Appendix C

Appendix C: UIC Program Owner or Operator Burden Reduction Efforts
In 2017 and 2018, EPA examined the UIC Program’s reporting forms to identify ways to reduce
the reporting burden on injection well owners or operators while maintaining USDW protection.
The workgroup identified elements on the forms that could be deleted or clarified, revised the
form instructions, and combined some of the forms. These changes improve clarity, reduce the
need for revising/correcting submitted information, and decrease the time needed to process UIC
requests, e.g., for permits. Collectively, these changes will reduce UIC reporting burden by
10,595 hours (approximately 3.5 percent) annually. This appendix describes the changes to the
forms and the resultant burden reductions.
Background
Owners or operators of injection wells submit information via the 7520 reporting forms
throughout the duration of an injection project to meet the Underground Injection Control (UIC)
Program’s requirements. 1 This information is submitted prior to injection to demonstrate that the
wells will be sited/constructed to protect underground sources of drinking water (USDWs),
during well operations to verify that the well is operating as designed, and after closure to
confirm that the well will not allow fluid movement that could endanger USDWs.
In 2017, EPA formed a workgroup to examine each of the reporting forms and identify ways to
reduce owner or operator burden while maintaining USDW protection. The workgroup identified
elements of the forms that could be deleted, significant and minor changes that clarify the
information being requested, and improvements to the forms’ instructions. These revisions:
•

Reduce the burden necessary to complete the forms.

•

Improve the likelihood that the forms will be submitted correctly (and therefore reduce
the time to process UIC requests).

•

Simplify the reporting process (particularly to small businesses)—while continuing to
provide EPA with all of the information needed to ensure USDW protection.

None of the technical activities associated with reporting UIC information have changed, as the
UIC program’s USDW-protective requirements have not changed. Therefore, these changes
reduce the clerical (i.e., non-technical) burden associated with completing the forms.
Burden Reduction by Form
The sections below describe the changes EPA made to each of the owner or operator reporting
forms, along with the resultant burden change. Table 1 (on the last page of this appendix)
summarizes all of the changes. These changes fall into three categories:
•

Deletions of fields that request information that can be reported in other ways or that
already exists in the permit record.

1

The 7520 forms must be used by owners or operators of wells in states where EPA directly implements the UIC
program; states with primary enforcement authority may use these forms or an equivalent form.

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•

Significant changes that reflect EPA’s recognition of how information is generated or
collected by well owners or operators or that allow submittal of documents generated as a
customary business practice. These changes reduce owner or operator time spent on
repackaging information solely for the purpose of reporting.

•

Minor changes that: clarify or better define what EPA needs, provide continuity across all
submittals over the duration of a project, or streamline the reporting of common
information.

7520-6: Permit Application
The permit application form is completed by applicants seeking UIC permits; it is primarily used
by owners or operators of Class I, Class II, and Class III wells, although prospective owners or
operators of some technically complex Class V wells may apply for UIC permits in limited
cases. EPA made the following changes to the permit application form:
•

Deleted three fields, including: legal contact, number of existing wells, and number of
wells per type.

•

Implemented two changes that clarify the information needed regarding ownership type
and commercial facilities. EPA also made minor clarifications to reduce the need for
double entry of contact information, reference a list of available SIC codes, and clarify
the information requested related to well status and latitude/longitude.

•

Created separate permit application forms and instructions tailored to each class of
injection well. EPA also significantly clarified the instructions for the attachments to the
permit application form. The revised instructions are organized to facilitate completing
the required attachments. For example, all of the information related to specific topics
(e.g., AoR and corrective action, site geology, well construction, or testing and
monitoring) is presented together to improve understanding. The instructions also expand
on and clarify the information EPA is requesting of each well class. These changes will
help permit applicants improve the quality of their submittals and potentially reduce the
need for revisions/corrections to the permit application, which will ultimately save
burden and the total time needed to complete the application process.

