
1.0
$39
$0
32
32
$1,234
0.5
2.0
4.7
2.8
10.0
$523
$0
32
320
$16,721
0.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.5
2.0
1.0
3.2
0.0
6.4
1.0
10.0
8.0
25.5
1.0
1.6
2.0
2.0
1.0
3.4
1.2
8.0
3.5
14.0
10.0
32.0
$47
$357
$148
$713
$503
$1,606
$193
$0
$0
$0
$0
$1,139
23
32
32
32
6
32
27
256
112
448
64
1,024
$5,429
$11,438
$4,724
$22,803
$3,216
$87,820
0.0
0.0
18.0
4.0
22.0
$991
$229
32
704
$39,051
0.0
0.0
0.0
2.0
0.0
0.0
6.0
4.2
12.0
1.0
0.8
4.0
9.0
5.0
16.0
$489
$227
$699
$0
$0
$0
32
32
32
288
160
512
$15,654
$7,279
$22,354
0.0
1.5
2.5
4.0
$144
$0
21
84
$3,026
0.2
1.0
1.9
8.0
0.2
1.0
2.4
10.0
$121
$503
$5,246
$4,586
1
21
3
210
$5,810
$106,855
2.5
17.0
0.5
20.0
$1,053
$0
0.2
4
$221
3.0
2.0
1.0
22.0
0.0
4.0
4.0
28.0
$301
$1,354
$0
$0
34
24
137
672
$10,301
$32,505
0.0
6.0
2.0
8.0
$349
$0
47
375
$16,389
0.0
16.1
3.3
128.7
1.3
16.1
4.6
160.9
$199
$8,084
$0
$73,771
4,446
9
20,607
1,510
$884,720
$768,167
0.0
27.5
3.0
30.5
$1,426
$0
271
8,272
$386,678
One-time
One-time
One-time
One-time
One-time
One-time
One-time
One-time
One-time
One-time
Requirements associated with completion reports (Per Well)
Prepare and submit completion form and supporting
One-time
0.0
documentation (7520-9).
Prepare and submit appropriate logs and tests during
One-time
0.0
construction.
Demonstrate mechanical integrity.
One-time
0.0
Prepare and submit information to support an aquifer
One-time
0.0
exemption request.
Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)
Respond to issues raised during permit review.
Every 5 years
0.0
Prepare and submit request for permit modification.
Occasional
0.0
Monitoring/Testing Requirements (Per Facility)
Monitor the nature of injected fluids.
As necessary
to obtain
0.0
representative
Monitor injection pressure and flow rate or volume of injected
Semi-monthly/
fluids, or meter and record injected and produced fluid
Continuous
0.0
volumes.
Demonstrate mechanical integrity.
Every 5 years
0.0
Monitor the fluid level in the injection zone where appropriate
Semi-monthly/
and monitor parameters chosen to measure water quality in the monthly
monitoring wells.
0.0
Underground Injection Control Program -- Information Collection Request
Page A-29
Table A-3
Annual Paperwork Burden and Costs Associated with Class III Wells: Operators
A
B
C
D
E
Hours and Costs per Response
Description of Requirement
Reporting Requirements (Per Facility)
Notify Director of (1) planned physical changes to the facility,
(2) anticipated noncompliance, (3) permit transfers, (4)
progress in meeting compliance schedule in permit, (5)
possible endangerment to a USDW.
Report to the Director on required monitoring, mechanical
integrity tests, and other required tests.
Recordkeeping Requirements (Per Facility)
Retain records of permitting data, calibration and maintenance
data, and monitoring results.
Closure Requirements (Per Facility)
Notify the Director before conversion or abandonment of the
well or in the case of area permits before closure of the project.
In DI programs, submit a plugging and abandonment report
within 60 days after plugging a well or at the time of the next
quarterly report.
Other Requirements (Per Facility)
In DI programs, submit revised demonstration of financial
responsibility.
Frequency
Legal
Managerial
Technical
Clerical
F
Total Hours and Costs
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
No of
Responses
Total
Hours/Year Total Cost/Year
Occasional
0.0
1.0
3.0
2.0
6.0
$287
$0
17
103
$4,911
0.0
1.0
10.0
19.0
30.0
$1,111
$0
684
20,520
$760,020
0.0
0.0
0.4
3.0
3.4
$105
$0
171
581
$17,901
0.0
1.0
0.5
0.5
2.0
$123
$0
2
4
$245
0.0
0.0
0.8
0.3
1.0
$44
$0
1
1
$42
0.0
0.5
0.5
1.0
2.0
$95
$0
77
155
57,184
Quarterly
At least 3
years
One-time
One-time
Occasional
TOTALS
6,176
$
$7,328
3,242,842
Note: Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-30
Table A-3 (continued)
Annual Paperwork Burden and Costs Associated with Class III Wells: States
A
Program Oversight Activities
Frequency
Initial/Start-up
Permit applications (Per Permit Application)
Consider the permit application, area of review, One-time
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
t tithe permit
d application,
d i area of
ti review,
f
One-time
Consider
relevant maps and cross sections, fluid
injection rate and volume, proposed
contingency plans, monitoring plans, and
t public
ti
d of issuance
d
ft
Provide
notice
of a ddraft
One-time
permit or intent to deny.
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review completion report.
One-time
Review information related to aquifer exemption One-time
requests and forward to EPA region.
Underground Injection Control Program -- Information Collection Request
B
C
D
Hours and Costs per Response
Unit Labor
Unit NonUnit Burden
Cost
Labor Cost
E
F
Total Hours and Cost
Number of
Total
Total
Responses Hours/Year
Cost/Year
20.0
$828
$0
13
260
$10,770
40.0
$1,657
$0
18
720
$29,825
2.0
$83
$0
48
96
$3,977
8.0
$331
$0
48
384
$15,907
10.0
$414
$0
48
480
$19,884
15.0
$621
$0
48
720
$29,825
2.0
$83
$0
21
42
$1,740
1.0
$41
$0
0.2
0.2
$9
Page A-31
Table A-3 (continued)
Annual Paperwork Burden and Costs Associated with Class III Wells: States
A
Program Oversight Activities
Permit reviews/modifications (Per Facility)
Review each permit to determine whether it
should be modified, revoked and reissued, or
terminated.
