UNDERGROUND
INJECTION
CONTROL
PROGRAM
INFORMATION
COLLECTION
REQUEST
April
15,
2003
Prepared
by:

The
Cadmus
Group,
Inc.
Arlington,
VA
22209
Prepared
for:

Office
of
Ground
Water
and
Drinking
Water
U.
S.
Environmental
Protection
Agency
Washington,
DC
20460
TABLE
OF
CONTENTS
1.
Identification
of
the
Information
Collection
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1
1(
a)
Title
and
Number
of
the
Information
Collection
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1
1(
b)
Short
Characterization
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1
2.
Need
For
and
Use
of
the
Collection
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3
2(
a)
Need/
Authority
for
the
Collection
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3
2(
b)
Practical
Utility/
Users
of
the
Data
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7
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
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11
3(
a)
Nonduplication
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11
3(
b)
Public
Notice
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11
3(
c)
Consultations
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11
3(
d)
Effects
of
Less
Frequent
Collection
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12
3(
e)
General
Guidelines
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13
3(
f)
Confidentiality
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13
3(
g)
Sensitive
Questions
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14
4.
Respondents
and
Information
Requested
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15
(
4)(
a)
Respondents/
SIC
Codes
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15
(
4)(
b)
Information
Requested
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16
5.
Information
Collected:
EPA
Activities,
Collection
Methodology,
and
Information
Management
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24
5(
a)
State
and
Agency
Activities
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24
5(
b)
Collection
Methodology
and
Management
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25
5(
c)
Small
Entity
Flexibility
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26
5(
d)
Collection
Schedule
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29
6.
Burden
and
Cost
of
the
Collection
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32
6(
a)
Respondent
Burden
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32
6(
b)
Respondent
Cost
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49
6(
c)
Agency
Burden
and
Cost
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51
6(
d)
Respondent
Universe
and
Total
Burden
and
Costs
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52
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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55
6(
f)
Reasons
for
Change
in
Burden
and
Cost
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57
6(
g)
Burden
Statement
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60
LIST
OF
EXHIBITS
2­
1
Classification
of
Underground
Injection
Wells
2­
2
Flow
of
Information
in
the
UIC
Program
4­
1
Respondents'
SIC
Codes
4­
2
Operator
Paperwork
Requirements
4­
3
State
Reporting
Forms
5­
1
Revised
State
Reporting
Frequency
6­
1A
Annual
Burden
and
Costs
Associated
with
Class
I
Hazardous
Wells:
Operators
Annual
Burden
and
Costs
Associated
with
Class
I
Hazardous
Wells:
States
6­
1B
Annual
Burden
and
Costs
Associated
with
Class
I
Nonhazardous
Wells:
Operators
Annual
Burden
and
Costs
Associated
with
Class
I
Nonhazardous
Wells:
States
6­
2
Annual
Burden
and
Costs
Associated
with
Class
II
Wells:
Operators
Annual
Burden
and
Costs
Associated
with
Class
II
Wells:
States
6­
3
Annual
Burden
and
Costs
Associated
with
Class
III
Wells:
Operators
Annual
Burden
and
Costs
Associated
with
Class
III
Wells:
States
6­
4
Annual
Burden
and
Costs
Associated
with
Class
IV/
Endangering
Class
V
Wells:
Operators
Annual
Burden
and
Costs
Associated
with
Class
IV/
Endangering
Class
V
Wells:
States
6­
5
Annual
Burden
and
Costs
Associated
with
Class
V
Wells:
Operators
Annual
Burden
and
Costs
Associated
with
Class
V
Wells:
States
6­
6
Annual
State
Burden
and
Cost
Associated
with
Preparing
7520
Forms
6­
7A
Federal
Burden
and
Cost
for
Reviewing
Class
I
Hazardous
Well
Data
6­
7B
Federal
Burden
and
Cost
for
Reviewing
Class
I
Nonhazardous
Well
Data
6­
8
Federal
Burden
and
Cost
for
Reviewing
Class
II
Well
Data
6­
9
Federal
Burden
and
Cost
for
Reviewing
Class
III
Well
Data
6­
10
Federal
Burden
and
Cost
for
Reviewing
Class
IV/
Endangering
Class
V
Well
Data
6­
11
Federal
Burden
and
Cost
for
Reviewing
Class
V
Well
Data
6­
12
Summary
of
Annual
Respondent
Burden
and
Costs
6­
13
Summary
of
Annual
Agency
Burden
and
Costs
6­
14
Change
in
Annual
Respondent
Burden
6­
15
Change
in
Annual
Respondent
Costs
LIST
OF
APPENDICES
APPENDIX
A
Federal
Register
Notice
on
UIC
Program
Reporting
Requirements
APPENDIX
B
UIC
Forms
APPENDIX
C
40
CFR
Sections
144,
146,
147,
and
148
1
Primary
enforcement
responsibility
(
primacy)
is
vested
in
states
that
have
UIC
programs
approved
by
EPA's
Administrator.
"
Direct
Implementation"
(
DI)
refers
to
programs
in
states
that
are
administered
directly
by
EPA
regional
offices.
Currently,
35
states
have
full
primacy
and
17
states
are
directly
implemented
by
EPA
regional
offices.
Five
states
have
a
combination
of
state
oversight
and
direct
implementation
commonly
referred
to
as
"
partial
primacy."
1.
Identification
of
the
Information
Collection
1(
a)
Title
and
Number
of
the
Information
Collection
Underground
Injection
Control
Program
Information
OMB
#
2040­
0042,
EPA
ICR
Number
0370.18
1(
b)
Short
Characterization
The
information
collected
upon
extension
of
the
approval
of
this
ICR
will
be
used
by
the
U.
S.
Environmental
Protection
Agency
(
EPA)
for
the
monitoring
and
enforcement
of
the
Underground
Injection
Control
(
UIC)
portion
of
the
Safe
Drinking
Water
Act
(
SDWA).
The
purpose
of
the
UIC
Program
is
to
establish
a
federal­
state
regulatory
system
to
ensure
that
actual
or
potential
underground
sources
of
drinking
water
(
USDWs)
are
not
endangered
by
the
underground
injection
of
contaminants.

