Burden Calculation Tables

037db27.xls

Underground Injection Control (UIC) Program (Renewal)

Burden Calculation Tables

OMB: 2040-0042

Document [xlsx]

Download: xlsx | pdf

Overview

Read me
Inventory
Labor rates
C1Assumptions
C2Assumptions
C3Assumptions
C5Assumptions
C6Assumptions
By activity
Resp summary
Change
7520s
ICR Tables
Bottom line
Class 1 H
C1hstate
Class 1 NH
C1nhstate
Class 2
C2State
Class 3
C3State
Class 4
C4state
Class 5
C5state
Class 6
C6state
Oversight
ICRAS forms
ICRAS calcs
all fed tables
Forms & CFR

Sheet 1: Read me

About the UIC ICR Spreadsheet

Basic rule: update the inventory and labor rates pages, and much of the remaining pages will be automatically updated.

Summary of worksheets in this file

Most of the updates will be to the yellow tabs: inventory, labor rates, and class-specific assumptions. Assumptions about state reporting are on the oversight tab (below the table); all are automated.

The summary tabs (purple) are the “analysis” of the numbers. These contain the ICR tables and explain what changed from the last ICR and why.

The operator and state burden/cost tables (blue tabs) are the detailed tables for Appendix A (from old operators file); change unit burdens for individual activities here.

The ICRAS forms tab (green) has information to complete OEI's ICR submission spreadsheet (new in 2018); ICRAS calcs is mostly obsolete, except one place holder for prior ICR numbers. [This sheet was used to populate the ICRAS/ROCIS site (which is no longer used, but retained in case it is reinstated).]

Fed tables (green tab) aren’t printed in the ICR anymore; these do feed the summary tables. DO NOT EDIT unless there is a reason to change a Fed unit burden.

Burden estimates

The burden estimates for individual activities are based on consultations. They usually do not change, unless activities do/we get comments.

Labor costs

Update the colored cells in the labor rates page.

Operator labor costs are based on BLS data, updated with each ICR (Different labor rates apply to Class 1/2/3, 4/5, and 6).

The labor rates sheet shows the industries used as inputs, and calculations of average values for these industry types.

Contractor rates are here too (They are non-labor costs, per the ICR Handbook, and are inflated per CPI).

See the yellow box (cell O1) on the labor rates page.

State and Federal labor rate is GS-9, Step 10 on current year's Federal pay schedule; multiplied by 1.6 to load.

Non-labor costs

These are based on consultations.

These are inflated from 1995 dollars to current year dollars. (From BLS web site CPI calculator.)

For Class VI, these are inflated from $2008 (the Class VI ICR). Need to update the inflation factor between $2008 and the current year for Class VI non-labor costs

The inflation factor (INFL) from CPI calculator is cell F3 on the labor rates sheet.

Contractor costs are incl. as non-labor costs, and inflated per CPI. These are based on consultations about what work is done in-house vs. outsourced, multiplied by contractor labor rate.

Number of respondents/responses

UPDATING THE INVENTORY PAGE IS THE MOST CRUCIAL STEP!!!

Inventory numbers drive many of the values for these; inventory is based on the most recent UIC online database and e-reported data -- see bottom of inventory page.

The C1Assumptions, etc. pages reference/link to these values, and are inputs to the Class-specific burden and cost sheets.

The values of many of the assumptions are dependent on the inventory sheet.

Assumptions about the numbers of permit applications, well closures, etc. reflect year-to-year inventory changes or web-based 7520 data.

Class IV and Class V respondents also drive from measures data about progress on surveying and addressing high priority wells.

Update assumptions about Class VI permit applications and wells operating separately-see Class VI assumptions page.

Burden and cost sheets

The activities listed are per the CFR.

Legal, managerial, technical and clerical unit burdens for various activities are based on consultations.

Unit burdens are then multiplied by the respective labor rates (in labor rates sheet), and summed for a unit labor cost.

Respondents and responses are based on consultations and drive heavily off of assumptions sheets.

Class-specific assumptions

These are on the yellow tabs and the state oversight tab.

They generally will not change, unless new information becomes available during consultations.

The yellow cells on these pages will change automatically as the inventory changes.

A few peach (in 2018)/green in 2021 cells on the assumptions sheets need to be checked/manually updated for each ICR. Pick another highlight color each ICR to track completion of this step.

Calculating change in burden

The "Resp summary," "Change," "By activity," and “ICRAS” sheets calculate change from the approved ICR.

***Before updating any assumptions, hard copy the last ICR's numbers into the "previous" columns so they can be compared to the linked numbers.***

See aqua shaded cells in Resp summary, Change, By activity, Inventory, Labor rates, ICRAS calcs, C1, C2, C3 assumptions. C2 assumptions for permitting are based on inventory differences so after this step, change will not be zero

Some of the class specific pages have scratch calculations under the tables. Most are specific to the current ICR.

For ICRAS/the OEI ICR submission spreadsheet, update the previous year's numbers in the shaded cells; everything else to submit the ICR submission worksheet is automated

Sheet 2: Inventory

State	Cl 1 status	CLASS 1 HW	CLASS 1 OTHER	C1Haz in prim	Class I NH In prim	Cl 2 status	CLASS 2 WELLS	C2 in prim	C2 in DI	Cl 3 status	CLASS 3 SITES	CLASS 3 WELLS	C3 sites in prim	C3 wells in prim	State	Cl 5 status	CLASS 5 WELLS	C5 in prim	Agency 1	Agency 2
Total		138	747	126	607		159,269	155,791	3,478		300	22,612	252	20,299			570,778	400,326	Total # prim. agencies:		59	Per Jill, and Anita memo
Connecticut	Prim			0	0	Prim		0		Prim			0	0	Connecticut	Prim	808	808	Connecticut Department of Environmental Protection.
Maine	Prim			0	0	Prim		0		Prim			0	0	Maine	Prim	2,223	2,223	Maine Department of Environmental Protection
Massachusetts	Prim			0	0	Prim		0		Prim			0	0	Massachusetts	Prim	2,599	2,599	Massachusetts Department of Environmental Protection
New Hampshire	Prim			0	0	Prim		0		Prim			0	0	New Hampshire	Prim	12,131	12,131	New Hampshire Department of Environmental Services
Rhode Island	Prim			0	0	Prim		0		Prim			0	0	Rhode Island	Prim	1,925	1,925	Rhode Island Department of Environmental Management
Vermont	Prim			0	0	Prim		0		Prim			0	0	Vermont	Prim	1,833	1,833	Vermont Department of Environmental Conservation
New Jersey	Prim	0	0	0	0	Prim		0		Prim	0	0	0	0	New Jersey	Prim	411	411	New Jersey Dept. of Environmental Protection
New York	DI			0	0	DI	326	0		DI	6	158	0	0	New York	DI	8,681	0
Puerto Rico	Prim			0	0	Prim		0		Prim			0	0	Puerto Rico	Prim	3,090	3,090	Puerto Rico Environmental Quality Board of Water Quality
Virgin Islands	DI			0	0	DI		0		DI			0	0	Virgin Islands	DI	67	0
DC	DI	0	0	0	0	DI		0		DI	0	0	0	0	DC	DI	236	0
Delaware	Prim			0	0	Prim		0		Prim			0	0	Delaware	Prim	1,700	1,700	Delaware Department of Natural Resources and Environmental Control
Maryland	Prim			0	0	Prim		0		Prim			0	0	Maryland	Prim	13,483	13,483	Maryland Department of the Environment
Pennsylvania	DI	0	0	0	0	DI	1,645	0		DI	0	0	0	0	Pennsylvania	DI	16,165	0
Virginia	DI	0	0	0	0	DI	13	0		DI	1	17	0	0	Virginia	DI	12,282	0
West Virginia	Prim	0	0	0	0	Prim	715	715		Prim	2	21	2	21	West Virginia	Prim	2,189	2,189	West Virginia Division of Environmental Protection
Alabama	Prim	0	0	0	0	Prim	251	251		Prim	1	4	1	4	Alabama	Prim	1,126	1,126	Alabama Dept. of Environmental Management	Alabama Oil & Gas, State Board
Florida	Prim	0	305	0	305	DI	70	0		Prim	0	0	0	0	Florida	Prim	18,325	18,325	Florida Department of Environmental Protection
Georgia	Prim	0	0	0	0	Prim		0		Prim	0	0	0	0	Georgia	Prim	17,300	17,300	Georgia Department of Natural Resources
Kentucky	DI		1	0	0	Prim	3,128	3,128		DI			0	0	Kentucky	DI	14,388	0	Kentucky Department of Natural Resources
Mississippi	Prim	5	9	5	9	Prim	1,321	1,321		Prim			0	0	Mississippi	Prim	7,500	7,500	Mississippi Oil and Gas Board	Mississippi Department of Environmental Quality
North Carolina	Prim			0	0	Prim		0		Prim			0	0	North Carolina	Prim	15,100	15,100	North Carolina Department of Environmental Quality
South Carolina	Prim	0	0	0	0	Prim		0		Prim	0	0	0	0	South Carolina	Prim	19,302	19,302	South Carolina Department of Health and Environmental Control
Tennessee	Prim	0	0	0	0	Prim	34	34		Prim	0	0	0	0	Tennessee	Prim	5,086	5,086	Tennessee Department of Environment and Conservation
Illinois	Prim	2	5	2	5	Prim	7,958	7,958		Prim			0	0	Illinois	Prim	33,915	33,915	Illinois Department of Natural Resources	Illinois Environmental Agency
Indiana	DI	4	13	0	0	Prim	1,161	1,161		DI			0	0	Indiana	DI	17,372	0	Indiana Department of Natural Resources/Oil and Gas Division
Michigan	DI	7	35	0	0	DI	1,420	0		DI	5	58	0	0	Michigan	DI	8,419	0
Minnesota	DI			0	0	DI		0		DI			0	0	Minnesota	DI	3,688	0
Ohio	Prim	12	5	12	5	Prim	2,336	2,336		Prim	5	56	5	56	Ohio	Prim	23,432	23,432	Ohio Department of Natural Resources	Ohio Environmental Agency
Wisconsin	Prim			0	0	Prim		0		Prim			0	0	Wisconsin	Prim	1,869	1,869	Wisconsin Department of Natural Resources
Arkansas	Prim	4	7	4	7	Prim	1,023	1,023		Prim			0	0	Arkansas	Prim	167	167	Arkansas Department of Environmental Quality	Arkansas Oil and Gas Commission
Louisiana	Prim	19	15	19	15	Prim	3,531	3,531		Prim	19	82	19	82	Louisiana	Prim	990	990	Louisiana Department of Natural Resources
New Mexico	Prim		6	0	6	Prim	4,175	4,175		Prim	9	9	9	9	New Mexico	Prim	2,364	2,364	New Mexico Energy, Minerals, and Natural Resources - Oil Conservation Division	New Mexico Environment Department
Oklahoma	Prim	0	6	0	6	Prim	11,000	11,000		Prim	0	0	0	0	Oklahoma	Prim	2,820	2,820	Oklahoma Corporation Commission	Oklahoma Department of Environmental Quality
Texas	Prim	77	90	77	90	Prim	54,151	54,151		Prim	200	4,528	200	4,528	Texas	Prim	56,625	56,625	Texas Commission on Environmental Quality	Texas Railroad Commission
Iowa	DI	0	0	0	0	DI	4	0		DI	0	0	0	0	Iowa	DI	5,358	0
Kansas	Prim	7	56	7	56	Prim	16,539	16,539		Prim	4	163	4	163	Kansas	Prim	9,114	9,114	Kansas Department of Health and Environment	Kansas Corporation Commission-Conservation Division
Missouri	Prim	0	0	0	0	Prim	434	434		Prim	0	0	0	0	Missouri	Prim	10,934	10,934	Missouri Department of Natural Resources
Nebraska	Prim	0	11	0	11	Prim	620	620		Prim	3	4,769	3	4,769	Nebraska	Prim	1,597	1,597	Nebraska Department of Environmental Quality	Nebraska Oil and Gas Conservation Commission
Colorado	DI		13	0	0	Prim	977	977		DI	17	17	0	0	Colorado	DI	2,911	0	Colorado Oil and Gas Conservation Commission
Montana	DI			0	0	Prim	1,143	1,143		DI			0	0	Montana	DI	7,043	0	Montana Board of Oil and Gas Conservation
North Dakota	Prim		8	0	8	Prim	1,454	1,454		Prim			0	0	North Dakota	Prim	933	933	North Dakota Department of Health	North Dakota Industrial Commission - Oil and Gas Division
South Dakota	DI			0	0	Prim	108	108		DI	14	14	0	0	South Dakota	DI	713	0	South Dakota Department of Environmental and Natural Resources
Utah	Prim	0	0	0	0	Prim	776	776		Prim	3	27	3	27	Utah	Prim	4,430	4,430	Utah Department of Environmental Quality	Utah Department of Natural Resources
Wyoming	Prim	0	84	0	84	Prim	4,989	4,989		Prim	6	10,640	6	10,640	Wyoming	Prim	1,340	1,340	Wyoming Department of Environmental Quality	Wyoming Oil and Gas Conservation Commission
Amer Samoa	DI			0	0	DI		0		DI			0	0	Amer samoa	DI	10	0
Arizona	DI			0	0	DI		0		DI	3	1,413	0	0	Arizona	DI	40,743	0
California	DI	1	58	0	0	Prim	35,841	35,841		DI	2	636	0	0	California	DI	23,121	0	California Department of Conservation; CalGEM
Ft. Peck	DI			0	0	Prim	32	32		DI			0	0		DI	3	0	Fort Peck Tribes
Guam	Prim			0	0	Prim		0		Prim			0	0	Guam	Prim	516	516	Guam Environmental Protection Agency
Hawaii	DI			0	0	DI		0		DI			0	0	Hawaii	DI	6,973	0
MP	Prim			0	0	Prim		0		Prim			0	0	MP	Prim	25	25	Commonwealth of Northern Mariana Islands, Division of Environmental Quality
Navajo	DI			0	0	Prim	475	475		DI			0	0		DI	218	0	Navajo Nation Environmental Protection Agency
Nevada	Prim			0	0	Prim	17	17		Prim			0	0	Nevada	Prim	2,371	2,371	Nevada Division of Environmental Protection
Alaska	DI		20	0	0	Prim	1,592	1,592		DI			0	0	Alaska	DI	2,061	0	Alaska Oil and Gas Conservation Commission
Idaho	Prim	0	0	0	0	Prim		0		Prim	0	0	0	0	Idaho	Prim	20,285	20,285	Idaho Department of Water Resources
Oregon	Prim	0	0	0	0	Prim	9	9		Prim	0	0	0	0	Oregon	Prim	40,546	40,546	Oregon Department of Environmental Quality
Washington	Prim	0	0	0	0	Prim	1	1		Prim	0	0	0	0	Washington	Prim	59,922	59,922	Washington Department of Ecology
Total Primacy	38					46				38						38
Total DI	20					12	180,199			20						20

Source: FY20 UIC Inventory, provided by Dan Feuer June 3, 2021																			Number of DI Programs, by Class:
																			Class1	8	All regions but 1 and 6 have at least 1 DI state
Last ICR Inventory (paste these to row 2 to calculate impact on change)																			Class2	6	All regions but 1, 6, 8 and 10 have at least 1 DI state
State	Cl 1 status	CLASS 1 HW	CLASS 1 OTHER	C1Haz in prim	Class I NH In prim	Cl 2 status	CLASS 2 WELLS	C2 in prim	C2 in DI	Cl 3 status	CLASS 3 SITES	CLASS 3 WELLS	C3 sites in prim	C3 wells in prim	State	Cl 5 status	CLASS 5 WELLS	C5 in prim	Class3	8	All regions but 1 and 6 have at least 1 DI state
Total		140	688	129	557		180,199	176,486	3,713		225	24,669	175	24,243			495,517	347,224	Class4	8	All regions but 1 and 6 have at least 1 DI state
																			Class5	8	All regions but 1 and 6 have at least 1 DI state
Inventory	Total	Class 1	Class 2	Class 3	Class 5	Class 3 sites													Class6	1	Region 5 as of Jan 2018
Total - 2018 ICR	701,213	828	180,199	24,669	495,517	225	Source: UIC Inventory, FY 2016												**This is used for the well-by-well exhibits; however 10 regions have oversight duties/report to Headquarters
Total - 2021 ICR	753,544	885	159,269	22,612	570,778	300	Source: UIC Inventory, FY 2020; NOTE: a few states (CA, OH, NY, AZ. DE, VI) were missing 2020 data so 2019 or 2018 data used; see below
Change	52,331	57	-20,930	-2,057	75,261	75
Percent change	7%	7%	-12%	-8%	15%	33%
Years between inventories	3				25,087

	Updating the inventory
	Use final UIC inventory numbers
	Check order (e.g., MA and ME flip)
	Combine rows if multiple agencies report
	Add up Class II subtypes
	Paste values into shaded columns
						Inventory sheet notes
						California	Class II - big drop; similar to 2019; big Class III jump
						Ohio	Class II, III data missing in 2020; use 2019.
						New York	2020 data missing; used 2018
						Arizona	2020 data missing; used 2018. Big Class III jump
						Delaware	2020 data missing; used 2019
						Virgin Islands	2020 data missing; used 2019
						Class V	INCOMPLETE. Dan F. provided updated total in Oct 2021; see Class V assumptions

Sheet 3: Labor rates

Labor rates used in UIC Program ICR					INFLATION			2018 Labor rates (for cost comparison)				To do each ICR:
	Class 1, 2, 3	Class 4/5			FACTOR:				Class 1, 2, 3	Class 4/5		Update the current year dollars using the CPI calculator (for Class VI too)
Legal	$96	$29			1.6982			Legal	$103.04	$26.13		Update the median hourly rates for the occupational sectors in rows 25-75
Managerial	$97	$61						Managerial	$89.98	$59.26		Update GS-9 salary
Technical	$56	$30				From BLS web site: CPI calculator		Technical	$48.74	$26.96
Clerical	$33	$25			100	1995 dollars		Clerical	$30.43	$20.86
State/federal	$46	$46			169.82	2020 dollars		State/federal	$43.71	$43.71
Contractor	$60	inflated to:	$102					Contractor	$60	(inflated each ICR)
Class 6					Inflating Class VI non-labor costs (relative to Class VI ICR)			Class 6
Tech 1 - Mining & Geological Engineer			$106		100	2008 dollars (Class VI non-labor)		Tech 1 - Mining & Geological Engineer			$103.41
Tech 2 - Geoscientist			$118		120.21	2020 dollars		Tech 2 - Geoscientist			$99.22

Class 1-3: Based on Bureau of Labor Statistics Occupational Employment Statistics, 2016, for NAICS codes 325000 (Chemical Manufacturing), 327000 (Nonmetallic Mineral Product Manufacturing), 211000 (Oil and Gas Extraction), 324000 (Petroleum and Coal Products Manufacturing), 326000 (Plastics and Rubber Products Manufacturing), and 331000 (Primary Metal Manufacturing). Labor rates were derived from BLS median hourly wages for the above industrial categories. Increased by 60 percent to account for overhead costs.
Class 4 and 5: Based on BLS Occupational Employment Statistics, 2016, for NAICS codes 447000 (Gasoline Stations) and 441000 (Motor Vehicle and Parts Dealers). Increased by 60 percent to account for overhead costs.
Class 6: Based on BLS Occupational Employment Statistics, 2016, for NAICS codes 21100 (Oil and Gas Extraction), increased by 60 percent to account for overhead costs.

http://www.bls.gov/oes/current/oessrci.htm
State/federal: GS-9, Step 10 on Federal pay schedule; multiplied by 1.6 to load.

	State/Agency
	GS-9, Step 10 Fed pay scale	$28.70	$45.92	2021 fed pay scale (accessed 9/30/21)


Class 1, 2, 3
NAICS	NAICS_TITLE	OCC_CODE	OCC_TITLE	ICR labor cat	H_MEDIAN
211000	Oil and Gas Extraction	43-0000	Office and administrative support occupations	C	$21.96
324000	Petroleum and Coal Products Manufacturing	43-0000	Office and administrative support occupations	C	$21.98
325000	Chemical Manufacturing	43-0000	Office and administrative support occupations	C	$21.16
326000	Plastics and Rubber Products Manufacturing	43-0000	Office and administrative support occupations	C	$19.24
327000	Nonmetallic Mineral Product Manufacturing	43-0000	Office and administrative support occupations	C	$18.82
331000	Primary Metal Manufacturing	43-0000	Office and administrative support occupations	C	$20.21	$20.56	Clerical average
325000	Chemical Manufacturing	23-0000	Legal occupations	L	$60.02	$60.02	Legal average
211000	Oil and Gas Extraction	11-0000	Management occupations	M	$69.83
324000	Petroleum and Coal Products Manufacturing	11-0000	Management occupations	M	$64.16
325000	Chemical Manufacturing	11-0000	Management occupations	M	$64.40
326000	Plastics and Rubber Products Manufacturing	11-0000	Management occupations	M	$54.39
327000	Nonmetallic Mineral Product Manufacturing	11-0000	Management occupations	M	$55.74
331000	Primary Metal Manufacturing	11-0000	Management occupations	M	$55.74	$60.71	Managerial average
211000	Oil and Gas Extraction	17-2041	Chemical engineers	T	$66.95
211000	Oil and Gas Extraction	19-4031	Chemical technicians	T	$32.81
324000	Petroleum and Coal Products Manufacturing	17-2041	Chemical engineers	T	$59.31
324000	Petroleum and Coal Products Manufacturing	19-4031	Chemical technicians	T	$32.65
324000	Petroleum and Coal Products Manufacturing	51-8091	Chemical plant and system operators	T	$36.65
324000	Petroleum and Coal Products Manufacturing	51-9011	Chemical equipment operators and tenders	T	$35.86
325000	Chemical Manufacturing	17-2041	Chemical engineers	T	$52.83
325000	Chemical Manufacturing	19-4031	Chemical technicians	T	$25.48
325000	Chemical Manufacturing	51-8091	Chemical plant and system operators	T	$30.96
325000	Chemical Manufacturing	51-9011	Chemical equipment operators and tenders	T	$24.40
326000	Plastics and Rubber Products Manufacturing	17-2041	Chemical engineers	T	$49.91
326000	Plastics and Rubber Products Manufacturing	19-4031	Chemical technicians	T	$22.47
326000	Plastics and Rubber Products Manufacturing	51-9011	Chemical equipment operators and tenders	T	$21.53
327000	Nonmetallic Mineral Product Manufacturing	17-2041	Chemical engineers	T	$43.00
327000	Nonmetallic Mineral Product Manufacturing	19-4031	Chemical technicians	T	$25.07
327000	Nonmetallic Mineral Product Manufacturing	51-9011	Chemical equipment operators and tenders	T	$22.85
331000	Primary Metal Manufacturing	17-2041	Chemical engineers	T	$43.00
331000	Primary Metal Manufacturing	19-4031	Chemical technicians	T	$25.07
331000	Primary Metal Manufacturing	51-8091	Chemical plant and system operators	T	$27.28
331000	Primary Metal Manufacturing	51-9011	Chemical equipment operators and tenders	T	$22.85	$35.05	Technical average

Class 4 & 5
NAICS	NAICS_TITLE	OCC_CODE	OCC_TITLE	ICR labor cat	H_MEDIAN
441000	Motor Vehicle and Parts Dealers	43-0000	Office and administrative support occupations	C	$16.36
447000	Gasoline Stations	43-0000	Office and administrative support occupations	C	$14.75	$15.56	Clerical average
441000	Motor Vehicle and Parts Dealers	11-0000	Management occupations	M	$49.69
447000	Gasoline Stations	11-0000	Management occupations	M	$26.54	$38.12	Managerial average
441000	Motor Vehicle and Parts Dealers	49-0000	Installation, maintenance, and repair occupations	T	$20.00
447000	Gasoline Stations	49-0000	Installation, maintenance, and repair occupations	T	$17.41	$18.71	Technical average
441000	Motor Vehicle and Parts Dealers	23-0000	Legal Occupations	L	$18.03	$18.03	Legal average - no BLS est. for 447000


Class 6

NAICS	NAICS_TITLE	OCC_CODE	OCC_TITLE	ICR labor cat	H_MEDIAN
211000	Oil and Gas Extraction	17-2171	Petroleum Engineers	Tech 1	$66.11
211000	Oil and Gas Extraction	19-2042	Geoscientists, Except Hydrologists and Geographers	Tech 2	$73.91


Note -- in 2014, replaced the AAPG and SPE sources for the Class VI ICR with rates from BLS to align to the source for other well classes. These labor rates from BLS are comparable.

