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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 well class. Tables A-1
through A-7 contain detailed estimates of the number of respondents and unit burden hours for required
paperwork-related activities. Legal, managerial, technical, and clerical staff hours are shown; Column A
presents the total unit burden for each activity.
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 estimates of the annual paperwork burden on operators of Class I hazardous and Class I
nonhazardous waste injection wells associated with permitting, monitoring and testing, reporting and
recordkeeping, and closing their facilities and state burden for oversight of Class I operators are presented in
Tables A-1A and Table A-1B, respectively.
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)
Legal
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Unit Labor
Burden
Cost
Unit Non-
No. of
Total
labor Cost (B) Responses Hours/Year Total Cost/Year
Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications
Read permit application directions.
One-time
Gather and submit description of activities requiring a
One-time
0.0
0.25
0.25
0.00
0.5
$38
$0
36
18
$1,379
3.0
2.0
9.0
5.8
19.8
$1,176
$0
36
711
$42,354
4.0
0.0
0.0
1.2
5.2
$422
$0
6
32
$2,609
0.0
1.5
5.5
0.0
7.0
$454
$25,643
36
252
$939,490
0.0
0.0
1.3
0.0
1.3
$73
$993
36
47
$38,388
0.0
1.5
16.0
0.0
17.5
$1,043
$53,239
36
630
$1,954,133
0.0
2.0
5.0
1.0
8.0
$506
$7,642
36
287
$293,332
permit, facility name and address, SIC codes,
ownership & facility status, facility location, listing of
relevant permits/construction approvals,
description of the business.
In DI programs, gather and submit a list of land
One-time
owners within one-quarter mile of the facility boundary.
Prepare and submit a map and tabulation of all wells withOne-time
the AoR.
Prepare and submit AoR protocol.
One-time
Prepare and submit maps/cross sections of local and
One-time
regional geology, USDWs.
Develop formation testing and stimulation programs
One-time
& injection procedures.
Prepare and submit contingency plans for shut-ins
One-time
0.0
3.0
10.0
1.9
14.9
$915
$297
36
537
$43,650
Prepare and submit ambient monitoring plan.
One-time
0.0
3.0
0.0
0.0
3.0
$287
$5,010
36
106
$190,665
Prepare and submit Corrective Action Plan.
One-time
0.0
2.0
3.0
2.2
7.2
$435
$12,694
36
259
$472,650
Prepare and submit descriptions of logs and tests,
One-time
0.0
2.0
8.0
4.8
14.8
$801
$6,368
36
533
$258,084
0.0
1.0
3.0
2.1
6.1
$336
$1,877
36
221
$79,637
0.0
1.4
2.0
1.3
4.7
$291
$2,310
36
169
$93,623
0.0
2.5
17.0
0.5
20.0
$1,213
$2,310
6.1
122
$21,555
or well failures.
construction schematics & operating data.
Prepare and submit closure plan, including demonstrationOne-time
of financial responsibility.
Prepare and submit post-closure care plan.
One-time
Prepare and submit information to support an aquifer
One-time
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)
Legal
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Unit Labor
Burden
Cost
Unit Non-
No. of
Total
labor Cost (B) Responses Hours/Year Total Cost/Year
Requirements for active hazardous waste facilities
Gather and submit dates of well operation and
One-time
0.0
0.0
26.6
10.9
37.5
$1,852
$9,680
36
1,351
$415,126
0.0
1.9
30.4
21.9
54.2
$2,609
$4,840
0
0
$0
0.0
1.9
15.2
1.8
18.9
$1,097
$3,227
36
681
$155,645
schedule.
Requirements associated with completion reports
0.0
0.0
0.5
0.5
1.0
$44
$0
36
35
$1,578
Prepare and submit completion report.
One-time
0.0
0.0
1.5
2.4
3.9
$164
$0
36
142
$5,916
Submit results of deviation checks, other
One-time
0.0
0.0
6.0
1.0
7.0
$369
$39,059
36
251
$1,419,377
0.0
2.0
18.0
0.0
20.0
$1,204
$25,473
36
720
$960,358
0.0
0.0
2.0
0.0
2.0
$112
$170
36
72
$10,151
0.0
1.0
4.0
0.0
5.0
$321
$42,455
36
180
$1,539,952
0.0
0.0
1.0
0.0
1.0
$56
$170
36
36
$8,132
0.0
2.0
6.0
0.0
8.0
$531
$8,491
36
288
$324,782
0.0
0.0
2.0
0.0
2.0
$112
$3,396
36
72
$126,308
0.0
24.0
120.0
30.0
174.0
$10,047
$891,555
36
6,264
$32,457,677
21.0
71.5
$3,892
$12,567
12
858
$197,506
specific waste information.
Gather and submit hazardous waste release
One-time
information.
Develop waste analysis plan.
One-time
Prepare construction logging/testing
One-time
logs & tests; sample formation fluids;
test injection and confining zones.
Demonstrate mechanical integrity.
One-time
Submit information on the anticipated
One-time
maximum pressure and flow rate.
Submit formation testing results.
One-time
Submit actual injection procedure.
One-time
Demonstrate hydrogeologic compatibility/
One-time
compatability of well materials.
Prepare and submit information on calculated
One-time
AoR.
No-migration petition requirements
Submit waste information and modeling data
One-time
to demonstrate that wastes will not migrate
from injection zone.
Requirements associated with permit renewals/modifications and petition modifications
Submit updated permit application
Occasional
0.0
attachments.
Request Permit Modification.
One-time
Prepare and submit Petition Modification.
One-time
Underground Injection Control Program -- Information Collection Request
9.0
41.5
0.0
2.0
6.0
2.0
10.0
$597
$7,302
3
30
$23,696
0.0
24.0
120.0
30.0
174.0
$10,047
$843,966
6
1,044
$5,124,081
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)
Legal
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Unit Labor
Burden
Cost
Unit Non-
No. of
Total
labor Cost (B) Responses Hours/Year Total Cost/Year
Monitoring/Testing Requirements (Per Facility)
Use continuous recording devices to monitor injection
Continuous
pressure, flow rate, volume, and temperature.
Conduct chemical monitoring of injectate as
As specified
prescribed in waste analysis plan.
in WAP
Conduct additional chemical monitoring as specified
Varies
by the Director.
Conduct casing pressure test and radioactive tracer
0.0
0.0
5.7
0.0
5.7
$320
$0
73
414
$23,215
0.0
0.0
38.0
0.0
38.0
$2,131
$5,095
291
11,040
$2,099,177
0.0
0.0
7.6
0.0
7.6
$426
$1,019
29
221
$41,984
0.0
3.8
5.2
0.0
9.0
$661
$7,033
58
523
$447,048
0.0
1.0
7.0
0.0
8.0
$490
$48,399
15
116
$710,168
Annual
survey of bottom-hole cement.
Conduct casing pressure test, radioactive tracer of
Every 5
bottom-hole cement, & noise/temperature logs to
years
check for movement along the borehole.
Conduct casing inspection log at workover.