Monitoring
and
enforcement
are
primarily
achieved
through
initial,
quarterly,
and
annual
reporting
requirements.
Information
is
gathered
both
at
the
state
program
level
and
at
the
regional
level.
Each
Region
has
the
role
of
implementing
UIC
programs
for
states
that
do
not
have
their
own
UIC
programs.
1
In
addition,
each
Region
must
compile
and
submit
information
to
EPA
Headquarters
from
all
UIC
programs
in
its
jurisdiction.
This
information
is
submitted
in
summary
reports
to
EPA
Headquarters.

EPA
collects
monitoring
data
and
test
results
from
operators
of
Class
I,
II,
and
III
injection
wells.
Class
IV
wells
are
banned
and
operators
of
these
wells
must
submit
plugging
and
abandonment
reports
as
they
are
closed.
EPA
requires
operators
of
existing
Class
V
motor
vehicle
waster
disposal
wells
in
ground
water
protection
areas
or
other
sensitive
ground
water
areas
to
close
these
wells
or
apply
for
a
permit
to
continue
injecting.
In
general,
Class
V
operators
submit
only
a
small
subset
of
the
information
required
of
Class
I,
II,
and
III
operators.
Section
144.6
of
40
CFR
describes
the
five
injection
well
types
(
see
Exhibit
2­
1).
EPA
also
collects
summary
information
on
permits,
compliance
and
enforcement,
inspections,
mechanical
integrity
testing,
and
inventory
for
all
wells
classes
from
permitting
authorities
in
primacy
states.

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
3,275,836
hours
(
an
average
of
1,091,945
hours
per
year),
and
the
present
value
cost
will
be
$
200,713,515
(
an
average
of
$
66,904,505
per
year).
The
burden
per
response
is
2.59
hours,
the
cost
per
response
is
$
158.43.
2.
Need
For
and
Use
of
the
Collection
This
Section
describes
EPA's
need
for
the
information
collected
pursuant
to
this
ICR
and
the
EPA
Regions'
and
Headquarters'
use
of
the
collected
data.
Section
2(
a)
demonstrates
both
the
need
and
legal
authority
for
information
collection.
Need
is
demonstrated
by
describing
the
potential
for
contamination
of
USDWs
and
the
statutory
requirements
that
justify
information
collection
to
prevent
contamination.
Legal
authority
is
demonstrated
by
identifying
laws
and
regulations
related
to
waste
disposal,
injection
wells,
and
the
UIC
Program.
Section
2(
b)
describes
the
practical
utility
and
the
users
of
the
information;
it
focuses
on
how
data
is
used
to
accomplish
program
objectives
and
manage
programs
at
each
level
of
implementation.

2(
a)
Need/
Authority
for
the
Collection
Potential
for
Contamination
The
fundamental
purpose
of
the
UIC
Program
is
to
prevent
the
contamination
of
current
and
potential
USDWs
by
keeping
injected
fluids
within
the
well
and
the
intended
injection
zone.
There
are
five
major
pathways
by
which
injected
fluids
can
migrate
into
USDWs.
The
following
discussion
describes
each
pathway
and
summarizes
information
collection
requirements
to
monitor
for
migration
through
the
pathway.

Pathway
1:
Faulty
Well
Construction
Contamination
through
this
pathway
is
caused
by
leaks
in
the
well
casing
or
fluid
forced
upward
between
the
well's
outer
casing
and
the
well
bore.
For
this
reason,
the
absence
of
significant
leaks
and
fluid
movement
in
the
well
bore
must
be
demonstrated
in
the
initial
permit
application,
and
every
five
years
thereafter.

Pathway
2:
Nearby
Wells
Fluids
from
the
pressurized
area
in
the
injection
zone
may
be
forced
upward
through
wells
in
the
area
of
injection.
Wells
that
penetrate
the
injection
area
in
the
zone
affected
by
this
pressure
must
be
properly
constructed
or
plugged.
For
this
reason,
plans
for
plugging
and
abandonment
are
submitted
with
the
permit
application.
In
addition,
DI
programs
require
that
plugging
and
abandonment
reports
be
submitted
if
the
operator
abandons
any
well.