Sheet 4: C1Assumptions

Some numbers are hard coded based on consultations; do not change unless this is recommended in consultation process								Class I start up costs - non labor estimates. These are inflated per the CPI, cell F3 on Labor rates tab
Yellow cells will automatically change each ICR based on inventory. Get application data from 7520-1 data.								HAZARDOUS FACILITIES: (NONHAZ BELOW)
								*Requirements associated with permit applications*		Unit Non-L $ (Average)
									Read permit application directions.	$0
								146.70(a)	Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, description of the business.	$0	DATA FROM 7520-1 (JUNE 2021)
Class I Inputs for Operator Burden								144.31(e)(9)	list of landowners	$0	Apps	2017	2018	2019	2020	avg	avg 2017-19
Input		Number	Var	Notes				146.70(a)(2,3)	Prepare and submit a map and tabulation of all wells within the AoR.	$15,100	c1	97	112	117	122	112	109
Total Hazardous facilities		73	HAZ	No. of wells/wells per facility				146.70(a)(4)	Prepare and submit AoR protocol.	$585	c2	5148	6193	6527	3327	5299	5,956	2020 seems incomplete
Total Nonhazardous facilities		393	NHAZ	No. of wells/wells per facility				146.70(a)(5-7)	Prepare and submit maps/cross sections of local and regional geology, USDWs.	$31,350	c3	24	32	75	45	44	44
New Permit applications - Hazardous		36	NPH	Average of 7520-1 data (2017-2020 - see at right); assume 1/3 of all Class I apps are Haz. CHANGED SOURCE IN 2021				146.70(a)(9-11)	Develop formation testing and stimulation programs and injection procedures.	$4,500
New Permit applications - Nonhazardous		73	NPN	Average of 7520-1 data (2017-2020); assume 2/3 are NHaz. CHANGED SOURCE IN 2021				146.70(a)(13)	Prepare and submit contingency plans for shut-ins or well failures.	$175
Applications for new wells at new facilities		30%	NPER	Calls, meeting				146.70(a)(14)	Prepare and submit ambient monitoring plan.	$2,950	Mods	2,017	2018	2019	2020	avg
Applications for new wells at existing facilities		70%	EPER	Calls, meeting				146.70(a)(15)	Prepare and submit Corrective Action Plan.	$7,475	c1	-	4	20	6	7.5
Hazardous Renewal Permit applications		12	RPH	Inventory, calls (see below)				146.70(a)(12,16,17)	Prepare and submit descriptions of logs and tests, construction schematics & operating data.	$3,750	c2	1,144	553	723	671	772.75
Nonhazardous Renewal Permit applications		20	RPN	Inventory, calls (see below)				146.70(d)	Prepare and submit certification of program to reduce quantity and toxicity of wastes.	$4,550	c3	1	2	0	0	0.75
Hazardous Plugging & Abandonments		1	HPA	EPA Inventory -- assumed even split				146.71(a)	Prepare and submit closure plan, including demonstration of financial responsibility.	$1,105	total	1,145	559	743	677
Nonhazardous Plugging & Abandonments		1	NPA	EPA Inventory -- assumed even split				146.72(a)(1)	Prepare and submit post-closure care plan.	$1,360
Wells Per Facility		1.9	WPF	EPA Inventory, confirmed by calls				*Requirements for active hazardous waste facilities*
Percent of facilities in Primacy states		83%	PRIM1	EPA Inventory (calculated)				144.31(g)(1)	Gather and submit dates of well operation and specific waste information.	$5,700
Percent of facilities in DI Programs		17%	DIclass1	EPA Inventory (calculated)				144.31(g)(2)	Gather and submit hazardous waste release information.	$2,850
Total wells		885		EPA Inventory				144.31(g)(3)	Gather & submit site investigation information.	$66,500
No. of hazardous wells		138		EPA Inventory				146.68(a)(1)	Develop waste analysis plan.	$1,900
No. of nonhazardous wells		747		EPA Inventory				148.20	No-migration petition	$525,000
Florida facilities affected by rule		0		Florida Rule ICR (was 16 in 2007; assume complete or accounted for - Nancy M says that 15 so far are subject to rule (3/25/11)
Florida facilities (municipal owners)		15		Per Nancy Marsh (3/25/11)
Petition modifications		6	PETMOD	Regions 5, 6				NONHAZARDOUS FACILITIES (HAZ AND NOTES ABOVE)
Permit Modifications		8		Average of 7520-1 data (2017-2020). CHANGED ASSUMPTION IN 2021				*Requirements associated with permit applications*		Unit Non-L $ (Average)
Permit Modifications - Hazardous		3	HMOD	37% of modifications					Read permit application directions.	$0
Permit Modifications - Nonhazardous		5	NMOD	63% of modifications				146.14(a) (1, 4-12)	Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership and facility status, facility location, listing of relevant permits or construction approvals, relevant maps and cross sections, construction s	$0
Percent of wells worked over		5%	WORK	Estimate				144.31(e)(9)	In DI programs, gather and submit a list of landowners within one-quarter mile of the facility boundary.	$0
Percent of facilities that are commercial		5%	COMM	Class I Database				146.14(a)(2,3)	Prepare and submit a map and tabulation of all wells within the AoR.	$12,080
Legal Labor Rate		$96.03	LEG1	Updated rates per BLS (links to labor rates sheet)				146.14(a)(4-6)	Prepare and submit maps/cross sections of local and regional geology, USDWs.	$31,350
Management Labor Rate		$97.14	MAN1	Updated rates per BLS (links to labor rates sheet)				146.14(a)(7,11,15)	Prepare and submit descriptions of logs and tests, construction schematics and operating data.	$3,750
Technical Labor Rate		$56.07	TECH1	Updated rates per BLS (links to labor rates sheet)				146.14(a)(8-10)	Develop formation testing and stimulation programs and injection procedures.	$4,500
Clerical Labor Rate		$32.90	CLER1	Updated rates per BLS (links to labor rates sheet)				146.14(a)(12)	Prepare and submit contingency plans for shut-ins or well failures.	$175
								146.14(a)(13)	Prepare and submit ambient monitoring plan.	$2,950
State Labor rate		$45.92	Staterate	GS-9, Step 10 on Federal pay schedule; multiplied by 1.6 to load.				146.14(a)(14)	Prepare and submit Corrective Action Plan.	$5,750
Class I permit applications requiring aquifer exemption		17%		Based on aquifer exemptions tracking system data				146.14(a)(16)	Prepare and submit closure plan, including demonstration of financial responsibility.	$1,105



		facilities
permit apps (inventory)		54
percent new	40%	21.6
percent renewal	60%	32.4
percent haz	37%
percent nonhaz	63%
haz & new		8
nonhaz & new		14
Haz & renewal		12
nonhaz & renewal		20

Summary - Class I
HAZARDOUS			NONHAZARDOUS			COMBINED
apps	5,993	$5,003,897	apps	7,940	$8,109,069	apps	13,933	$13,112,966
completion	1,761	$4,394,975	completion	2363.04158653846	$7,542,717	completion	4,124	$11,937,692
petition	6,264	$32,457,677	petition			petition	6,264	$32,457,677
startup total	14,018	$0	startup total	10,303	$15,651,786	startup total	24,321	$15,651,786
ren/mods	1,932	$5,345,284	ren/mods	460	$171,949	ren/mods	2,392	$5,517,233
mon/test	14,266	$5,404,941	mon/test	72,891	$21,629,186	mon/test	87,157	$27,034,127
report	7,566	#VALUE!	report	27,617	$1,729,391	report	35,183	#VALUE!
rkeep	363	$11,947	rkeep	1,573	$51,737	rkeep	1,936	$63,685
R&R total	7,930	#VALUE!	R&R total	29,190	$1,781,129	R&R total	37,119	#VALUE!
closure	42	$57,387	closure	2	$81	closure	44	$57,469
TOTAL	38,187	#VALUE!	TOTAL	112,846	$39,234,131	TOTAL	151,032	#VALUE!
(labor)		#VALUE!	(labor)		$6,087,041	(labor)		#VALUE!
(nonlabor)		$51,023,167	(nonlabor)		$33,147,090	(nonlabor)		$84,170,257

Sheet 5: C2Assumptions

Some numbers are hard coded based on consultations; do not change unless this is recommended in consultation pocess
Yellow cells will change automatically each ICR based on inventory. Get application data from 7520-1 data.
ASSUMPTION	VALUE	VAR NAME	NOTES
Total permit applications received	5,956	PAPPS	Based on average of 7520-1 data reported 2017-2019 (2020 data seemed unusually low); data are on Class I page. CHANGED ASSUMPTION IN 2021
Wells per area permit issued (non-HF)	3.1		Assumption. Source: EPA data from FY 1995
Total wells constructed	5,658	NWELL	Apps * 0.95. Assume that about 95% of apps get a permit, per assumptions in 2018. CHANGED ASSUMPTION IN 2021			-
Permit modifications	773	MODS	Average of 7520-1 data (2017-2020). CHANGED ASSUMPTION IN 2021			-
% of new wells in DI states	2%	WDI	Assumption based on analysis of EPA inventory.			-
% of new wells in Primacy states	98%	WPRI	Assumption based on analysis of EPA inventory.			1411
# of pluggings	1,044	PLUG	Assumption based on net change in inventory 1994-1995
II-R wells per lease	32	FACR	Assumption based on analysis of Texas data (from Class II RIA).
II-D wells per lease	1.9	FACD	Assumption based on analysis of Texas data (from Class II RIA).
Total wells per lease	33.9	FACA	Assumption based on analysis of Texas data (from Class II RIA).
Total leases	4,698	FAC	Calculated
total wells	159,269		From inventory. 1998 total = 160,970; 2001 = 146,878; 2004 = 141,129; 2010 = 150,851; 2014 = 176,516
% of wells for which operator performs	18.86%	AORO	Assumption based on consultations
% of wells for which state performs	22.23%	AORS	Assumption based on consultations
% of requiring AoR (not subject to variance or overlap)	41.1%	AORD	The Cadmus Group, Inc., Technical Issues Paper for Developing Area of Review Guidance (Draft), Contract No. 68-C4-0011, Work Assignment No. 1-38 (September 8, 1995).
Wells per operator (except HF)	10	FACA2	Assumption based on consultations
Total operators	15,927	FAC2	Calculated
Legal labor rate	$96.03	LEG	Updated rates per BLS (in labor rates sheet)	oper	1,073,400
Management labor rate	$97.14	MAN	Updated rates per BLS (in labor rates sheet)	state	132,980
Technical labor rate	$56.07	TECH	Updated rates per BLS (in labor rates sheet)
Clerical labor rate	$32.90	CLER	Updated rates per BLS (in labor rates sheet)
Contractor labor rate	$59.91	CON
Wells in DI states	3,478
State Labor rate	$45.92	STATE2
Operators in Primacy	15,579		Calculated
Operators in DI	348		Calculated
Wells in Primacy states	155,791
Percent in DI	2%		Assumption based on inventory
Class II permit applications requiring aquifer exemption	3%		Assumption based on aquifer exemptions tracking system data


New diesel HF wells subject to permitting activities	-		Zeroed out in 2018. Based on a 2014 EPA assessment of the number of disclosures to the FracFocus data base related to fractures that occurred between 1/1/2011 and 2/28/13, and include one or more diesel compounds in wells in DI states. Because the representativeness of FracFocus well records is unknown, this number is likely to be an underestimate; however it represents a small portion of the Class II universe and total ICR burden; this may be balanced by the fact that it is anticipated that operators may be moving away from use of DF compounds.
HF facilities (for permitting)	-		Because the DFHF Guidance recommendations are "short term" it is assumed that, over the ICR clearance period, permitting and operating activities will involve the same numbers of wells.
HF Facilities (for operating)	-		Assume all HF wells are in DI states

Sheet 6: C3Assumptions

Some numbers are hard coded based on consultations; do not change unless this is recommended in consultation pocess

Yellow cells will change each ICR based on inventory. Get application data from 7520-1 data.

Class 3 Assumptions

2003 UIC spreadsheet data - provides insight on breakout by type

Total new permit applications received

PAPPS3

Average of 7520-1 data (2017-2020). CHANGED ASSUMPTION IN 2021; data are on Class I page

Total

Total active

% of applications for individual permits

40%

PIND

Assumption based on consultations

Metals

4,601

1,205

7,215

743

13,764

13,021.00

96.5%

% of applications for area permits

60%

PAREA3

Assumption based on consultations

Salt

439

257

727

470.00

3.5%

Total wells constructed

NWELL3

Same as apps (to avoid negative numbers where inventory assumptions drop). CHANGED ASSUMPTION IN 2021

Other

7.00

0.1%

No. permit mods

Average of 7520-1 data (2017-2020). CHANGED ASSUMPTION IN 2021

C3 total

5,047

1,227

7,224

1,000

18,618

13,498.00

Plug/abandonments

Assumption based on consultations

Total includes wells not above

Inventory

22,612

INV

UIC inventory

Primacy

90%

In 2001 this was 99%; was 30% in 2007; 48% in 2011

10%

DIclass3

Calculated

Facilities

300

FAC3

Calculated. This number (rather than well inventory) drives the burden

Wells per facility

WFAC

Calculated

Uranium mining - 95%

21,481

URAN

Type -specific data no longer maintained; percent based on 1995 ICR, confirmed by 2003 data

Salt mining - 4%

904

SALT

Type -specific data no longer maintained; percent based on 1995 ICR, confirmed by 2003 data

Brine mining/other - 1%

226

OTH

Type -specific data no longer maintained; percent based on 1995 ICR, confirmed by 2003 data

Uranium mining facilities

URFAC

Type -specific data no longer maintained; percent based on 1995 ICR.

Salt solution mining facilities

SALFAC

Type -specific data no longer maintained; percent based on 1995 ICR.

Other Class III facilities

199

OTHFAC

Type -specific data no longer maintained; percent based on 1995 ICR.

Wells per uranium facility

1,174

WURFAC

Calculated

Wells per salt facility

WSAFAC

Calculated

Wells per other Class III facility

WOTHFAC

Calculated

Monitoring wells per facility

110

MONIT

Assumption based on consultations

Legal labor rate

$96.03

LEG3

Updated rates per BLS (links from operator sheet)

Managerial labor rate

$97.14

MAN3

Updated rates per BLS (links from operator sheet)

Technical labor rate

$56.07

TECH3

Updated rates per BLS (links from operator sheet)

Clerical labor rate

$32.90

CLER3

Updated rates per BLS (links from operator sheet)

Contractor labor rate

$59.91

CON3

State labor rate

$45.92

Class III permit applications requiring aquifer exemption

Based on aquifer exemptions tracking system data

No longer used in the ICR (all based on initial consultations)

Total renewal permit applications received

RAPPS

Not used in ICR

Total permits issued

NPERM

Not used in ICR

No. area permits

Not used in ICR

No wells covered by area permits

Not used in ICR

Wells per facility doing MIT

105

WMIT

Not used in ICR

Sheet 7: C5Assumptions

See the read me page about changing these values!!!
Update the shaded cells; all others reference other cells. Also add inventory information below
Class V Inputs

Input	Number	Var.	Notes
New wells on inventory	19,348	NEWINV	Increase in inventory since 2001 to normalize for increase/decrease year to year (see below)
Permit applications submitted	10		EPA estimate, all in primacy states (added in 2018); the 7520-1 data includes 1000s of Class V apps, which may include inventory sheets too. Keeping this BPJ estimate may be appropriate.
Legal labor rate	$28.85	LEG	From labor rates sheet
Management labor rate	$60.98	MAN	From labor rates sheet
Technical labor rate	$29.93	TECH	From labor rates sheet
Clerical labor rate	$24.89	CLER	From labor rates sheet
Cesspools closing	-		These closures are accounted for on the Class IV/endangering Class V page (beginning 2018)
MVWDWS closing	-		These closures are accounted for on the Class IV/endangering Class V page (beginning 2018)
MVWDWS getting a permit	-		Assumed to be zero beginning in 2018
MVWDWS monitoring	1,479		Frozen as of the 2015 ICR, beginning 2018
Percent in Primacy states	70%		Based on inventory
State labor rate	$45.92		From labor rate sheet
Percent submitting 7520-16 electronically	70%		Per Colin 10/14/21 - use this to est a total burden savings and percent reporting electronically

Comparing the Class V inventory over the years provides an estimate of the number of inventory submittals to review
Note: as of 2013, the Class V numbers on the inventory are no longer "frozen."
	Number	Change from prior inventory
Inventory 2001	206,379
Inventory 2006	402,020	195,641
Inventory 2007	424,098	22,078
Inventory 2008	456,990	32,892
Inventory 2009	495,032	38,042				From last ICR (to compare):
Inventory 2010	511,184	16,152		19,348	Average increase 2001-current year	19,276
Inventory 2012	486,511	-24,673			Add newer inventory data; update this formula to count rows/divide by time span
Inventory 2013	480,921	-5,590
Inventory 2014	481,957	1,036
Inventory 2015	474,367	-7,590
Inventory 2016	495,517	21,150
Inventory 2017	513,523	18,006
Inventory 2018	528,597	15,074
Inventory 2019	549,707	21,110
Inventory 2020	574,000	24,293	Dan 10/4/21: "A rough estimate looks like we have about 574k Class V wells for 2020. We are still missing a state or two, but that number will be much closer to the final inventory" Note: inventory page does not have final Class V totals in 2020; should be ok as it only provides Primacy/DI split, which doesn’t change

Sheet 8: C6Assumptions

See the read me page about changing these values!!!
Update shaded cells each ICR
Note: the ICR unit burdens assume that operators (not contractors) perform most activities – this conservatively over-estimates burden. Consider reaching out to early permittees for reality check on this assumption.

Class VI Inputs for Operator Burden				Source
	Total/yr (o/o)	Primacy	DI		Year 1 (Prim)	Year 2 (Prim)	Year 3 (Prim)	Year 1 (DI)	Year 2 (DI)	Year 3 (DI)	Permitting activity assumptions (see notes below):
Class VI permit applications	13.33	5.00	8.33	UIC estimate	6	7	2	10	10	5	15 in primacy states; 25 in DI states (most by 2023 to meet 45Q deadline)
Class VI waiver applications	0.00	0.00	0.00	UIC estimate	0	0	0	0	0	0	None
Class VI wells in oper. phase	2.67	0.33	2.33	UIC estimate	0	0	1	1	2	4	CES (in 2023 and 2024); 1 ND, 1 WY project, 2 Wabash wells will begin to operate in 2024; ADM CCS2 will inject 2022-2024
Class VI doing an AoR reeval	0.33	0	0.33	UIC estimate	0	0	0	0	1	0	No reevals
Class VI wells ceasing injection	0	0	0	UIC estimate	0	0	0	0	0	0	None
Class VI wells doing PISC	1	0	1	UIC estimate	0	0	0	1	1	1	ADM CCS1 will perform PISC for the duration
Class VI wells performing n-e. demo	0	0	0	UIC estimate	0	0	0	0	0	0	None

Mining & Geological Engineer labor rate	$105.78
Geoscientist labor rate	$118.26
Class VI inflation factor	1.2021			From BLS CPI calculator (final rule ICR was in 2008 dollars; inflate to match current year)
Primacy applications (total over clearance period)	5			UIC estimate: 2 states (Wyoming and Utah or Texas) will apply for Class VI primacy
Class VI primacy agencies	2			UIC estimate: ND, WY primacy approved as of June 2021 (and will be a primacy state throughout the ICR period). They are one of the primacy agencies listed on the inventory sheet







							Assumptions (to Dan 6/11/21):
							CES will construct a well in 2022, and operate in 2023 and 2024
Impact of state primacy approvals over last ICR (2021)							1 project in ND and 1 in WY will construct in 2023, begin to operate in 2024
If the only operating well would be in ND (covered in last ICR); no change due to primacy							The 2 Wabash wells will be constructed in 2023, and begin to operate in 2024
Assume that 4 new states will have primacy relative to 2018, and therefore incur application burden							10 permit applications will be submitted in primacy states (most in 2022 and 2023 to meet 45Q deadline)
If ~3 apps are in ND, remainder of primacy permit application burden is in new primacy states							15 permit applications will be submitted in DI states (most in 2022 and 2023 to meet 45Q deadline)
So 12/15 of the applications (80% of review burden) is due to the primacy shift							ADM CCS2 will inject 2022-2024
							ADM CCS1 will perform PISC for the duration
							5 states will apply for primacy


							From Dan in red (6/29); response in purple:
							CES will construct a well in 2022, and operate in 2023 and 2024 seems reasonable
							1 project in ND and 1 in WY will construct in 2023, begin to operate in 2024 numbers are questionable. Not aware of any projects in WY (CarbonSAFE project will not apply for Class VI). Aware of 4-5 likely projects in ND, I think we can assume that at least 2 of these will apply, if not all of them. Keep assumption about 2 projects in a primacy state (specific states are irrelevant)
							The 2 Wabash wells will be constructed in 2023, and begin to operate in 2024 plausible
							15? permit applications will be submitted in primacy states (most in 2022 and 2023 to meet 45Q deadline) How are you breaking down the transition when an applicant applies to EPA, but then the state gets primacy to complete the permit? I don’t think we can get that granular
							25? permit applications will be submitted in DI states (most in 2022 and 2023 to meet 45Q deadline) (most projects range from 1-4 wells)
							ADM CCS2 will inject 2022-2024
							ADM CCS1 will perform PISC for the duration
							5 states will apply for primacy


							Revisions to make:
							Change the number of apps in primacy/DI states
							Note about multi-well projects may necessiate reducing the average burden/permit in future ICRs. Each well needs a permit application, but some efforts can be combined/saved.