Overall, these changes reduce the clerical burden associated with permit applications by 3 to
4%, 2 saving permit applicants 713 hours annually (most of this savings is to Class II applicants,
due to the number of Class II permit applications submitted annually).
7520-7: Application to Transfer Permit/Ownership
This form, which may be submitted by Class I, II, and III well owners or operators occasionally
during the permit term, ensures that the Director has current information on who owns/operates
the well. EPA made the following changes to this form:

2

The percent reduction in the clerical burden varies by well class because EPA estimates different reporting burdens
for each class of injection well based on the specific activities performed to meet the class-specific requirements.

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•

Deleted six fields that are not relevant to processing the ownership transfer, including:
name/address of surface owner; a graphical depiction of the township, range, and section
of the well location; well status; type of permit; number of wells; and lease number.

•

Clarified what is requested in the well activity field.

•

Developed instructions to clarify the information requested.

These changes collectively reduce the clerical burden associated with submitting Form 7520-7
by 7 to 13%, for an overall annual savings of 91 hours.
7520-8: Quarterly Injection Well Monitoring Report
The Injection Well Monitoring Report must be submitted by owners or operators of non-Class II
wells (primarily Class I and III wells) quarterly during injection operations. It provides
information to demonstrate that the well is operating in compliance with the UIC permit and has
mechanical integrity or to provide early indication of USDW endangerment. EPA made the
following changes to the quarterly monitoring report:
•

Clarified the monthly total volume and yearly cumulative volume injected fields to better
align to how injection well owners or operators record this information. Because each of
these items is reported for each of three months, this equates to 6 significant clarifications
to the form.

•

Clarified that reporting of minimum, average, and maximum temperature and minimum,
average, and maximum pH need only be reported if these are specified in the UIC permit.
Because each of these parameters is reported for each of three months, this equates to 18
significant clarifications.

•

Developed instructions that describe and clarify the information to be reported.

These changes reduce the clerical burden to Class I and Class III well owners or operators
associated with quarterly reporting of monitoring results by 4 to 11%, for a total annual burden
savings of 4,338 hours.
7520-11: Annual Class II Disposal/Injection Well Monitoring Report
Owners or operators of Class II wells must submit annual monitoring reports to demonstrate that
the well is operating as planned and has mechanical integrity or provide early indication of
USDW endangerment. EPA made the following changes to the annual monitoring report:
•

Deleted name/address of surface owner; township, range, and section depiction; type of
permit; and number of wells.

•

Deleted average injection pressure and minimum injection pressure; because both of
these parameters are reported for each month of the year, this equates to 24 deletions
from the form.

•

Clarified that reporting the tubing-casing annulus pressure is required only if it is
specified in the UIC permit; because this is reported for each month of the year, this
equates to 12 changes to the form.

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•

Clarified what must be reported for well activity and lease name.

•

Provided instructions that describe or clarify the information to be reported.

These changes reduce the clerical burden associated with annual reporting on Class II monitoring
by approximately 6%, for a total annual burden savings of 1,500 hours.
7520-16: Inventory of Injection Wells
The inventory form is submitted by owners or operators of Class V wells before the well is
constructed to provide basic information about the well (in lieu of a permit application) to ensure
that the Director is aware of the existence of the well. EPA made the following changes to the
inventory form:
•

Deleted four fields that are not critical to maintaining the injection well inventory
including: transaction type, numeric county code, facility ID, and ownership.

•

Changed the format to facilitate data entry of the requested information about the facility
and the legal contact.

•

Clarified the instructions for entering latitude and longitude information.

These changes collectively reduce the clerical burden to Class V well owners or operators
associated with submitting inventory information by approximately 31%, for an overall annual
savings of 2,811 hours.
7520-17: Pre-Closure Notification Form
Class V well owners or operators submit a pre-closure notification form before plugging their
well to demonstrate to the Director that the well will be plugged in a manner that will not allow it
to become a conduit for fluid movement that could endanger USDWs.
This form was developed in 1999 in connection with an effort to use “plain English” and make
the reporting requirements as brief and clear as possible. Therefore, the pre-closure notification
form presented limited need for clarification. EPA made the following changes to the pre-closure
notification form:
•

Deleted the name of preparer field.

•

Changed the format to facilitate data entry of the requested information about the facility
and the owner or operator.

•

Clarified what must be reported regarding the well’s construction.

Overall, these changes reduce the clerical burden associated with pre-closure notifications by
approximately 14%, saving Class V well owners or operators 90 hours annually.