Pathway
3:
Faults
or
Fractures
in
Confining
Strata
Fluids
may
be
forced
upward
out
of
the
pressurized
area
through
faults
or
fractures
in
the
confining
beds.
This
contamination
pathway
is
tracked
using
two
information
collection
requirements.
First,
permit
information
is
used
to
ensure
that
wells
are
sited
such
that
they
inject
below
a
confining
bed
that
is
free
of
known
open
faults
or
fractures.
Second,
injection
pressures
are
monitored
so
that
fractures
are
not
propagated
in
the
injection
zone
or
initiated
in
the
confining
bed
zone.
Pathway
4:
Direct
Injection
Class
IV
wells,
which
inject
into
or
above
USDWs
and
have
a
high
potential
to
endanger
human
health,
are
illegal.
Most
Class
V
wells
inject
nonhazardous
fluids
into
or
above
formations
that
contain
USDWs.
These
include,
but
are
not
limited
to,
motor
vehicle
waste
disposal
wells,
cesspools,
agricultural
drainage
wells,
storm
water
drainage
wells,
industrial
drainage
wells,
and
untreated
sewage
waste
disposal
wells.
In
a
regulatory
effort
to
address
the
Class
V
wells
that
pose
the
greatest
threat,
EPA
has
banned
the
construction
of
new
large­
capacity
cesspools,
and
requires
operators
of
existing
large­
capacity
cesspools
to
close
their
wells.
EPA
is
also
banning
new
motor
vehicle
waste
disposal
wells
and
is
requiring
operators
of
existing
motor
vehicle
waste
disposal
wells
in
ground
water
protection
areas
or
other
sensitive
ground
water
areas
to
close
these
wells
or
apply
for
a
permit
to
continue
injecting.

Pathway
5:
Lateral
Displacement
Fluid
may
be
displaced
from
the
injection
zone
into
hydraulically
connected
USDWs.
Permit
information
regarding
the
proximity
of
underground
injection
wells
to
USDWs
is
considered
by
the
permitting
authority
in
making
a
determination
of
whether
the
wells
are
properly
sited.
Well
operators
are
required
to
control
injection
pressure
and
conduct
monitoring
and
testing
to
track
any
lateral
migration
of
fluids.

Legal
Authority
Injection
wells
are
regulated
by
EPA's
Office
of
Ground
Water
and
Drinking
Water
(
OGWDW),
as
mandated
by
Sections
1421,
1422,
1423,
1425,
1431,
1445,
and
1450
of
the
SDWA
of
1974,
as
amended.
The
regulation
of
hazardous
waste
injection
is
jointly
authorized
by
the
SDWA
and
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
of
1976.
The
Hazardous
and
Solid
Waste
Amendments
(
HSWA)
of
1984
amended
RCRA
to
prohibit
the
land
disposal
of
hazardous
waste
unless
it
can
be
demonstrated
that
there
will
be
no
migration
from
the
disposal
unit
for
as
long
as
the
waste
remains
hazardous.
Underground
injection
of
hazardous
wastes
is
included
in
Section
3004(
k)
of
HSWA
as
a
land
disposal
technique.

Under
Section
1445
of
the
SDWA,
persons
subject
to
federal
or
state
UIC
programs
must:
"
establish
and
maintain
such
records,
make
such
reports,
conduct
such
monitoring,
and
provide
such
information
as
the
Administrator
may
reasonably
require
by
regulation
to
assist
him
in
establishing
regulations
under
this
title
.
.
."

The
specific
requirements
for
the
UIC
Program
are
established
in
the
Code
of
Federal
Regulations
(
CFR),
Title
40,
Sections
144
through
148
as
follows:

Section
144
­
Underground
Injection
Control
Program.
This
section
describes
the
general
requirements
of
the
Program,
authorizes
certain
types
of
wells,
defines
permitting
procedures,
and
establishes
procedures
for
ensuring
financial
responsibility.
Information
Collection
Request
5
Section
145
­
State
UIC
Program
Requirements.
This
section
describes
the
requirements
that
state
programs
must
meet
and
the
method
for
obtaining
program
approval.

Section
146
­
UIC
Program:
Criteria
and
Standards.
This
section
contains
the
technical
criteria
and
standards
that
various
classes
of
underground
injection
wells
must
meet.
Monitoring
and
reporting
criteria
are
outlined.

Section
147­
State
UIC
Programs.
This
section
describes
the
provisions
of
the
UIC
programs
of
individual
states
and
territories.

Section
148
­
Hazardous
Waste
Injection
Restrictions.
This
section
identifies
hazardous
wastes
that
are
restricted
from
disposal
into
Class
I
hazardous
waste
injection
wells.
It
outlines
the
standards
and
procedures
by
which
Class
I
hazardous
waste
facility
operators
may
petition
to
dispose
of
restricted
hazardous
wastes.

These
Sections
contain
information
collection
requirements
that
are
applicable
to
operators
of
underground
injection
wells
and
to
administrators
of
primacy
and
DI
programs.
These
sections
of
40
CFR
144­
148
are
reproduced
in
Appendix
C.
Exhibit
2­
1
describes
the
five
classes
of
injections
wells.
A
summary
of
the
specific
requirements
for
operators
is
given
in
Exhibit
4­
2,
Operator
Paperwork
Requirements;
the
paperwork
requirements
for
states
as
respondents
are
presented
in
Exhibit
4­
3,
State
Reporting
Forms.
Exhibit
2­
1
Classification
of
Underground
Injection
Wells
Class
I
Wells
that
inject
industrial
and
municipal
waste,
including
hazardous
waste,
beneath
the
lowermost
formation
containing
a
USDW.

Class
II
Wells
used
to
dispose
of
fluids
which
are
brought
to
the
surface
in
connection
with
oil
or
natural
gas
production;
to
inject
fluids
for
enhanced
recovery
of
oil
or
natural
gas;
or
to
store
hydrocarbons.