Occasional
0.0
3.8
8.0
0.0
11.8
$818
$8,440
4
43
$33,619
Conduct pressure fall-off test.
Annual
0.0
6.0
18.0
0.0
24.0
$1,592
$19,693
73
1,743
$1,545,941
Conduct ambient monitoring.
Annual
0.0
0.4
1.9
0.0
2.3
$143
$6,793
73
166
$503,791
0.0
4.0
15.0
5.7
24.7
$1,841
$0
291
7,188
$534,908
0.0
1.0
2.0
1.0
4.0
$290
$1,528
73
291
$132,094
0.0
1.0
2.0
3.0
6.0
$290
$0
1
4
$211
0.0
1.0
0.0
0.0
1.0
$96
$0
73
73
$6,975
0.0
1.0
1.0
0.9
2.9
$182
$0
4
10
$661
Reporting Requirements (Per Facility)
Prepare and submit report on maximum
Quarterly
injection pressure, total injectate volume, and
monitoring and testing results.
Prepare and submit MIT report.
Annual
Notify Director of: any planned physical
Occasional
changes to facility, changes that may result
in noncompliance, permit transfers,
planned workovers, USDW endangerment.
Prepare and submit revised plugging and
Annual
abandonment cost estimate.
Report on: events exceeding operating
Occasional
parameters or triggering alarms; changes in
annular fluid volume; workovers or other
testing; or permit transfers.
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)
Legal
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit
Unit Labor
Burden
Cost
Unit Non-
No. of
Total
labor Cost (B) Responses Hours/Year Total Cost/Year
Recordkeeping Requirements (Per Facility)
Maintain monitoring information, calibration &
3 years
maintenance records, required reports,
application data, monitoring
results, and most recent plugging &
abandonment cost estimate.
0.0
0.0
0.0
5.0
5.0
$164
$0
73
363
$11,947
Closure Requirements (Per Well)
Prepare and submit notice of intent to close.
One-time
0.0
0.5
0.0
1.0
1.5
$81
$0
1
2
$81
Prepare and submit closure report.
One-time
0.0
2.0
8.0
0.0
10.0
$643
$3,396
1
10
$4,039
Conduct pressure fall-off test.
One-time
0.0
1.0
5.0
0.0
6.0
$378
$19,693
1
6
$20,070
Demonstrate mechanical integrity.
One-time
0.0
2.0
18.0
0.0
20.0
$1,204
$31,789
1
20
$32,993
Notify state or local zoning or drilling
One-time
0.0
0.5
1.0
3.0
4.5
$203
$0
authorities
TOTAL
1
5
2,065
38,187
$203
$
53,350,957
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.
Unit Burden
Frequency (A)
(B)
Unit Labor
Cost
E
F
Total Hours and Costs
Unit Nonlabor
Cost
Number of
State
Responses
Total State
Hours/Year
Total State
Cost/Year
One-time
Provide public notice of issuance of a draft permit or intent to One-time
deny.
Consider public comments.
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review notice of completion of construction.
One-time
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
$1,837
$0
30
1,193
$54,768
1.0
$46
$0
30
30
$1,369
6.0
$276
$0
30
179
$8,215
2.0
$92
$0
30
60
$2,738
7.0
$321
$0
30
209
$9,584
2.0
$92
$0
30
60
$2,738
1.0
$46
$0
5
5
$233
18.0
$827
$0
30
537
$24,645
10.0
$459
$0
30
298
$13,692
10.0
$459
$0
5
50
$2,282
30.0
$1,378
$0
10
298
$13,692
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
Unit Burden
Frequency (A)
(B)
Quarterly
Annual
Unit Labor
Cost
E
F
Total Hours and Costs
Unit Nonlabor
Cost
Number of
State
Responses
Total State
Hours/Year
Total State
Cost/Year
1.5
$69
$0
241
361
$16,574
4.0
$184
$0
48
193
$8,840
Annual
4.0
2.0
$184
$92
$0
$0
12
46
48
93
$2,210
$4,254
Occasional
2.0
$92
$0
5
10
$456
2.0
$92
$0
1
2
$92
24.0
$1,102
$0
1
706
24
3,648
$1,102
$167,532
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
Unit
Unit Non-
Hours and Costs per Response
(A)
F
T otal Hours and Costs
Unit
Labor
Labor Cost
Managerial
Technical
Clerical
Burden
Cost
(B)
0.0
0.25
0.25
0.00
0.5
$38
$0
73
37
$2,796
3.0
2.0
9.0
5.8
19.8
$1,179
$0
73
1,448
$86,071
4.0
0.0
0.0
1.2
5.2
$423
$0
13
65
$5,298
0.0
1.5
5.5
0.0
7.0
$454
$20,514
73
511
$1,530,691
0.0
1.5
16.0
0.0
17.5
$1,043
$53,239
73
1,278
$3,962,547
0.0
2.0
8.0
2.4
12.4
$723
$6,368
73
908
$517,652
0.0
2.0
7.0
1.0
10.0
$619
$7,642
73
728
$603,031
0.0
3.0
10.0
1.9
14.9
$916
$297
73
1,091
$88,574
0.0
3.0
3.0
2.9
8.9
$556
$5,010
73
651
$406,269
0.0
2.0
3.0
2.2
7.2
$436
$9,765
73
528
$744,655
0.0
1.0
3.0
2.1
6.1
$336
$1,877
73
448
$161,486
0.0
2.5
17.0
0.5
20.0
$0
$0
12.4
248
$0
Frequency
Description of Requirement
E
Legal
No. of
Total
Responses Hours/Year Total Cost/Year
Initial/Startup Requirements (Per Permit Application)
Requirements associated with permit applications
Read permit application directions.
One-time
Gather and submit description of
One-time
activities requiring a permit,
facility name & address, SIC codes,
ownership & facility
status, facility location,
list of relevant permits/construction
approvals, description of the business.
In DI programs, gather and submit a
One-time
list of landowners within 1/4 mile of
the facility boundary.
Prepare and submit a map and
One-time
tabulation of all wells within the AoR.
Prepare and submit maps/cross
One-time
sections of local and regional geology,
USDWs.
Prepare and submit descriptions of
One-time
logs and tests, construction
schematics and operating data.
Develop formation testing and
One-time
stimulation programs and injection
Prepare and submit contingency plans One-time
for shut-ins or well failures.
Prepare and submit ambient
One-time
monitoring plan.
Prepare and submit Corrective Action
One-time
Plan.
Prepare and submit closure plan,
One-time
including demonstration of financial
responsibility.
Prepare and submit information to
One-time
support an aquifer exemption request.