Frequency
Closure (Per Facility)
Review plugging and abandonment report (DI
only).
C
D
E
F
Total Hours and Cost
Number of
Total
Total
Responses Hours/Year
Cost/Year
Every 5 years
Review request for permit modification or reOccasional
issuance.
Monitoring/Testing (Per Facility)
Review mechanical integrity test data submitted Every 5 years
by operators.
Review monitoring data submitted by operators. Quarterly
Other Reporting (Per Facility)
Respond to periodic notifications by owners
and operators.
Recordkeeping (Per Facility)
Maintain administrative record (DI).
B
Hours and Costs per Response
Unit Labor
Unit NonUnit Burden
Cost
Labor Cost
4.0
$166
$0
18
71
$2,931
20.0
$828
$0
23
460
$19,055
0.5
$21
$0
18
9
$366
0.25
$10
$0
354
88
$3,663
4.0
$166
$0
18
72
$2,983
4.0
$166
$0
0
0
$0
4.0
$166
$0
0
674
0
3,402
Occasional
One-time
One-time
TOTAL
$
$0
140,934
Note: Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-32
Reporting and Recordkeeping
Operators of Class III facilities will incur a burden of 30 hours per facility per quarter for quarterly
reporting on monitoring and any MITs performed. About 10 percent of operators will spend 6 hours per year on
occasional reporting activities. EPA estimates that each Class III operator spends approximately 3.4 hours on
recordkeeping annually.
Closure
EPA estimates that Class III operators who close their projects will take 2 hours to prepare written
notifications to the Director. Operators in DI programs will spend one hour to submit a plugging and
abandonment report.
Burden on Primacy Agencies Associated with Class III Wells
For the Class III Program, primacy agency staff review and respond to permit applications, permit
reviews/modifications, and monitoring and testing data submitted by operators. State burden associated with
each activity involved in the oversight of Class III programs is presented in Column A of Table A-3.
Depending on whether the permit is issued or denied, EPA estimates that states will spend between 20
and 77 hours reviewing each Class III permit application. Primacy agency staff will spend 4 hours determining
whether to reissue, modify, or revoke each permit during the five-year review process, and 20 hours reviewing
each request for a permit modification or re-issuance. Class III primacy agencies spend from 0.25 to 4 hours
per report reviewing monitoring and MIT data or occasional reports submitted by operators (see details in Table
A-3). EPA estimates that state staff will spend 1 hour per request reviewing aquifer exemption requests for
Class III owners or operators in their state and forwarding these requests to the EPA Region for a determination.
Burden Associated with Class IV and Endangering Class V Wells
Paperwork burden on operators of Class IV/endangering Class V wells and on states for administering
these wells is presented Table A-4.
Class IV and Endangering Class V Well Operators
Class IV wells and Class V wells that are found to be endangering USDWs are banned from injection,
and owners of these wells are required to close them and submit plugging and abandonment reports to states or
DI programs. The exception to the ban is for those Class IV wells used to inject contaminated ground water
that has been treated and re-injected into the same formation from which it was drawn. These wells are
authorized by rule for the life of the well if such subsurface emplacement of fluid is approved by EPA or a State
pursuant to the provisions for the cleanup of releases under the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 or RCRA. EPA estimates that the operator burden associated with this
one-time requirement to submit a plugging and abandonment report will be 10 hours per well (See Table A-4).
Because these wells are banned, there are no permitting or monitoring requirements.
Burden on Primacy Agencies Associated with Class IV and Endangering Class V Wells
State burden associated with Class IV and endangering Class V wells involves review by primacy
agency staff of closure plans submitted by operators. EPA estimates the state burden to be one hour per review.
Underground Injection Control Program – Information Collection Request
Page A-33
Burden Associated with Class V Wells
EPA’s estimate of the annual paperwork burden on operators and states associated with Class V wells is
presented in Column A of Table A-5.
Class V Operators
Activities for Class V well operators include submitting inventory information and permitting and/or
closure of motor vehicle waste disposal wells (MVWDWs) and large-capacity cesspools.
Inventory Activities
Recent efforts by the Regions and state primacy agencies to address the potential threats to USDWs
posed by Class V wells will likely increase compliance with the inventory requirement. Each Class V well
operator will take 0.5 hours to prepare and submit inventory information to the appropriate Regional or state
primacy agency.
Activities Required Under the Class V Rule
Under the Class V Rule, facilities that wish to continue operating motor vehicle waste disposal wells
must seek waivers from the ban on existing motor vehicle waste disposal wells and apply for permits. As a
condition of the permit, facilities must submit all monitoring reports to the UIC Director. Owners of
MVWDWs and large-capacity cesspools that close are required to submit pre-closure notifications.
Note: While the Class V Rule required that all closure or permitting activities be completed by January
2007 (the latest date by which operators with state-granted extensions would be required to have closed or
applied for a permit), EPA assumes that existing wells will continue to be located and permitted or closed.
Thus, some permitting/closure burden is included in this ICR.
Operators of Large-Capacity Cesspools
Operators of facilities with large-capacity cesspools will need to become familiar with the Class V
requirements and prepare and submit a pre-closure notification to their primacy agencies. EPA assumes that
each facility will require a total of 4.5 hours to complete these activities.
Operators of Motor Vehicle Waste Disposal Wells
All operators of facilities with MVWDWs must read the regulations and contact their primacy agencies
to determine if their wells are located in a source water protection area (SWPA) or other sensitive ground water
area. These activities will require 4 hours. If a well is located within one of these areas, the owner/operator will
either close the well or seek a waiver and apply for a permit.