Sheet 9: By activity

This sheet allocates o/o burden and cost by type of activity; it is helpful for analysis of why burden/cost changed. Copy the previous ICR numbers in the aqua cells to the right; the tables on the left link to oper pages to compare. Update notes by hand.
	Respondents	Unit burden	Total Burden	Total Cost	Notes	2018 Burden	Burden change	Burden% change	2018 Cost	Cost change	Cost % change
Class 1 Haz
Permitting/ startup			15,950	$47,201,833	New assumption for # apps based on 7520-1 data in 2021	5,067	10,883	215%	$14,139,767	$33,062,067	234%
Monitoring/ testing			14,266	$5,404,941	Monitoring and reporting changes commensurate w/ inventory changes for Class I - III	14,472	(207)	-1%	$5,218,702	$186,239	4%		Inventory-dependent changes (2021) -- monitoring, reporting, recordkeeping
Reporting			7,566	#VALUE!		7,676	(110)	-1%	$657,325	#VALUE!	#VALUE!			2018 burden	2021 burden	Change	Pct change - this s/b commensurate w/ inventory	Inventory change (as a check)
Recordkeeping			363	$11,947		368	(5)	-1%	$11,211	$737	7%		Class I H	22,517	22,195
Well closure			42	$57,387		42	0	0%	$55,225	$2,162	4%		Class I NH	94,018	102,081
Total			38,187	#VALUE!		27,626	10,561	38%	$20,082,230	#VALUE!	#VALUE!		Class I	116,535	124,276	7,741	6.6%	6.9%
													Class II	815,015	720,353	(94,661)	-11.6%	-11.6%
Class 1 Nhaz	Respondents	Unit burden	Total Burden	Total Cost	Notes	Total Burden			Total Cost				Class III	66,441	88,588	22,147	33.3%	33.3%	In 2021, overall drop b/c of Class II, which is majority of operators
Permitting/ startup			10,763	$15,823,735	New assumption for # apps based on 7520 data.	2,468	8,295	336%	$3,073,630	$12,750,105	415%		Total I-III	997,991	933,217	(64,774)
Monitoring/ testing			72,891	$21,629,186		67,134	5,757	9%	$18,881,530	$2,747,655	15%
Reporting			27,617	$1,729,391		25,436	2,181	9%	$1,469,376	$260,015	18%
Recordkeeping			1,573	$51,737		1,448	124	9%	$44,074	$7,663	17%
Well closure			2	$81		2	0	0%	$75	$6	8%		Permit application changes (2021) -- monitoring, reporting, recordkeeping
Total			112,846	$39,234,131		96,488	16,358	17%	$23,468,686	$15,765,444	67%			2018 burden	2021 burden		Pct change - this reflects change in assumed # apps
													Class I H	5,067	15,950
Class 2	Respondents	Unit burden	Total Burden	Total Cost	Notes	Total Burden			Total Cost				Class I NH	2,468	10,763
Permitting/ startup	5,956	45 to 67	349,708	$26,710,988	New assumption for # apps based on 7520-1 data in 2021. Permitting is highest-burden activity. Total also includes completion reports and permit mods.	90,232	259,475	288%	$5,999,308	$20,711,680	345%	Num of apps increased a lot in 2021	Class I	7,535	26,713	19,178	254.5%
Monitoring/ testing	15,927	0.6 to 3	416,966	$123,973,084	Respondents = operators (not wells). Quarterly injectate monitoring; Recording of P/R/V (monthly); 5-year MITs.	471,761	(54,795)	-12%	$133,163,891	$(9,190,808)	-7%	num of responses dropped in 2021	Class II	90,232	349,708	259,475	287.6%
Reporting	15,927	6	239,680	$12,879,306	Report monitoring data, MIT results; occasional reporting	271,174	(31,495)	-12%	$12,865,624	$13,682	0%		Class III	6,013	12,889	6,876	114.3%
Recordkeeping	15,927	4	63,708	$2,465,013		72,080	(8,372)	-12%	$2,523,276	$(58,263)	-2%		Total I-III	103,780	389,309	285,529	275.1%
Well closure	1,044	3	3,270	$184,000	Notification to director	3,262	8	0%	$169,570	$14,429	9%		Class VI	3,577	47,699	44,121	1233.3%
Other	35	2	70	$3,809	Update financial responsibility in DI programs	74	(5)	-6%	$3,705	$103	3%
Total			1,073,400	$166,216,198		908,583	164,817	18%	$154,725,375	$11,490,823	7%
Unit burdens are ranges because not all respondents do all activities; also frequencies of activities vary.
Class 3	Respondents	Unit burden	Total Burden	Total Cost	Notes	Total Burden			Total Cost
Permitting/ startup			12,889	$4,668,151	New assumption for # apps based on 7520 data. Change in tot. app burden commensurate w/ responses; completion assumptions/MIT assumptions changed = large increase in total MIT burden	6,013	6,876	114%	$1,858,349	$2,809,802	151%
Monitoring/ testing			53,971	$4,104,188	increase commensurate w/ inventory change in # of sites (33% in 2021)	40,479	13,493	33%	$2,791,167	$1,313,021	47%
Reporting			33,596	$1,464,474		25,197	8,399	33%	$987,692	$476,782	48%
Recordkeeping			1,020	$36,338		765	255	33%	$24,926	$11,411	46%
Well closure			4	$294		4	0	4%	$261	$33	13%
Other			33	$1,792	FR demo in DI programs	6	27	492%	$276	$1,516	550%
Total			101,513	$10,275,236		72,464	29,050	40%	$5,662,670	$4,612,566	81%
							0
Class 4	Respondents	Unit burden	Total Burden	Total Cost	Notes	Total Burden			Total Cost
Well closure			698	$20,042	Used 7520-2B data in 2021, instead of SDW-08 data (no longer reported)	6,503	(5,806)	-89%	$165,832	$(145,790)	-88%
Total			698	$20,042		6,503	(5,806)	-89%	$165,832	$(145,790)	-88%
							0			0
Class 5	Respondents	Unit burden	Total Burden	Total Cost	Notes	Total Burden			Total Cost
Inventory			6,613	$164,578	Small unit burden, high number of responses. Similar est of # inventory forms as in last ICR	6,827	(214)	-3%	$142,436	$22,142	16%
permit applications			1,036	$1,082,518	Unchanged since 2018 9no data; EPA agrees)	1,036	0		$1,043,730	$38,788
Rule: Perm/close*			0	$-	These activities are complete as of 2018 ICR	0	0	#DIV/0!	$-	$-	#DIV/0!
Rule: Monitoring*			17,009	$8,158,506	No new data on universe	17,009	0	0%	$7,840,409	$318,097	4%
Total			24,657	$9,405,602		24,871	(214)	-1%	$9,026,574	$379,028	4%


Class 6			Total Burden	Total Cost		Total Burden			Total Cost
Permitting/ startup			47,699	$69,947,096	Assuming a big jump in apps per 45Q	3,577	44,121	1233%	$5,059,860	$64,887,236	1282%
Monitoring/ testing			1,361	3,361,019		681	681	100%	1,633,135	1,727,884	106%
Reporting			176	18,617		88	88	100%	9,100	9,517	105%
Recordkeeping			0	0		0	0	#DIV/0!	0	0	#DIV/0!
Well closure/post-injection			40	860,682		40	0	0%	836,221	24,461	3%
Other			373	39,419	AoR reevaluations	373	0	0%	38,537	882	2%
Total			49,649	$74,226,832		4,759	44,890	943%	$7,576,853	$66,649,980	880%

All Classes - conform math; see eval in Column S					Pct of total o/o burden		Burden change	Burden% change	2018 Cost	Cost change	Cost % change
Permitting/ startup/inventory			444,656	$165,598,899	32%	114,185	330,472	289%	$30,130,913	$135,467,986	450%
Monitoring/ testing			576,465	$166,630,923	41%	611,535	(35,071)	-6%	$169,528,835	$(2,897,912)	-2%
Reporting			308,635	#VALUE!	22%	329,571	(20,936)	-6%	$15,989,117	#VALUE!	#VALUE!
Recordkeeping			66,663	$2,565,035	5%	74,661	(7,998)	-11%	$2,603,488	$(38,452)	-1%
Well closure			4,055	$1,122,487	0%	9,853	(5,798)	-59%	$1,227,185	$(104,699)	-9%
Other			475	$45,020	0.03%	452	23	5%	$42,518	$2,502	6%
Total			1,400,950	#VALUE!		1,140,258	260,692	23%	$219,522,055	#VALUE!	#VALUE!



						Monitoring, test, report	(56,007)

Sheet 10: Resp summary

															Haz + Nonhaz
Summary of Annual Respondent Burden and Costs -- this page draws from the individual Class-specific tables and feeds all the summary sheets														burden	38,187	112,846	3,648	#VALUE!
							2018 ICR numbers							labor	#VALUE!	$6,087,041	$167,532	#VALUE!
Respondent Type	Number of Respondents	Number of Responses	Total Hours/ Year	Total Annual Labor Cost	Total Annual Non-labor Cost	Total Annual Respondent Cost	Respondent Type	Number of Respondents	Number of Responses	Total Hours/ Year	Total Annual Labor Cost	Total Annual Non-labor Cost	Total Annual Respondent Cost	nonlabor	$51,023,167	$33,147,090	$-
Class IH (operators)	73	2,065	38,187	#VALUE!	$51,023,167	#VALUE!								total $	#VALUE!	$39,234,131	$167,532	#VALUE!
Class IH (states)	38	706	3,648	$167,532	$0	$167,532
Class INH (operators)	393	6,636	112,846	$6,087,041	$33,147,090	$39,234,131
Class INH (states)	38	2,092	#VALUE!	#VALUE!	$0	#VALUE!

Class I (operators)	466	8,701	151,032	#VALUE!	84,170,257	#VALUE!	Class I (operators)	436	6,569	124,114	$6,107,337	$37,443,580	$43,550,916
Class I (states)	38	2,798	#VALUE!	#VALUE!	0	#VALUE!	Class I (states)	38	2,133	6,058	$264,829	$0	$264,829
Class II (operators)	15,927	418,056	1,073,400	$56,894,584	$109,321,614	$166,216,198	Class II (operators)	18,020	416,777	908,583	$41,873,053	$112,852,321	$154,725,375
Class II (states)	46	92,358	132,980	$6,106,460	$0	$6,106,460	Class II (states)	46	77,623	64,732	$2,829,570	$0	$2,829,570
Class III (operators)	300	10,562	101,513	$4,995,581	$5,279,655	$10,275,236	Class III (operators)	225	7,737	72,464	$3,132,610	$2,530,060	$5,662,670
Class III (states)	38	1,571	4,483	$205,865	$0	$205,865	Class III (states)	38	1,179	2,706	$118,283	$0	$118,283
Class IV (operators)	71	142	698	$20,042	$0	$20,042	Class IV (operators)	659	1318.66666666667	6503.42424242424	$165,832	$0	$165,832
Class IV (states)	38	56	56	$2,549	$0	$2,549	Class IV (states)	38	508	508	$22,192	$0	$22,192
Class V (operators)	20,837	28,232	24,657	$682,927	$8,722,675	$9,405,602	Class V (operators)	20,765	28,160	24,871	$601,812	$8,424,763	$9,026,574
Class V (states)	38	14,618	7,938	$364,494	$0	$364,494	Class V (states)	38	14,554	8,143	$355,934	$0	$355,934
Class VI (operators)	17	230	49,649	$5,651,568	$68,575,264	$74,226,832	Class VI (operators)	4	43	4,759	$482,019	$7,094,834	$7,576,853
Class VI (states)	5.0	22	6,951	$319,198	$0	$319,198	Class VI (states)	1	3	1,058	$46,240	$0	$46,240
UIC Primacy Agencies	59	767	66,936	$3,073,678	$0	$3,073,678	UIC Primacy Agencies	59	767	67,762	$2,961,991	$0	$2,961,991
Respondent Total		578,113	#VALUE!	#VALUE!	$276,069,465	#VALUE!	Respondent Total		557,370	1,292,260	$58,961,701	$168,345,558	$227,307,259

operator total	37,618	465,923	1,400,950	#VALUE!	$276,069,465	#VALUE!	operator total	45,753	533,819	1,434,967	$65,541,594	$173,166,157	$238,707,751
state total	59	112,190	#VALUE!	#VALUE!	$-	#VALUE!	state total	233	135,645	279,078	$11,560,545	$64,101	$11,624,646

3 year total		1,734,340	#VALUE!	#VALUE!	$828,208,394	#VALUE!
Burden/cost per response			#VALUE!			#VALUE!

Difference (2018 to 2021)			Hours change	Labor Cost change	Non-labor Cost change	Total Cost change
Class I (operators)			26,919	#VALUE!	$46,726,677	#VALUE!
Class I (states)			#VALUE!	#VALUE!	$0	#VALUE!
Class II (operators)			164,817	$15,021,531	($3,530,708)	$11,490,823
Class II (states)			68,248	$3,276,890	$0	$3,276,890
Class III (operators)			29,050	$1,862,971	$2,749,595	$4,612,566
Class III (states)			1,777	$87,582	$0	$87,582
Class IV (operators)			-5,806	($145,790)	$0	($145,790)
Class IV (states)			-452	($19,643)	$0	($19,643)
Class V (operators)			-214	$81,115	$297,913	$379,028
Class V (states)			-205	$8,560	$0	$8,560
Class VI (operators)			44,890	$5,169,550	$61,480,430	$66,649,980
Class VI (states)			5,893	$272,958	$0	$272,958
UIC Primacy Agencies			-826	$111,687	$0	$111,687
Total			#VALUE!	#VALUE!	$107,723,907	#VALUE!

	Annual	3-year total
Total labor costs	#VALUE!	#VALUE!
Total capital costs	$13,979,335	$41,938,004	capital costs=hardware for database (oversight)+ c6 capital costs
Total O&M costs	$262,090,130	$786,270,391	all other non-labor is O&M
Total non-labor costs	$276,069,465	$828,208,394
Total ICR cost	#VALUE!	#VALUE!

Percent change -- are hours/costs changes commensurate?
			Hours change	Labor Cost change	Non-labor Cost change	Total Cost change	Notes
Class I (operators)			17.8%	#VALUE!	55.5%	#VALUE!
Class I (states)			#VALUE!	#VALUE!		#VALUE!
Class II (operators)			15.4%	26.4%	-3.2%	7%	explained by more apps/fewer T&M; each has diff labor/non-labor split
Class II (states)			51.3%	53.7%		54%
Class III (operators)			28.6%	37.3%	52.1%	45%
Class III (states)			39.6%	42.5%		43%
Class IV (operators)			-831.9%	-727.4%		-727%
Class IV (states)			-814.8%	-770.8%		-771%
Class V (operators)			-0.9%	11.9%	3.4%	4%	small drop in hours, but labor costs increased
Class V (states)			-2.6%	2.3%		2%
Class VI (operators)			90.4%	91.5%	89.7%	90%
Class VI (states)			84.8%	85.5%		86%
UIC Primacy Agencies			-1.2%	3.6%		4%	same num hours; labor more expensive
Total			#VALUE!	#VALUE!	39%	#VALUE!

Sheet 11: Change

Change in Annual Respondent Burden - hard enter values for previous ICR; current ICR columns reference other worksheets.


Operator Burden Change	Previous (2018)	This ICR (2021)	Net Change	Pct change	Reasons for change (2021)	Non-labor cost change	Non-Labor cost change (%)		Reasons for Change (2018)				Reasons for Change in 2015
Class I (operators)	124,114	151,032	26,919	22%	Inventory increased by 7% (this affects the burden for monitoring/reporting activities); new assumption for # permit apps from 22 to 109 (big unit burden) based on average of 7520 data - change from past BPJ, but better data.	$46,726,677	56%		Class I inventory changed -2% since 2015				Adjustment - inventory increased 30% since 2011
Class II (operators)	908,583	1,073,400	164,817	18%	Inventory reduced by 12%; new assumption for # apps from 1,289 to 5,956 (big ticket) based on 7520 data. Non-labor cost decrease due to lower inventory/fewer doing monitoring/reporting	($3,530,708)	-3%		Class II inventory changed only 2% since 2015. Much smaller increase than in past ICRs -- affects permitting est, which is highest burden activity.				Adjustments. Inventory change between 2014 and 2011 was 3.5x inventory change over previous 2 ICRs (this drives number of permit applications, which are a significant component of the o/o burden). Inventory changes also affect total monitoring burden Also to a much smaller extent, addition of aquifer exemptions and following DFHF guidance added to burden. This is biggest component of ICR change. Note -- more of an impact to total burden tnhan total cost, b/c cyclic T&M is cost heavy and non-CBP.
Class III (operators)	72,464	101,513	29,050	40%	Number of sites (driver of M&R burden) increased 33%; new assumption for # apps from 14 to 44 (big ticket) based on 7520 data	$2,749,595	52%		Commensurate with increase in Class III sites (32%) since 2015				Adjustment - reflects change in the number of facilities; also added aquifer exemptions
Class IV (operators)	6,503	698	-5,806	-89%	Using 7520-2B data for well closure instead of PAMs (was 659 closures, now 71)	$0	0%		Commensurate with inventory change
Class V (operators)	24,871	24,657	-214	-0.9%	Inventory data shows consistent annual increase relative to last ICR; small adjustment only. Number of applications did not change. Any burden savings for e-version of 7520-16?	$297,913	3%		Class V inventory changed 3% since 2015; assume no additional Class V Rule permitting; added Class V permit applications				Adjustment. Big drop in the number of MVWDWs assumed to have permits and do sampling (cyclical and labor/cost intensive). ICR assumes that states are encouraging facilities to close rather than get permits. Also, a drop in MVWDWS and l-c cesspools identified/closed as Class V rule implementation is nearly complete (but new ones will still be identified). Also, a general decreasing trend in inventory. Small added burden to account for apps via 750-6.
Class VI (operators)	4,759	49,649	44,890	943%	Big increase in number of apps expected to meet 45Q credit	$61,480,430	90%		Reduced number of permit applications (biggest component)				Adjustment – more Class VI permit applications expected in this ICR period; also burdens adjusted based on experience in early implementation.
Operator Total	1,141,294	1,400,950	259,656	23%		$107,723,907	39%

Primacy Burden Change	Previous (2018)	This ICR (2021)	Net Change	Pct change	Reasons for change (2021)				Reasons for Change (2018)				Reasons for Change in 2015
Class I (states)	6,058	#VALUE!	#VALUE!	#VALUE!	Many new apps reviewed (from 19 to 90 in primacy states); also higher % of total wells are in primacy states				DI v. Primacy split changed (WY fix); added 2 new H apps to review
Class II (states)	64,732	132,980	68,248	105%	Many new apps reviewed (from 1,262 to 5,826 in primacy state)								Adjustments to number of permit apps to process
Class III (states)	2,706	4,483	1,777	66%	Many new apps reviewed (from 18 to 39 in primacy state); also higher % of total wells are in primacy states				Reduction due to revising assumed number of permit applications from 48 (hard coded per consultations) to 18 (based on the site inventory)
Class IV (states)	508	56	-452	-89%	Using 7520-2B numbers for well closure instead of PAMs (was 659, now 71)				Commensurate with inventory change
Class V (states)	8,143	7,938	-205	-2.5%	Inventory data shows consistent annual increase relative to last ICR; small adjustment only
Class VI (states)	1,058	6,951	5,893	557%	Increase in apps; also a shift from DI burden as states get primacy				Reduced number of permit applications to review and states applying for primacy				Adjustment – more Class VI permit applications expected in this ICR period; also burdens adjusted for review of applications based on experience in early implementation. Offset by continuing primacy application (no primacy apps in previous ICR cycle).
UIC Primacy Agencies	67,762	66,936	-826	-1%	We need to estimate burden for using web-based system (no good input from WG). Do we make an estimate and ask for reaction? Assume state recordkeeping burden reduction?				Added KY; fixes to number of primacy states per QA. No more e-reporting/frequency break.				Adjusted unit burden for e-reporters per EPA survey; changed reporting frequencies for PAMs (semi to annual) and ereporting (Q to semi).
State Total	150,966	#VALUE!	#VALUE!	#VALUE!


Total changes: 2018-2021
2018 totals	hours	total cost (lab+non)	reponses		Inventory	Total	Class 1	Class 2	Class 3	Class 5	Class 3 sites
operator	1,141,294	$220,708,221	460,604		Total - 2018 ICR	701,213	828	180,199	24,669	495,517	225							0
state	150,966	$6,599,038	96,765		Total - 2021 ICR	753,544	885	159,269	22,612	570,778	300
Total	1,292,260	$227,307,259	557,370		Change	52,331	57	-20,930	-2,057	75,261	75
					Percent change	7%	7%	-12%	-8%	15%	33%
2021 totals
operator	1,400,950	#VALUE!	465,923
state	#VALUE!	#VALUE!	112,190		Changes in # of wells in Primacy states
total	#VALUE!	#VALUE!	578,113			Previous	This ICR
					Class I wells	83%	83%				Kyle's Summary Table
Change					Class II	98%	98%					2018	2021	Change	Percent Change
operator	259,656	#VALUE!	5,319		Class III sites	78%	84%				Respondents	40,168	37,677	-2,491	-6%
state	#VALUE!	#VALUE!	15,425		Class IV						Burden	1,292,260	#VALUE!	#VALUE!	#VALUE!
total	#VALUE!	#VALUE!	20,744		Class V	70%	70%				Total Cost	$227,307,259	#VALUE!	#VALUE!	#VALUE!
											O&M Cost	$168,345,558	$276,069,465	$107,723,907	64%
For section 6(f)											Labor Cost	$58,961,701	#VALUE!	#VALUE!	#VALUE!
Approved burden - Oper & State	1,292,260
This ICR burden - Oper & State	#VALUE!												Respondents by Class	This ICR	2018Respondents	Pct	Change
Change	#VALUE!												Class1	466	436	7%	30
Oper change	259,656												Class2	15,927	18,020	-12%	-2,093
State change	#VALUE!												Class3	300	225	33%	75
													Class4	71	659	-89%	-589
Reasons for change													Class5	20,837	20,765	0.3%	73
ROCIS splits between Agency discretion (aka Program changes) and Agency estimate (aka adjustments). The rows below break out the Agency discretion change in hrs/resp/$ by type of respondent. All other changes are Agency estimate.													Class6	17	4	373%	14
For ICR bullets and ICRAS form														37,618	40,109		-2,490
*Program changes ("Agency discretion" in ROCIS)*		ROCIS category	Burden change	responses change	Non-lab cost change	Notes
7520 burden changes -oper		Pr	-240	0	$0	This is the savings associated with using the e-version of 7520-16. See Class V page; only # hours changes. States get a savings too (see state sheet).
States gaining Class VI primacy		S/M	4,160	16	$0	Assume ~80% of Class VI application burden is by states w/ new primacy (see Class VI assumptions page)
State savings due to Web-based data system and e-7520-16		S/M	-826	0	$0	No more recordkeeping burden; some inventory savings due to e-7520-16
Total due to Agency discretion		S/M total	3,334	16	$0
		Private total	-240	0	$0

*Adjustments ("Agency estimate" in ROCIS) --only need this for ICR bullets, so just hours are calculated*
Permit applications (1-3)			285,529			In 2021, different assumptions source affected this greatly; operator only
Class VI applications			44,121			Big increase in apps expected per 45Q tax credit; operator only
Class IV/V closures			-5,806			In 2021, different assumptions source affected this greatly; operator only
Inventory-dependent changes (M&R)			-64,774			Sums monitoring, reporting, rkeeping rows; operator only (commensurate w/ Class I - III inventory drop)
Other changes			#VALUE!			Everything not included above (state changes and closures of all but 4/5, aquifer exemptions)
Total adjustments			#VALUE!