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
Unit
Unit Non-
Hours and Costs per Response
(A)
Requirements associated with completion reports
Prepare and submit completion report. One-time
Prepare and submit a report of
F
T otal Hours and Costs
Unit
Labor
Labor Cost
Managerial
Technical
Clerical
Burden
Cost
(B)
0.0
0.0
1.5
2.4
3.9
$163
$0
73
285
$11,922
0.0
0.0
6.0
1.0
7.0
$368
$39,059
73
508
$2,878,151
0.0
2.0
3.5
0.0
5.5
$391
$11,038
73
402
$834,305
0.0
0.0
2.0
0.0
2.0
$112
$170
73
146
$20,584
0.0
1.0
4.0
0.0
5.0
$321
$42,455
73
365
$3,122,680
0.0
0.0
1.0
0.0
1.0
$56
$170
73
73
$16,490
0.0
2.0
6.0
0.0
8.0
$531
$8,491
73
584
$658,585
0.0
8.0
11.0
2.0
21.0
$1,460
$5,944
20
420
$148,068
0.0
2.0
6.0
0.0
8.0
$531
$4,246
5
40
$23,881
0.0
0.0
38.0
0.0
38.0
$2,131
$3,396
1,573
59,760
$8,692,292
0.0
0.0
5.7
0.0
5.7
$320
$0
393
2,241
$125,663
0.0
1.0
8.0
0.0
9.0
$546
$20,973
79
708
$1,692,034
0.0
8.0
16.0
0.0
24.0
$1,674
$19,693
393
9,436
$8,400,532
0.0
0.4
1.5
0.0
1.9
$122
$6,793
393
747
$2,718,665
Frequency
Description of Requirement
E
Legal
No. of
Total
Responses Hours/Year Total Cost/Year
One-time
deviation checks and other logs and
tests during construction.
Demonstrate mechanical integrity.
One-time
Submit information on the anticipated One-time
maximum pressure and flow rate.
Submit results of the formation testing One-time
program.
Submit actual injection procedure.
One-time
Demonstrate hydrogeologic
One-time
compatibility/ compatibility of well
materials.
Requirements associated with permit renewals/modifications
Submit updated components of permit Occasional
application attachments.
Prepare and submit request for permit Occasional
modification.
Monitoring/Testing Requirements (Per Facility)
Analyze injected fluids.
Per permit
Monitor injection pressure, flow rate
Continuous
and volume, and annulus pressure.
Demonstrate mechanical integrity.
Every 5
years
Conduct pressure fall-off test.
Annual
Conduct ambient monitoring.
Annual
Underground Injection Control Program -- Information Collection Request
Page A-9
Table A-1B
Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
A
B
C
D
Hours and Costs per Response
Frequency
Description of Requirement
(A)
Legal
Managerial Technical Clerical
E
F
Total Hours and Costs
Unit
Unit Non-
Unit
Labor
Labor Cost
Burden
Cost
(B)
No. of
Total
Responses Hours/Year Total Cost/Year
Reporting Requirements (Per Facility)
Quarterly
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
0.0
0.0
4.0
10.4
14.4
$566
$0
1,573
22,635
$890,438
0.0
2.0
6.0
4.0
12.0
$662
$1,406
393
4,718
$813,217
0.0
1.0
2.0
3.0
6.0
$308
$0
20
118
$6,054
0.0
1.0
0.0
0.0
1.0
$97
$0
131
131
$12,730
0.0
1.0
2.0
0.9
3.9
$240
$1,528
4
15
$6,953
0.0
0.0
0.0
4.0
4.0
$132
$0
393
1,573
$51,737
0.0
0.5
0.0
1.0
1.5
$81
$0
Annual
and pressure fall-off test.
Notify Director of: any planned physical Occasional
changes to facility, changes that may
result in noncompliance, permit
transfers, planned workovers, possible
endangerment to a USDW.
Submit periodic updates of financial
Occasional
responsibility for closure that account
for inflation.
Report results of: any required
Occasional
mechanical integrity tests, other
required tests, well workovers, or
permit transfers
Recordkeeping Requirements (Per Facility)
Maintain monitoring information,
At least 3
calibration & maintenance records,
years
required reports, application data,
and monitoring results.
Closure Requirements (Per Well)
Notify the Director before conversion or One-time
abandonment of the well or closure of
the project.
TOTAL
1
6,636
2
112,846 $
$81
39,234,131
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 Labor
Cost
Unit NonLabor Cost
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.
Unit Burden
(B)
E
Total Hours and Cost
Number of
State
Total State
Total State
Responses
Hours/Year
Cost/Year
20.0
$918
$0
6
121
$5,553
40.0
$1,837
$0
54
2,177
$99,951
1.0
$46
$0
60
60
$2,776
6.0
$276
$0
60
363
$16,659
2.0
$92
$0
60
121
$5,553
7.0
$321
$0
60
423
$19,435
2.0
$92
$0
60
121
$5,553
1.0
$46
$0
10
10
$472
30.0
$1,378
$0
17
497
$22,820
One-time
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
E
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.
TOTAL
Unit Burden
Frequency (A)
(B)
Every 5 years
Annual
Quarterly
Occasional
One-time
Unit Labor
Cost
Total Hours and Cost
Unit NonLabor Cost
Number of
State
Responses
Total State
Hours/Year
Total State
Cost/Year
4.0
2.0
$184
$92
$0
$0
65
326
261
651
$11,962
$29,906
2.0
$92
$0
1,303
2,605
$119,624
1.0
$46
$0
8
8
$380
1.0
$46
$0
1
2,092
1
7,419
$46
$340,691
Notes:
(A) For quarterly activities, the number of responses = number of facilities X 4.
(B) EPA assumes one well per facility for start-up and closure activities; and 1.9 wells per facility for all other activities.
Regions review 17 percent of MITs and 23 percent of pressure fall-off tests in primacy states.
Numbers may not add due to rounding.
Underground Injection Control Program -- Information Collection Request
Page A-12
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 that
is acceptable to permitting authorities and for using EPA-approved tests. These assumptions include the
following:
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 are likely to 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 the 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.
Underground Injection Control Program – Information Collection Request
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 via Form 7520-61 will be 215 hours per permit. (This unit burden incorporates the above assumptions
about customary business practices.) Applicants will also spend 6.1 hours developing the plugging and
abandonment plan and financial responsibility cost estimate, using Form 7520-19. 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 (Form 7520-18) will be 3.9 hours per facility. The burden to perform specific
activities related to completion reports (e.g., MITs and formation testing) 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 Class I hazardous 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.
1
References to the federal reporting forms are provided throughout this appendix; owners or operators in some primacy states may
report using state equivalents to these forms.
Underground Injection Control Program – Information Collection Request
Page A-14
Permit Renewals and Modifications
Class I operating permits are valid for up to ten years, after which operators must apply to renew their
permits. Additionally, from time to time, operators of Class I hazardous facilities may need to modify their
permits or their no-migration petitions. Paperwork submittals include: permit renewals, permit modifications,
and petition modifications.