If they choose to close their wells, owners of MVWDWs must notify the UIC Program Director at least
30 days prior to well closure, sample their injectate, and submit a pre-closure notification form (Form
7520-17 or a state equivalent). These operators would incur a burden of 3 hours.
Underground Injection Control Program – Information Collection Request
Page A-34
Table A-4
Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: Operators
A
Description of Requirement
Closure Requirements (Per Well)
Submit a plugging and abandonment report
within 60 days after plugging a well.
TOTAL
Questions
Frequency
Managerial
Technical
Clerical
B
C
Unit Burden
Unit Labor
Cost
10.0
$238
D
Unit Nonlabor Cost
E
F
Total Hours and Costs
No. of
Total
Total
Responses Hours/Year
Cost/Year
One-time
0
7.5
2.5
$0
990
990
9,900
9,900
$235,165
$235,165
Note:
Numbers may not add due to rounding.
Underground Injection Control Program - Information Collection Request
Page A-35
Table A-4 (continued)
Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: States
A
Description of Requirement
Closure
Review closure plan.
Frequency
B
C
D
Hours and Costs per Response
Unit
Unit Burden Unit Labor
Nonlabor
(A)
Cost
Cost
One-time
TOTAL
1.0
$41
$0
E
F
Total Hours and Cost
Number of
Responses
Total
Hours/Year
758
758
758
758
Total
Cost/Year
$31,399
$31,399
Note:
Numbers may not add due to rounding.
Underground Injection Control Program - Information Collection Request
Page A-36
Table A-5
Annual Paperwork Burden and Costs Associated with Class V Wells: Operators
A
B
C
D
E
F
No. of
Responses
Total
Hours/Year
Total
Cost/Year
Hours and Costs per Response
Description of Requirement
Frequency
Legal
Managerial
Technical
Inventory Requirements
In DI programs, submit inventory information prior to One-time
commencing injection.
0.0
0.0
0.0
Class V Rule Requirements for Owners/Operators of Large-Capacity Cesspools
Read regulations.
One-time
0.0
0.0
3.0
Prepare and submit pre-closure notification (Form
One-time
7520-17).
0.0
0.5
0.8
Class V Rule - Startup Requirements for Owners / Operators of Motor Vehicle Waste Disposal Wells
Contact state or local agency to determine
One-time
requirements.
0.0
0.0
1.0
Read regulations.
One-time
For wells that will close, sample injectate and
One-time
maintain record.
Prepare and submit pre-closure notification (Form
One-time
7520-17).
For wells obtaining a waiver, conduct initial sampling. One-time
Unit Burden
Unit Labor
Cost
Unit Non-labor
Cost (A)
0.5
0.5
$10
$0
24,860
12,430
$237,462
0.0
3.0
$76
$0
7
20
$506
0.3
1.5
$54
$0
7
10
$357
Clerical
0.0
0.0
3.0
0.0
0.0
1.0
3.0
$25
$76
$0
$0
33
33
33
100
$843
$2,530
0.0
0.0
1.0
0.5
1.5
$35
$706
32
48
$23,467
0.0
0.5
0.8
0.3
1.5
$54
$0
32
48
$1,695
1.0
0.5
1.5
$35
$706
2
3
$1,235
25.0
21.0
54.0
$1,510
$0
2
90
$2,517
1.0
0.5
1.5
$35
$706
5,916
8,874
$4,384,165
1.0
0.5
1.5
$35
$1,847
1,479
2,219
$2,782,598
3.0
1.0
4.0
$95
$0
1,479
33,881
5,916
29,789
$140,529
$7,577,905
0.0
0.0
For wells obtaining a waiver, prepare and submit
One-time
permit application.
0.0
8.0
Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal Wells
Conduct quarterly injectate sampling.
Quarterly
0.0
0.0
Conduct annual sludge sampling (concurrent with
Annual
injectate sampling).
0.0
0.0
Annual reporting and recordkeeping of all monitoring Annual
results.
0.0
0.0
TOTAL
Notes:
(A) EPA assumes that there are no start-up costs; all non-labor costs are O & M costs.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-37
Table A-5 (continued)
Annual Paperwork Burden and Costs Associated with Class V Wells: States
A
Description of Requirement
Initial/Startup
Frequency
B
C
D
Hours and Costs per Response
Unit Nonlabor
Unit Burden (A) Unit Labor Cost
Cost
E
F
Total Hours and Cost
Number of
Responses
Total Hours/Year
Total Cost/Year
Review inventory information.
Primacy State Activities Associated With the Class V Rule
One-time
0.5
$21
$0
16,154
8,077
$334,573
Provide technical assistance to owners/operators (at start-up).
One-time
1.0
$41
$0
78
78
$3,230
Review and file pre-closure notifications.
One-time
1.3
$52
$0
75
93
$3,869
Review, approve, and file waivers/permit applications.
One-time
8.3
$344
$0
3
27
$1,117
Annual
0.8
$33
$0
961
17,271
769
9,044
Review and file annual monitoring reports.
TOTAL
$
$31,848
374,637
Notes:
(A) Unit burdens for initial/start-up activities reported on a per-permit basis. Unit burden for other activities reported on a per-operator basis.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-38
The specific information required in a permit application will be defined by the States or EPA regions.
For purposes of this analysis, EPA assumes that the permit requirements will be similar to those required
in existing UIC permit applications (40 CFR 144.31) including: a description of activities requiring a
permit, inventory information, topographic maps, and a brief description of the business. These
operators will also sample their injectate. The burden for these activities is estimated to be 55.5 hours,
the majority of which is for preparing the permit application.
Operators of MVWDWs that are granted permits will be required to sample their injectate quarterly and
sludge annually and submit these results once per year. These operators will incur an annual burden of 7 hours.