This is the intro paragraph to the change section (6(f)) of the ICR. Adjust text, plus/minus to reflect increase vs. decrease in burden.
The current total annual approved burden on operators and primacy states associated with the UIC Program is	1,292,260	hours. This ICR renewal request estimates a total annual respondent burden of	#VALUE!	hours. Thus, there is a net increase in burden of	#VALUE!	hours between the approved and requested amounts. Of this,	259,656	hours is increased operator burden and	#VALUE!	is increased primacy agency burden.

Sheet 12: 7520s

Exhibit 6-2: Annual Reporting Burden by Form (Operators) 2022-2024
Form	Well classes responding	Unit burden/ response	Number of responses	Total burden (this class)	Total burden (this form)	Notes
7520-6: UIC Permit Application	I-H	215	36	5,631	261,456	The number of responses equals the number of permit applications/year; not all applicants perform all permit application-related activities, so these numbers may not appear to total.		Every cell here links to something else
	I-NH	104	73	7,244				EPA combined and revised the operator reporting forms in 2018 to reduce clerical burden.
	II	61	5,956	242,607				The burdens on the class-specific pages reflect the final forms.
	III	123	44	4,939				See “form burden reduction.xls” in 2018 ICR files folder for more on how form revisions and associated burden reductions were calculated.
	V	104	10	1,036
7520-7: Application to Transfer Permit/Ownership	I-H	2.9	1	3	1,165	The ICR assumes that a portion of the occasional notifications to the Director are permit transfer applications.		Exhibit 6-4: Annual Reporting Burden by Form (Primacy States)
	I-NH	3.9	1	4				Form	Unit burden/ response	Number of responses	Total burden
	II	4.7	239	1,115				7520-1: Report on Permit Review and Issuance (Annual)	4.5	59	266
	III	5.8	8	44				7520-2A: Report on Compliance Evaluation (Semi-annual)	6.0	118	708
7520-8: Injection Well Monitoring Report	I-H	24.7	291	7,188	63,245			7520-2B: Report on Compliance Evaluation for Significant Noncompliance (Semi-annual)	5.5	118	649
	I-NH	14.4	1,573	22,635				7520-3: Report on Mechanical Integrity Tests/Remedial Action (Annual)	5.0	59	295
	III	27.9	1,200	33,421				7520-4: Report on Quarterly Exceptions (Quarterly)	2.0	236	472
7520-11: Annual Class II Disposal/Injection Well Monitoring Report	II	29.7	4,698	139,621	139,621
7520-16: Inventory of Class V Injection Wells	V	0.4	19,348	6,613	6,613		This is the text for Paperwork Reduction Act notices (on owner or operator forms); copy to Word and clean up formatting.
7520-17: Class V Pre-Closure and Post-Closure Notification Form	V	1.4	71	96	96	The number of responses includes closures of Class IV/endangering Class V wells.	7520-6	The public reporting and recordkeeping burden for this collection of information is estimated to average	215	hours per response for operators of Class I hazardous wells,	104	hours per response for operators of Class I non-hazardous wells,	61	hours per response for operators of Class II wells,	123	hours per response for operators of Class III wells.	104	hours per response for operators of Class V wells.
7520-18: Completion Report for Injection Wells	I-H	3.9	36	142	19,038	The number of responses equals the number of permit applications/year; not all applicants perform all completion-related activities, so these numbers may not appear to total.	7520-7	The public reporting and recordkeeping burden for this collection of information is estimated to average between	2.9	and	5.8	hours per response, depending on the injection well class.
	I-NH	3.9	73	285			7520-8	The public reporting and recordkeeping burden for this collection of information is estimated to average	24.7	hours per response for operators of Class I hazardous wells,	14.4	hours per response for operators of Class I non-hazardous wells, and	27.9	hours per response for operators of Class III wells.
	II	3.3	5,658	18,439			7520-11	The public reporting and recordkeeping burden for this collection of information is estimated to average	29.7	hours per response.
	III	3.9	44	172			7520-16	The public reporting and recordkeeping burden for this collection of information is estimated to average	0.4	hours per response.
7520-19: Well Rework, Plugging & Abandonment Plan, or Plugging & Abandonment Affidavit	I-H	6.1	37	224	37,754	Numbers may not appear to total because: (1) not all respondents perform all of the plugging activities described in the ICR (particularly Class II); and (2) the ICR estimates that a small number of operators will submit occasional rework notifications each year (incurring a slightly lower unit burden than shown).	7520-17	The public reporting and recordkeeping burden for this collection of information is estimated to average	1.4	hours per response.
	I-NH	6.1	74	452			7520-18	The public reporting and recordkeeping burden for this collection of information is estimated to average between	3.3	and	3.9	hours per response, depending on the injection well class.
	II	6.0	6,195	36,689			7520-19	The public reporting and recordkeeping burden for this collection of information is estimated to average between	6.0	and	7.9	hours per response, depending on the injection well class.
	III	7.9	52	389
Notes: Numbers may not appear to total due to rounding. Class VI well operators report via the Geologic Sequestration Data Tool.






DO NOT DELETE THE ROWS BELOW. These rows describe the burden in the old (before 2018) forms. They also feed the P&A form burden in the exhibit. They also support some of the burden reduction calculations. The ICR now reflects the renumbered Forms set (with some combination of old forms 12 and 14 to account for diff. burdens and responses).
7520-9: Completion Form for Injection Wells	I-H	3.9	36	142	599	Nothing depends on these (keep for records)
	I-NH	3.9	73	285
	III	3.9	44	172
7520-10: Completion Report for Brine Disposal, Hydrocarbon Storage, or Enhanced Recovery Well	II	3.3	5,658	18,439	18,439	This feeds the burden statement - varies by class/activity reported
7520-12: Well Rework Record	I-H	2.9	1	3	1,165	These feed the exhibit above
	I-NH	3.9	1	4
	II	4.7	239	1,115
	III	5.8	8	44
7520-14: Plugging and Abandonment Plan	I-H	6.1	36	221	36,589	These feed the exhibit above
	I-NH	6.1	73	448
	II	6.0	5,956	35,574
	III	7.9	44	346

Sheet 13: ICR Tables

These are Exhibits 6-1, 6-2, 6-3, and 6-7 in the ICR. No inputs to this sheet are needed; every cell references another sheet.
Exh 6.1 A: Class 1											Exhibit 6.3 Annual Primacy Agency Burden and Cost
Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents		Program Type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response	Respondents
Operators	151,032	#VALUE!	$84,170,257	#VALUE!	8,701.1	17.36	#VALUE!		466		Class 1 Primacy	#VALUE!	#VALUE!	$0	#VALUE!	2,798.4	#VALUE!	#VALUE!	38
Primacy States	#VALUE!	#VALUE!	$0	#VALUE!	2,798.4	#VALUE!	#VALUE!		38		Class 2 Primacy	132,980	$6,106,460	$0	$6,106,460	92,357.6	1.44	$66.12	46
DI Programs	19,885	$913,101	$0	$913,101	815.8	24.37	$1,119.27		8		Class 3 Primacy	4,483	$205,865	$0	$205,865	1,571.5	2.85	$131.00	38
Total	#VALUE!	#VALUE!	$84,170,257	#VALUE!	12,315.3	#VALUE!	#VALUE!		512		Class 4 Primacy	56	$2,549	$0	$2,549	55.5	1.00	$45.92	38
											Class 5 Primacy	7,938	$364,494	$0	$364,494	14,617.7	0.54	$24.94	38
Exh 6.1 B: Class 2											Class 6 Primacy	6,951	$319,198	$0	$319,198	22.3	311.25	$14,292.43	5
Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents		Subtotal -oper oversight	#VALUE!	#VALUE!	$0	#VALUE!	111,423.1	#VALUE!	#VALUE!	59
Operators	1,073,400	$56,894,584	$109,321,614	$166,216,198	418,055.8	2.57	$397.59		15,927		States as Respondents	66,936	$3,073,678	$0	$3,073,678	767.0	87.27	$4,007.40	59
Primacy States	132,980	$6,106,460	$0	$6,106,460	92,357.6	1.44	$66.12		46		Total	#VALUE!	#VALUE!	$0	#VALUE!	112,190.1	#VALUE!	#VALUE!
DI Programs	5,938	$272,682	$0	$272,682	5,111.9	1.16	$53.34		6
Total	1,212,319	$63,273,726	$109,321,614	$172,595,339	515,525.3	2.35	$334.80		15,979
											Exh 6.5 Annual Agency Burden and Cost
Exh 6.1 C: Class 3											Program Type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response	Respondents
Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents		Class I DI	19,885	$913,101	$0	$913,101	815.8	24.37	$1,119.27	10
Operators	101,513	$4,995,581	$5,279,655	$10,275,236	10,562.0	9.61	$972.85		300		Class II DI	5,938	$272,682	$0	$272,682	5,111.9	1.16	$53.34	10
Primacy States	4,483	$205,865	$0	$205,865	1,571.5	2.85	$131.00		38		Class III DI	215	$9,886	$0	$9,886	161.3	1.33	$61.28	10
DI Programs	215	$9,886	$0	$9,886	161.3	1.33	$61.28		8		Class IV DI	15	$700	$0	$700	15.3	1.00	$45.92	10
Total	106,212	$5,211,332	$5,279,655	$10,490,987	12,294.8	8.64	$853.29		346		Class V DI	3,242	$148,889	$0	$148,889	6,229.7	0.52	$23.90	10
											Class VI DI	9,060	$416,028	$0	$416,028	43.1	210.37	$9,660.08	1
Exh 6.1 D: Class 4											HQ Activities	4,160	$191,027	$0	$191,027	1.0	4,160	191,027	11
Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents		Total	42,516	$1,952,314	$0	$1,952,314	12,378.1	3.43	$157.72	10
Operators	698	$20,042	$0	$20,042	141.5	4.93	$141.64		71		DI Total	38,356	$1,761,287	$0	$1,761,287	12,377.1	3.10	$142.30
Primacy States	56	$2,549	$0	$2,549	55.5	1.00	$45.92		38
DI Programs	15	$700	$0	$700	15.3	1.00	$45.92		8		Exhibit 6.7 All Classes
Total	769	$23,291	$0	$23,291	212.3	3.62	$109.74		117		Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response	Respondents
											Operators	1,400,950	#VALUE!	$276,069,465	#VALUE!	465,923.1	3.01	#VALUE!	37,618
Exh 6.1 E: Class 5											Primacy States	#VALUE!	#VALUE!	$0	#VALUE!	112,190.1	#VALUE!	#VALUE!	59
Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents		Respondent total	#VALUE!	#VALUE!	$276,069,465	#VALUE!	578,113.2	#VALUE!	#VALUE!	37,677
Operators	24,657	$682,927	$8,722,675	$9,405,602	28,232.5	0.87	$333.15		20,837		Federal	42,516	$1,952,314	$0	$1,952,314	12,378.1	3.43	$157.72	11
Primacy States	7,938	$364,494	$0	$364,494	14,617.7	0.54	$24.94		38		Total	#VALUE!	#VALUE!	$276,069,465	#VALUE!	590,491.2	#VALUE!	#VALUE!	37,688
DI Programs	3,242	$148,889	$0	$148,889	6,229.7	0.52	$23.90		8
Total	35,837	$1,196,310	$8,722,675	$9,918,985	49,079.9	0.73	$202.10		20,883		3-yr tot. (non-Fed)	Burden	Labor Cost	O&M Cost	Total Cost	Responses
												#VALUE!	#VALUE!	$828,208,394	#VALUE!	1,734,340
Exh 6.1 F: Class 6											Per response	#VALUE!			#VALUE!
Respondent type	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents		Per respondent	#VALUE!			#VALUE!
Operators	49,649	$5,651,568	$68,575,264	$74,226,832	230.3	215.61	$322,351.62		17.3
Primacy States	6,951	$319,198	$0	$319,198	22.3	311.25	$14,292.43		5.0
DI Programs	9,060	$416,028	$0	$416,028	43.1	210.37	$9,660.08		1.0
Total	65,660	$6,386,794	$68,575,264	$74,962,058	295.7	222.07	$253,535.71		23.3


Exh 6.1 G: All Classes	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Burd/ Resp	$/ Response		Respondents
Class 1 operators	151,032	#VALUE!	$84,170,257	#VALUE!	8,701.1	17.36	#VALUE!		466
Class 2 operators	1,073,400	$56,894,584	$109,321,614	$166,216,198	418,055.8	2.57	$397.59		15,927
Class 3 operators	101,513	$4,995,581	$5,279,655	$10,275,236	10,562.0	9.61	$972.85		300
Class 4 operators	698	$20,042	$0	$20,042	141.5	4.93	$141.64		71
Class 5 operators	24,657	$682,927	$8,722,675	$9,405,602	28,232.5	0.87	$333.15		20,837
Class 6 operators	49,649	$5,651,568	$68,575,264	$74,226,832	230.3	215.61	$322,351.62		17
All Classes	1,400,950	#VALUE!	$276,069,465	#VALUE!	465,923	3.01	#VALUE!		37,618




For FR Notice:
Number of respondents:		37,677
Responses per respondent:		15.34
Frequency of response:		annual, semi-annual, quarterly
Burden per response:		#VALUE!
Annual burden hours:		#VALUE!
Annual costs:		#VALUE!
Annual labor costs:		#VALUE!
Annual non-labor costs:		$276,069,465
Change (hours)		#VALUE!




This is the penultimate paragraph of section 1 of the ICR
EPA estimates that, over the three years covered by this request, the total burden on underground injection well operators and primacy agencies associated with UIC requirements will be	#VALUE!	hours (an average of	#VALUE!	hours per year), and the present value cost will be	#VALUE!	(an average of	#VALUE!	per year). The public reporting and recordkeeping burden for this collection of information is estimated to average	#VALUE!	hours, or	#VALUE!	per response annually. The annual burden per respondent is	#VALUE!	hours; the cost per respondent is	#VALUE!

First para of 6(b)(i) Cost to Operators
Annual costs to injection well operators are estimated at approximately	#VALUE!	million, which consists of	$276.1	million in non-labor costs and	#VALUE!	million in labor costs.

For section 6(d):
EPA estimates that the total non-federal respondent burden over the three years covered by this ICR is	#VALUE!	million hours (or	#VALUE!	million hours per year). The total cost to respondents is	#VALUE!	million (or	#VALUE!	million per year).

Sheet 14: Bottom line

Exhibit 6.6 Bottom Line Annual Burden and Cost
Number of Respondents	37,677	=	37,618	Operators (from EPA inventory) +
			59	Primacy agencies
Total Annual Responses	578,113	=	465,923	Operator responses (from Exhibit 6-1G) +
			112,190	Primacy agency responses (from Exhibit 6-3)
Number of Responses per Respondent	15.3	=	578,113	Total annual responses from above/
			37,677	Total respondents from above
Total Respondent Hours	#VALUE!	=	1,400,950	Operator burden hours (from Exhibit 6-1G) +
			#VALUE!	Primacy agency burden hours (from Exhibit 6-3)
Hours per Response	#VALUE!	=	#VALUE!	Total annual hours from above/
			578,113	Total responses from above
Annual O&M and Capital Cost	$276,069,465	=	$276,069,465	Operator non-labor cost (from Exhibit 6-1G) +
			$0	Primacy agency non-labor cost (from Exhibit 6-3)
Total Respondent Cost	#VALUE!	=	#VALUE!	Operator cost (from Exhibit 6-1G) +
			#VALUE!	Primacy agency cost (from Exhibit 6-5)
Total Hours (Respondents)	#VALUE!	=	#VALUE!	Total respondent hours from above +
			42,516	Total EPA hours (from Exhibit 6-5)
Total Cost (Respondents plus Agency)	#VALUE!	=	#VALUE!	Total respondent cost from above +
			$1,952,314	Total EPA cost (from Exhibit 6-5)


This is Exhibit 6-6 in the ICR. No inputs to this sheet are needed; every cell references another sheet.

Sheet 15: Class 1 H


	Table A-1A
	Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: Operators

							A	B	C	D	E	F
			Hours and Costs per Response											Total Hours and Costs
CFR Citation	Description of Requirement	Frequency (A)	Legal	Managerial	Technical	Clerical	Unit Burden	Unit Labor Cost	Unit Non-labor Cost (B)	No. of Responses	Total Hours/Year	Total Cost/Year		No. of Respondents	Total labor cost	Total nonlabor cost			7520 form used
	Initial/Startup Requirements (Per Permit Application)
	*Requirements associated with permit applications*
	Read permit application directions.	One-time	0.0	0.25	0.25	0.00	0.5	$38	$0	36	18	$1,379		36	$1,379	$0		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)	Gather and submit description of activities requiring a permit, facility name and address, SIC codes, ownership & facility status, facility location, listing of relevant permits/construction approvals, description of the business.	One-time	3.0	2.0	9.0	5.8	19.8	$1,176	$0	36	711	$42,354		36	$42,354	$0		Clerical burden changed in 2018 per form redesign.	7520-6
144.31(e)(9)	In DI programs, gather and submit a list of land owners within one-quarter mile of the facility boundary.	One-time	4.0	0.0	0.0	1.2	5.2	$422	$0	6	32	$2,609		6	$2,609	$0		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(2,3)	Prepare and submit a map and tabulation of all wells within the AoR.	One-time	0.0	1.5	5.5	0.0	7.0	$454	$25,643	36	252	$939,490		36	$16,348	$923,142		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(4)	Prepare and submit AoR protocol.	One-time	0.0	0.0	1.3	0.0	1.3	$73	$993	36	47	$38,388		36	$2,624	$35,764		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(5-7)	Prepare and submit maps/cross sections of local and regional geology, USDWs.	One-time	0.0	1.5	16.0	0.0	17.5	$1,043	$53,239	36	630	$1,954,133		36	$37,544	$1,916,589		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(9-11)	Develop formation testing and stimulation programs & injection procedures.	One-time	0.0	2.0	5.0	1.0	8.0	$506	$7,642	36	287	$293,332		36	$18,224	$275,108		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(13)	Prepare and submit contingency plans for shut-ins or well failures.	One-time	0.0	3.0	10.0	1.9	14.9	$915	$297	36	537	$43,650		36	$32,951	$10,699		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(14)	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		36	$10,316	$180,349		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(15)	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		36	$15,664	$456,986		Clerical burden changed in 2018 per form redesign.	7520-6
146.70(a)(12,16,17)	Prepare and submit descriptions of logs and tests, construction schematics & operating data.	One-time	0.0	2.0	8.0	4.8	14.8	$801	$6,368	36	533	$258,084		36	$28,827	$229,257		Clerical burden changed in 2018 per form redesign.	7520-6
146.71(a)	Prepare and submit closure plan, including demonstration of financial responsibility.	One-time	0.0	1.0	3.0	2.1	6.1	$336	$1,877	36	221	$79,637		36	$12,083	$67,554		Clerical burden changed in 2018 per form redesign.	7520-19
146.72(a)(1)	Prepare and submit post-closure care plan.	One-time	0.0	1.4	2.0	1.3	4.7	$291	$2,310	36	169	$93,623		36	$10,479	$83,144		Clerical burden changed in 2018 per form redesign.	7520-6
146.72(a)(1)	Prepare and submit information to support an aquifer exemption request.	One-time	0.0	2.5	17.0	0.5	20.0	$1,213	$2,310	6.1	122	$21,555		6	$7,421	$14,134
	*Requirements for active hazardous waste facilities*
144.31(g)(1)	Gather and submit dates of well operation and specific waste information.	One-time	0.0	0.0	26.6	10.9	37.5	$1,852	$9,680	36	1,351	$415,126		36	$66,656	$348,471		Clerical burden changed in 2018 per form redesign.	7520-6
144.31(g)(2)	Gather and submit hazardous waste release information.	One-time	0.0	1.9	30.4	21.9	54.2	$2,609	$4,840	0	0	$0		36	$0	$0		Clerical burden changed in 2018 per form redesign.	7520-6
146.68(a)(1)	Develop waste analysis plan.	One-time	0.0	1.9	15.2	1.8	18.9	$1,097	$3,227	36	681	$155,645		36	$39,488	$116,157		Clerical burden changed in 2018 per form redesign.	7520-6
146.66(f)	Prepare construction logging/testing schedule.	One-time	0.0	0.0	0.5	0.5	1.0	$44	$0	36	35	$1,578		36	$1,578	$0		Clerical burden changed in 2018 per form redesign.	7520-6
	*Requirements associated with completion reports*														$0	$0
146.70	Prepare and submit completion report.	One-time	0.0	0.0	1.5	2.4	3.9	$164	$0	36	142	$5,916		36	$5,916	$0		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(1)	Submit results of deviation checks, other logs & tests; sample formation fluids; test injection and confining zones.	One-time	0.0	0.0	6.0	1.0	7.0	$369	$39,059	36	251	$1,419,377		36	$13,267	$1,406,110		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(2)	Demonstrate mechanical integrity.	One-time	0.0	2.0	18.0	0.0	20.0	$1,204	$25,473	36	720	$960,358		36	$43,330	$917,028		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(3)	Submit information on the anticipated maximum pressure and flow rate.	One-time	0.0	0.0	2.0	0.0	2.0	$112	$170	36	72	$10,151		36	$4,037	$6,114		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(4)	Submit formation testing results.	One-time	0.0	1.0	4.0	0.0	5.0	$321	$42,455	36	180	$1,539,952		36	$11,572	$1,528,380		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(5)	Submit actual injection procedure.	One-time	0.0	0.0	1.0	0.0	1.0	$56	$170	36	36	$8,132		36	$2,019	$6,114		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(6)	Demonstrate hydrogeologic compatibility/ compatability of well materials.	One-time	0.0	2.0	6.0	0.0	8.0	$531	$8,491	36	288	$324,782		36	$19,106	$305,676		Clerical burden changed in 2018 per form redesign.	7520-18
146.70(b)(7)	Prepare and submit information on calculated AoR.	One-time	0.0	0.0	2.0	0.0	2.0	$112	$3,396	36	72	$126,308		36	$4,037	$122,270		Clerical burden changed in 2018 per form redesign.	7520-18
	*No-migration petition requirements*														$0	$0
148.22(a)	Submit waste information and modeling data to demonstrate that wastes will not migrate from injection zone.	One-time	0.0	24.0	120.0	30.0	174.0	$10,047	$891,555	36	6,264	$32,457,677		36	$361,697	$32,095,980
	*Requirements associated with permit renewals/modifications and petition modifications*														$0	$0
144.39	Submit updated permit application attachments.	Occasional	0.0	9.0	41.5	21.0	71.5	$3,892	$12,567	12	858	$197,506		12	$46,706	$150,800
144.51(f)	Request Permit Modification.	One-time	0.0	2.0	6.0	2.0	10.0	$597	$7,302	3	30	$23,696		3	$1,790	$21,907
148.20(f)	Prepare and submit Petition Modification.	One-time	0.0	24.0	120.0	30.0	174.0	$10,047	$843,966	6	1,044	$5,124,081		6	$60,283	$5,063,798
	Monitoring/Testing Requirements (Per Facility)														$0	$0
146.67(f)	Use continuous recording devices to monitor injection pressure, flow rate, volume, and temperature.	Continuous	0.0	0.0	5.7	0.0	5.7	$320	$0	73	414	$23,215		73	$23,215	$0
146.68(a)(2)	Conduct chemical monitoring of injectate as prescribed in waste analysis plan.	As specified in WAP	0.0	0.0	38.0	0.0	38.0	$2,131	$5,095	291	11,040	$2,099,177		73	$619,061	$1,480,115
146.68(a)(3)	Conduct additional chemical monitoring as specified by the Director.	Varies	0.0	0.0	7.6	0.0	7.6	$426	$1,019	29	221	$41,984		7	$12,381	$29,602
146.68(d)(1,2)	Conduct casing pressure test and radioactive tracer survey of bottom-hole cement.	Annual	0.0	3.8	5.2	0.0	9.0	$661	$7,033	58	523	$447,048		58	$38,390	$408,657
146.68(d)(3)	Conduct casing pressure test, radioactive tracer of bottom-hole cement, & noise/temperature logs to check for movement along the borehole.	Every 5 years	0.0	1.0	7.0	0.0	8.0	$490	$48,399	15	116	$710,168		15	$7,113	$703,055
146.68(d)(4)	Conduct casing inspection log at workover.	Occasional	0.0	3.8	8.0	0.0	11.8	$818	$8,440	4	43	$33,619		4	$2,970	$30,649
146.68(e)(1)	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		73	$115,641	$1,430,300
146.68(e)(2)	Conduct ambient monitoring.	Annual	0.0	0.4	1.9	0.0	2.3	$143	$6,793	73	166	$503,791		73	$10,419	$493,372
	Reporting Requirements (Per Facility)														$0	$0
144.51(l)(1-3, 5-8)	Prepare and submit report on maximum injection pressure, total injectate volume, and monitoring and testing results.	Quarterly	0.0	4.0	15.0	5.7	24.7	#VALUE!	$0	291	7,188	#VALUE!		73	#VALUE!	$0		Clerical burden changed in 2018 per form redesign.	7520-8
144.62(b, c)	Prepare and submit MIT report.	Annual	0.0	1.0	2.0	1.0	4.0	#VALUE!	$1,528	73	291	#VALUE!		73	#VALUE!	$111,009
146.69(a)(1,4,7)	Notify Director of: any planned physical changes to facility, changes that may result in noncompliance, permit transfers, planned workovers, USDW endangerment.	Occasional	0.0	1.0	2.0	3.0	6.0	#VALUE!	$0	1	4	#VALUE!		1	#VALUE!	$0
146.69(a)(2,3,5); 146.69(b)(2,3)	Prepare and submit revised plugging and abandonment cost estimate.	Annual	0.0	1.0	0.0	0.0	1.0	#VALUE!	$0	73	73	#VALUE!		73	#VALUE!	$0
167.69(b)(1)	Report on: events exceeding operating parameters or triggering alarms; changes in annular fluid volume; workovers or other testing; or permit transfers.	Occasional	0.0	1.0	1.0	0.9	2.9	$182	$0	4	10	$661		4	$661	$0		Clerical burden changed in 2018 per form redesign.	7520-19
	Recordkeeping Requirements (Per Facility)														$0	$0
144.51(j); 144.62(d)	Maintain monitoring information, calibration & maintenance records, required reports, application data, monitoring results, and most recent plugging & abandonment cost estimate.	3 years	0.0	0.0	0.0	5.0	5.0	$164	$0	73	363	$11,947		73	$11,947	$0
	Closure Requirements (Per Well)														$0	$0
146.71(b)	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		1	$81	$0
146.71(c)	Prepare and submit closure report.	One-time	0.0	2.0	8.0	0.0	10.0	$643	$3,396	1	10	$4,039		1	$643	$3,396
146.71(d)(1)	Conduct pressure fall-off test.	One-time	0.0	1.0	5.0	0.0	6.0	$378	$19,693	1	6	$20,070		1	$378	$19,693
146.71(d)(2)	Demonstrate mechanical integrity.	One-time	0.0	2.0	18.0	0.0	20.0	$1,204	$31,789	1	20	$32,993		1	$1,204	$31,789
146.72(b, c)	Notify state or local zoning or drilling authorities and Regional Administrator following closure.	One-time	0.0	0.5	1.0	3.0	4.5	$203	$0	1	5	$203		1	$203	$0
	TOTAL									2,065	38,187	#VALUE!			#VALUE!	51,023,167