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7520-18: Completion Report for Injection Wells
The well completion form, which must be submitted following construction or conversion of a
well, provides information to verify that the well was constructed as planned in order to ensure
that injected fluids will remain within the identified injection zone.
As part of the burden reduction effort, EPA merged the former Completion Form for Injection
Wells (Form 7520-9) with the Completion Report for Brine Disposal, Hydrocarbon Storage, or
Enhanced Recovery (Form 7520-10) into a significantly streamlined form that allows owners or
operators to submit limited information on the form and attach contractor/service company
reports or similar documents that are developed as a customary business practice.
•

For Class II well owners or operators (who submit 97 percent of all completion reports),
this reduced the number of fields that were previously on Form 7520-10 from 39 fields to
22 fields. These owners or operators will no longer need to record: the name/address of
the surface owner; township, range, and section depiction; type of permit; number of
wells; well activity; lease name; anticipated daily injection pressure; type of injected
fluid; casing and tubing information (i.e., outside diameter, weight, depth); stimulation
information (i.e., interval treated, materials used); wireline log types and intervals logged;
and cement information (i.e., sacks and class of cement, and the depth and diameter of
the borehole cemented).

•

Other owners or operators who previously reported on Form 7520-9 no longer need to
report: name/address of owner or operator, facility address, well status, well activity, type
of permit, number of wells, or lease number. Because Form 7520-9 already requested
limited information, fewer deletions were needed to streamline the form.

Additionally, EPA:
•

Clarified six fields on the previous Form 7520-10 and two of the fields that were on Form
7520-9.

•

Clarified the instructions (particularly those for Class II well owners or operators) to help
owners or operators improve the quality of their submittals so that multiple
revisions/corrections are not needed, which will ultimately save burden.

These changes reduce the clerical burden to Class I and Class III well owners or operators by 2
to 4% and the clerical burden associated with Class II completion reporting by 30%, for an
overall annual savings of 914 hours.
7520-19: Well Rework, Plugging & Abandonment Plan, or Plugging & Abandonment Affidavit
A Plugging and Abandonment Plan must be submitted with a Class I, II, or III permit application
to provide information to demonstrate that the well will be plugged in a manner that will not
allow it to become a conduit for fluid movement. Following closure of the well, a report is
submitted to document the procedures followed. Additionally, owners or operators may
occasionally need to submit information on well reworks during the permit term so the Director
can ensure that well maintenance activities will be conducted in a manner that will not
compromise the integrity of the well.

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EPA merged the former Well Rework Record (Form 7520-12) and Plugging and Abandonment
Plan (Form 7520-14) to streamline the information reported and afford burden savings where
owners or operators can update previously submitted information and attach reports that are
developed as a customary business practice and that could be interpreted more easily. EPA also
developed instructions for the form to clarify the information needed and reduce confusion.
To reduce the burden associated with submitting information about well reworking that was
previously reported on Form 7520-12, EPA:
•

Deleted six fields, including: name/address of contractor; the graphical depiction of the
township, range, and section of the well location; total depth before rework; total depth
after rework; type of permit; and number of wells.

•

Simplified the reporting of technical information by allowing owners or operators to
submit contractor/service company reports or similar documents in lieu of entering the
information on the form. This change eliminates burdensome data entry of information
about: casing record before rework (i.e., casing size and depth, cement sacks and type,
top and bottom of perforations, and treatment record); casing record after rework (i.e.,
casing size and depth, cement sacks and type, top and bottom of perforations, and
treatment record); rework operations; and wireline log information (type and intervals).

•

Clarified what must be reported regarding the well type and well identifying information.

To reduce the burden associated with reporting on well plugging and abandonment that was
previously submitted on Form 7520-14, EPA:
•

Deleted five fields, including: name/address of owner or operator, well location
depiction, lease name, type of authorization, and number of wells.

•

Eliminated data entry of technical information related to: casing and tubing record after
plugging (i.e., size, weight, put in well, left in well, hole size); method of plug
emplacement; cementing information (i.e., size of hole or pipe, depth to bottom of tubing
or pipe, sacks of cement, slurry volume, calculated top of plug, measured top of plug,
slurry weight, and type of cement); and information on open hole and/or perforated
intervals. Other significant burden reduction changes are provided by no longer requiring
the owner or operator to enter information about Class II subtypes or the cost estimate on
the form.