Class
III
Wells
that
inject
fluids
for
the
extraction
of
minerals
including:
mining
of
sulfur
by
the
Frasch
process;
in
situ
production
of
uranium
or
other
metals
such
as
ore
bodies
that
are
not
conventionally
mined;
and
solution
mining
of
salts
or
potash.

Class
IV
Wells
used
by
generators
of
hazardous
waste
or
of
radioactive
waste,
or
by
owners
or
operators
of
hazardous
waste
management
facilities,
to
inject
into
or
above
strata
that
contain
a
USDW.
These
wells
are
banned.

Class
V
Injection
wells
not
included
in
Classes
I,
II,
III,
or
IV.
Typical
examples
include,
but
are
not
limited
to:
agricultural
drainage
wells,
storm
water
drainage
wells,
industrial
drainage
wells,
untreated
sewage
waste
disposal
wells,
motor
vehicle
waste
disposal
wells,
and
cesspools.

Statutory
Requirements
Section
1421(
b)
of
the
SDWA
states
that
regulations
for
state
UIC
programs
must
contain
minimum
requirements
for
effective
programs
to
prevent
underground
injection
which
endangers
USDWs.
Therefore,
EPA
must:

°
Publish
minimum
national
requirements
for
effective
state
UIC
programs;

°
List
states
that
need
UIC
programs;

°
Make
grants
to
states
for
developing
and
implementing
UIC
programs;

°
Review
proposed
state
programs
and
approve
or
disapprove
them;

°
Promulgate
and
enforce
UIC
programs
in
those
states
that
choose
not
to
participate
in
or
do
not
develop
and
operate
approved
programs;
and
°
Evaluate
state/
regional
UIC
programs
for
effectiveness
in
meeting
statutory
and
regulatory
requirements.
Information
Collection
Request
7
2
The
7520
forms
are
described
in
Exhibit
4­
3.
In
addition
to
these
regulations,
other
rules
are
aimed
at
providing
EPA
with
the
information
it
needs
to
administer
its
program
and
to
determine
what
new
measures,
if
any,
are
necessary
to
achieve
its
statutory
mandate.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
information
users
include
regional
and
Headquarters
staff
who
make
decisions
regarding
UIC
regulations,
compliance
and
enforcement
actions,
funding
for
state
and
regional
UIC
programs,
and
strategic
and
policy
issues
related
to
the
mission
of
OGWDW
and
EPA.
Primacy
agents
in
states
use
the
summary
information
reported
on
the
7520
forms2
to
target
inspection
and
enforcement
activity,
to
establish
permit
terms
and
conditions,
to
track
performance
against
demands,
and
to
identify
violations
and
assess
their
significance.
In
addition,
the
primacy
agent
can
use
the
summary
reports
it
supplies
to
EPA
Headquarters
to
evaluate
its
own
program
activities,
such
as
the
number
of
mechanical
integrity
tests
(
MITs)
witnessed,
the
number
of
inspections
conducted,
and
the
number
of
permits
reviewed.

Exhibit
2­
2
charts
the
flow
of
information
from
operators,
states,
and
Regions
to
EPA
Headquarters.
Operators
submit
data
to
states
(
in
primacy
states),
or
to
EPA
regional
offices
(
in
DI
states).
Each
primacy
state
in
turn
submits
the
data
to
its
respective
EPA
regional
office,
which
reviews
the
information
and
forwards
it,
along
with
its
own
data
from
DI
states,
to
EPA
Headquarters.
All
information
in
the
quarterly,
semi­
annual,
and
annual
reports
received
at
EPA
Headquarters
is
stored
and
analyzed
using
computerized
databases.
These
reports
are
the
only
data
available
to
EPA
Headquarters
to
fulfill
UIC
program
needs
and
responsibilities.
The
following
sections
give
a
more
detailed
analysis
of
the
uses
made
of
the
collected
information.

Headquarters'
Management
of
the
National
Program
EPA
Headquarters
uses
reported
information
to
respond
to
information
requests
and
perform
analyses
for
EPA
management,
the
Office
of
Management
and
Budget,
Congress,
and
the
public.
Headquarters
oversees
primacy
agents
by
using
the
reports
to
track,
evaluate,
and
report
on
program
performance.
Performance
targets
and
measures
for
EPA
regional
programs
are
established
by
EPA
and
tracked
against
Government
Performance
and
Results
Act
(
GPRA)
goals.
EPA
tracks
high
priority
activities
that
guide
the
Regions
in
carrying
out
UIC
program
objectives.
EPA
negotiates
with
the
Regions
to
obtain
commitments
for
performance
based
on
these
guidelines.

In
addition
to
its
use
for
regional
oversight
purposes,
state
and
regional
information
is
also
used
to
justify
future
program
modifications.
For
example,
the
information
collected
may
be
used
to
determine
if
requirements
pertaining
to
rule­
authorized
wells
or
mechanical
integrity
testing
are
effective.
State
and
regional
data
is
used
as
background
information
in
making
these
types
of
decisions.

Regional
Oversight
of
Primacy
Programs
The
primary
use
of
quarterly,
semi­
annual,
and
annual
reports
submitted
to
the
Regions
is
to
help
the
Regions
oversee
the
performance
of
the
primacy
agents.
The
information
is
used
to
track
individual
state
progress
against
commitments,
and
to
ensure
that
state
programs
have
the
ability
to
take
timely
and
appropriate
action
in
response
to
direct
threats
to
the
public
health
due
to
contamination
of
USDWs.