	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.


	number of respondents:	73

										8,701	151,032	#VALUE!	0	0	#VALUE!	51,023,167	30,624

Sheet 16: C1hstate


	Table A-1A (continued)
	Annual Paperwork Burden and Costs Associated with Class I Hazardous Wells: States

			A	B	C	D	E	F
			Hours and Costs per Response			Total Hours and Costs
CFR Citation	Description of Requirement	Frequency (A)	Unit Burden (B)	Unit Labor Cost	Unit Nonlabor Cost	Number of State Responses	Total State Hours/Year	Total State Cost/Year	Number of Responses (Dl)	Total DI Hours/Year
	Initial/Start-up
	*Permit Applications*
124.6(d)	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.	One-time	40.0	$1,837	$0	30	1,193	$54,768	6	247.3
124.10	Provide public notice of issuance of a draft permit or intent to deny.	One-time	1.0	$46	$0	30	30	$1,369	6	6.2
124.11	Consider public comments.	One-time	6.0	$276	$0	30	179	$8,215	6	37.1
124.15	Issue final permit decision.	One-time	2.0	$92	$0	30	60	$2,738	6	12.4
124.17	Respond to comments.	One-time	7.0	$321	$0	30	209	$9,584	6	43.3
146.70(b)	Review notice of completion of construction.	One-time	2.0	$92	$0	30	60	$2,738	6	12.4
	Review information related to aquifer exemption requests and forward to EPA region.	One-time	1.0	$46	$0	5	5	$233	6	6.2
	*No-Migration Petitions*
148.22	Review and respond to petition request.	One-time	18.0	$827	$0	30	537	$24,645	6	11,520.0
148.22(b)	Public notice/public comment.	One-time	10.0	$459	$0	30	298	$13,692	6	5,184.0
148.20(f)	Review and respond to petition modification request.	One-time	10.0	$459	$0	5	50	$2,282	1	600.0
	*Permit renewals/modifications*
144.39	Review and respond to requests for permit modifications or re-issuance.	Occasional	30.0	$1,378	$0	10	298	$13,692	2	61.8
	Monitoring/Testing
146.69; 268.1(e)(1)	Review quarterly monitoring and testing results.	Quarterly	1.5	$69	$0	241	361	$16,574	50	74.8
146.68(d)(1)(2)	Review casing pressure test and radioactive tracer survey of bottom-hole cement.	Annual	4.0	$184	$0	48	193	$8,840	18	72.6
146.68(d)(1)(2)(3)	Review casing pressure test, radioactive tracer survey of bottom-hole cement, and logs.	Every 5 years	4.0	$184	$0	12	48	$2,210	2	10.0
146.71(d)	Review pressure fall-off test.	Annual	2.0	$92	$0	46	93	$4,254	47	94.7
	Other Reporting
144.51(l); 146.69(a); 146.69(b)	Respond to periodic notifications by owners and operators.	Occasional	2.0	$92	$0	5	10	$456	1	2.1
	Closure
146.70(c)	Review closure and post-closure plans prior to approving plugging and abandonment.	One-time	2.0	$92	$0	1	2	$92	0	0.0
146.71(d)(1)	Witness and review pressure fall-off test prior to authorizing closure.	One-time	24.0	$1,102	$0	1	24	$1,102	0	0.0
	TOTAL					706	3,648	$167,532		17,985

	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.

Sheet 17: Class 1 NH


	Table A-1B
	Annual Paperwork Burden and Costs Associated with Class I Nonhazardous Wells: Operators
																Segregate municipal burden and cost for ROCIS reporting (assume FL facilities are 30% of all NH)
							A	B	C	D	E	F
			Hours and Costs per Response												Total Hours and Costs
CFR Citation	Description of Requirement	Frequency (A)	Legal	Managerial	Technical	Clerical	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost (B)	No. of Responses	Total Hours/Year	Total Cost/Year		No. of Respondents		Municipal burden	Municipal labor cost	Municipal nonlabor cost	Municipal cost	Municipal responses		7520 form used
	Initial/Startup Requirements (Per Permit Application)
	*Requirements associated with permit applications*
	Read permit application directions.	One-time	0.0	0.25	0.25	0.00	0.5	$38	$0	73	37	$2,796		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a) (1, 4-12)	Gather and submit description of activities requiring a permit, facility name & address, SIC codes, ownership & facility status, facility location, list of relevant permits/construction approvals, description of the business.	One-time	3.0	2.0	9.0	5.8	19.8	$1,179	$0	73	1,448	$86,071		73							Clerical burden changed in 2018 per form redesign.	7520-6
144.31(e)(9)	In DI programs, gather and submit a list of landowners within 1/4 mile of the facility boundary.	One-time	4.0	0.0	0.0	1.2	5.2	$423	$0	13	65	$5,298		13							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(2,3)	Prepare and submit a map and tabulation of all wells within the AoR.	One-time	0.0	1.5	5.5	0.0	7.0	$454	$20,514	73	511	$1,530,691		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(4-6)	Prepare and submit maps/cross sections of local and regional geology, USDWs.	One-time	0.0	1.5	16.0	0.0	17.5	$1,043	$53,239	73	1,278	$3,962,547		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(7,11,15)	Prepare and submit descriptions of logs and tests, construction schematics and operating data.	One-time	0.0	2.0	8.0	2.4	12.4	$723	$6,368	73	908	$517,652		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(8-10)	Develop formation testing and stimulation programs and injection procedures.	One-time	0.0	2.0	7.0	1.0	10.0	$619	$7,642	73	728	$603,031		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(12)	Prepare and submit contingency plans for shut-ins or well failures.	One-time	0.0	3.0	10.0	1.9	14.9	$916	$297	73	1,091	$88,574		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(13)	Prepare and submit ambient monitoring plan.	One-time	0.0	3.0	3.0	2.9	8.9	$556	$5,010	73	651	$406,269		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(14)	Prepare and submit Corrective Action Plan.	One-time	0.0	2.0	3.0	2.2	7.2	$436	$9,765	73	528	$744,655		73							Clerical burden changed in 2018 per form redesign.	7520-6
146.14(a)(16)	Prepare and submit closure plan, including demonstration of financial responsibility.	One-time	0.0	1.0	3.0	2.1	6.1	$336	$1,877	73	448	$161,486		73							Clerical burden changed in 2018 per form redesign.	7520-19
	Prepare and submit information to support an aquifer exemption request.	One-time	0.0	2.5	17.0	0.5	20.0	$0	$0	12.4	248	$0		12
	*Requirements associated with completion reports*												permit
146.14(b)	Prepare and submit completion report.	One-time	0.0	0.0	1.5	2.4	3.9	$163	$0	73	285	$11,922		73							Clerical burden changed in 2018 per form redesign.	7520-18
146.14(b)(1)	Prepare and submit a report of deviation checks and other logs and tests during construction.	One-time	0.0	0.0	6.0	1.0	7.0	$368	$39,059	73	508	$2,878,151		73							Clerical burden changed in 2018 per form redesign.	7520-18
146.14(b)(2)	Demonstrate mechanical integrity.	One-time	0.0	2.0	3.5	0.0	5.5	$391	$11,038	73	402	$834,305		73							Clerical burden changed in 2018 per form redesign.	7520-18
146.14(b)(3)	Submit information on the anticipated maximum pressure and flow rate.	One-time	0.0	0.0	2.0	0.0	2.0	$112	$170	73	146	$20,584		73							Clerical burden changed in 2018 per form redesign.	7520-18
146.14(b)(4)	Submit results of the formation testing program.	One-time	0.0	1.0	4.0	0.0	5.0	$321	$42,455	73	365	$3,122,680		73							Clerical burden changed in 2018 per form redesign.	7520-18
146.14(b)(5)	Submit actual injection procedure.	One-time	0.0	0.0	1.0	0.0	1.0	$56	$170	73	73	$16,490		73							Clerical burden changed in 2018 per form redesign.	7520-18
146.14(b)(6)	Demonstrate hydrogeologic compatibility/ compatibility of well materials.	One-time	0.0	2.0	6.0	0.0	8.0	$531	$8,491	73	584	$658,585		73							Clerical burden changed in 2018 per form redesign.	7520-18
	*Requirements associated with permit renewals/modifications*
144.39	Submit updated components of permit application attachments.	Occasional	0.0	8.0	11.0	2.0	21.0	$1,460	$5,944	20	420	$148,068		20
144.51(f)	Prepare and submit request for permit modification.	Occasional	0.0	2.0	6.0	0.0	8.0	$531	$4,246	5	40	$23,881		5
	Monitoring/Testing Requirements (Per Facility)
146.13(b)(1)	Analyze injected fluids.	Per permit	0.0	0.0	38.0	0.0	38.0	$2,131	$3,396	1,573	59,760	$8,692,292		393		17,928	$1,005,302	$1,602,386	$2,607,688	472
146.13(b)(2)	Monitor injection pressure, flow rate and volume, and annulus pressure.	Continuous	0.0	0.0	5.7	0.0	5.7	$320	$0	393	2,241	$125,663		393		672	$37,699	$0	$37,699	118
146.13(b)(3)	Demonstrate mechanical integrity.	Every 5 years	0.0	1.0	8.0	0.0	9.0	$546	$20,973	79	708	$1,692,034		79		212	$12,874	$494,737	$507,610	24
146.13(d)(1)	Conduct pressure fall-off test.	Annual	0.0	8.0	16.0	0.0	24.0	$1,674	$19,693	393	9,436	$8,400,532		393		2,831	$197,477	$2,322,683	$2,520,160	118
146.13(d)(2)	Conduct ambient monitoring.	Annual	0.0	0.4	1.5	0.0	1.9	$122	$6,793	393	747	$2,718,665		393		224	$14,407	$801,193	$815,600	118
	Reporting Requirements (Per Facility)
146.13(c)(1)	Report on: physical, chemical, and other characteristics of injected fluids; injection pressure, flow rate, and volume; and monitoring of USDWs.	Quarterly	0.0	0.0	4.0	10.4	14.4	$566	$0	1,573	22,635	$890,438		393		6,790	$267,131	$0	$267,131	472	Clerical burden changed in 2018 per form redesign.	7520-8
146.13(d)	Report results of ambient monitoring and pressure fall-off test.	Annual	0.0	2.0	6.0	4.0	12.0	$662	$1,406	393	4,718	$813,217		393		1,415	$78,118	$165,847	$243,965	118
144.51(l)(1-3, 5-8)	Notify Director of: any planned physical changes to facility, changes that may result in noncompliance, permit transfers, planned workovers, possible endangerment to a USDW.	Occasional	0.0	1.0	2.0	3.0	6.0	$308	$0	20	118	$6,054		20		35	$1,816	$0	$1,816	6
144.52(a)(7)	Submit periodic updates of financial responsibility for closure that account for inflation.	Occasional	0.0	1.0	0.0	0.0	1.0	$97	$0	131	131	$12,730		131		39	$3,819	$0	$3,819	39
146.13(c)(2)	Report results of: any required mechanical integrity tests, other required tests, well workovers, or permit transfers.	Occasional	0.0	1.0	2.0	0.9	3.9	$240	$1,528	4	15	$6,953		4		5	$283	$1,803	$2,086	1	Clerical burden changed in 2018 per form redesign.	7520-7
	Recordkeeping Requirements (Per Facility)
144.51(j)(2)	Maintain monitoring information, calibration & maintenance records, required reports, application data, and monitoring results.	At least 3 years	0.0	0.0	0.0	4.0	4.0	$132	$0	393	1,573	$51,737		393		472	$15,521	$0	$15,521	118
	Closure Requirements (Per Well)
144.51(n)	Notify the Director before conversion or abandonment of the well or closure of the project.	One-time	0.0	0.5	0.0	1.0	1.5	$81	$0	1	2	$81		1
	TOTAL									6,636	112,846	$39,234,131		393		30,624	$1,634,447	$5,388,648	$7,023,094	1,603

	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.









	Intro to Class I section of ICR:
	The total annual burden on the	466	operators of Class I wells nation-wide is estimated to be	151,032	hours. See Exhibit 6-1A. Of this total, EPA estimates the annual burden for the	73	operators of Class I hazardous wells to be	38,187	hours, and the burden for the	393	operators of Class I non-hazardous wells to be	112,846	hours annually

Sheet 18: C1nhstate


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			Total Hours and Cost
Description of Requirement	Frequency (A)	Unit Burden (B)	Unit Labor Cost	Unit Non-Labor Cost	Number of State Responses	Total State Hours/Year	Total State Cost/Year	Notes
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.	One-time	20.0	$918	$0	6	121	$5,553
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	40.0	$1,837	$0	54	2,177	$99,951
Provide public notice of issuance of a draft permit or intent to deny.	One-time	1.0	$46	$0	60	60	$2,776
Consider public comments.	One-time	6.0	$276	$0	60	363	$16,659
Issue final permit decision.	One-time	2.0	$92	$0	60	121	$5,553
Respond to comments.	One-time	7.0	$321	$0	60	423	$19,435
Review notice of completion of construction.	One-time	2.0	$92	$0	60	121	$5,553
Review information related to aquifer exemption requests and forward to EPA region.	One-time	1.0	$46	$0	10	10	$472
*Permit renewals/modifications*
Review and respond to requests for permit modifications or re-issuance.	Occasional	30.0	$1,378	$0	17	497	$22,820
Monitoring/Testing
Review casing pressure test and logs.	Every 5 years	4.0	$184	$0	65	261	$11,962
Review pressure fall-off test.	Annual	2.0	$92	$0	326	651	$29,906
Review monitoring data submitted by operators.	Quarterly	2.0	$92	$0	1,303	2,605	$119,624
Other Reporting
Respond to periodic notifications by owners and operators.	Occasional	1.0	$46	$0	8	8	$380	Assumes 1% of inventory notifies.
Closure
Review plugging and abandonment report.	One-time	1.0	$46	$0	1	1	$46
TOTAL					2,092	#VALUE!	#VALUE!

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.

Sheet 19: Class 2


Table A-2
Annual Paperwork Burden and Costs Associated with Class II Wells: Operators

						A	B	C	D	E	F
		Hours and Costs per Response							Total Hours and Costs
Description of Requirement	Frequency	Legal	Managerial	Technical	Clerical	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost	No. of Responses	Total Hours/Year	Total Cost/Year	Uninflated unit nonlabor cost	No. of Respondents	Total Labor Cost	Total Other Cost		7520 form used
Initial/Start-up Requirements
*Requirements associated with permit applications (Per Permit Application)*
Read permit application directions.	One-time	0.0	0.0	0.5	0.5	1.0	$44	$0	5,956	5,832	$260,892	$0	5,956	$260,892	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Gather and submit: description of activities 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.	One-time	0.1	0.0	1.0	0.4	1.5	$78	$0	5,956	8,835	$466,298	$0	5,956	$466,298	$0	Clerical burden changed in 2018 per form redesign.	7520-6
For DI programs, gather and submit a list of all land owners within one quarter mile of the facility boundary.	One-time	0.2	0.0	0.0	1.0	1.2	$51	$214	130	151	$34,429	$126	130	$6,599	$27,830	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit plugging and abandonment plan.	One-time	0.0	0.6	4.8	0.6	6.0	$346	$0	5,956	35,574	$2,062,464	$0	5,956	$2,062,464	$0	Clerical burden changed in 2018 per form redesign.	7520-19
Show evidence of financial responsibility for closure.	One-time	0.0	5.0	5.0	9.6	19.6	$1,081	$0	5,956	116,646	$6,440,656	$0	5,956	$6,440,656	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit proposed Corrective Action Plan.	One-time	0.0	0.3	2.9	0.2	3.4	$198	$0	596	2,020	$117,966	$0	596	$117,966	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit revised Corrective Action Plan.	One-time	0.0	1.0	9.6	0.7	11.3	$658	$0	119	1,343	$78,324	$0	119	$78,324	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit Area of Review map. (State/DI Program performs study)	One-time	0.0	0.0	1.0	0.0	1.0	$56	$42	1,324	1,324	$130,462	$25	1,324	$74,248	$56,214	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit Area of Review map and study.	One-time	0.0	0.1	2.9	1.9	4.9	$235	$232	1,123	5,550	$524,287	$136	1,123	$264,167	$260,120	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit proposed operating data.	One-time	0.0	0.1	1.8	0.1	2.0	$114	$0	5,956	11,887	$677,797	$0	5,956	$677,797	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit geological data on the injection and confining zone.	One-time	0.0	0.5	8.0	1.0	9.5	$529	$0	5,956	56,335	$3,148,909	$0	5,956	$3,148,909	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit name and depth to bottom of USDWs.	One-time	0.0	0.1	2.3	0.1	2.5	$142	$255	5,956	14,865	$2,361,959	$150	5,956	$844,787	$1,517,172	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit schematic of the well.	One-time	0.0	0.0	2.8	0.2	3.0	$163	$0	5,956	17,819	$972,703	$0	5,956	$972,703	$0	Clerical burden changed in 2018 per form redesign.	7520-6
Prepare and submit information to support an aquifer exemption request.	One-time	0.0	2.5	17.0	0.5	20.0	$1,213	$0	179	3,574	$216,659	$0	179	$216,659	$0
*Requirements associated with completion reports (Per Well)*														$0	$0
Prepare and submit completion report.	One-time	0.0	0.0	1.5	1.8	3.3	$142	$0	5,658	18,439	$803,319	$0	5,956	$803,319	$0	includes DFHF o/o; Clerical burden changed in 2018 per form redesign.	7520-18
Perform and report on appropriate logs and other tests during construction.	One-time	0.0	0.2	1.9	0.2	2.4	$139	$5,095	849	2,037	$4,441,804	$3,000	849	$117,864	$4,323,940	includes DFHF o/o
Demonstrate mechanical integrity.	One-time	0.0	0.0	7.0	0.0	7.0	$393	$229	5,658	39,607	$3,518,143	$135	5,956	$2,220,961	$1,297,182	includes DFHF o/o
*Requirements associated with permit reviews/modifications (Per Permit/Per Operator)*					0.0									$0	$0
Respond to issues raised during permit review.	Every 5 years	0.0	0.5	2.0	0.5	3.0	$177	$0	1,593	4,778	$282,171	$0	1,593	$282,171	$0
Prepare and submit request for permit modification.	Occasional	0.0	0.4	2.8	0.8	4.0	$222	$0	773	3,092	$171,746	$0	773	$171,746	$0
Monitoring/Testing Requirements (Per Operator)														$0	$0
Monitor the nature of injected fluids.	As necessary to obtain representative data	0.0	0.0	2.0	0.0	2.0	$112	$51	63,708	127,415	$10,390,378	$30	15,927	$7,144,731	$3,245,647	includes DFHF o/o
Record injection pressure, flow rate, and cumulative volume.	At least every 30 days.	0.0	0.0	0.6	0.3	0.8	$41	$0	191,123	160,543	$7,762,126	$0	15,927	$7,762,126	$0	includes DFHF o/o
Demonstrate mechanical integrity.	Every 5 years	0.0	0.0	3.0	0.0	3.0	$168	$2,293	43,003	129,008	$105,820,579	$1,350	15,927	$7,234,040	$98,586,539	includes DFHF o/o
Reporting Requirements (Per Operator)														$0	$0
Gather and submit groundwater monitoring data, analyses of injected fluids, a description of geologic strata, and other items as requested.	Annual	0.0	3.0	22.0	4.7	29.7	$1,680	$0	4,698	139,621	$7,894,184	$0	4,698	$7,894,184	$0	includes DFHF o/o; frequency is annual (not occasional) per form title (2018 change) respondents = all facilities, not just DI (2018 change); Clerical burden changed in 2018 per form redesign.	7520-11
In DI programs, notify Regional Administrator 30 days prior to MIT.	Every 5 years	0.0	0.0	0.5	0.5	1.0	$44	$0	37	37	$1,640	$0	184	$1,640	$0	includes DFHF o/o
Notify Director of: any planned physical changes to facility, changes that may result in noncompliance, permit transfers, planned workovers, possible endangerment to a USDW.	Occasional	0.0	1.0	1.5	2.2	4.7	$253	$0	956	4,461	$241,360	$0	956	$241,360	$0	Clerical burden changed in 2018 per form redesign.	7520-7
Report monitoring data, including monthly records of injected fluids, any changes in characteristics or sources of injected fluids.	Annual	0.0	0.0	3.3	1.7	5.0	$242	$0	15,927	79,635	$3,849,030	$0	15,927	$3,849,030	$0	includes DFHF o/o
Report MIT results.	Annual	0.0	0.0	1.0	0.0	1.0	$56	$0	15,927	15,927	$893,091	$0	15,927	$893,091	$0	includes DFHF o/o
Recordkeeping Requirements (Per Operator)														$0	$0
Retain records of permitting data, nature and composition of injected fluids, and all monitoring results.	At least 3 years	0.0	0.0	1.0	3.0	4.0	$155	$0	15,927	63,708	$2,465,013	$0	15,927	$2,465,013	$0
Closure Requirements (Per Operator)														$0	$0
In DI programs, notify director of revisions to plugging and abandonment plan.	One-time	0.0	0.5	2.5	1.0	4.0	$222	$0	0	1	$51	$0	0	$51	$0
Notify the Director before conversion or abandonment of the well, or in the case of area permits, before closure of the project.	One-time	0.0	1.0	0.0	2.0	3.0	$163	$0	1,044	3,132	$170,102	$0	1,044	$170,102	$0
In DI programs, submit a plugging and abandonment report within 60 days after plugging a well.	One-time	0.0	0.0	4.5	1.5	6.0	$302	$306	23	137	$13,847	$180	23	$6,878	$6,969
Other Requirements (Per Operator)														$0	$0
In DI programs, submit revised demonstration of financial responsibility.	Occasional	0.0	0.5	0.5	1.0	2.0	$110	$0	35	70	$3,809	$0	35	$3,809	$0
TOTALS									418,056	1,073,400	$166,216,198		15,927	$56,894,584	$109,321,614

Note: Numbers may not add due to rounding.