•

Clarified what must be reported regarding the locational and well identifying information.

These changes reduce the clerical burden associated with reporting on planned well reworking
by 10 to 19%, and reporting associated with well plugging and abandonment by 4 to 17%, for a
total annual savings of 139 hours.
Total Burden Reduction
Collectively, the changes described above will reduce annual burden to injection well owners or
operators associated with completing the UIC reporting forms by 10,595 hours, an annual burden
savings of approximately 3.5 percent. Figure 1 below summarizes this information, presenting
the previous and revised unit and total burdens for each form, along with the total annual burden
savings associated with the revisions to each form.

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Figure 1: Summary of 7520 Form Burden Reduction to Owners or Operators
Form

7520-6: UIC Permit Application

7520-7: Application to Transfer
Permit
7520-8: Injection Well Monitoring
Report
7520-9: Completion Form for
Injection Wells

7520-10: Completion Report for
Brine Disposal, Hydrocarbon
Storage, or Enhanced Recovery Well
7520-11: Annual Disposal/Injection
Well Monitoring Report
7520-12: Well Rework Record

7520-14: Plugging and
Abandonment Plan
7520-16: Inventory of Injection
Wells
7520-17: Pre-Closure Notification
Form

Previous total
Previous total
annual
annual burden,
burden, by
by form
class
1,262
1,396
58,913
53,187
2,029
1,040
3
4
1,392
1,351
34
7,368
57,543
23,175
27,000
32
160
56
72

Previous
burden/
response

I-H
I-NH
II
III
V
I-H
I-NH
II
III
I-H
I-NH
III
I-H
I-NH
III

8
14
1,289
18
10
1
1
270
6
295
1,448
900
8
14
18

217.1
104.0
61.4
123.7
104.0
3.0
4.0
5.0
6.0
25.0
16.0
30.0
4.0
4.0
4.0

II

1,228

4.0

4,911

4,911

3.3

4,001

4,001

910

II
I-H
I-NH
II
III
I-H
I-NH
II
III

5,316
1
1
270
6
8
14
1,289
18

30.0
3.0
4.0
5.0
6.0
6.6
6.6
6.0
8.0

159,468
3
4
1,351
34
53
92
7,734
144

159,468

29.7
2.9
3.9
4.7
5.8
6.1
6.1
6.0
7.9

157,969
3
4
1,262
33
49
86
7,699
141

157,969

1,500

1,301

91

7,976

48

V

19,276

0.5

9,638

9,638

0.4

6,827

6,827

2,811

V

659

1.5

989

989

1.4

899

899

90

1,392

8,024

Revised
burden/
response

Revised total
Revised total
annual
Total annual
annual burden,
burden, by
burden savings
by form
class
1,251
1,389
58,200
713
52,505
2,019
1,036
3
4
1,301
91
1,262
33
7,293
4,338
53,206
20,847
25,066
32
156
4
55
70

Number of
responses

Well classes
responding

214.9
103.5
60.8
123.1
103.6
2.9
3.9
4.7
5.8
24.7
14.4
27.9
3.9
3.9
3.9

Notes:
Forms 7520-9 and 7520-10 have been merged into a combined well completion form (Form 7520-18).
The Paperwork Reduction Act notice on Form 7520-9 reflected the estimated hours to complete the form and attachments; the “previous
burden/response” burden in the table above reflects the ICR estimate to complete the form.
Forms 7520-12 and 7520-14 have been merged into a combined well reworking and plugging and abandonment form (Form 7520-19).
Numbers may not appear to total due to rounding.