EPA anticipates that the burden associated with renewing permits for a Class I hazardous facility will be
71.5 hours per renewal. Specific activities associated with 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 need 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 operations. 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 24.7 hours per report for completing monitoring reports
on a quarterly basis (on Form 7520-8), and 4 hours to report on the results of MITs. In addition, EPA assumes
that 5 percent of operators will spend 2.8 hours annually submitting various occasional reports (e.g., on changes
to the facility, permit transfers, planned workovers, noncompliance or anticipated noncompliance, or events
triggering alarms or shutdown devices) via Forms 7520-7 or 7520-19. 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 (Form 7520-6) add 104 hours to the customary
business activities of Class I nonhazardous facility operators. Applicants will also spend 6.1 hours developing
the plugging and abandonment plan and financial responsibility cost estimate, using Form 7520-19. Column A
of Table A-1B presents EPA’s estimates of unit 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.
Underground Injection Control Program – Information Collection Request
Page A-16
EPA estimates that the unit burden on Class I nonhazardous facility operators for preparing and
submitting completion reports (Form 7520-18) is 3.9 hours. This unit burden varies from that for Class I
hazardous facilities, as Class I nonhazardous facility operators are not required to submit information on the
calculated AoR. Burden estimates for specific activities associated with completion of new wells (e.g., MITs
and formation testing) are presented in Column A of Table A-1B.
Permit Renewals/Modifications
As with Class I hazardous facility operators, EPA assumes that applicants for Class I nonhazardous
injection permit renewals will revise 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. Approximately 20 percent of operators will spend 9 hours to demonstrate mechanical integrity each year.
Reporting and Recordkeeping
Operators will spend 14.4 hours per facility reporting quarterly on the chemical and physical
characteristics of injectate, flow rate, and volume (via Form 7520-8). Class I nonhazardous facility operators
will spend 12 hours per facility reporting on the results of ambient monitoring and pressure fall-off testing.
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 about 4
hours submitting additional reports (e.g., of changes to the facility, permit transfers, planned workovers,
noncompliance or anticipated noncompliance, or events triggering an alarm or shutdown) via Forms 7520-7 or
7520-19.
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.
Underground Injection Control Program – Information Collection Request
Page A-17
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
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.
The average burden for preparing permit application forms (Form 7520-6) and the supporting
documentation is approximately 61 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 complete 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 about:
6 hours to prepare plugging and abandonment plans (Form 7520-19);
19 hours to prepare financial responsibility information;
2 hours to prepare proposed operating data;
9.5 hours to prepare geological data on injection and confining zones;
2.5 hours to identify and determine depth to the bottom of USDWs; and
3 hours to prepare well schematics.
Underground Injection Control Program – Information Collection Request
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.
0.2
0.0
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
$44
$0
5,956
5,832
$260,892
1.0
0.4
1.5
$78
$0
5,956
8,835
$466,298
0.0
1.0
1.2
$51
$214
130
151
$34,429
0.0
0.6
4.8
0.6
6.0
$346
$0
5,956
35,574
$2,062,464
0.0
5.0
5.0
9.6
19.6
$1,081
$0
5,956
116,646
$6,440,656
0.0
0.3
2.9
0.2
3.4
$198
$0
596
2,020
$117,966
0.0
1.0
9.6
0.7
11.3
$658
$0
119
1,343
$78,324
0.0
0.0
1.0
0.0
1.0
$56
$42
1,324
1,324
$130,462
0.0
0.1
2.9
1.9
4.9
$235
$232
1,123
5,550
$524,287
0.0
0.1
1.8
0.1
2.0
$114
$0
5,956
11,887
$677,797
0.0
0.5
8.0
1.0
9.5
$529
$0
5,956
56,335
$3,148,909
0.0
0.1
2.3
0.1
2.5
$142
$255
5,956
14,865
$2,361,959
0.0
0.0
2.8
0.2
3.0
$163
$0
5,956
17,819
$972,703
0.0
2.5
17.0
0.5
20.0
$1,213
$0
179
3,574
$216,659
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.
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
1.8
3.3
$142
$0
5,658
18,439
$803,319
0.0
0.2
1.9
0.2
2.4
$139
$5,095
849
2,037
$4,441,804
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
0.0
7.0
$393
$229
5,658
39,607
$3,518,143
2.0
0.5
3.0
$177
$0
1,593
4,778
$282,171
2.8
0.8
4.0
$222
$0
773
3,092
$171,746
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.
0.0
0.0
2.0
0.0
2.0
$112
$51
63,708
127,415
$10,390,378
0.0
0.0
0.6
0.3
0.8
$41
$0
191,123
160,543
$7,762,126
0.0
0.0
3.0
0.0
3.0
$168
$2,293
43,003
129,008
$105,820,579
0.0
3.0
22.0
4.7
29.7
$1,680
$0
4,698
139,621
$7,894,184
0.0
0.0
0.5
0.5
1.0
$44
$0
37
37
$1,640
0.0
1.0
1.5
2.2
4.7
$253
$0
956
4,461
$241,360
0.0
0.0
3.3
1.7
5.0
$242
$0
15,927
79,635
$3,849,030
0.0
0.0
1.0
0.0
1.0
$56
$0
15,927
15,927
$893,091
Every 5 years
Reporting Requirements (Per Operator)
Gather and submit groundwater monitoring
Annual
data, analyses of injected fluids, a description
of geologic strata, and other items as
requested.
In DI programs, notify Regional Administrator Every 5 years
30 days prior to MIT.
Notify Director of: any planned physical
Occasional
changes to facility, changes that may result in
noncompliance, permit transfers, planned
workovers, 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.
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.
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
$155
$0
15,927
63,708
$2,465,013
0.0
0.5
2.5
1.0
4.0
$222
$0
0
1
$51
0.0
1.0
0.0
2.0
3.0
$163
$0
1,044
3,132
$170,102
0.0
0.0
4.5
1.5
6.0
$302
$306
23
137
$13,847
0.0
0.5
0.5
1.0
2.0
$110
$0
35
418,056
70
1,073,400
Occasional
TOTALS
$
$3,809
166,216,198
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
$276
$92
$92
$184
$230
$0
$0
$0
$0
$0
5,826
5,826
5,826
5,826
1,099
34,956
11,652
11,652
23,304
5,493
$1,605,162
$535,054
$535,054
$1,070,108
$252,251
2.5
2.0
$115
$92
$0
$0
1,324
5,535
3,310
11,069
$152,006
$508,301
1.0
$46
$0
166
166
$7,625
1.0
$46
$0
1,558
1,558
$71,539
4.0
$184
$0
756
3,024
$138,884
0.5
$23
$0
42,064
21,032
$965,780
0.3
$11
$0
15,579
3,895
$178,848
1.0
$46
$0
0
0
$0
Initial/Start-up
Permit applications (Per Permit Application)
One-time
Review permit application and supporting
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)
Every 5 years
Review mechanical integrity test data
submitted by operators.
Review monitoring data submitted by
Annual
operators.
Recordkeeping
One-time
Maintain administrative record in DI
programs.
Underground Injection Control Program - Information Collection Request
Total
Cost/Year
Page A-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
Frequency
E
F
Total Hours and Cost
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
Number of
Responses
Total
Hours/Year
2.0
$92
$0
935
1,869
$85,847
1.0
$46
$0
0
92,358
0
132,980
$0
$6,106,460
Other Reporting (Per Operator)
Respond to periodic notifications by owners Occasional
and operators.