Regions
also
have
enforcement
responsibilities
and
must
use
well
specific
information
to
track
state
enforcement
response
actions
for
all
significant
noncompliers
(
SNCs),
i.
e.,
those
injection
wells
that
are
most
likely
to
contaminate
USDWS.
The
statutory
responsibility
to
initiate
federal
enforcement
actions
may
be
delegated
to
a
Region
if
a
primacy
state
does
not
fulfill
its
responsibilities.

Like
EPA
Headquarters,
the
Regions
use
the
data
to
develop
regional
operating
budgets
and
program
plans,
allocate
resources,
track
state­
by­
state
performance,
and
respond
to
inquiries.
The
Regions
are
responsible
for
reviewing
and
verifying
the
information
on
the
quarterly
reports
before
sending
them
to
EPA
Headquarters.
Information
Collection
Request
9
Region
Submits
to
EPA
HQ:

°
Injection
well
inventory
°
Permit
review
and
issuance
°
Inspections/
MIT
testing
°
Compliance
evaluation
°
Significant
noncompliance
evaluation
°
Exceptions
list
report
Exhibit
2.2
UIC
Program
Information
Flowchart
Headquarters
Uses
for
Regional
Submittals:

°
National
budget
and
program
planning
activities
°
Resource
allocation
and
State
grant
allotments
°
Annual
report
of
UIC
Program
°
Track
program
performances
against
expectations
and
commitments
of
Regions
°
Management
information
for
policy
and
program
activities,
briefings
of
Agency
management
°
Responses
to
Congressional,
OMB,
GAO,
public
(
FOIA)
information
requests
EPA
HEADQUARTERS
EPA
REGIONS
DI
Uses
for
Owner
Submittals:

°
Target
inspection
and
enforcement
activity
°
Establish
permit
conditions
and
terms
°
Track
performance
against
plans
Regional
Oversight
Uses
for
Primacy
State
Submittals:

°
Establish
budget
and
planning
targets
°
Negotiate
State
workplans
and
track
State
performance
against
commitments
°
Evaluate
States
against
expectations
and
overall
Regional
performance
PRIMACY
STATES
Primacy
State
Uses
for
Owner
Submittals:

°
Target
inspection
and
enforcement
activity
°
Establish
permit
terms
and
conditions
°
Track
performance
against
plans
°
Identify
violations
and
assess
their
significance
for
enforcement
Primacy
State
Submits
to
Region:

°
Injection
well
inventory
°
Permit
review
and
issuance
°
Inspections/
MIT
testing
°
Compliance
evaluation
°
Significant
noncompliance
evaluation
°
Exceptions
list
report
Submits
to
Primacy
State
or
EPA
Region:

°
Permit
information
°
Annual
or
quarterly
report
°
Notification
of:

 
Abandonment
 
Change
of
well
ownership
 
Noncompliance
OWNER/
OPERATOR
Annually:

Semi­

Annually:

Quarterly:
Annually:

Semi­

Annually:

Quarterly:
Direct
Implementation
of
State
Programs
In
addition
to
their
oversight
responsibilities,
EPA
regional
offices
must
implement
the
UIC
Program
in
states
without
primacy.
As
administrators
of
UIC
programs
in
DI
states,
EPA
regional
offices
use
information
from
operators
in
several
ways.

First,
initial
permit
application
materials
provide
the
information
required
by
regional
offices
to
determine
if
proposed
underground
injection
wells
are
properly
designed
and
sited
to
minimize
the
possibility
of
USDW
contamination.
The
primary
responsibility
of
a
regional
office
is
to
use
well
information
submitted
prior
to
construction
and
during
completion
to
ensure
that
injected
fluids
will
remain
in
the
selected
injection
zone
and
will
not
leak
into
areas
that
could
result
in
contaminated
USDWS.

Following
permit
approval
and
completion
work,
the
permitting
authority
uses
monitoring
and
testing
reports
submitted
by
operators
to
determine
if
(
l)
there
is
a
leak
in
the
casing,
tubing,
or
packer,
or
(
2)
there
is
significant
fluid
movement
into
a
USDW
through
vertical
channels
adjacent
to
the
well
bore.

Regional
offices
with
DI
authority
also
use
information
required
of
operators
to
focus
efforts
on
injection
wells
in
need
of
enforcement
attention.
Operators
who
have
been
out
of
compliance
for
at
least
two
consecutive
quarters
are
identified
on
the
exceptions
list.
These
violators
are
targeted
for
enforcement
action.
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
This
Section
discusses
that
EPA
has
no
other
means
available
to
gather
the
requested
information;
it
also
describes
EPA's
solicitation
of
public
comments
in
the
Federal
Register
and
Agency
consultations
in
developing
the
burden
and
cost
estimates;
describes
how
less
frequent
reporting
may
endanger
USDWs;
and
discusses
Paperwork
Reduction
Act
general
guidelines
and
provisions
for
confidentiality.