Burden on Primacy Agencies Associated with Class V Wells
State primacy agencies’ burden associated with Class V wells includes time associated with reviewing
inventory information, processing permit applications and pre-closure notifications, and reviewing and
responding to monitoring data submitted by operators within their states. State burden associated with oversight
of Class V programs is presented in Column A of Table A-5.
EPA estimates that states will spend 0.5 hours per Class V facility reviewing inventory information.
EPA estimates that states will review permit applications and pre-closure notifications submitted by operators of
facilities with motor vehicle waste disposal wells and large-capacity cesspools. State primacy agencies will also
review annual monitoring reports submitted by operators (details are presented in Table A-5).
Burden Associated with Class VI Wells
EPA’s estimate of the annual paperwork burden on operators and states associated with Class VI wells is
presented in Column A of Table A-6. The burden estimates presented for Class VI wells are weighted averages
that take into account the formation type, injection depth waiver status, and number of facilities that are active
during this ICR clearance period. As such, these burden estimates are not representative of any one situation
under which a GS project will operate.
Class VI Operators
Activities for Class VI well operators include permitting and start-up-related reporting, demonstration of
financial responsibility, monitoring and testing, AoR reevaluations and associated plan revisions, and closure
and post-injection site care related paperwork activities.
EPA anticipates that Class VI facility operators will rely on contractors to assist them for information
collection activities such as 3D seismic surveys, aerial surveys, and test well drilling. The costs associated with
contractor labor and other contractor services are included in the operator costs presented in Column C of Table
A-6. However, as geologic sequestration is a relatively new endeavor, there are still many activities for which
uncertainty exists as to whether they will customarily be performed by operators or contractors. Those
activities were classified as operator burden to provide a conservatively large estimate of operator burden.
EPA assumes that some activities required of Class VI operators (such as developing maps and crosssections of the receiving formation) are customary business practices that would be performed by operators
even in the absence of regulation. Unit burden and costs used in Table A-6 represent the costs of performing
each activity required of Class VI operators that are incremental to customary business practices.
Underground Injection Control Program – Information Collection Request
Page A-39
Table A-6
Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators
A
B
C
Hours and Costs Per Response
Unit NonTechnical 1
Technical 2
Unit Labor
Labor Cost
Description Of Requirement
Frequency
(Engineer)
(Geologist)
Unit Burden
Cost
(A)
Initial/Startup Requirements (Per Permit Application)
Requirements Associated with Permit Applications
Prepare and submit Class VI permit application,
including attachments and the testing and monitoring
plan, emergency and remedial response, injection well
plugging, and post-injection site care and site closure
plan.
One-Time
Conduct 3D seismic survey to identify faults and
fractures; obtain and analyze seismic history.
One-Time
E
F
Total Hours andCosts
Number of
Total
Responses Hours/ Year Total Cost/Year
240
300
540
$58,524
$546,184
3.3
1,800
$2,015,694
0
180
180
$19,074
$605,365
3.3
600
$2,081,463
30
129
159
$17,012
$140,292
3.3
530
$524,346
One-Time
0
44
44
$4,705
$0
3.3
148
$15,683
One-Time
0
10
10
$1,060
$18,276
3.3
33
$64,453
One-Time
0
240
240
$25,432
$0
3.3
800
$84,774
One-Time
40
0
40
$4,456
$0
3.3
133
$14,852
One-Time
140
300
440
$47,385
$101,646
3.3
1,467
$496,770
One-Time
724
1924
$207,809
$0
3.3
6,413
$692,698
One-Time
100
300
$32,333
$0
1.0
300
$32,333
Obtain geomechanical and geochemical information
on injection zone, subsurface aquifers including all
USDWs, and the confining zone in the area of review. One-Time
Develop maps and cross sections of the injection
zone, subsurface aquifers including all USDWs, and
the confining zone in the area of review.
Take initial samples to develop a geochemical
baseline for injection zones and confining zones.
Prepare geologic characterization report
demonstrating: suitability of receiving zone, storage
capacity and injectivity, trapping mechanism free of
nonsealing faults, competent confining system, etc.
Demonstrate financial responsibility to ensure funds
will be available for required future actions.
Conduct aerial and database search for artificial
penetrations (wells) within the area of review;
determine integrity/plugging status of each.
Perform complex modeling of CO2 fluid flow and
migration (reservoir simulations) and prepare AoR
and corrective action plan.
Compile and submit information to support an
injection depth waiver application.
D
Underground Injection Control Program -- Information Collection Request
1,200
200
Page A-40
Table A-6
Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators
A
B
C
D
E
F
Hours and Costs Per Response
Total Hours andCosts
Unit NonTechnical 1
Technical 2
Unit Labor
Labor Cost Number of
Total
Description Of Requirement
Frequency
(Engineer)
(Geologist)
Unit Burden
Cost
(A)
Responses Hours/ Year Total Cost/Year
Requirements Associated with Injection Well Construction
Design and install equipment for injection wells to
measure: injected volumes, pressure, flow rates, and
annulus pressure.
One-Time
0
0
0
$0
$399,518
3.3
0
$1,331,726
Install check/shut-off valve on injection well.
One-Time
0
0
0
$0
$2,759
3.3
0
$9,197
One-Time
Construct monitoring wells.
0
0
0
$0
$2,370,318
3.3
0
$7,901,061
Design and install equipment for monitoring wells to
measure: pressure, temperature, resisitivity, salinity,
CO2, and any other required parameters.
One-Time
0
0
0
$0
$169,956
3.3
0
$566,522
Monitoring/Testing Requirements (Per Operator)
Analyze injectate stream and perform corrosion
monitoring.
Quarterly
62
0
62
$6,851
$16,303
13.3
820 $
308,715
Operate and maintain monitoring wells and the
monitoring equipment within them.
Annual
13
0
13
$1,395
$462,195
3.3
42
$1,545,301
Conduct periodic monitoring of groundwater quality
and geochemistry.