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Table 1: Changes to the 7520 Forms
Form
7520-6: Permit
Application

•
•
•

Deletions
Legal contact
Number of existing wells
Number of wells per type

•
•

Significant changes
Clarify instructions about reporting type of
ownership
Clarify instructions about what is meant by a
"commercial" facility

•

Minor clarifications
Reference “owner” contact information if
it is the same as operator
Reference a SIC code list
Clarify the well status information
requested
Use decimal system for latitude and
longitude (2 changes)
Replace “Well Activity” with “Well Type"

•
•

Eliminate first two Qtr/Qtr section entries
Replace “Well Activity” with “Well Type"

•
•
•
•

7520-7:
Application to
Transfer Permit

•
•
•
•
•
•

7520-8: Injection
Well Monitoring
Report

Name/address of surface owner
T-R-S depiction block
Well status
Type of permit
Number of wells
Lease number
•
•
•

7520-9:
Completion Form
for Injection
Wells

•
•
•
•
•
•
•

Name/address of owner or operator
Facility address
Well status
Well activity
Type of permit
Number of wells
Lease number

Change monthly total and yearly cumulative
volume units to barrels (6 items)
Clarify that minimum, average, and maximum
temperature need only be reported if specified in
the permit (9 items)
Clarify that minimum, average, and maximum pH
need only be reported if specified in the permit
(9 items)

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Form
7520-10:
Completion
Report for Brine
Disposal,
Hydrocarbon
Storage, or
Enhanced
Recovery Well

7520-11: Annual
Disposal/Injection
Well Monitoring
Report

7520-12: Well
Rework Record

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Deletions
Name/address of surface owner
T-R-S depiction block
Type of permit
Number of wells
Well activity
Lease name
Anticipated daily injection pressure
Type of injected fluid
Casing and tubing information (3
changes)
Stimulation information (2 changes)
Wireline log information (2 changes)
Cement information (4 changes)
Name/address of surface owner
T-R-S depiction block
Type of permit
Number of wells
Average pressure (12 changes)
Minimum pressure (12 changes)
Name/address of contractor
T-R-S depiction block
Total depth before rework
Total depth after rework
Type of permit
Number of wells

Significant changes
•
•
•
•
•

Minor clarifications
Replace “Well Activity” with “Well Type"
Clarify what is requested in the injection
interval fields (2 changes)
Re-title “Depth to Bottom of Lowermost
Freshwater Formation”
Replace “Lease name” with “Full well
name”
Clarify the instructions regarding
“Materials and amount used”

•

Clarify that reporting the tubing-casing annulus
pressure is only required if it is specified in the
permit (12 changes)

•
•

Replace “Well Activity” with “Well Type"
Replace “Lease name” with “Full well
name”

•

Replace requests for detailed information with
open space to describe the work, including:
o Casing record before rework (7 changes)
o Casing record after rework (7 changes)
o Rework operations
o Wireline logs (2 changes)

•

Clarify what is requested for “Well
Activity” by renaming as "Well Type"
Replace “Lease name” with “Full well
name”

Underground Injection Control Program – Information Collection Request

•

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Form
7520-14: Plugging
& Abandonment
Plan

•
•
•
•
•

Deletions
Name/address of owner or operator
T-R-S depiction block
Lease name
Type of authorization
Number of wells

•

•
•
7520-16:
Inventory of
Injection Wells

•
•
•
•

Transaction type
Numeric county code
Facility ID
Ownership

•

7520-17: PreClosure
Notification Form

•

Name of preparer

•

•

•

Significant changes
Replace requests for detailed information with
open space to describe the planned work,
including:
o Casing and tubing record after plugging (5
changes)
o Method of cement plug emplacement
o Information about cement plugs (8 changes)
o Open hole and/or perforated intervals (4
changes)
No longer report Class II subtypes in well class
Allow the owner or operator to attach the well
plugging cost estimate
Combine facility name and address into a single
space to facilitate data entry
Combine legal contact name, address, and
organization into a single space to facilitate data
entry
Combine facility name and address into a single
space to facilitate data entry
Combine owner or operator name and address
into a single space to facilitate data entry

•
•

Minor clarifications
Eliminate first two Qtr/Qtr section entries
Replace “Lease name” with “Full well
name”

•

Clarify latitude and longitude instructions

•

Replace “Well construction” with “well
sub-type”

Notes:
The forms listed on this table reference the previous form numbers. EPA merged Forms 7520-9 and 7520-10 into a combined well completion form (Form
7520-18), and Forms 7520-12 and 7520-14 into a combined well reworking and plugging and abandonment form (Form 7520-19).

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