Closure (Per Operator)
For DI programs, review plugging and
One-time
abandonment report.
TOTAL
Total
Cost/Year
Note: Numbers may not add due to rounding
Underground Injection Control Program - Information Collection Request
Page A-23
Based on studies of state AoR practices and requirements, EPA estimates that state primacy agencies
and EPA Regions will determine that a complete AoR study 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.
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 expects 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 historical information, 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 (Form 7520-18)
for each new Class II well (at an estimated 3.3 hours/report). 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 3.7 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 expects 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.
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 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 performing 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, 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 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.
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.
Underground Injection Control Program – Information Collection Request
Page A-25
Reporting and Recordkeeping
Each year, EPA estimates that Class II operators spend about 5 hours preparing annual monitoring
reports. These reports include summaries of monthly or weekly observations of flow, pressure, and cumulative
volume. In addition, EPA estimates that 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, planned workovers, progress in
achieving compliance milestones, and noncompliance or malfunctions that may endanger a USDW via Forms
7520-7 or 7520-19. EPA estimates that approximately 6 percent of operators submit one of these occasional
reports each year. Operators will spend an estimated average of 4.7 to 6.0 hours to prepare these reports.
Operators of rule-authorized wells in DI states may be required to gather and submit ground water
monitoring data, analyses of injected fluids, and other items as requested annually. EPA predicts that each
report (Form 7520-11) will take about 30 hours to prepare. In addition, operators of rule-authorized wells will
spend an estimated one hour per operator to notify the Region prior to performing MITs.
EPA predicts that each operator will spend about 4 hours annually to maintain records on permitting,
monitoring, and testing.
Closure
EPA estimates that each operator closing 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, EPA estimates that 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 4 hours reviewing each request for a permit
modification or renewal. EPA estimates that state staff will spend 1 hour per request reviewing aquifer
exemption requests for Class II owners or operators in their state and forwarding these requests to the EPA
Region for a determination.
Underground Injection Control Program – Information Collection Request
Page A-26
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 123 hours to prepare a new permit application form (Form
7520-6) and the required attachments. 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 approximately:
7.9 hours to prepare plugging and abandonment plans (Form 7520-19);
3.5 hours to demonstrate financial responsibility;
14 hours to prepare proposed corrective action plans;
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;
9 hours to prepare proposed operating data, formation testing and stimulation programs, and injection
procedures;
5 hours to prepare schematics of the wells; and
16 hours to prepare monitoring plans.
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 must also perform a two-part MIT and submit a well completion form. Operators of Class III
facilities, especially uranium mining facilities, typically develop their projects in multiple phases under the
same area permit and submit a single completion report (Form 7520-18) for the entire facility. Based on
conversations with operators and states, EPA estimates that operators of Class III wells will spend an average of
3.9 hours to prepare the completion report, 161 hours to demonstrate mechanical integrity at all wells, and 2.4
hours to 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 participate in 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
every two weeks, 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 twice 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 ensure that no mined ore is escaping
from the intended zone. EPA assumes that UIC requirements increase the time spent on monitoring for 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: a description of activities requiring a
One-time
permit; facility name and address; SIC codes; ownership and
facility status; facility location; and listing of relevant permits or
construction approvals.
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.
Prepare and submit information to support an aquifer
exemption request.
One-time
One-time
One-time
One-time
One-time
One-time
One-time
Legal
Managerial
0.0
Clerical
Unit Burden
Unit Labor
Cost
Unit NonLabor Cost
No of
Responses
Total
Hours/Year Total Cost/Year
$0
44
43
$1,937
0.0
0.5
0.5
1.0
$44
0.5
2.0
4.7
2.7
9.9
$595
$0
44
436
$26,194
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
1.5
1.9
1.9
1.0
3.3
1.2
7.9
3.4
13.9
10.0
31.9
$51
$407
$169
$819
$578
$1,846
$214
$0
$0
$0
$0
$1,265
4.5
44
44
44
0.9
44
5
346
151
613
9
1,404
$1,193
$17,897
$7,417
$36,033
$508
$136,871
0.0
0.0
18.0
3.9
21.9
$1,137
$255
44
963
$61,244
0.0
0.0
0.0
2.0
0.0
0.0
6.0
4.2
12.0
1.0
0.8
3.9
9.0
5.0
15.9
$563
$261
$801
$0
$0
$0
44
44
44
395
219
699
$24,758
$11,488
$35,232
0.0
2.5
17.0
0.5
0.0
20.0
$1,213
$0
0.4
9
$534
One-time
One-time
One-time
One-time
Requirements associated with completion reports (Per Facility)
Prepare and submit completion form and supporting
One-time
documentation.
Prepare and submit reports of appropriate logs and tests
One-time
during construction.
Demonstrate mechanical integrity.
One-time
0.0
0.0
1.5
2.4
3.9
$163
$0
44
172
$7,180
0.0
0.0
0.2
16.1
1.9
128.7
0.2
15.5
2.4
160.2
$139
$9,288
$5,828
$81,956
44
44
105
7,051
$262,539
$4,014,719
3.0
2.0
1.0
22.0
0.0
4.0
4.0
28.0
$347
$1,560
$0
$0
60
1
240
28
$20,849
$1,560
0.0
0.0
6.0
2.0
8.0
$402
$0
82
659
$33,113
0.0
0.0
0.0
16.1
3.3
128.7
1.3
16.1
4.6
160.9
$229
$9,308
$0
$81,956
7,800
16
36,152
2,649
$1,787,838
$1,502,572
0.0
0.0
27.5
3.0
30.5
$1,641
$0
476
14,512
$780,665
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.
Technical
F
Total Hours and Costs
As necessary
to obtain
representative
data
Semi-monthly/
Continuous
Monitor injection pressure and flow rate or volume of injected
fluids, or meter and record injected and produced fluid
volumes.
Demonstrate mechanical integrity.
Every 5 years
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.
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: any planned physical changes to facility,
changes that may result in noncompliance, permit transfers,
planned workovers, 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.
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
1.8
5.8
$325
$0
30
175
$9,760
0.0
1.0
10.0
16.9
27.9
$1,212
$0
1,200
33,421
$1,454,714
0.0
0.0
0.4
3.0
3.4
$121
$0
300
1,020
$36,338
0.0
1.0
0.5
0.5
2.0
$142
$0
2
4
$283
0.0
0.0
0.8
0.3
1.0
$50
$0
0
0
$10
0.0
0.5
0.5
1.0
2.0
$110
$0
16
33
101,513
Quarterly
At least 3
years
Closure Requirements (Per Facility)
Notify the Director before conversion or abandonment of the
One-time
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.
One-time
Occasional
TOTALS
10,562
$
$1,792
10,275,236
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
Initial/Start-up
Permit applications (Per Permit Application)
Consider the permit application, area of review,
relevant maps and cross sections, fluid injection
rate and volume, proposed contingency plans,
monitoring plans, and construction procedures
and issue notice of intent to deny.