Sheet 20: C2State


Table A-2 (continued)
Annual Paperwork Burden and Costs Associated with Class II Wells: States

		A	B	C	D	E	F
		Hours and Costs per Response			Total Hours and Cost
Description of Requirement	Frequency	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost	Number of Responses	Total Hours/Year	Total Cost/Year
Initial/Start-up
*Permit applications (Per Permit Application)*
Review permit application and supporting documentation and prepare draft permit.	One-time	6.0	$276	$0	5,826	34,956	$1,605,162
Consider public comments.	One-time	2.0	$92	$0	5,826	11,652	$535,054
Issue final permit decision.	One-time	2.0	$92	$0	5,826	11,652	$535,054
Respond to comments.	One-time	4.0	$184	$0	5,826	23,304	$1,070,108
Review operator's AoR map and study.	One-time	5.0	$230	$0	1,099	5,493	$252,251	101,436
Review operator's AoR map and perform AoR study.	One-time	2.5	$115	$0	1,324	3,310	$152,006
Review completion report.	One-time	2.0	$92	$0	5,535	11,069	$508,301
Review information related to aquifer exemption requests and forward to EPA region.	One-time	1.0	$46	$0	166	166	$7,625
*Permit reviews/modifications (Per Operator)*
Review each permit to determine whether it should be modified, revoked and reissued, or terminated.	Every 5 years	1.0	$46	$0	1,558	1,558	$71,539
Review request for permit modification or re-issuance.	Occasional	4.0	$184	$0	756	3,024	$138,884
Monitoring/Testing (Per Operator)
Review mechanical integrity test data submitted by operators.	Every 5 years	0.5	$23	$0	42,064	21,032	$965,780
Review monitoring data submitted by operators.	Annual	0.3	$11	$0	15,579	3,895	$178,848
Recordkeeping
Maintain administrative record in DI programs.	One-time	1.0	$46	$0	0	0	$0
Other Reporting (Per Operator)
Respond to periodic notifications by owners and operators.	Occasional	2.0	$92	$0	935	1,869	$85,847
Closure (Per Operator)
For DI programs, review plugging and abandonment report.	One-time	1.0	$46	$0	0	0	$0
TOTAL					92,358	132,980	$6,106,460

Note: Numbers may not add due to rounding




				Impact of permit app change	resp	hours	cost
				at 5743 (this ICR)	31,261	101,436	$4,657,937
				at 1411 (2007 ICR)	7,667	24,291	$924,233
				change	23,594	77,145	$3,733,704
				Env	13,213	43,201	2,090,874
				Energy	10,381	33,944	$1,642,830

Sheet 21: Class 3


	Table A-3
	Annual Paperwork Burden and Costs Associated with Class III Wells: Operators

							A	B	C	D	E	F				D	E
			Hours and Costs per Response							Total Hours and Costs
CFR Citation	Description of Requirement	Frequency	Legal	Managerial	Technical	Clerical	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost	No of Responses	Total Hours/Year	Total Cost/Year	No Respondents	uninflated unit nonlabor	total labor cost	total non labor cost		7520 form used
	Initial/Start-up Requirements
	*Requirements associated with permit applications (Per Permit Application)*
	Read permit application directions.	One-time	0.0	0.0	0.5	0.5	1.0	$44	$0	44	43	$1,937	44	$0	$1,937	$0	No. of respondents changed in 2018 -- formerly hard coded at 24; changed to reflect changes in site inventory. Clerical burden changed in 2018 per form redesign.	7520-6
144.31(e)(1-8)	Gather and submit: a description of activities requiring a permit; facility name and address; SIC codes; ownership and facility status; facility location; and listing of relevant permits or construction approvals.	One-time	0.5	2.0	4.7	2.7	9.9	$595	$0	44	436	$26,194	44	$0	$26,194	$0	Clerical burden changed in 2018 per form redesign.	7520-6
144.31(e)(9)	For DI programs, gather and submit a list of all land owners within one quarter mile of the facility boundary.	One-time	0.2	0.0	0.0	1.0	1.2	$51	$214	4.5	5	$1,193	5	$126	$230	$963	Clerical burden changed in 2018 per form redesign.	7520-6
144.31(e)(10)	Prepare and submit plugging and abandonment plan.	One-time	0.0	0.0	6.4	1.5	7.9	$407	$0	44	346	$17,897	44	$0	$17,897	$0	Clerical burden changed in 2018 per form redesign.	7520-19
144.52(a)(7)	Show evidence of financial responsibility for closure.	One-time	0.0	0.5	1.0	1.9	3.4	$169	$0	44	151	$7,417	44	$0	$7,417	$0	Clerical burden changed in 2018 per form redesign.	7520-6
144.55(a)	Prepare and submit proposed Corrective Action Plan.	One-time	0.0	2.0	10.0	1.9	13.9	$819	$0	44	613	$36,033	44	$0	$36,033	$0	Clerical burden changed in 2018 per form redesign.	7520-6
144.55(a)	Prepare and submit revised Corrective Action Plan.	One-time	0.0	1.0	8.0	1.0	10.0	$578	$0	0.9	9	$508	0.9	$0	$508	$0	Clerical burden changed in 2018 per form redesign.	7520-6
146.34(a)(2,3)	Prepare and submit AoR map and study.	One-time	0.0	3.2	25.5	3.3	31.9	$1,846	$1,265	44	1,404	$136,871	44	$745	$81,204	$55,667	Clerical burden changed in 2018 per form redesign.	7520-6
146.34(a)(4-6)	Prepare and submit maps and cross-sections of USDWs within AoR, local geology, and regional geology.	One-time	0.0	0.0	18.0	3.9	21.9	$1,137	$255	44	963	$61,244	44	$150	$50,036	$11,208	Clerical burden changed in 2018 per form redesign.	7520-6
146.34(a)(7-10)	Prepare and submit proposed operating data, formation testing program, stimulation program, and injection procedure.	One-time	0.0	2.0	6.0	1.0	9.0	$563	$0	44	395	$24,758	44	$0	$24,758	$0	Clerical burden changed in 2018 per form redesign.	7520-6
146.34(a)(11)	Prepare and submit schematic of the well.	One-time	0.0	0.0	4.2	0.8	5.0	$261	$0	44	219	$11,488	44	$0	$11,488	$0	Clerical burden changed in 2018 per form redesign.	7520-6
146.34(a)(12)	Prepare and submit monitoring plan.	One-time	0.0	0.0	12.0	3.9	15.9	$801	$0	44	699	$35,232	44	$0	$35,232	$0	Clerical burden changed in 2018 per form redesign.	7520-6
	Prepare and submit information to support an aquifer exemption request.	One-time	0.0	2.5	17.0	0.5	20.0	$1,213	$0	0.4	9	$534	0	$0	$534	$0
	*Requirements associated with completion reports (Per Facility)*					0.0									$0	$0
144.51(m)(1)	Prepare and submit completion form and supporting documentation.	One-time	0.0	0.0	1.5	2.4	3.9	$163	$0	44	172	$7,180	44	$0	$7,180	$0	2018 change in respondents: assume that these are bundled based on initial consultations (which assumed only a couple dozen new forms); number now tied in increase in well -- not site -- inventory. Clerical burden changed in 2018 per form redesign.	7520-18
146.32(b)	Prepare and submit reports of appropriate logs and tests during construction.	One-time	0.0	0.2	1.9	0.2	2.4	$139	$5,828	44	105	$262,539	44	$3,432	$6,097	$256,442	Clerical burden changed in 2018 per form redesign.	7520-18
146.33(b)(3)	Demonstrate mechanical integrity.	One-time	0.0	16.1	128.7	15.5	160.2	$9,288	$81,956	44	7,051	$4,014,719	44	$48,260	$408,664	$3,606,055	Assume 50% rely on cementing records. 2018 change - this is the ony startup activity tied to number of wells, not sites. Clerical burden changed in 2018 per form redesign.	7520-18
	*Requirements associated with permit reviews/renewals/modifications (Per Permit/Per Facility)*														$0	$0
144.36(a)	Respond to issues raised during permit review.	Every 5 years	0.0	3.0	1.0	0.0	4.0	$347	$0	60	240	$20,849	60	$0	$20,849	$0
144.51(f)	Prepare and submit request for permit modification.	Occasional	0.0	2.0	22.0	4.0	28.0	$1,560	$0	1	28	$1,560	1	$0	$1,560	$0
	Monitoring/Testing Requirements (Per Facility)
146.33(b)(1)	Monitor the nature of injected fluids.	As necessary to obtain representative data	0.0	0.0	6.0	2.0	8.0	$402	$0	82	659	$33,113	82	$0	$33,113	$0
146.33(b)(2)	Monitor injection pressure and flow rate or volume of injected fluids, or meter and record injected and produced fluid volumes.	Semi-monthly/ Continuous	0.0	0.0	3.3	1.3	4.6	$229	$0	7,800	36,152	$1,787,838	300	$0	$1,787,838	$0
146.33(b)(3)	Demonstrate mechanical integrity.	Every 5 years	0.0	16.1	128.7	16.1	160.9	$9,308	$81,956	16	2,649	$1,502,572	16	$48,260	$153,252	$1,349,320	Assume 50% rely on cementing records
146.33(b)(4,5)	Monitor the fluid level in the injection zone where appropriate and monitor parameters chosen to measure water quality in the monitoring wells.	Semi-monthly/ monthly	0.0	0.0	27.5	3.0	30.5	$1,641	$0	476	14,512	$780,665	18	$0	$780,665	$0
	Reporting Requirements (Per Facility)
144.51(l)	Notify Director of: any planned physical changes to facility, changes that may result in noncompliance, permit transfers, planned workovers, possible endangerment to a USDW.	Occasional	0.0	1.0	3.0	1.8	5.8	$325	$0	30	175	$9,760	30	$0	$9,760	$0	Clerical burden changed in 2018 per form redesign.	7520-7
146.33(c)	Report to the Director on required monitoring, mechanical integrity tests, and other required tests.	Quarterly	0.0	1.0	10.0	16.9	27.9	$1,212	$0	1,200	33,421	$1,454,714	300	$0	$1,454,714	$0	Clerical burden changed in 2018 per form redesign.	7520-8
	Recordkeeping Requirements (Per Facility)
144.31(f,j)	Retain records of permitting data, calibration and maintenance data, and monitoring results.	At least 3 years	0.0	0.0	0.4	3.0	3.4	$121	$0	300	1,020	$36,338	300	$0	$36,338	$0
	Closure Requirements (Per Facility)
144.51(n)	Notify the Director before conversion or abandonment of the well or in the case of area permits before closure of the project.	One-time	0.0	1.0	0.5	0.5	2.0	$142	$0	2	4	$283	2	$0	$283	$0
144.51(p)	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.	One-time	0.0	0.0	0.8	0.3	1.0	$50	$0	0	0	$10	0	$0	$10	$0
	Other Requirements (Per Facility)
144.52(a)(7) (Lifetime permit holders)	In DI programs, submit revised demonstration of financial responsibility.	Occasional	0.0	0.5	0.5	1.0	2.0	$110	$0	16	33	$1,792	31	$0	$1,792	$0
	TOTALS									10,562	101,513	$10,275,236			4,995,581	5,279,655

	Note: Numbers may not add due to rounding.



									Impact of facility changes
										Responses	hours	cost
									2007	5,543	50,333	$2,276,663
									2011	9,923	88,624	$5,607,085
									change	4,381	38,291	$3,330,422

Sheet 22: C3State


Table A-3 (continued)
Annual Paperwork Burden and Costs Associated with Class III Wells: States

		A	B	C	D	E	F
		Hours and Costs per Response			Total Hours and Cost
Program Oversight Activities	Frequency	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost	Number of Responses	Total Hours/Year	Total Cost/Year
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.	One-time	20.0	$918	$0	39	790	$36,276
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.	One-time	40.0	$1,837	$0	39	1,580	$72,552
Provide public notice of issuance of a draft permit or intent to deny.	One-time	2.0	$92	$0	39	79	$3,628
Consider public comments.	One-time	8.0	$367	$0	39	316	$14,510
Issue final permit decision.	One-time	10.0	$459	$0	39	395	$18,138
Respond to comments.	One-time	15.0	$689	$0	39	592	$27,207
Review completion report.	One-time	2.0	$92	$0	39	79	$3,628
Review information related to aquifer exemption requests and forward to EPA region.	One-time	1.0	$46	$0	0.0	0.0	$0
*Permit reviews/modifications (Per Facility)*
Review each permit to determine whether it should be modified, revoked and reissued, or terminated.	Every 5 years	4.0	$184	$0	54	215	$9,893
Review request for permit modification or re-issuance.	Occasional	20.0	$918	$0	1	20	$918
Monitoring/Testing (Per Facility)
Review mechanical integrity test data submitted by operators.	Every 5 years	0.5	$23	$0	54	27	$1,237
Review monitoring data submitted by operators.	Quarterly	0.25	$11	$0	1,077	269	$12,367
Other Reporting (Per Facility)
Respond to periodic notifications by owners and operators.	Occasional	4.0	$184	$0	30	120	$5,510
Recordkeeping (Per Facility)
Maintain administrative record (DI).	One-time	4.0	$184	$0	0	0	$0
Closure (Per Facility)
Review plugging and abandonment report (DI only).	One-time	4.0	$184	$0	0	0	$0
TOTAL					1,571	4,483	$205,865

Note: Numbers may not add due to rounding.

Sheet 23: Class 4

																Class IV Inputs								PAMS data were formerly used to estimate the number of closures. New approach based on SDW-08 in 2018 ICR
Table A-4																																From UIC database		From 2003 UIC Measures	From 2003 UIC Measures	From 2003 UIC Measures
Annual Paperwork Burden and Costs Associated with Class IV/Endangering Class V Wells: Operators																					Input	Number	Var.	Notes						State	Cl 4/5	CLASS 4 SITES	C4 wells in prim	C4P closed	C5 ACP closed	C5 AB closed year	Total closed	Closed in Prim
																Percent in Primacy states	78%	PRIM	Primacy/DI split of closures reported on form 7520-B					Connecticut	Prim	0	0	0	0	0	0	0
						A	B	C	D	E	F					Percent in DI states	22%	DI	Primacy/DI split of closures reported on form 7520-B					Maine	Prim		0	0	0	0	0	0
		Hours and Costs per Response											Total Hours and Costs							Plugging/abandonments	71	PA	Reported on form 7520-2B						Massachusetts	Prim		0	0	0	0	0	0
Description of Requirement	Frequency	Legal	Managerial	Technical	Clerical	Unit Burden	Unit Labor Cost	Unit Non-labor Cost	No. of Responses	Total Hours/Year	Total Cost/Year					Legal labor rate								New Hampshire	Prim		0	0	0	313	313	313
Closure Requirements (Per Well)																Management labor rate	$60.98	MAN	From labor rates sheet					Rhode Island	Prim		0	0	0	0	0	0
Plug injection well.	One-time	0	0	7	1.5	8.5	$247	$0	71	601	$17,463
Prepare and submit pre-closure notification (Form 7520-17)	One-time	0	0	0.5	0.86	1.4	$36	$0	71	96	$2,579	Burden changed per 7520 edits in 2018 (was 1.5 hrs)				Technical labor rate	$29.93	TECH	From labor rates sheet					Vermont	Prim	0	0	0	0	0	0	0
TOTAL									142	698	$20,042					Clerical labor rate	$24.89	CLER	From labor rates sheet					New Jersey	Prim		0	0	0	0	0	0
																								New York	DI		0	0	77	0	77	0
Note:																								Puerto Rico	DI	0	0	0	0	0	0	0
Numbers may not add due to rounding.																								DC	DI	0	0	0	0	0	0	0
																								Delaware	Prim	0	0	0	0	0	0	0
																								Maryland	Prim	0	0	0	0	34	34	34
																								Pennsylvania	DI	11	0	0	0	59	59	0
														Approach in 2021 -- Data from Form 7520-2B: voluntary and non-voluntary Class V closures (no more measures reporting)										Virginia	DI	2	0	0	0	4	4	0
														Year	Prim	DI	Total							West Virginia	Prim	0	0	0	62	61	123	123
														2017	41	43	84							Alabama	Prim	0	0	0	0	0	0	0
Inputs to the right (column Z)														2018	61	15	76							Florida	Prim	0	0	0	0	0	0	0
														2019	44	3	47							Georgia	Prim	0	0	0	0	0	0	0
														2020	76	0	76							Kentucky	DI	0	0	0	0	0	0	0
															222	61	283							Mississippi	Prim	0	0	0	0	0	0	0
														Pct	78%	22%								North Carolina	Prim	0	0	0	0	1	1	1
														Annual average	70.75									South Carolina	Prim	0	0	0	0	0	0	0
																								Tennessee	DI	0	0	0	0	0	0	0
																								Illinois	Prim	0	0	0	0	0	0	0
																								Indiana	DI	0	0	0	0	0	0	0
																								Michigan	DI	1	0	0	0	0	0	0
														Changed approach in 2018:										Minnesota	DI	0	0	0	0	0	0	0
														SDW-08: Number of Class V MVWDWs and large capacity cesspools that are closed or permitted (cumulative).										Ohio	Prim	0	0	0	110	0	110	110
														We can add inventory totals each ICR and use a running average or last 3-years' average, depending on what seems correct.										Wisconsin	Prim	0	0	0	0	0	0	0
																								Arkansas	Prim	0	0	0	0	0	0	0
														Year	Cumulative	Change								Louisiana	Prim		0	0	0	0	0	0
														2013	26,031									New Mexico	Prim		0	0	0	0	0	0
														2014	26,560	529								Oklahoma	Prim	1	1	0	0	0	0	0
														2015	27,683	1,123		659	3 year average					Texas	Prim	0	0	0	147	0	147	147
														2016	28,009	326								Iowa	DI		0	0	0	0	0	0
														2017	25,736	(2,273)								Kansas	Prim		0	0	0	3	3	3
																								Missouri	Prim	0	0	0	0	0	0	0
																								Nebraska	Prim		0	0	0	5	5	5
																								Colorado	DI	0	0	0	49	0	49	0
																								Montana	DI	0	0	0	6	0	6	0
																								North Dakota	Prim	0	0	0	0	0	0	0
																								South Dakota	DI	0	0	0	9	0	9	0
																								Utah	Prim	2	2	0	0	8	8	8
																								Wyoming	DI	0	0	0	0	5	5	0
																								Arizona	DI	0	0	0	0	0	0	0
																								California	DI	0	0	0	0	0	0	0
																								Hawaii	DI	0	0	0	0	0	0	0
																								Nevada	Prim		0	0	0	0	0	0
																								Alaska	DI	0	0	0	23	0	23	0
																								Idaho	Prim	0	0	0	0	0	0	0
																								Oregon	Prim	56	56	3	0	11	14	14
																								Washington	Prim	0	0	0	0	0	0	0
																								Total		73	59	3	483	504	990	758
																											81%					77%






		Sums 7520+inventory/measures
		Sums ongoing data flow

Sheet 24: C4state


Table A-4 (continued)	Table A-4 (continued)
	Annual Burden and Costs Associated with Class IV/Endangering Class V Wells: States

			A	B	C	D	E	F
			Hours and Costs per Response			Total Hours and Cost
CFR Citation	Description of Requirement	Frequency	Unit Burden (A)	Unit Labor Cost	Unit Nonlabor Cost	Number of Responses	Total Hours/Year	Total Cost/Year
	Closure
144.23(b)(3)	Review closure plan.	One-time	1.0	$46	$0	56	56	$2,549
	TOTAL					56	56	$2,549

	Note:
	Numbers may not add due to rounding.