3(
a)
Nonduplication
Well­
specific
data
obtained
from
operators
of
injection
wells
and
the
state
reports
that
rely
on
such
data
comprise
virtually
all
of
the
information
covered
by
this
ICR.
To
the
best
of
the
Agency's
knowledge,
this
information
is
not
required
or
collected
by
any
other
agency
or
regulation.
The
Department
of
Energy
does
collect
information
relating
to
production
for
enhanced
recovery
wells
in
its
"
Annual
Report
for
Enhanced
Oil
Recovery
(
EOR)
Incentive"
(
OMB
Clearance
No.
19054135).
This
information
pertains
to
oil
production,
and
is
related
to
but
different
from
the
information
EPA
uses
to
evaluate
injection
well
operators.
However,
on
a
case­
by­
case
basis,
permitting
authorities
may
use
this
information
to
supplement
existing
information
on
enhanced
recovery
wells.

Since
both
Class
I
and
Class
IV
wells
(
now
banned)
involve
the
injection
of
hazardous
wastes,
there
is
potential
overlap
between
UIC
programs
under
the
SDWA
and
hazardous
waste
regulations
promulgated
under
RCRA.
Historically,
the
regulations
established
provisions
for
RCRA
interim
status
(
Part
A
permit)
[
40
CFR
270.64]
for
Class
I
hazardous
wells
in
states
in
which
no
UIC
program
had
been
approved
or
promulgated.
The
regulations
allow
the
UIC
permit
to
be
issued
in
lieu
of
a
Part
B
RCRA
permit
if
the
UIC
hazardous
waste
well
meets
certain
conditions
specified
in
40
CFR
270.64(
c).
Thus,
although
UIC
hazardous
waste
wells
are
coregulated
under
RCRA
and
the
SDWA,
there
is
no
duplication
of
information
collection
between
RCRA
and
the
UIC
Program.

3(
b)
Public
Notice
EPA
published
a
notice
requesting
comment
on
the
burden
and
cost
associated
with
the
UIC
Program
reporting
requirements
in
the
Federal
Register
on
May
3,
2001
(
66
FR
22225).
The
Agency
received
no
comments
on
the
draft
ICR.
A
copy
of
the
Federal
Register
Notice
of
this
information
collection
is
attached
to
this
ICR
as
Appendix
A.

3(
c)
Consultations
Information
collection
requirements
from
operators
and
states
have
been
evolving
since
1980
as
a
result
of
periodic
reassessment
of
the
information
needs
of
the
UIC
Program.
Most
recently,
EPA
has
reevaluated
these
needs
in
conjunction
with
the
Presidential
directive
to
reduce
existing
paperwork
requirements
by
25
percent,
and
to
reduce
regular
reporting
by
50
percent.
In
July
of
1995,
EPA
solicited
input
from
state
UIC
Directors,
operators,
and
other
interested
parties
on
revising
the
UIC
Program
to
reduce
burden.
State
officials
suggested
combining,
simplifying,
or
eliminating
some
of
the
7520
forms,
or
reducing
the
frequency
at
which
primacy
agents
report
this
information
to
EPA.
Operators
suggested
that
EPA
decrease
the
frequency
at
which
operators
report
on
injectate
parameters
or
other
testing
results.

In
developing
burden
and
cost
estimates
and
underlying
assumptions,
EPA
consulted
knowledgeable
staff
in
the
EPA
regional
offices
and
states
that
are
most
active
in
the
UIC
programs.
Collectively,
these
offices
are
the
permitting
authorities
for
the
majority
of
injection
wells
in
each
well
class.
In
some
cases,
these
officials
contacted
operators
or
consultants
in
the
states
and
regions
to
solicit
input
on
operator
burden
and
costs.
In
August
1996,
EPA
held
a
meeting
of
regional,
state,
and
industry
staff
to
discuss
the
underlying
ICR
assumptions
and
estimated
burden
and
cost
associated
with
UIC
activities.
Members
of
the
workgroup
have
reviewed
this
ICR.
Furthermore,
in
1997,
EPA
convened
a
workgroup
of
state
and
regional
staff
to
review
the
7520
reporting
forms
and
make
recommendations
for
improving
them.
This
workgroup
is
frequently
consulted
on
7520
and
ICR
issues.

3(
d)
Effects
of
Less
Frequent
Collection
There
are
two
types
of
respondents
for
whom
efforts
could
be
made
to
minimize
burden:
(
1)
operators
of
injection
wells;
and
(
2)
primacy
state
agencies.

Operators
All
Class
I,
II,
and
III
operators
are
required
to
observe
pressure,
flow,
and
cumulative
volume
of
injected
wastes,
and
demonstrate
mechanical
integrity.
Some
operators
must
sample
and
analyze
their
injectate
and
conduct
ambient
monitoring.
These
requirements
provide
DI
and
state
primacy
programs
with
crucial
information
to
assess
whether
injection
wells
pose
a
potential
threat
to
USDWs.
In
developing
the
current
monitoring
and
testing
frequencies,
EPA
attempted
to
strike
a
balance
between
ensuring
protection
of
USDWs
and
placing
an
excessive
burden
on
operators.

Less
frequent
monitoring
and
testing
might
allow
injection
wells
to
operate
in
a
manner
that
could
threaten
or
cause
considerable
damage
to
USDWs
if
evidence
of
such
a
situation
were
undiscovered
for
a
long
time.
EPA
has
determined
that
operator
reporting
at
the
specified
frequencies
for
each
well
class
are
at
the
minimum
protective
frequency
for
the
following
reasons:

°
State
and
DI
programs
use
injectate
pressure
and
volume
data
to
ensure
that
the
pressures
caused
by
injection
activities
do
not
cause
fractures
to
initiate
in
the
confining
zone.
Less
frequent
monitoring
would
not
provide
the
necessary
data
to
ensure
that
injection
does
not
initiate
fractures
in
the
confining
zone
or
that
injectate
or
formation
fluids
are
not
displaced
into
USDWs.
Information
Collection
Request
13
°
MITs
can
reduce
the
amount
of
damage
a
well
failure
can
cause
to
USDWs
by
detecting
those
failures.
The
degree
to
which
this
damage
can
be
reduced
depends
on
the
frequency
of
MITs.
Less
frequent
MITs
would
raise
the
potential
for
contamination
of
USDWs.