Monthly
21
0
21
$2,339
$10,906
40.0
840
$529,816
Conduct external mechanical integrity tests.
Annual
0
0
0
$0
$181,804
3.3
0
$606,013
Every Five
Years
Conduct pressure fall-off testing.
0
0
0
$0
$34,268
0.7
0
$22,845
Conduct 3D seismic survey to track movement of the Every Five
CO2 plume and pressure front.
Years
0
0
0
$0
$1,194,570
0.7
0
$796,380
Activities Associated with Area of Review Reevaluations
Conduct updated AoR modeling. Based on new
results, update AoR and Corrective Action Plan,
Testing and Monitoring Plan, and Emergency and
Remedial Response Plan.
Every Five
Years
Underground Injection Control Program -- Information Collection Request
1,118
0
1,118
$124,536
$0
0
0
$0
Page A-41
Table A-6
Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators
A
B
C
D
E
F
Hours and Costs Per Response
Total Hours andCosts
Unit NonTechnical 1
Technical 2
Unit Labor
Labor Cost Number of
Total
Description Of Requirement
Frequency
(Engineer)
(Geologist)
Unit Burden
Cost
(A)
Responses Hours/ Year Total Cost/Year
Reporting and Recordkeeping Requirments (Per Operator)
Report to regulators; maintain records of data from all
data gathering activities.
Semi-Annual
33
0
33
$3,676
$0
6.7
220
$24,506
Plugging, Post-Injection Site Care, and Site ClosurePost
Requirements (Per Operator)
Demonstrate financial ability (accounting for inflation) Injection,
to close site.
One-Time
PostInjection,
Perform a MIT prior to plugging the injection well.
One-Time
PostConduct ground water monitoring - operate and
Injection,
maintain monitoring wells and the monitoring
Annual
equipment within them.
PostInjection,
Every 5
Track the CO2 plume and pressure front.
Post
Injection,
Submit results of post-injection monitoring.
Every 5
TOTAL
Notes:
(A) Unit Non-Labor Cost inflated by 20% to account for G&A
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
8
0
8
$891
$0
0
0
$0
0
0
0
$0
$34,776
0
0
$0
0
0
0
$0
$531,971
0
0
$0
0
0
0
$0
$1,194,570
0
0
$0
40
0
40
$4,456
$0
0
112.3
0
14,146 $
$0
19,665,149
Page A-42
Table A-6 (continued)
Annual Paperwork Burden and Costs Associated with Class VI Wells: States
A
B
C
D
E
F
Hours and Costs Per Response
Total Hours and Costs
Unit NonUnit Labor
Labor Cost
Number of
Total
Total
Description Of Requirement
Frequency Unit Burden
Cost
(A)
Responses Hours/ Year
Cost/Year
Initial/Startup Requirements (Per Permit Application)
Review the permit application and other information
submitted by the operator, considering: AoR, relevant maps,
site geology, formation testing results, well schematics and
construction procedures, proposed injection procedure,
status of corrective action on wells in the AoR, well logging,
testing, and mechanical integrity data, and project plans.
One-time
780
$32,311
$0
0.33
260.0
$10,770
Review financial responsibility demonstration.
Determine and specify tubing, packing, casing, and
cementing requirements based on review of information
submitted by operator.
One-time
100
$4,142
$0
0.33
33.3
$1,381
One-time
140
$5,799
$0
0.33
46.7
$1,933
Witness logging and testing.
Review applications for waviers to inject above the
lowermost underground source of drinking water.
Monitoring and Recordkeeping
Review reports submitted by operators; recordkeeping of
data from all data gathering activities.
One-time
20
$828
$0
0.33
6.7
$276
One-time
200
$8,285
$0
0.33
66.7
$2,762
Review mechanical integrity test data.
Area of Review Reevaluation
Annual
40
$1,657
$0
0
0
$0
Annual
14
$559
$0
0
0
$0
150
$6,214
$0
0
0
$0
40
$1,657
$0
0
0
$0
$43,081
$0
2.3
4.0
Every 5
Review updated AoR modeling and updated plans.
years
Site Closure
Review relevant data prior to granting approval for plugging
and abandonment of a well.
One-time
Project-Independent Activities
Prepare and submit primacy application.
TOTAL
Notes:
One-time
1,040
2,427
2,840
$
$100,522
117,644
Numbers may not add due to rounding.
Undergound Injection Control Program -- Information Collection Request
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Initial Permitting/Start-up
EPA estimates that the operator burden associated with applying for Class VI permits, including
submitting all required attachments and plans will be 540 hours per permit. Submitted plans include an Area of
Review and Corrective Action Plan, a Testing and Monitoring Plan, an Emergency and Remedial Response
Plan, an Injection Well Plugging Plan, and a Post-Injection Site Care and Site Closure Plan.
In addition to applying for permits, EPA estimates that owners or operators of Class VI wells will incur
burden above customary business practices to perform the following start-up activities:
Conduct a 3D seismic survey to identify faults and fractures and to obtain and analyze the seismic
history of the site (180 hours).
Obtain geomechanical and geochemical information on the injection zone, other subsurface aquifers
(including all USDWs), and the confining zone in the AoR (159 hours).
Develop maps and cross-sections of the injection zone, other subsurface aquifers (including all
USDWs), and the confining zone in the AoR (44 hours).
Prepare a geologic characterization report demonstrating the suitability of the injection zone, storage
capacity and injectivity, the presence of a trapping mechanism free of non-sealing faults, and a
competent confining zone (240 hours).
Estimate the costs of activities to be covered by financial responsibility and demonstrate financial
responsibility for these activities (40 hours).
Conduct aerial and database searches for artificial penetrations (wells) within the AoR, and determine
integrity and plugging status of each (440 hours).
Perform complex modeling (reservoir simulations) of carbon dioxide flow and fluid migration to
delineate the AoR (1,924 hours).