		Class IV/V state inputs (all link to Operator inputs)
			Input	Number	Var.	Notes
			Percent in Primacy	78%	PRIM
			Percent in DI	22%	DI
			Plug/abandon	71	PA	SDW-08 data (links to C4 oper sheet)
			Labor rate	$45.92	LRATE	GS-9 step 10
			States with Class IV primacy	38		EPA's web site (links to inventory page)

Sheet 25: Class 5


	Table A-5
	Annual Paperwork Burden and Costs Associated with Class V Wells: Operators

							A	B	C	D	E	F
			Hours and Costs per Response											Total Hours and Costs
CFR Citation	Description of Requirement	Frequency	Legal	Managerial	Technical	Clerical	Unit Burden	Unit Labor Cost	Unit Non-labor Cost (A)	No. of Responses	Total Hours/Year	Total Cost/Year		No. of Respondents	Total labor cost	Total non-labor cost	Uninflated unit nonlabor
	Inventory Requirements
144.83(a)	Submit inventory information prior to commencing injection.	One-time	0.0	0.0	0.0	0.4	0.4	$9	$0	19,348	6,613	$164,578	Total burden in 2021 reflects some savings by ppl who e-file 7520-16 (see below). Burden changed per 7520 edits in 2018 (was 0.5 hrs)	19,348	$164,578	$0
	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.	One-time	7.0	17.3	61.8	17.5	103.6	$3,541	$104,711	10	1,036	$1,082,518	added in 2018 ICR to address new Class V specific 7520-6. Assume burden/cost similar to Class I NH	10	$35,408	$1,047,110	$61,660
	Class V Rule - Ongoing Activities for Owners / Operators of Motor Vehicle Waste Disposal Wells
144.88 (b)	Conduct quarterly injectate sampling.	Quarterly	0.0	0.0	1.0	0.5	1.5	$42	$785	5,916	8,874	$4,892,179		1,479	$250,673	$4,641,507	$462
144.88 (b)	Conduct annual sludge sampling (concurrent with injectate sampling).	Annual	0.0	0.0	1.0	0.5	1.5	$42	$2,051	1,479	2,219	$3,096,727		1,479	$62,668	$3,034,058	$1,208
144.88 (b)	Annual reporting and recordkeeping of all monitoring results.	Annual	0.0	0.0	3.0	1.0	4.0	$115	$0	1,479	5,916	$169,600		1,479	$169,600	$0	$0
	TOTAL									28,232	24,657	$9,405,602		20,837	682926.725121265	$8,722,675	$64,254

	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.


										Number of respondents:	20,837
	Savings associated with not printing/mailing paper 7520-16:
		Unit	Number	Total
	Paper reporting	0.35	5,805	2,056
	E-reporting (95% of above burden)	0.34	13,544	4,557
				6,613
	Unit burden is the same; but e-reporters save 5% by not having to print, stamp, mail. Number is per Colin estimate of % reporting this way.

	E-filers	70%
	Clerical labor rate	$24.89


	Total before adjustment	6,853	hours
	Change	-240







									Class V Rule change	responses	hours	cost	O&M cost
									2007 ICR	35,273	86,433	$24,418,335	$22,489,574
									This ICR	8,884	18,044	$9,241,024	$8,722,675
									Change	(26,389)	(68,389)	($15,177,311)	($13,766,899)	shift away from labor-intensive permitting activities to more expensive sampling activities

									Inv changes
									2007 ICR	15,000	7,500	$128,700
									This ICR	19,348	6,613	$164,578
									Change	4,348	(887)	$35,878



									2018 ICR assumes for the first time that start-up activities associated with the Class V rule are complete.
									Rows are zeroed out and hidden
									If we need to undo, update assumptions page and unhide rows.

Sheet 26: C5state


Table A-5 (continued)
Annual Paperwork Burden and Costs Associated with Class V Wells: States

		A	B	C	D	E	F
		Hours and Costs per Response			Total Hours and Cost
Description of Requirement	Frequency	Unit Burden (A)	Unit Labor Cost	Unit Nonlabor Cost	Number of Responses	Total Hours/Year	Total Cost/Year		Total Labor	Total nonlabor
Initial/Startup
Review inventory information.	One-time	0.5	$23	$0	13,570	6,548	$300,672	In 2021, cost savings due to e-reporting. See below	$300,672	$0
Review permit applications. Consider the permit application and attachments, prepare draft permit, solicit and respond to public comments.	One-time	56.0	$2,572	$0	10	560	$25,715	Added in 2018; assume similar activities to Class I NH	$25,715	$0
Primacy State Activities Associated With the Class V Rule
Review and file annual monitoring reports.	Annual	0.8	$37	$0	1,037	830	$38,107		$38,107	$0	38,107	39,529,503	-	39,529,503
TOTAL					14,618	7,938	$364,494		$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.



Cost savings due to e-reporting of inventory information
		Unit	Number	Total
Paper reporting		0.50	4,071	2,036
E-reporting (95% of above)		0.48	9,499	4,512
				6,548
Unit burden is the same; but e-reporters save 5% by not having to print, stamp, mail.

E-filers		70%
Clerical labor rate


Total before adjustment		6,785	hours
Change		-237

Sheet 27: Class 6


Table A-6
Annual Paperwork Burden and Costs Associated with Class VI Wells: Operators
				A	B	C	D	E	F							Inflated unit non-labor costs		Uninflated unit non-labor costs (from Rule ICR; inflate these relative to 2011)
		Hours and Costs Per Response					Total Hours andCosts				Total Hours and Costs
Description Of Requirement	Frequency	Technical 1 (Engineer)	Technical 2 (Geologist)	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost (A)	Number of Responses	Total Hours/ Year	Total Cost/Year		No. of Respondents	Total labor cost	Total capital cost	Total O&M cost	Total non-labor cost	Capital Costs ($/response)	O&M Costs ($/response)	Capital Costs ($/response)	O&M Costs ($/response)
Initial/Startup Requirements (Per Permit Application)
*Requirements Associated with Permit Applications*																				Except where noted, these costs are the ER unit costs from the Class VI ICR/cost analysis; the "applicability of ER" (relative to saline) factors in the cost analysis are analogous to CBP adjustments for an ICR.
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		13.33	$811,507	$-	$8,090,787	$8,090,787	$-	$505,674	$-	$420,659	adjusted upward based on early permit reviews
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		13.33	$283,814	$-	$8,967,454	$8,967,454	$-	$560,466	$-	$466,239
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		13.33	$245,711	$-	$2,078,190	$2,078,190	$-	$129,887	$-	$108,050
Develop maps and cross sections of the injection zone, subsurface aquifers including all USDWs, and the confining zone in the area of review.	One-Time	0	44	44	$5,251	$0	13.3	592	$70,008		13.33	$70,008	$-	$-	$-	$-	$-	$-	$-
Take initial samples to develop a geochemical baseline for injection zones and confining zones.	One-Time	0	10	10	$1,183	$20,305	13.3	133	$286,500		13.33	$15,767	$-	$270,732	$270,732	$-	$16,921	$-	$14,076	adjusted upward based on early permit reviews
Prepare geologic characterization report demonstrating: suitability of receiving zone, storage capacity and injectivity, trapping mechanism free of nonsealing faults, competent confining system, etc.	One-Time	0	240	240	$28,381	$0	13.3	3,200	$378,419		13.33	$378,419	$-	$-	$-	$-	$-	$-	$-
Demonstrate financial responsibility to ensure funds will be available for required future actions.	One-Time	40	0	40	$4,231	$0	13.3	533	$56,414		13.33	$56,414	$-	$-	$-	$-	$-	$-	$-	adjusted upward based on early permit reviews
Conduct aerial and database search for artificial penetrations (wells) within the area of review; determine integrity/plugging status of each.	One-Time	140	300	440	$50,285	$112,928	13.3	5,867	$2,176,180		13.33	$670,473	$-	$1,505,707	$1,505,707	$-	$94,107	$-	$78,285	used saline cost model input; not CBP. Adjusted labor est based on early permit applications
Perform complex modeling of CO2 fluid flow and migration (reservoir simulations) and prepare AoR and corrective action plan.	One-Time	724	1,200	1,924	$218,489	$0	13.3	25,653	$2,913,187		13.33	$2,913,187	$-	$-	$-	$-	$-	$-	$-	adjusted upward based on early permit reviews
Compile and submit information to support an injection depth waiver application.	One-Time	100	200	300	$34,229	$0	-	-	$0		-	$-	$-	$-	$-	$-	$-
*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		13.33	$-	$5,918,179	$-	$5,918,179	$369,886	$-	$307,700	$-
Install check/shut-off valve on injection well.	One-Time	0	0	0	$0	$3,065	13.3	0	$40,871		13.33	$-	$40,871	$-	$40,871	$2,554	$-	$2,125	$-
Construct monitoring wells.	One-Time	0	0	0	$0	$2,633,419	13.3	0	$35,112,257		13.33	$-	$33,461,336	$1,650,921	$35,112,257	$2,091,333	$103,183	$1,739,733	$85,835
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		13.33	$-	$2,517,618	$-	$2,517,618	$157,351	$-	$130,897	$-
Monitoring/Testing Requirements (Per Operator)											0	0	$-	$-	0
Analyze injectate stream and perform corrosion monitoring.	Quarterly	62	0	62	$6,505	$18,113	10.7	656	$262,591		2.67	$69,389	$-	$193,202	$193,202	$-	$15,094	$-	$12,556
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		2.67	$3,533	$-	$1,369,328	$1,369,328	$-	$427,915	$-	$355,973
Conduct periodic monitoring of groundwater quality and geochemistry.	Monthly	21	0	21	$2,221	$12,117	32.0	672	$458,818		2.67	$71,079	$-	$387,738	$387,738	$-	$10,097	$-	$8,400
Conduct external mechanical integrity tests.	Annual	0	0	0	$0	$201,984	2.7	0	$538,623		2.67	$-	$-	$538,623	$538,623	$-	$168,320	$-	$140,021
Conduct pressure fall-off testing.	Every Five Years	0	0	0	$0	$38,072	0.5	0	$20,305		0.53	$-	$-	$20,305	$20,305	$-	$31,726	$-	$26,393
Conduct 3D seismic survey to track movement of the CO2 plume and pressure front.	Every Five Years	0	0	0	$0	$1,327,165	0.5	0	$707,821		0.53	$-	$-	$707,821	$707,821	$-	$1,105,971	$-	$920,032
Activities Associated with Area of Review Reevaluations											0	0	$-	$-	0
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	1,118	0	1,118	$118,258	$0	0.3	373	$39,419		-	$39,419	$-	$-	$-	$-	$-	$-	$-
Reporting and Recordkeeping Requirments (Per Operator)											0	0	$-	$-	0
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		2.67	$18,617	$-	$-	$-	$-	$-	$-	$-
Plugging, Post-Injection Site Care, and Site Closure Requirements (Per Operator)											0	0	$-	$-	0
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.	One-Time	0	0	0	$0	$38,636	0	0	$0		-	$-	$-	$-	$-	$-	$32,197	$-	$26,784	this is the cost of a C1H MIT in 2011 ICR so we can inflate all C6 stuff relative to 2008$
Conduct ground water monitoring - operate and maintain monitoring wells and the monitoring equipment within them.	Annual	0	0	0	$0	$591,018	1	0	$591,018		1.00	$-	$-	$591,018	$591,018	$-	$492,515	$-	$409,712
Track the CO2 plume and pressure front.	Every 5 Years	0	0	0	$0	$1,327,165	0	0	$265,433		1.00	$-	$-	$265,433	$265,433	$-	$1,105,971	$-	$920,032
Submit results of post-injection monitoring.	Annual	40	0	40	$4,231	$0	1	40	$4,231		1.00	$4,231	$-	$-	$-	$-	$-	$-	$-
Perform non-endangerment demonstration and submit results.	One-Time	400	0	400	$42,310	$0	0	0	$0		-	$-	$-	$-	$-	$-	$-	$-	$-	Added this in 2018
TOTAL							230.3	49,649	$74,226,832			$5,651,568	$41,938,004	$26,637,261	$68,575,264
Notes:
(A) Unit Non-Labor Cost inflated by 20% to account for G&A
Numbers may not add due to rounding.



Breakout by phase - Class VI	responses	hours	labor	non-labor	total
Permitting/startup	173.3	47,699	$5,445,300	$64,501,796	$69,947,096
testing and monitoring	49.1	1,361	$144,002	$3,217,017	$3,361,019
reporting	5.3	176	$18,617	$0	$18,617
AoR reeval	0	373	$39,419	$0	$39,419
Plug/PISC	2	40	$4,231	$856,451	$860,682
Total	230	49,649	$5,651,568	$68,575,264	$74,226,832		No. of Respondents	Number of Responses	Total Hours/ Year	Total Annual Labor Cost	Total Annual Non-labor Cost
							17.33	230	49648.7	$5,651,568	$68,575,264

Sheet 28: C6state

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
Description Of Requirement	Frequency	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost (A)	Number of Responses	Total Hours/ Year	Total Cost/Year
Initial/Startup Requirements (Per Permit Application)
Review the permit application and other information submitted by the operator, considering: AoR, relevant maps, site geology, formation testing results, well schematics and construction procedures, proposed injection procedure, status of corrective action on wells in the AoR, well logging, testing, and mechanical integrity data, and project plans.	One-time	780	$35,818	$0	5	3,900	$179,088
Review financial responsibility demonstration.	One-time	100	$4,592	$0	5	500	$22,960
Determine and specify tubing, packing, casing, and cementing requirements based on review of information submitted by operator.	One-time	140	$6,429	$0	5	700	$32,144
Witness logging and testing.	One-time	20	$918	$0	5	100	$4,592
Review applications for waviers to inject above the lowermost underground source of drinking water.	One-time	200	$9,184	$0	-	0.0	$0
Monitoring and Recordkeeping
Review reports submitted by operators; recordkeeping of data from all data gathering activities.	Annual	40	$1,837	$0	0.33	13	$612
Review mechanical integrity test data.	Annual	13.5	$620	$0	0.33	5	$207
Area of Review Reevaluation
Review updated AoR modeling and updated plans.	Every 5 years	150	$6,888	$0	0.00	0	$0
Post-Injection Site Care and Site Closure
Review relevant data prior to granting approval for plugging and abandonment of a well.	One-time	20	$918	$0	0.00	0	$0
Review post-injection monitoring data.	Annual	15	$689	$0	0.00	0	$0
Review non-endangerment demonstration and authorize site closure.	One-time	40	$1,837	$0	0.00	0	$0
Project-Independent Activities
Prepare and submit primacy application.	One-time	1,040	$47,757	$0	1.7	1,733	$79,595
TOTAL					22.3	6,951	$319,198
Notes:

Numbers may not add due to rounding.


				Number of Respondents	Number of Responses	Total Hours/ Year	Total Annual Labor Cost	Total Annual Non-labor Cost	Total Annual Respondent Cost
				5.00	22.3	6951.2	$319,198	0	$319,198



























Avg 2012-2014

Sheet 29: Oversight


Table A-7
Annual State Burden and Cost for Program Oversight and Reporting

		A	B	C	D	E	F
		Hours and Costs per Response			Total Hours and Cost				Labor cost	Non-labor cost
Description of Requirement	Frequency	Unit Burden	Unit Labor Cost	Unit Nonlabor Cost	Number of Responses	Total Hours/Year	Total Cost/Year				Number of Respondents	annual paper burden	annual paper cost
Program Oversight
Oversee and implement UIC program in the State, for example, update regulations or guidances as needed.	Ongoing	1,040	$47,757	$0	59	61,360	$2,817,651		$2,817,651	$0	59
7520 Forms Reporting
Report on Permit Review and Issuance (7520-1)	Annual	4.5	$207	$0	59	266	$12,192		$12,192	$0	59	5	$207
Report on Compliance Evaluation (7520-2A)	Semi-annual	6.0	$276	$0	118	708	$32,511		$32,511	$0	59	12	$551
Report on Compliance Evaluation for Significant Non-Compliance (7520-2B)	Semi-annual	5.5	$253	$0	118	649	$29,802		$29,802	$0	59	11	$505
Report on Mechanical Integrity Tests/Remedial Action (7520-3)	Annual	5.0	$230	$0	59	295	$13,546		$13,546	$0	59	5	$230
Report on Quarterly Exceptions (7520-4)	Quarterly	2.0	$92	$0	236	472	$21,674		$21,674	$0	59	8	$367
Inventory Reporting
Conduct inventory-related activities, e.g., review operator data and report to EPA's online inventory data system.	Annual	54	$2,480	$0	59	3,186	$146,301	Reduced annual burden by 10% in 2021 to account for savings due to e-reporting of inventory data on 7520-16	$146,301	$0	0	54	$2,480
Total					767	66,936	$3,073,678	Recordkeeping zeroed out/hiden in 2021	$3,073,678	$0	59

Notes:
There may be more than one agency per state with Primacy authority.
Numbers may not add due to rounding.




7520 Summary	tot state hrs	tot state cost

reporting	2,390	$109,726
rkeeping	0	$-
total	2,390	$109,726

Oversight Inputs
Input	Number	Var.
Labor rate	$45.92	LRATE	From labor rates page
State agencies	59	PRIM	Based on tally of UICDB reporters (KY added in Jan 2018)

Respondents that report electronically (need for the ICR)	59




Calculating impact of changes (2021):
	Responses (2018)	Hours (2018)	Non-lab Cost (2018)	Responses (2021)	Hours (2021)	Non-lab Cost (2021)	Change - resp	Change - hrs	Change - $
Program Oversight	59	61,360	$-	59	61,360	$-	-	-	$-
7520 Forms Reporting	590	2,390	$-	590	2,390	-	-	-	-
Inventory Reporting	59	3,540	$-	59	3,186	-	-	(354)	-
Recordkeeping	59	472	$-	59	-	-	-	(472)	-
Total	767	67,762	$-	767	66,936	$-	-	(826)	$-

Change due to web-based data system/e-7520-16:							-	(826)	$-






For 2018 ICR:
States will no longer report via the UIC database. It is shut down.
Implemented this change by zeroing out column G in the "Activities related to populating the National UIC Database." These rows are hidden.
Also, for other activities, responses = number of primacy agencies (times 2 or 4 for semi-annual or quarterly responses)
No measures reporting as of 2018 -- zeroed out # of responses and hid row.

Sheet 30: ICRAS forms

In 2014, ICRAS was replaced with an ICR submission spreadsheet. Enter the numbers highlighted in yellow into the OEI spreadsheet; that spreadsheet calculates the green numbers.														Notes
This page is linked to the ICRAS calcs page. The only thing to do is update the prior numbers in aqua on that page based on exh 6-7 of approved ICR; everything else should be automatic.														Agency discretion = program change (new forms, primacy states, UIC database)
Environmental Management - private										Environmental Management - private				Agency estimate =adjustment (inventory, misc.)
Small entities	28,801		Pct electronic:	38.8%	All Class VI; some % of Class V inventory.				10. Respondents	37,618	28,801	Blue numbers are entered into ICRAS; others are calculated.
Responses/ respondent	12.38556								11. frequency - responses per respondent	12.3855609876437	(small)
Annual frequency	1								Annual Freq:
									Annual responses/yr:
	Respondents	Responses	Burden	Cost (O&M)	Time/ response	Annual hour burden	Cost/ response	Annual cost burden	14 - hour and cost burden	Time	Cost
Reporting	37,618	449,230	1,334,110	$276,069,465	2.97	1,334,110	$614.54		Reporting	2.86336992534238	592.52154061342
Recordkeeping	37,618	16,693	66,839	$0	4.00	66,839	$0.00		Rkeeping	0.14345584380416	0
Third-party disclosure	0	0	0	$0	0.00	0	$0.00		Third party	0	0
Total	37,618	465,923	1,400,950	$276,069,465	3.01	1,400,950	$592.52	#VALUE!

Allocate Change in Burden
	This ICR	Previously approved	Change	Due to new statute	Due to agency action	Due to Agency estimate	Due to Violation		15. Allocate change	Total requested	Due to agency discretion (program change)	Due to Agency estimate	Approved
Annual Responses	465,923	460,604	5,319	0	0	5,319	0		Responses	465,923	0	5,319	460,604
Annual Burden	1,400,950	1,141,294	259,656	0	-240	259,896	0		Hour burden	1,400,950	-240	259,896	1,141,294
Annual Cost	$276,069,465	$168,345,558	$107,723,907	$0	$0	$107,723,907	$0		Cost (O&M) burden	$276,069,465	$0	107,723,907	$168,345,558
The Approved numbers need to match what is on the "bottom line" in ICRAS - it can change between ICRs.

Environmental Management - state govt.										Environmental Management - state govt.
Small entities	0		Pct electronic:	100.0%	Use of web-based data system				10. Respondents	59
Responses/ respondent	1,901.52679								11. frequency - responses per respondent	1901.52678869236
Annual frequency	1								Annual Freq:
Hour and Cost Burden									Annual responses/yr:
	Respondents	Responses	Burden	Cost (O&M)	Time/ response	Annual hour burden	Cost/ response	Annual cost burden	14 - hour and cost burden	Time	Cost
Reporting	59	112,131	#VALUE!	$0	#VALUE!	#VALUE!	$0.00		Reporting	#VALUE!	0.000000000
Recordkeeping	59	59	0	$0	0.00	0	$0.00		Rkeeping	0	#VALUE!
Third-party disclosure	0	0	0	$0	0.00	0	$0.00		Third party	0	#VALUE!
Total	59	112,190	#VALUE!	$0	#VALUE!	#VALUE!	$0.00	#VALUE!	Total

Allocate Change in Burden
	This ICR	Previously approved	Change	Due to new statute	Due to agency action	Due to Agency estimate	Due to Violation		15. Allocate change	Total requested	Due to agency discretion	Due to Agency estimate	Approved
Annual Responses	112,190	96,765	15,425	0	16	15,409	0		Responses	112,190	16.00	15,408.63	96,765
Annual Burden	#VALUE!	150,966	#VALUE!	0	3,334	#VALUE!	0		Hour burden	#VALUE!	3,334.00	#VALUE!	150,966
Annual Cost	$0	$0	$0	$0	$0	$0	$0		Cost (O&M) burden	$0	0.00	0.00	$0


Environmental Management - federal govt.										Environmental Management - federal govt.
Small entities	0		Pct electronic:	100.0%	Use of web-based data system for DI				10. Respondents	11
Responses/ respondent	1,125.27854								11. frequency	1125.2785416218
Annual frequency	1								Annual Freq:
Hour and Cost Burden									Annual responses/yr:
	Respondents	Responses	Burden	Cost (O&M)	Time/ response	Annual hour burden	Cost/ response	Annual cost burden	14 - hour and cost burden	Time	Cost
Reporting	11	12,347	42,455	$0	3.44	42,455	$0.00	$1,952,314	Reporting	3.42983197936078	0.000000000
Recordkeeping	11	31	61	$0	1.97	61	$0.00	$0	Rkeeping	0.004915315442369	0
Third-party disclosure	0	0	0	$0	0.00	0	$0.00	$0	Third party	0	0
Total	11	12,378	42,516	$0	3.43	42,516	$0.00	$1,952,314	Total

Allocate Change in Burden
	This ICR	Previously approved	Change	Due to new statute	Due to agency action	Due to Agency estimate	Due to Violation		15. Allocate change	Total requested	Due to agency discretion	Due to Agency estimate	Approved
Annual Responses	12,378	12,039	339	0	0	339	0		Responses	12,378	0	339	12,039
Annual Burden	42,516	17,835	24,681	0	0	24,681	0		Hour burden	42,516	0	24,681	17,835
Annual Cost	$0	$0	$0	$0	$0	$0	$0		Cost (O&M) burden	$0	$0	$0	$0

For part 1: annual cost to federal government:			$1,952,314							Total - all IC types
										Total requested	Due to agency discretion	Due to Agency estimate	Approved
									Responses	590,491	16	21,066	569,409
Total - all IC types (to compare)									Hour burden	#VALUE!	3,094	#VALUE!	1,310,095
Hour and Cost Burden									Cost (O&M) burden	$276,069,465	$0	$107,723,907	$168,345,558
	Respondents	Responses	Burden	Cost (O&M)	Total cost
Reporting	37,688	573,709	#VALUE!	$276,069,465
Recordkeeping	37,688	16,783	66,900	$0
Total	37,688	590,491	#VALUE!	$276,069,465	#VALUE!
non-Fed total	37,677	578,113	#VALUE!	$276,069,465	#VALUE!