Consider the permit application, area of review,
relevant maps and cross sections, fluid injection
rate and volume, proposed contingency plans,
monitoring plans, and construction procedures
and prepare draft permit.
Provide public notice of issuance of a draft permit
or intent to deny.
Consider public comments.
Frequency
One-time
Issue final permit decision.
One-time
Respond to comments.
One-time
Review completion report.
One-time
Review information related to aquifer exemption
requests and forward to EPA region.
One-time
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
One-time
20.0
$918
$0
39
790
$36,276
40.0
$1,837
$0
39
1,580
$72,552
2.0
$92
$0
39
79
$3,628
8.0
$367
$0
39
316
$14,510
10.0
$459
$0
39
395
$18,138
15.0
$689
$0
39
592
$27,207
2.0
$92
$0
39
79
$3,628
1.0
$46
$0
0.0
0.0
$0
One-time
One-time
Underground Injection Control Program -- Information Collection Request
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.
Review request for permit modification or reissuance.
Monitoring/Testing (Per Facility)
Review mechanical integrity test data submitted
by operators.
Review monitoring data submitted by operators.
Other Reporting (Per Facility)
Respond to periodic notifications by owners and
operators.
Recordkeeping (Per Facility)
Maintain administrative record (DI).
Closure (Per Facility)
Review plugging and abandonment report (DI
only).
Frequency
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
Every 5 years
Occasional
Every 5 years
4.0
$184
$0
54
215
$9,893
20.0
$918
$0
1
20
$918
0.5
$23
$0
54
27
$1,237
0.25
$11
$0
1,077
269
$12,367
4.0
$184
$0
30
120
$5,510
4.0
$184
$0
0
0
$0
4.0
$184
$0
0
1,571
0
4,483
Quarterly
Occasional
One-time
One-time
TOTAL
$
$0
205,865
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 27.9 hours per facility per quarter for quarterly
reporting on monitoring and any MITs performed (Form 7520-8). About 10 percent of operators will spend
about 6 hours per year on occasional reporting activities (e.g., on planned changes to the facility, anticipated
noncompliance, permit transfers, planned workovers, progress in meeting a compliance schedule, or possible
endangerment to a USDW) via Forms 7520-7 or 7520-19. 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 will spend one hour to submit a plugging and abandonment report.
Burden on Primacy Agencies Associated with Class III Wells
Class III 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 A3). 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 these owners or operators will incur a one-time burden
of 1.4 hours to prepare and submit a pre-closure notification (Form 7520-17) and 8.5 hours to plug their 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 (or, for a small number of
operators, submitting permit applications) and the results of monitoring by operators of motor vehicle waste
disposal wells (MVWDWs) subject to the Class V Rule.
Inventory Activities
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 approximately 0.4 hours to prepare and submit inventory information (Form 7520-16) to the appropriate
Regional or state primacy agency.
Permitting
Class V well owners or operators who have been requested by the permitting authority to complete a
permit application (Form 7520-6) will prepare and submit an application that is similar to that requested for
other well classes. These applicants will gather and submit the following types of information: AoR and
corrective action information; geological data on the injection and confining zone and information about
USDWs; descriptions of logs and tests; construction schematics; operating data; a monitoring plan; and a
closure plan that includes a demonstration of financial responsibility.
The time needed to complete a Class V permit application will vary based on the specific project;
however EPA assumes that the burden will be similar to that for a Class I non-hazardous permit application, or
approximately 104 hours per response. The burden reflects the time that is above customary business practices
that is needed to oversee and furnish information to contractors who perform much of the required work.
Activities Required Under the Class V Rule
Operators of MVWDWs that were granted permits under the Class V Rule will sample their injectate
quarterly (and incur a burden of 1.5 hours, 4 times per year) and sample sludge annually (1.5 hours). They will
submit these results once annually and incur a burden of 4 hours to prepare the report and retain records.
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 and permit applications, and reviewing monitoring data submitted by owners or operators
of MVWDWs 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 approximately 0.5 hours per Class V facility reviewing inventory
information. Class V Primacy agencies will spend 56 hours responding to each Class V permit application. State
primacy agencies will also spend 0.8 hours annually to review each monitoring report submitted by operators of
MVWDWs (details are presented in Table A-5).
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
B
C
D
Hours and Costs per Response
Description of Requirement
Closure Requirements (Per Well)
Plug injection well.
Prepare and submit pre-closure notification
(Form 7520-17)
TOTAL
Frequency
Legal
One-time
One-time
Managerial
Technical
Clerical
E
F
Total Hours and Costs
Unit Burden
Unit Labor
Cost
Unit Nonlabor Cost
No. of
Responses
Total
Hours/Year
Total
Cost/Year
0
0
7
1.5
8.5
$247
$0
71
601
$17,463
0
0
0.5
0.86
1.4
$36
$0
71
142
96
698
$2,579
$20,042
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
B
C
D
Hours and Costs per Response
Description of Requirement
Closure
Review closure plan.
Frequency
Unit Burden
(A)
Unit Labor
Cost
Unit Nonlabor
Cost
1.0
$46
$0
One-time
TOTAL
E
F
Total Hours and Cost
Number of
Responses
56
56
Total
Hours/Year
56
56
Total
Cost/Year
$2,549
$2,549
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
Inventory Requirements
Submit inventory information prior to commencing
injection.
Permitting
Prepare and submit permit application (if required).
Gather and submit: AoR and corrective action
information; geological data on the injection and
confining zone and information about USDWs;
descriptions of logs and tests; construction
schematics; operating data; monitoring plan; and
closure plan, including demonstration of financial
responsibility.
Frequency
One-time
Legal
Managerial
0.0
Technical
0.0
Clerical
Unit Burden
Unit Labor
Cost
Unit Non-labor
Cost (A)
0.0
0.4
0.4
$9
$0
19,348
6,613
$164,578
61.8
17.5
103.6
$3,541
$104,711
10
1,036
$1,082,518
1.0
0.5
1.5
$42
$785
5,916
8,874
$4,892,179
1.0
0.5
1.5
$42
$2,051
1,479
2,219
$3,096,727
3.0
1.0
4.0
$115
$0
1,479
28,232
5,916
24,657
$169,600
$9,405,602
One-time
7.0
17.3
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
B
C
D
Hours and Costs per Response
Unit Nonlabor
Description of Requirement
Frequency
Unit Burden (A)
Unit Labor Cost
Cost
E
F
Total Hours and Cost
Number of
Responses
Total Hours/Year
Total Cost/Year
Initial/Startup
Review inventory information.
One-time
0.5
$23
$0
13,570
6,548
$300,672
One-time
56.0
$2,572
$0
10
560
$25,715
Annual
0.8
$37
$0
Review permit applications. Consider the permit application
and attachments, prepare draft permit, solicit and respond
to public comments.
Primacy State Activities Associated With the Class V Rule
Review and file annual monitoring reports.
TOTAL
1,037
830
$38,107
14,618
7,938
$364,494
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
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, it is uncertain whether some activities
will customarily be performed by operators or contractors. Those activities were classified as operator burden to
provide a conservatively high 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.