Monitoring/Testing
Class VI well operators will be required to perform quarterly analysis of the injectate stream and
perform corrosion testing of the injection well, which is estimated to require approximately 61.5 hours per
operator per quarter. Additionally, operators will incur an annual burden of approximately12.5 hours to operate
and maintain monitoring wells and the monitoring equipment within them. Operators must also perform
groundwater quality and geochemical monitoring which is estimated to require approximately 21 hours per
month. Owners or operators will also hire contractors to perform annual external MITs and to track the extent of
the carbon dioxide plume and pressure front.
Area of Review Reevaluations
Owners or operators of Class VI wells must reevaluate the AoR for the GS project at least every five
years. Based on the results of the reevaluation, operators will update and resubmit their Area of Review and
Corrective Action Plan, the Testing and Monitoring Plan, and the Emergency and Remedial Response Plan or
demonstrate that no updates are necessary. They will also update the financial responsibility demonstration as
needed to address any changes to these plans. (Note that owners or operators will also review their financial
responsibility demonstrations annually to account for inflation; this is assumed to involve a negligible burden
that is accounted for in the AoR reevaluation estimate.)
Underground Injection Control Program – Information Collection Request
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EPA estimates that, each year, 20 percent of operators will reevaluate the AoR and update the
aforementioned plans and submit them to the primacy agency for review and approval. Each operator is
estimated to incur 1,118 hours of burden once every five years for AoR reevaluations, which is assumed to
include burden incurred by operators to respond to issues raised during a review of the Class VI permit, which
is required every five years, per 40 CFR 144.36.
Reporting and Recordkeeping
Operators of Class VI wells will spend 33 hours every six months (or 66 hours per year) to report the
results of required monitoring and testing and keep records of all data-gathering activities.
Closure and Post-Injection Site Care
There are two closure and post-injection site care activities for which operators incur burden. It is
estimated that operators will require 8 hours to demonstrate financial ability (accounting for inflation) to
properly close the site. This occurs once at the beginning of the post-injection period. Subsequently, operators
are assumed to report monitoring results to regulators every five years during the post-injection site care period,
which is estimated to require 40 hours per operator, every five years.
Burden on Primacy Agencies Associated with Class VI Wells
State primacy agencies’ burden associated with Class VI wells includes reviewing and responding to
permit applications, monitoring and testing data, AoR reevaluations, and closure and post-injection site care
information submitted by operators. Due to the potentially long life spans of injection operations, no AoR
reevaluations or closure and post-injection site care activities are anticipated to occur during the ICR clearance
period. State burden associated with each activity involved in the oversight of Class VI programs is presented in
Column A of Table A-6.
EPA estimates that states will incur 1,040 burden hours per permit application to review Class VI permit
applications and all supporting information, including reviewing geologic information and well schematics;
evaluating the AoR modeling; and reviewing the draft project plans and financial responsibility cost estimates
and instruments.
State primacy agencies will incur an estimated 2.2 hours of burden annually per operator reviewing
reports and data records submitted by operators. Every year, they will also incur approximately 13.5 hours of
burden per operator reviewing MIT results. State primacy agencies will review modeling updates to the AoR
and other revised plans submitted by operators every five years, requiring approximately 20 hours per review.
States as Respondents
State burden associated with program oversight and compiling and reporting data using the 7520 forms
and the UIC measures reporting process is presented in Column A of Table A-7. The burden on states
associated with completing the 7520 forms ranges from 2 to 6 hours per form. States will also report annually
to EPA on the UIC Program measures via an online reporting system. EPA estimates the annual burden
associated with this effort will be 60 hours per state primacy agency. States will also report inventory
information annually to EPA. The burden associated with the oversight activities for the UIC Program well
inventory includes compiling the number of each Class of well, and reporting to an EPA online inventory. EPA
estimates the annual burden associated with this effort will be 60 hours per primacy agency.
Underground Injection Control Program – Information Collection Request
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EPA estimates that the annual recordkeeping burden on state primacy agencies associated with the 7520
forms and the inventory form will be 40 hours per agency. EPA estimates that maintenance of inventory data
will account for the bulk of the recordkeeping burden.
EPA estimates that, in each primacy program, one-half of an FTE (1,040 hours) is devoted to
implementing the state UIC Program. Implementation activities states may perform include updating state
regulations as needed to reflect new federal rules or providing guidance, training, or other information to well
operators.
State Activities Associated with the National UIC Database
EPA Headquarters deployed the National UIC database in December 2007. States are able to transfer
the data needed to generate the information they currently report via the 7520 forms, the inventory, and the
measures data to Headquarters. (Once they set up this data transfer process, States will no longer be required to
complete the 7520 forms, report UIC inventory or measures data, or retain records.) Appendix B describes the
data transfer activities in detail, EPA’s burden and cost estimates, and the burden and cost savings to states
associated with the national UIC database.
Start-up costs for states that have UIC databases include the costs associated with developing the data to
transfer to the National UIC Database and setting up the data flow process. EPA estimates that, on average, the
total “data development” burden to these programs is about 310 hours. Annualizing the effort over the estimated
6-year phase-in schedule, this equals 51.6 hours per program annually, of which 10 hours will be conducted by
state staff (the remaining work will be performed by contractors).
States with existing data bases will also need to set up a data flow (i.e., data mapping, conversion to
Extensible Markup Language, and setting up the data transfer through EPA’s Central Data Exchange). The total
data flow burden is estimated to be 210 hours per program. Annualized over 6 years, this equates to 35 hours
per year per program, of which 25 hours are state burden.
To assist states without a UIC data base, EPA Headquarters developed an Access database. Because the
database would be designed to the needs of the National UIC Database and Headquarters would perform the
basic programming, the start-up effort for states without a UIC data base is assumed to be less intensive than for
those states that already have a database. EPA estimates the start-up burden to these state programs is 250
hours/ program (state and contractor labor), or 41.6 hours per year, annualized over 6 years. Of this, 8 hours will
be state burden.