°
Permitting
authorities
require
timely
data
on
the
chemical
composition
of
operators'
injectate
to
ensure
that
potentially
incompatible
injected
substances
will
not
come
into
contact
with
each
other.

Class
I
operating
permits
are
currently
renewed
every
ten
years.
This
frequency
is
necessary
to
provide
permitting
authorities
an
opportunity
to
review
facility
operations
to
ensure
that
injection
operations
will
not
endanger
USDWs.

State
Primacy
Agencies
As
Section
5(
d)
of
this
ICR
states,
EPA
has
recently
reduced
the
frequency
at
which
state
primacy
agencies
report
certain
information
to
EPA
via
the
7520
forms.
EPA
has
also
deleted
the
Grant
Utilization
Form
(
7520­
5).
The
Agency
has
reduced
the
frequency
at
which
this
information
is
reported
to
the
greatest
extent
possible
while
continuing
to
ensure
effective
oversight
of
state
primacy
programs.

3(
e)
General
Guidelines
Two
provisions
of
the
UIC
regulations
exceed
the
Paperwork
Reduction
Act
guideline
for
response
time.
Pursuant
to
40
CFR
144.51(
l)
and
144.28(
b),
operators
are
required
to
report
by
phone
within
24
hours
and
in
writing
within
five
days
"
any
noncompliance
which
may
endanger
health
or
the
environment."
This
is
an
emergency
provision
necessary
to
enable
permitting
authorities
to
take
timely
and
appropriate
steps
to
reduce
or
eliminate
any
potential
threat
to
public
health.

3(
f)
Confidentiality
Operators
of
injection
wells
may
claim
confidentiality,
as
provided
in
40
CFR
144.5
Confidentiality
of
Information.
If
confidentiality
is
requested,
the
information
is
treated
in
accordance
with
the
provisions
of
40
CFR
Part
2,
Public
Information.
Any
confidentiality
claim
must
be
made
at
the
time
of
submission
in
the
manner
prescribed
by
the
application
form
or
its
instructions.
In
the
case
of
other
submissions,
respondents
may
claim
confidentiality
by
stamping
the
words
"
confidential
business
information"
on
each
page
containing
such
information.
Claims
of
confidentiality
for
the
following
information
will
be
denied:

°
the
name
and
address
of
any
permit
applicant
or
permittee;
and
°
information
regarding
the
existence,
absence,
or
level
of
contaminants
in
drinking
water.

If
no
claim
of
confidentiality
is
made
at
the
time
of
submission,
EPA
may
make
the
information
available
to
the
public
without
further
notice.
However,
the
information
is
collected
for
the
Agency's
internal
use
and
there
are
no
plans
to
routinely
release
or
publish
any
of
the
data.

3(
g)
Sensitive
Questions
There
are
no
sensitive
questions
pertaining
to
this
ICR.
4.
Respondents
and
Information
Requested
This
Section
identifies
respondents
affected
by
this
information
collection;
and
describes
the
data
items
and
activities
required
of
operators,
states,
and
DI
programs.

(
4)(
a)
Respondents/
SIC
Codes
Operators
of
injection
wells
are
identified
by
standard
industrial
classification
(
SIC)
codes.
Operator
respondents
for
underground
injection
wells
are
categorized
by
the
industries
that
produce
fluid
wastes
and
the
type
of
fluid
injected
into
each
well
class.
The
SIC
codes
associated
with
each
well
class
are
listed
in
Exhibit
4­
1.

Exhibit
4­
1
Respondents'
SIC
Codes
UIC
Class
SIC
Code
Description
I
#
Major
Group
13
#
Major
Group
28
#
Major
Group
26
#
Major
Group
29
#
Major
Group
32
#
Major
Group
33
#
Major
Group
36
#
Major
Group
37
#
Major
Group
45
#
Major
Group
49
#
4953
#
Major
Group
89
#
Major
Group
99
#
Oil
and
gas
extraction
#
Chemicals
and
allied
products
#
Paper
and
allied
products
#
Petroleum
and
coal
products
#
Stone,
clay
and
glass
products
#
Primary
metal
industries
#
Electrical
and
electronic
machinery
#
Transportation
equipment
#
Transportation
by
air
#
Electric,
gas,
and
sanitary
services
#
Hazardous
waste
disposal
#
Services
not
elsewhere
classified
#
Nonclassifiable
establishments
II
#
1311
#
1321
#
1381
#
Crude
petroleum
and
natural
gas
#
Natural
gas
liquids
#
Drilling
oil
and
gas
wells
III
#
Major
Group
10
#
Major
Group
14
#
Metal
mining
#
Mining
and
quarrying
of
non­
metallic
minerals
IV
(
Banned)
#
NA
#
NA
V
#
01,
02,
074,
075
#
4789,
4953,
9511
#
7542
#
7033,
9111
#
4142,
4212,
4213,
4581,
5015,
5511,
5521,
5531,
5541,
7514,
7515,
7532,
7533,
7537,
7538,
7539,
7549,
9111
#
Agricultural
or
storm
drainage
wells
#
Domestic
wastewater
disposal
wells
#
Industrial
process
disposal
wells
#
Recreational
vehicle
parks
and
campsites,
executive
offices
(
e.
g.,
state
parks
and
campgrounds)