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 formations (including all
USDWs), and the confining zone in the AoR (44 hours);
Conduct baseline ground water sampling of the injection and confining zones for comparison to future
geochemical monitoring results (10 hours);
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 NonLabor Cost
Technical 1
Technical 2
Unit Labor
(A)
Description Of Requirement
Frequency
(Engineer)
(Geologist)
Unit Burden
Cost
Initial/Startup Requirements (Per Permit Application)
Requirements Associated with Permit Applications
D
E
F
Total Hours andCosts
Number of
Total
Responses Hours/ Year Total Cost/Year
Prepare and submit Class VI permit application,
including all attachments and plans.
One-Time
240
300
540
$60,863
$606,809
13.3
7,200
$8,902,294
Conduct 3D seismic survey to identify faults and
fractures; obtain and analyze seismic history.
One-Time
0
180
180
$21,286
$672,559
13.3
2,400
$9,251,268
Obtain geomechanical and geochemical information
on injection zone, subsurface aquifers including all
USDWs, and the confining zone in the area of review. One-Time
30
129
159
$18,428
$155,864
13.3
2,120
$2,323,901
One-Time
0
44
44
$5,251
$0
13.3
592
$70,008
One-Time
0
10
10
$1,183
$20,305
13.3
133
$286,500
One-Time
0
240
240
$28,381
$0
13.3
3,200
$378,419
One-Time
40
0
40
$4,231
$0
13.3
533
$56,414
One-Time
140
300
440
$50,285
$112,928
13.3
5,867
$2,176,180
One-Time
724
$218,489
$0
13.3
25,653
$2,913,187
One-Time
100
$34,229
$0
-
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.
Underground Injection Control Program -- Information Collection Request
1,200
200
1,924
300
-
$0
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 NonLabor Cost Number of
Total
Technical 1
Technical 2
Unit Labor
(A)
Responses Hours/ Year Total Cost/Year
Description Of Requirement
Frequency
(Engineer)
(Geologist)
Unit Burden
Cost
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
$443,863
13.3
0
$5,918,179
Install check/shut-off valve on injection well.
One-Time
0
0
0
$0
$3,065
13.3
0
$40,871
One-Time
0
0
0
$0
$2,633,419
13.3
0
$35,112,257
Construct monitoring wells.
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
$188,821
13.3
0
$2,517,618
Monitoring/Testing Requirements (Per Operator)
Analyze injectate stream and perform corrosion
monitoring.
Quarterly
62
0
62
$6,505
$18,113
10.7
656 $
262,591
Operate and maintain monitoring wells and the
monitoring equipment within them.
Annual
13
0
13
$1,325
$513,498
2.7
33
$1,372,861
Conduct periodic monitoring of groundwater quality
and geochemistry.
Monthly
21
0
21
$2,221
$12,117
32.0
672
$458,818
Conduct external mechanical integrity tests.
Annual
0
0
0
$0
$201,984
2.7
0
$538,623
Every Five
Years
0
0
0
$0
$38,072
0.5
0
$20,305
Conduct pressure fall-off testing.
Conduct 3D seismic survey to track movement of the Every Five
CO2 plume and pressure front.
Years
0
0
0
$0
$1,327,165
0.5
0
$707,821
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
$118,258
$0
0.3
373
$39,419
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 NonLabor Cost Number of
Total
Technical 1
Technical 2
Unit Labor
(A)
Responses Hours/ Year Total Cost/Year
Description Of Requirement
Frequency
(Engineer)
(Geologist)
Unit Burden
Cost
Reporting and Recordkeeping Requirments (Per Operator)
Report to regulators; maintain records of data from all
data gathering activities.
Semi-Annual
33
0
33
$3,491
$0
5.3
176
$18,617
Plugging, Post-Injection Site Care, and Site Closure Requirements (Per Operator)
Demonstrate financial ability (accounting for inflation)
to close site.
One-Time
8
0
8
$846
$0
0
0
$0
Perform a MIT prior to plugging the injection well.
Conduct ground water monitoring - operate and
maintain monitoring wells and the monitoring
equipment within them.
One-Time
0
0
0
$0
$38,636
0
0
$0
Annual
0
0
0
$0
$591,018
1
0
$591,018
Track the CO2 plume and pressure front.
Every 5
Years
0
0
0
$0
$1,327,165
0
0
$265,433
Submit results of post-injection monitoring.
Annual
40
0
40
$4,231
$0
1
40
$4,231
400
0
400
$42,310
$0
0
230.3
Perform non-endangerment demonstration and submit
results.
One-Time
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
0
49,649 $
$0
74,226,832
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,
One-time
testing, and mechanical integrity data, and project plans
780
$35,818
$0
5
3,900
$179,088
Review financial responsibility demonstration.
Determine and specify tubing, packing, casing, and
cementing requirements based on review of information
submitted by operator.
One-time
100
$4,592
$0
5
500
$22,960
One-time
140
$6,429
$0
5
700
$32,144
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
$918
$0
5
100
$4,592
One-time
200
$9,184
$0
-
Review mechanical integrity test data.
Area of Review Reevaluation
Prepare and submit primacy application.
TOTAL
Notes:
$0
Annual
40
$1,837
$0
0.33
13
$612
Annual
13.5
$620
$0
0.33
5
$207
150
$6,888
$0
0.00
0
$0
20
$918
$0
0.00
0
$0
Annual
15
$689
$0
0.00
0
$0
One-time
40
$1,837
$0
0.00
0
$0
$47,757
$0
1.7
22.3
Every 5
Review updated AoR modeling and updated plans.
years
Post-Injection Site Care and Site Closure
Review relevant data prior to granting approval for plugging
One-time
and abandonment of a well.
Review post-injection monitoring data.
Review non-endangerment demonstration and authorize
site closure.
Project-Independent Activities
0.0
One-time
1,040
1,733
6,951
$
$79,595
319,198
Numbers may not add due to rounding.
Undergound Injection Control Program -- Information Collection Request
Page A-43
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); and
Perform complex modeling (reservoir simulations) of carbon dioxide flow and fluid migration to
delineate the AoR (1,924 hours).
In addition, applicants seeking to inject carbon dioxide for geologic storage above or between USDWs
must apply for an injection depth waiver. EPA estimates this burden to be 300 hours per waiver application.
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 approximately 12.5 hours to operate
and maintain monitoring wells and the monitoring equipment within them. Operators must also perform ground
water 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.)
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.
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Closure and Post-Injection Site Care (PISC)
During the post-injection phase, Class VI well operators will spend 8 hours to update their financial
demonstrations to account for inflation at the beginning of the post-injection period. Operators will also perform
an MIT prior to plugging the injection well (incurring non-labor costs only). Operators will perform ground
water monitoring and carbon dioxide plume and pressure front tracking as described in their PISC and Site
Closure Plan. EPA assumes that this monitoring will be performed by contractors and there will be no labor
burden, but owners or operators will incur an annual burden of 40 hours to report monitoring results to the
permitting authority during the post-injection site care phase. Finally, prior to receiving authorization to perform
site closure activities, Class VI well operators must submit a demonstration that, based on monitoring and other
site-specific data, the project does not pose an endangerment to USDWs.