Following establishment of a data flow, states will need to enter UIC data into their data bases; EPA
estimated that states will spend 40 hours annually on this ongoing effort. States will also submit their data to the
National UIC Database and respond to QA and data validation issues. EPA estimates that these tasks will
require 4 hours, and be incurred twice annually (8 hours total).
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Table A-7
Annual State Burden and Cost for Program Oversight and Reporting
A
B
C
D
Hours and Costs per Response
Description of Requirement
Program Oversight
Oversee and implement UIC program in the State, for
example, update regulations or guidances as needed.
7520 Forms Reporting
Frequency
E
F
Total Hours and Cost
Unit Labor
Cost
Unit Nonlabor
Cost
1,040
$43,081
$0
58
60,320
$2,498,696
4.5
$186
$0
18
83
$3,417
6.0
$249
$0
37
220
$9,113
5.5
$228
$0
37
202
$8,354
5.0
$207
$0
18
92
$3,797
2.0
$83
$0
73
147
$6,076
60
$2,485
$0
18
1,100
$45,566
60
$2,485
$0
18
1,100
$45,566
10
$428
$
3,782
7
76
$30,870
25
$1,036
$
2,082
7
183
$22,866
8
$345
$
4,219
5
42
$22,822
40
4
$1,657
$166
$0
$0
40
79
1,587
317
$65,726
$13,145
40
$1,657
$0
18
435
733
66,201
$30,378
$2,806,393
Unit Burden
Number of
Responses
Total
Hours/Year Total Cost/Year
Ongoing
Complete and submit Permit Review and Issuance Form Annual
(7520-1)
Complete and submit Compliance Evaluation Form (7520- Semi-annual
2A)
Complete and submit Compliance Evaluation for
Significant Non-Compliance Form (7520-2B)
Semi-annual
Complete and submit Mechanical Integrity
Tests/Remedial Action Form (7520-3)
Annual
Complete and submit Quarterly Exceptions List Form
(7520-4)
Quarterly
Inventory and Measures Reporting
Conduct inventory-related activities, e.g., review operator Annual
data and report to EPA's online inventory data system.
Report on UIC Measures to Headquarters
Annual
Activities related to populating the National UIC Database
Start-up activities (per program)
Develop data to meet UIC database needs (programs
One-time
with UIC databases)
Build data flow through data node (programs with UIC
One-time
databases)
Build data flow through data node (programs without
One-time
databases)
Ongoing activities (per program)
Enter UIC data into state database
Ongoing
Data flow and QA checks
Semi-annual
Recordkeeping
Maintain records of 7520 forms
Ongoing
Notes:
There may be more than one agency per state with Primacy authority.
EPA assumes that once states transition to electronic reporting, they will no longer complete 7520 forms or submit inventory and measures data to EPA. See Appendix B.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
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A.2 Estimating the Respondent Universe
In this section, EPA describes the number of respondents subject to each paperwork activity in this ICR.
The number of responses for each activity is shown in Column D of Tables A-1 through A-7. This number,
known as the respondent universe, is based on EPA’s assumptions of the number of permittees subject to each
paperwork requirement, e.g., the number of permit applications or well closures expected, or the percent of
permittees subject to monitoring or reporting requirements and the frequency with which they must comply
with those requirements. The frequency at which each activity is performed is also presented in Tables A-1
through A-7, along with EPA’s description of each activity. Specific assumptions about the respondent
universe for each well class are described below.
Class I
EPA inventory data indicate that there are 845 Class I wells, of which 140 inject hazardous waste, and
705 inject nonhazardous waste.
Class I Hazardous
According to EPA’s inventory, there are 140 Class I hazardous waste wells, with an average of 1.9 wells
at each facility. EPA estimates that 8 new Class I hazardous waste facility operating permits will be issued each
year (6 for one new well at an existing facility, and the remaining two for newly constructed facilities). EPA
further anticipates that 12 Class I hazardous facility operators will renew their permits each year; 5 will modify
their permits each year, and 6 operators will modify their petitions each year. EPA estimates that, on average,
1.4 owners or operators of Class I hazardous waste well will apply for aquifer exemptions each year, and that all
of these will constitute non-substantial revisions to their state’s UIC program. All operators of Class I hazardous
waste facilities must monitor and report at various frequencies (see Table A-1A). EPA expects that one Class I
hazardous well will close during each year of the life of this ICR.
Class I Nonhazardous
EPA estimates that there are 705 Class I nonhazardous waste wells at 371 facilities, an average of 1.9
wells per facility. The Agency estimates that 14 new nonhazardous waste injection permits will be issued each
year. EPA anticipates that 20 Class I nonhazardous facility operators will renew their permits each year, and 9
Class I nonhazardous facility operators will modify their permits each year. EPA estimates that, on average, 2.4
owners or operators of Class I nonhazardous waste well will apply for aquifer exemptions each year, and that all
of these will constitute non-substantial revisions to their state’s UIC program. Every operator of a Class I
nonhazardous waste facility must monitor and report at various frequencies, as shown in Table A-1B. Based on
past data, EPA anticipates that one Class I nonhazardous well in a primacy state will close each year.
Class II
The UIC inventory includes 176,516 Class II wells. EPA assumes that the typical Class II facility has
approximately 10 wells, thus there are approximately 17,652 Class II facilities.
EPA anticipates that, collectively, EPA regional offices and primacy states will receive approximately
8,983 permit applications for Class II wells each year during the life of this ICR. Details of the numbers of
Class II operators subject to each paperwork requirement are presented in Column D of Table A-2.
Based on previous studies of state AoR practices and requirements, EPA projects that state primacy
agencies and EPA Regions will determine that a complete AoR is not necessary for approximately 80 percent of
Underground Injection Control Program – Information Collection Request
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permit applications, and the remaining applicants will submit an AoR map and an AoR study as part of the
permit application. EPA estimates that 898 applicants will submit corrective action plans to address specific
problems identified by the AoR study, and that EPA regional or state primacy staff will require 20 percent of
these owners or operators to revise their corrective action plans.