Allocate Change in Burden
	This ICR	Approved	Change
Annual Responses	590,491	569,409	21,082
Annual Burden	#VALUE!	1,310,095	#VALUE!
Annual O&M Cost	$276,069,465	168,345,558	$107,723,907

non-Fed Resp	578,113	557,370	20,744
non-Fed Burden	#VALUE!	1,292,260	#VALUE!
non-Fed Cost	$276,069,465	$168,345,558	$107,723,907

Sheet 31: ICRAS calcs

Information Collections - UIC Program		Update the aqua cells with last ICR's numbers; everything else here is linked.
Business area (Affected public)	Respondents	Small entities	Responses	Total burden	Reporting burden	Rkeeping burden	Labor$	O&M$	Capital$	Non-Labor$	Total$	Respondents Included
Env. Mgmt/Poll prev (Private sector - business)	37,618	28,801	465,923	1,400,950	1,334,110	66,839	#VALUE!	$276,069,465	$0	$276,069,465	#VALUE!	All Class 1- 6 operators; all C5 and 1/2 of c2 are small biz. NOTE: Previous ICRs excluded municipal ww disposal wells, but OMB takes numbers out of the ICR
Env. Mgmt/Poll prev (State and local governments)	59	0	112,190	#VALUE!	#VALUE!	0	#VALUE!	$0	$0	$0	#VALUE!	Primacy agencies
Env. Mgmt/Poll prev (Federal government)	11	0	12,378	42,516	42,455	61	$1,952,314	$0	$0	$0	$1,952,314	10 regions + Headquarters
Total	37,688	28,801	590,491	#VALUE!	#VALUE!	66,900	#VALUE!	$276,069,465	$0	$276,069,465	#VALUE!


By IC Type-2021 ICR	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Respondents
Env Mgmt - private	1,400,950	#VALUE!	$276,069,465	#VALUE!	465,923	37,618	all operators
Env Mgmt - state	#VALUE!	#VALUE!	$0	#VALUE!	112,190	59	all states
Env Mgmt - Federal	42,516	$1,952,314	$0	$1,952,314	12,378	11	fed burden
Total	#VALUE!	#VALUE!	$276,069,465	#VALUE!	590,491	37,688


Small entity count - assumptions
50% of Class II are small businesses (ICR, Section 5c)
All Class V are small businesses (slight overstatement - ICR says "majority" are)

Recordkeeping (from tables)	responses	burden	non labor cost
Class 1	466	1,936	$0	Env mgmt - private
Class 2	15,927	63,708	$0	Env mgmt - private
Class 3	300	1,020	$0	Env mgmt - private
Class 4	0	0	$0	Env mgmt - private
Class 5 (cannot disaggregate from reporting)	0	0	$0	Env mgmt - private
Class 6	5	176	$0	Env mgmt - private
States as respondents	59	0	$0	Env mgmt - state
Federal (Class 1, 2, 3 activities)	31	61	$0	Env mgmt - federal
Rkeeping total	16,788	66,900	$0


2018 ICR Totals by type
	Annual Burden	Labor Cost	O&M Cost	Total Cost	Responses	Respondents
Env Mgmt - private	1,141,294	52,362,663	168,345,558	220,708,221	460,604	40,109
Env Mgmt - state	150,966	6,599,038	0	6,599,038	96,765	59	The sum of these 2 rows shows on the OMB approval form (burden, O&M, responses)
Env Mgmt - Federal	17,835	779,603	0	779,603	12,039	11
Total	1,310,095	$59,741,304	$168,345,558	$228,086,862	569,409	40,179


Change	This ICR Responses	This ICR Burden	This ICR O&M Cost	Approved Responses	Approved Burden	Approved O&M Cost	Change in Responses	Change in Burden	Change in Cost
Env Mgmt - private	465,923	1,400,950	$276,069,465	460,604	1,141,294	$168,345,558	5,319	259,656	$107,723,907
Env Mgmt - state/local	112,190	#VALUE!	$0	96,765	150,966	$0	15,425	#VALUE!	$0
Env Mgmt - Federal	12,378	42,516	$0	12,039	17,835	$0	339	24,681	$0
Total	590,491	#VALUE!	276,069,465	569,409	1,310,095	168,345,558	21,082	#VALUE!	$107,723,907

Sheet 32: all fed tables

Note: These detailed tables aren’t printed in the ICR anymore (they just feed the summary exhibits). If we ever use them again, they need some formatting fixes.
DO NOT EDIT THIS PAGE!!! The inputs link to the class-specific input sheets - all changes to these values should be made there.
The only changes to be made to this page would be to add/change unit burdens. The first few columns are the fed inputs page – none of the values are changed in here.

Inputs -- driven by Class-specific assumptions pages
Class 1		values when we started 2007 ICR
Total Hazardous facilities	73	63
Total Nonhazardous facilities	393	224
New Permit applications - Hazardous	36	8
New Permit applications - Nonhazardous	73	14
Hazardous Renewal Permit applications	12	12
Nonhazardous Renewal Permit applications	20	20
Percent of facilities in Primacy states	83%	76%
Percent of facilities in DI Programs	17%	24%
Petition modifications	6	6
Class IH aquifer exemption requests	6
Class INH aquifer exemption requests	12
Federal labor rate	$45.92	$39.01

Class 2
Total permit applications received	5,956	4,900
Permit modifications	773	4,010
Total wells constructed	5,658	6,537
% of new wells that are in DI states	2%	8%
# of pluggings	1,044	1,044
% of wells for which operator performs AoR	41.1%	18.9%
Wells per operator	$96.03	10
Total operators	97	14,113
Operators in DI	0	13,406
Wells in DI	15,579
HFDF application in DI states	0
Class II aquifer exemption requests	179

Class 3
Pct Class 3 in DI states	10%	59%
Class 3 Facilities	300	166
Class 3 permit applications	44
Class III aquifer exemption requests	0.44

Class 4/5
Pluggings	71	990
Percent in DI states	22%	23%

Class 5
Percent in DI	30%	55%
New wells on inventory	19,348	18,000
Cesspools closing	0	1,000
MV closing	0	411
MV getting a waiver	0	1,082
MV doing monitoring	1,479	5,436

Class 6
Class VI permit applications in DI states	8
Class VI waiver applications in DI states	0
Class VI wells in operation in DI states	2
Class VI doing an AoR reeval in DI states	0
Class VI wells ceasing injection in DI states	0
Class VI wells doing PISC in DI states	1
Class VI wells doing non-end demo in DI states	0
Class VI primacy applications (total over clearance period)	5


				Exhibit 6-7A						#VALUE!
				Federal Burden and Cost for Reviewing Class I Hazardous Well Data

						A	B	C	D
			CFR Citation	Description of Requirement	Frequency (A)	Unit Burden (B)	Number of Responses	Total Hours/Year	Total Cost/Year
				Initial/Start-up
				*Permit Applications*
			124.6(d)	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.	One-time	40	6	247.3	$11,357
			124.7	Prepare and issue statement of basis (DI only).	One-time	1	6	6.2	$284
			124.8	Develop and issue fact sheet.	One-time	4	0	0	$0
			124.10	Provide public notice of issuance of a draft permit or intent to deny.	One-time	1	6	6.2	$284
			124.11	Consider public comments.	One-time	6	6	37.1	$1,704
			124.15	Issue final permit decision.	One-time	2	6	12.4	$568
			124.17	Respond to comments.	One-time	7	6	43.3	$1,987
			146.70(b)	Review notice of completion of construction.	One-time	2	6	12.4	$568
				Review information related to aquifer exemption requests and make a determination.	One-time	8	6.1	49.0	$2,248
				*No-Migration Petitions*
			148.22	Review and respond to petition request.	One-time	320	36	11,520.0	$528,998
			148.22(b)	Public notice/public comment.	One-time	144	36	5,184.0	$238,049
			148.20(f)	Review and respond to petition modification request.	One-time	100	6	600.0	$27,552
				*Permit renewals/modifications*
			144.39	Review and respond to requests for permit modifications or re-issuance.	Occasional	30	2	61.8	$2,839
				Monitoring/Testing
			146.69; 268.1(e)(1)	Review quarterly monitoring and testing results.	Quarterly	2	50	74.8	$3,437
			146.68(d)(1)(2)	Review casing pressure test and radioactive tracer survey of bottom-hole cement.	Annual	4	18	72.6	$3,336
			146.68(d)(1)(2)(3)	Review casing pressure test, radioactive tracer survey of bottom-hole cement, and logs.	Every 5 years	4	2	10.0	$458		Class I total	816	19,885	$913,101
			146.71(d)	Review pressure fall-off test.	Annual	2	47	94.7	$4,350
				Recordkeeping
			124.18(b)	Maintain administrative record of permit decision.	One-time	1	6	6.2	$284
				Other Reporting
			144.51(l); 146.69(a); 146.69(b)	Respond to periodic notifications by owners and operators.	Occasional	2	1	2.1	$95
				Closure
			146.70(c)	Review closure and post-closure plans prior to approving plugging and abandonment.	One-time	2	0	0	$0
			146.71(c)	Review closure report.	One-time	1	0	0	$0
			146.71(d)(1)	Witness and review pressure fall-off test prior to authorizing closure.	One-time	24	0	0	$0
				TOTAL			265	18,040	$828,399

				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.




				Exhibit 6-7B
				Federal Burden and Cost for Reviewing Class I Nonhazardous Well Data

						A	B	C	E	D
			CFR Citation	Description of Requirement	Frequency (A)	Unit Burden (B)	Number of Responses	Total Hours/Year	Total State Cost	Total Cost/Year
				Initial/Start-up
				*Permit applications*
			124.6(b)	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.	One-time	20.0	1.3	25.1	$0	$1,151
			124.6(d)	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	40.0	11	451.4	$0	$20,727
			124.7	Prepare and issue statement of basis.	One-time	1.0	11	11.3	$0	$518
			124.8	Develop and issue fact sheet.	One-time	4.0	0	0.0	$0	$0
			124.10	Provide public notice of issuance of a draft permit or intent to deny.	One-time	1.0	11	11.3	$0	$518
			124.11	Consider public comments.	One-time	6.0	11	67.7	$0	$3,109
			124.15	Issue final permit decision.	One-time	2.0	13	25.1	$0	$1,151
			124.17	Respond to comments.	One-time	7.0	13	87.8	$0	$4,030
			144.51(m)	Review notice of completion of construction.	One-time	2.0	13	25.1	$0	$1,151
				Review information related to aquifer exemption requests and make a determination.	One-time	8.0	12	99.3	$0	$4,559
				*Permit renewals/modifications*
			144.39	Review and respond to requests for permit modifications or re-issuance.	Occasional	30.0	3	103.1	$0	$4,732
				Monitoring/Testing
			146.13(b)(3)	Review casing pressure test and logs.	Every 5 years	4.0	25	98.3	$0	$4,514
			146.13(b)(3)	Review pressure fall-off test.	Annual	2.0	142	284.8	$0	$13,080
			146.13(c)	Review monitoring data submitted by operators.	Quarterly	2.0	270	540.2	$0	$24,806
				Recordkeeping
			124.18(b)	Maintain administrative record of permit decision.	One-time	1.0	13	12.5	$0	$576
				Other Reporting
			144.51(l)	Respond to periodic notifications by owners and operators.	Occasional	1.0	2	1.7	$0	$79
				Closure
			144.51(p)	Review plugging and abandonment report.	One-time	1.0	0	0.0	$0	$0
				TOTAL			551	1,845	$0	$84,702

				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.




				Exhibit 6-8
				Federal Burden and Cost for Reviewing Class II Well Data

						A			B	C	D
			CFR Citation	Description of Requirement	Frequency	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost	Number of Responses	Total Hours/Year	Total Cost/Year	Notes
			Initial/Start-up	Initial/Start-up
			*Permit applications (Per Permit Application)*	*Permit applications (Per Permit Application)*
			124.6(d)	Review permit application and supporting documentation and prepare draft permit.	One-time	6.0	$276	$0	130	780	$35,835
			124.11	Consider public comments.	One-time	2.0	$92	$0	130	260	$11,945	Assumes that 10% require public hearing.
			124.15	Issue final permit decision.	One-time	2.0	$92	$0	130	260	$11,945
			124.17	Respond to comments.	One-time	4.0	$184	$0	130	520	$23,890
			146.24(a)(3)	Review operator's AoR map and study.	One-time	5.0	$230	$0	53	267	$12,271
			146.24(a)(3)	Review operator's AoR map and perform AoR study.	One-time	2.5	$115	$0	0	0	$0
			144.51(m)	Review completion report.	One-time	2.0	$92	$0	124	247	$11,348
				Review information provided by HF well operators to meet the DFHF Guidance recommendations.	One-time	25.0	$1,148	$0	0	0	$0
				Review information related to aquifer exemption requests and make a determination.	One-time	8.0	$367	$0	179	1,429	$65,640
			*Permit reviews/modifications (Per Operator)*	*Permit reviews/modifications (Per Operator)*
			144.36(a)	Review each permit to determine whether it should be modified, revoked and reissued, or terminated.	Every 5 years	1.0	$46	$0	0	0	$10	Assumes that 47% of wells are permitted. Range = .5 to 2 hours
			144.39	Review request for permit modification or re-issuance.	Occasional	4.0	$184	$0	17	68	$3,101
			Monitoring/Testing (Per Operator)	Monitoring/Testing (Per Operator)
			146.23(b)(3)	Review mechanical integrity test data submitted by operators.	Every 5 years	0.5	$23	$0	4,206	2,103	$96,578
			146.23(c)	Review monitoring data submitted by operators.	Annual	0.25	$11	$0	0	0	$0
			Recordkeeping (Per Operator)	Recordkeeping (Per Operator)
			124.18(b)	Maintain administrative record in DI programs.	One-time	1.0	$46	$0	2	2	$97
			Other Reporting (Per Operator)	Other Reporting (Per Operator)
			144.51(l)	Respond to periodic notifications by owners and operators.	Occasional	2.0	$92	$0	0	0	$12	Assumes respondents = 6% of operators.
			Closure (Per Operator)	Closure (Per Operator)
			144.51(p); 144.28(k) (Rule authorized)	For DI programs, review plugging and abandonment report.	One-time	1.0	$46	$0	0	0	$11
			TOTAL	TOTAL					$5,112	$5,938	$272,682

				Note: Numbers may not add due to rounding




				Exhibit 6-9
				Federal Burden and Cost for Reviewing Class III Well Data

						A			B	C	D
			CFR Citation	Description of Requirement	Frequency	Unit Burden	Unit Labor Cost	Unit Non-Labor Cost	Number of Responses	Total Hours/Year	Total Cost/Year
			Initial/Start-up	Initial/Start-up
			*Permit applications (Per Permit Application)*	*Permit applications (Per Permit Application)*
			124.6(b)	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.	One-time	20	$918	$0	0	0	$0
			124.6(d)	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.	One-time	40	$1,837	$0	1	40	$1,837
			124.7	Prepare and issue statement of basis.	One-time	5	$230	$0	0	0	$0
			124.8	Develop and issue fact sheet.	One-time	3	$138	$0	0	0	$0
			124.10	Provide public notice of issuance of a draft permit or intent to deny.	One-time	2	$92	$0	2	4	$184
			124.11	Consider public comments.	One-time	8	$367	$0	2	16	$735
			124.15	Issue final permit decision.	One-time	10	$459	$0	2	20	$918
			124.17	Respond to comments.	One-time	15	$689	$0	2	30	$1,378
			144.51(m)	Review completion report.	One-time	2	$92	$0	0	0	$0
				Review information related to aquifer exemption requests and make a determination.	One-time	8	$367	$0	0	3.52	$162
			*Permit reviews/modifications (Per Facility)*	*Permit reviews/modifications (Per Facility)*
			144.36(a)	Review each permit to determine whether it should be modified, revoked and reissued, or terminated.	Every 5 years	4	$184	$0	1	4	$184
			144.39	Review request for permit modification or re-issuance.	Occasional	20	$918	$0	1	20	$918
			Monitoring/Testing (Per Facility)	Monitoring/Testing (Per Facility)
			146.33(b)(3)	Review mechanical integrity test data submitted by operators.	Every 5 years	1	$23	$0	6	3	$141
			146.33(c)	Review monitoring data submitted by operators.	Quarterly	0.25	$11	$0	123	31	$1,409
			Other Reporting (Per Facility)	Other Reporting (Per Facility)
			144.51(l)	Respond to periodic notifications by owners and operators.	Occasional	4	$184	$0	1	4	$184
			Recordkeeping (Per Facility)	Recordkeeping (Per Facility)
			124.18(b)	Maintain administrative record (DI).	One-time	4	$184	$0	10	40	$1,837
			Closure (Per Facility)	Closure (Per Facility)
			144.51(p)	Review plugging and abandonment report (DI only).	One-time	4	$184	$0	0	0	$0
			TOTAL	TOTAL					161	215	$9,886

				Note: Numbers may not add due to rounding.




				Exhibit 6-10
				Federal Burden and Cost for Reviewing Class IV/High Priority Class V Well Data

						A	B	C	D
				Description of Requirement	Frequency	Unit Burden	Number of Responses	Total Hours/Year	Total Cost/Year
				Closure
				Review closure plan.	One-time	1.0	15	15	$700
				TOTAL			15	15	$700

				Note:
				Numbers may not add due to rounding.




			Exhibit 6-11
			Federal Burden and Cost for Reviewing Class V Well Data

					A	B	C	D
			Description of Requirement	Frequency	Unit Burden	Number of Responses	Total Hours/Year	Total Cost/Year
			Program Oversight Activities
			Oversee and implement UIC program, for example, update regulations or guidances as needed.	Ongoing	0	10	0	$0
			Inventory Requirements
			Review inventory information.	One-time	0.5	5,778	2,889	$132,664
			EPA Activities Associated with Class V Rule Requirements - DI States
			Provide technical assistance to owners/operators (at start-up).	One-time	1.0	0	0	$0
			Review and file pre-closure notifications.	One-time	1.3	0	0	$0
			Review, approve, and file waivers/permit applications.	One-time	8.3	0	0	$0
			Review and file annual monitoring reports.	Annual	0.8	442	353	$16,225
			TOTAL			6,230	3,242	$148,889

			Note:
			Numbers may not add due to rounding.


				Exhibit 6-11
				Federal Burden and Cost for Reviewing Class VI Well Data

						A				B	C	D
				Description of Requirement	Frequency	Unit Burden	Unit Labor Cost	Capital Costs ($/response)	Unit Non-Labor Cost (A)	Number of Responses	Total Hours/Year	Total Cost/Year
				Program Oversight Activities
				Oversee and implement UIC program, for example, update regulations or guidances as needed.	Ongoing	$0
				Initial/Startup Requirements (Per Permit Application)
				Review the permit application and other information submitted by the operator, considering: AoR, relevant maps, site geology, formation testing results, well schematics and construction procedures, proposed injection procedure, status of corrective action on wells in the AoR, well logging, testing, and mechanical integrity data, and project plans.	One-time	780	$35,818	$-	$-	8.33	6500.0	$298,480
				Review financial responsibility demonstration.	One-time	100	$4,592	$-	$-	8.33	833.3	$38,267
				Determine and specify tubing, packing, casing, and cementing requirements based on review of information submitted by operator.	One-time	140	$6,429	$-	$-	8.33	1166.7	$53,573
				Witness logging and testing.	One-time	20	$918	$-	$-	8.33	166.7	$7,653
				Review applications for waviers to inject above the lowermost underground source of drinking water.	One-time	200	$9,184	$-	$-	-	0.0	$-
				Monitoring and Recordkeeping
				Review reports submitted by operators; recordkeeping of data from all data gathering activities.	Semi-annual	40	$1,837	$-	$-	4.67	186.7	$8,572
				Review mechanical integrity test data.	Annual	14	$620	$-	$-	2.33	31.5	$1,446
				Area of Review Reevaluation
				Review updated AoR modeling and updated plans.	Every 5 years	150	$6,888	$-	$-	0.07	10.0	$459
				Post-Injection Site Care and Site Closure
				Review relevant data prior to granting approval for plugging and abandonment of a well.	One-time	20	$918		$-	-	0.0	$-
				Review post-injection monitoring data.	Annual	15	$689		$-	1.0	15.0	$689
				Review non-endangerment demonstration and authorize site closure.	One-time	40	$1,837	$-	$-	-	0.0	$-
				Project Independent Activities
				Review primacy applications.	One-time	90.0	$4,133	$-	$-	1.67	150.0	$6,888
				TOTAL						43.1	9,060	$416,028
				Notes:
				(A) Unit Non-Labor Cost inflated by 20% to account for G&A
				Numbers may not add due to rounding.

Sheet 33: Forms & CFR

	Env Mgmt - private	Env Mgmt - state	Env Mgmt - Federal	This page helps populate the old ICRAS information it splits forms, CFRs, frequency by respondent category.
7520-1 Permit Review and Issuance/Wells in Area of Review		X	X
7520-2A Compliance Evaluation		X	X
7520-2B Compliance Evaluation - Significant Noncompliance		X	X
7520-3 Mechanical Integrity Test/Remedial Actions		X	X
7520-4 Quarterly Exceptions List		X	X
7520-6 UIC Permit Application	X
7520-7 Application to Transfer Permit	X
7520-8 Injection Well Monitoring report	X	X
7520-11 Annual Disposal/Injection Well Monitoring Report	X
7520-16 Inventory of Injection Wells	X
7520-17 Pre-Closure Notification Form	X
7520-18 Completion Form for Injection Wells	X
7520-19 Well Rework, P&A Plan/Affidavit	X


40 CFR 144	X	X	X
41 CFR 145	X	X	X
42 CFR 146	X	X	X
43 CFR 147	X	X	X
44 CFR 148	X	X	X


Hourly (24 -7)
Hourly Bus (40 per week)
Daily (7 per week)
Daily Bus (5 per week)
Weekly (52 per year)
Monthly
Yearly	X	X	X
Every Decade
Quarterly	X	X	X
Semi-annually		X	X
Biennially
Other (Describe every 5 yrs )	X

File Type	application/vnd.ms-excel
Author	Shari Ring
Last Modified By	Shari Ring
File Modified	2021-11-04
File Created	2001-04-13