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. 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 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 40 hours of burden annually per operator
reviewing reports and data records submitted by operators. Every year, they will also spend approximately 13.5
hours per permit to review MIT results. State primacy agencies will review modeling updates to the AoR and
other revised plans submitted by operators every five years, requiring approximately 150 hours per review.
Primacy agencies will incur burden to review post-injection monitoring results. These activities include:
reviewing data prior to granting approval for plugging the well (20 hours); reviewing post-injection monitoring
data (15 hours annually); and reviewing non-endangerment demonstrations and authorizing the performance of
site closure activities (40 hours).
States as Respondents
State burden associated with program oversight and compiling and reporting summary program data and
inventory information is presented in Column A of Table A-7. The burden on states associated with reporting
summary information using EPA’s web-based reporting system ranges from 2 to 6 hours. States will also report
inventory information annually to EPA, and the burden associated with compiling the number of wells by class,
and reporting to an EPA online inventory will be 54 hours per primacy agency.
EPA estimates that, in each primacy program, 0.5 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.
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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
Report on Permit Review and Issuance (7520-1)
Frequency
Annual
Report on Compliance Evaluation (7520-2A)
Semi-annual
Report on Compliance Evaluation for Significant NonCompliance (7520-2B)
Semi-annual
Report on Mechanical Integrity Tests/Remedial Action
(7520-3)
Annual
Report on Quarterly Exceptions (7520-4)
Quarterly
Unit Burden
Ongoing
Inventory Reporting
Conduct inventory-related activities, e.g., review operator Annual
data and report to EPA's online inventory data system.
Total
Unit Labor
Cost
E
F
Total Hours and Cost
Unit Nonlabor Number of
Cost
Responses
Total
Hours/Year
Total
Cost/Year
1,040
$47,757
$0
59
61,360
$2,817,651
4.5
$207
$0
59
266
$12,192
6.0
$276
$0
118
708
$32,511
5.5
$253
$0
118
649
$29,802
5.0
$230
$0
59
295
$13,546
2.0
$92
$0
236
472
$21,674
54
$2,480
$0
59
767
3,186
66,936
$146,301
$3,073,678
Notes:
There may be more than one agency per state with Primacy authority.
Numbers may not add due to rounding.
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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, i.e., 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. Assumptions about permitting are based on information reported on
Form 7520-1; assumptions about the number of Class I, II, and III well operators performing monitoring and
reporting activities are based on the UIC inventory; the number of Class IV/endangering Class V wells closing
is based on data reported on Form 7520-2B, and estimates about the Class VI universe are based on
consultations with UIC Program staff.
Class I
EPA inventory data indicate that there are 885 Class I wells, of which 138 inject hazardous waste, and
747 inject nonhazardous waste.
Class I Hazardous
According to EPA’s inventory, there are 138 Class I hazardous waste wells, with an average of 1.9 wells
at each facility. EPA estimates that 36 new Class I hazardous waste facility operating permits will be issued
each year. EPA further anticipates that 12 Class I hazardous facility operators will renew their permits each
year; 3 will modify their permits each year, and 6 operators will modify their petitions each year. EPA estimates
that, on average, 6.1 owners or operators of a 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 747 Class I nonhazardous waste wells, an average of 1.9 wells per facility.
The Agency estimates that 73 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 5 Class I
nonhazardous facility operators will modify their permits each year. EPA estimates that, on average, 12.4
owners or operators of Class I nonhazardous waste wells 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 159,269 Class II wells. EPA assumes that the typical Class II facility has
approximately 10 wells, thus there are approximately 15,926 Class II facilities.
EPA anticipates that approximately 5,956 Class II permit applications will be submitted to permitting
authorities 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.
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EPA estimates that state primacy agencies and EPA Regions will determine that a complete AoR study
is not necessary for approximately 80 percent of permit applications, and the remaining applicants will submit
an AoR map and an AoR study as part of the permit application. EPA estimates that 596 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 179 owners or operators of Class II wells will apply for aquifer exemptions each
year, and that all of these will constitute non-substantial revisions to their state’s UIC program.
Prior to obtaining approval to begin injection, operators must demonstrate mechanical integrity and
submit completion reports for an estimated 5,658 new Class II wells each year.
EPA estimates that approximately 80,000 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 1,593 Class II operators will submit requests for
permit modifications.
EPA anticipates that 15,927 owners or operators of Class II wells will perform annual MITs and sample
ground water and report the results to the permitting authority each year. EPA also estimates that, each year,
approximately 1,044 operators will plug and abandon their wells.
Class III
EPA estimates that there are approximately 300 facilities with Class III wells (18 uranium mining, 82
salt solution mining, and 200 brine mining/other sites).
EPA regional offices and state primacy agencies expect to receive an average of 44 permit applications
from Class III operators each year. EPA estimates that, on average, 0.4 Class III owners or operators will apply
for aquifer exemptions each year, and that these will constitute non-substantial revisions to their state’s UIC
program.
Operators of all 300 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 mining
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
EPA anticipates that 71 Class IV wells and endangering Class V wells will close each year. EPA
estimates that 22 percent of Class IV and endangering Class V wells are in DI states.
Class V
The current EPA inventory of Class V wells includes approximately 574,000 wells. EPA anticipates that
approximately 19,348 operators of new Class V facilities will submit inventory information each year over the
life of this ICR, based on trends in the UIC program inventory. EPA estimates that 10 Class V permit
applications will be submitted each year and all of these will be in primacy states.
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EPA estimates that 1,479 operators of motor vehicle waste disposal wells that have opted to obtain a
permit will conduct quarterly injectate sampling and annual sludge sampling, as required by the Class V Rule.
Class VI
EPA estimates that, over the clearance period, 15 Class VI permit applications will be submitted in a
primacy state (an average of 5 per year) and 25 Class VI permit applications will be submitted to DI programs
(an average of 8 per year) will apply for a permit (and they will not be accompanied by injection depth waiver
applications).
EPA also estimates that about one owner or operator will be injecting carbon dioxide into a Class VI
well at the beginning of the clearance period, and that up to 5 owners or operators will be injecting by the third
year of the period covered by this ICR (an average of 2.67 wells in operation each year over the life of the ICR).
One of these operators (an average of 0.3/year) will perform an AoR reevaluation during the three years covered
by the ICR. Additionally, another owner or operator will perform post-injection monitoring throughout the
clearance period. EPA estimates that 5 states will apply for Class VI primacy during the ICR clearance period.
States as Respondents
EPA assumes that 59 primacy agencies in 42 states, three territories, and two tribes (Navajo and Fort
Peck) will report UIC information (e.g., summary and inventory data) to EPA. 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).
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| File Type | application/pdf |
| File Title | Microsoft Word - Appendix A.doc |
| Author | Shari.Ring |
| File Modified | 2021-11-03 |
| File Created | 2021-10-22 |