EPA estimates that 269 Class II owners or operators will apply for aquifer exemptions each year, and
that all of these will constitute non-substantial revisions to their state’s UIC program. EPA also estimates that
30 owners or operators of production wells in DI states will perform HF using diesel fuels and be subject to the
permitting and monitoring and reporting recommendations in the DFHF Guidance.
Prior to obtaining approval to begin injection, operators must demonstrate mechanical integrity and
submit completion reports for an estimated 8,585 new Class II wells each year.
EPA estimates that approximately 88,258 Class II wells (50 percent of the inventory) are permitted, and
that 20 percent of operators will undergo permit reviews each year, and half of these will need to respond to
issues raised during the reviews. In addition, EPA expects that 2,648 Class II operators will submit requests for
permit modifications.
EPA projects that 17,682 Class II well owners or operators will perform annual MITs and sample
ground water and report the results to the permitting authority each year.
EPA projects that, each year, approximately 1,044 operators will plug and abandon their wells. In
addition, EPA assumes that approximately one operator in a DI program will elect to plug its wells in a manner
different from the one specified in its plugging and abandonment plan, triggering a revision to the plugging and
abandonment plan.
Class III
EPA estimates that there are approximately 171 facilities with Class III wells (10 uranium mining, 47
salt solution mining, and 114 brine mining/other sites). A typical uranium facility has approximately 2,072
Class III wells, a typical salt mining facility has 19 wells, and a typical brine mining/other facility has 2 wells.
EPA regional offices and state primacy agencies expect to receive 32 permit applications from Class III
operators each year. EPA estimates that, on average, 0.2 Class III owners or operators will apply for aquifer
exemptions each year, and that all of these will constitute non-substantial revisions to their state’s UIC program.
Operators of all 171 Class III facilities will monitor injection pressure, flow rate, or volume of injected
fluids semi-monthly, or meter injected and produced fluid volumes continuously. EPA anticipates that
operators of salt solution mining facilities will submit analyses of their injectate once each year, and operators
of salt solution mining facilities will perform two-part MITs on all of their wells every five years. All uranium
well operators monitor water quality in the injection zone and overlying freshwater aquifers either semimonthly or monthly. EPA estimates that approximately 2 Class III operators will close their projects annually.
Class IV/Endangering Class V
Based on UIC measures data reported by the states in 2003, EPA anticipates that 990 Class IV wells and
endangering Class V wells will close each year. EPA estimates 23 percent of Class IV and endangering Class V
wells are in DI states.
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Class V
The current EPA inventory of Class V wells includes 479,838 wells. This number is imprecise, and it is
estimated that perhaps 3 to 5 times as many Class V wells actually exist. EPA anticipates that approximately
24,860 operators of Class V facilities will submit inventory information each year over the life of this ICR,
based on trends in the UIC program inventory.
Facilities Subject to the Class V Rule
The Class V rule required that all large-capacity cesspools be closed and that all motor vehicle waste
disposal wells (MVWDWs) either close their well or obtain a permit by 2007 (the burden associated with these
activities was estimated in previous UIC Program ICRs). EPA assumes that most facilities affected by the Class
V Rule will have closed their wells or obtained a permit by this time; however, a limited number of largecapacity cesspools and MVWDWs are expected to be identified during the course of inspections or other
activities. EPA understands that primacy agencies have focused their efforts on closing MVWDWs and not
issuing permits. Thus, this ICR assumes that some permitting and closure activities associated with Class V
Rule will occur during this clearance period.
EPA estimates, based on data from the states, that operators of 20 large-capacity cesspools need to close
their facilities during the clearance period (an average of 7 per year). In addition, EPA estimates that operators
of 285 MVWDWs (95/year) will close and 15 MVWDW operators (5/year) will apply for a permit during the
clearance period. Furthermore, operators of 1,479 MVWDWs that have opted to obtain a permit will conduct
quarterly injectate sampling and annual sludge sampling, as required under the Class V rule.
Class VI
EPA estimates that, over the clearance period, 10 owners or operators will apply for a Class VI permit.
Of these, 9 will be in DI states, and the other will be in a primacy state (and one will be accompanied by an
application for an injection depth waiver). On an annualized average basis, this equates to primacy states
processing 0.33 permit applications per year and DI states reviewing 3 permit applications per year.
Permit application reviews and the subsequent drilling procedures take up to a few years to complete.
Thus, EPA assumes that by the end of the clearance period, 10 wells will be in operation, with most beginning
operations in the second and third years of the clearance period. EPA does not anticipate that any Class VI well
owners or operators will perform AoR reevaluations or post-injection site care /site closure activities during the
clearance period. EPA estimates that 7 states will apply for Class VI primacy during the clearance period.
States as Respondents
EPA assumes that 58 primacy agencies in 40 states and two tribes (Navajo and Fort Peck) will report
UIC data to EPA, either electronically or on paper forms. This number reflects the fact that, in some states,
more than one agency oversees UIC activities (e.g., states typically regulate Class II wells through agencies
other than those overseeing other classes of wells for which they have primacy).
Because of the effort involved in initiating data transfer to the National UIC database EPA assumes that
states will accomplish this at varying paces, depending on many variables including available funding and staff.
This results in a phased-in schedule for populating the National UIC Database. EPA estimates that, at the
beginning of this information collection, 14 programs will have transitioned to electronic reporting. Fifteen (15)
additional programs are expected to transition to e-reporting in 2015; 10 programs are expected to do so in
2016; and the remaining 12 programs are expected to transition in 2017.
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| File Type | application/pdf |
| File Title | Microsoft Word - Appendix A v1 |
| Author | shari.ring |
| File Modified | 2014-12-16 |
| File Created | 2014-06-10 |