#
Bus
charter
services,
trucking,
airports,
flying
fields,
and
airport
terminal
services;
motor
vehicle
parts;
motor
vehicle
dealers;
auto
and
home
supply
stores;
gasoline
service
stations;
passenger
car
rental
or
leasing;
automotive
repair
and
services;
executive
offices
(
e.
g.,
town
garages)
3
Permits
may
be
issued
on
an
area
basis
as
well
as
on
an
individual
basis,
except
for
hazardous
waste
injection
wells.
Refer
to
Section
5(
b)
for
a
description
of
how
the
permitting
process
minimizes
the
information
burden
on
owners
and
operators.
(
4)(
b)
Information
Requested
(
4)(
b)(
1)
Data
Items,
Including
Recordkeeping,
Required
from
Operators
Required
data
items
vary
according
to
well
class
and
authorization
category
(
permitted
well
vs.
rule­
authorized
well).
The
information
required
of
operators
is
listed
in
Exhibit
4­
2.

Initial
Reporting
Requirements
Two
methods
are
available
for
obtaining
approval
for
underground
injection:
rule
authorization
and
permitting.
Existing
Class
II
enhanced
recovery
(
II­
R)
and
hydrocarbon
storage
wells
are
authorized
by
rule
for
life
and
do
not
require
permits.
All
new
Class
I,
II,
and
III
wells
require
permits.
New
Class
V
wells
may
be
rule­
authorized,
although,
in
some
states
or
regions,
operators
of
Class
V
wells
may
be
required
to
obtain
permits.

Rule­
Authorized
Wells
Wells
in
existence
before
the
promulgation
of
specific
permitting
regulations
are
authorized
by
rule
until
regulations
require
them
to
be
permitted.
To
meet
initial
reporting
requirements,
operators
of
rule­
authorized
wells
are
required
to
submit
inventory
information
(
i.
e.,
facility
name;
name
and
address
of
the
facility's
legal
contact;
ownership
status;
and
operating
status
of
the
injection
well)
to
the
permitting
authority
using
Form
7520­
16.
Operators
must
also
submit
a
plugging
and
abandonment
plan
and
information
regarding
financial
responsibility.
Authorization
terminates
if
the
operator
fails
to
supply
any
required
information,
or
if
the
well
loses
mechanical
integrity.

Permitted
Wells3
Operators
of
permitted
wells
must
follow
a
two­
step
permit
application
procedure.
The
operator
must
submit
a
permit
application
prior
to
construction,
and
a
completion
report
before
commencing
injection.
Operators
must
include
the
following
information
with
their
permit
applications:

°
Inventory
Information:
name
of
the
facility,
name
and
address
of
legal
contact,
ownership
of
facility,
SIC
code(
s),
and
a
description
of
the
activities
requiring
a
permit,
[
all
well
Classes];
Information
Collection
Request
17
Exhibit
4­
2
Operator
Paperwork
Requirements
Activity
Class
I­
H
I­
N
II
III
V
Provide
Inventory
Information

Permit
Application
List
of
Landowners





Area
of
Review
Methods




Maps
of
Wells/
Area
of
Review




Corrective
Action
Plan




Maps
and
Cross
Sections
of
USDWs



Names
and
Depths
of
USDWs

Maps
and
Cross
Sections
of
Local
Geology



Maps
and
Cross
Sections
of
Regional
Geology



Geological
Data
on
Injection
and
Confining
Zones

Operating
Data




Formation
Testing
Program



Stimulation
Program



Injection
Procedures



Construction
Details




Changes
in
Injected
Fluid

Plans
for
Well
Failures



Ambient
Monitoring
Program



Plugging
and
Abandonment
Plan




Financial
Assurance




Completion
Report
Results
of
Logs
and
Tests
Performed
During
Construction




MIT
Results




Anticipated
Maximum
Injection
Pressure
&
Flow
Rate




Formation
Testing
Results




Actual
Injection
Procedure




Hydrogeologic
Compatibility/
Compatibility
of
Well
Materials


Status
of
Corrective
Action




Monitoring
and
Reporting
Analyze
and
Report
on
Chemical
Composition
of
Injectate





Record
and
Report
Injection
Pressure,
Volume,
&
Flow
Rate




Perform
and
Report
on
MIT




Conduct
and
Report
on
Ambient
Monitoring



Conduct
and
Report
on
Pressure
Fall­
Off
Test


Recordkeeping
Retain
Monitoring,
Testing,
Permitting
Records





Closure
Closure
Report
(
DI
only)




4
This
requirement
may
be
waived
if
the
Regional
Administrator
determines
that
it
is
too
burdensome
(
e.
g.,
if
the
well
is
located
in
a
populated
area).
Some
regions
may
also
require
operators
to
notify
all
landowners
of
their
intent
to
construct
the
well.

List
of
Landowners:
a
list
of
landowners
within
one­
quarter
mile
of
the
facility
(
in
DI
programs)
[
all
well
Classes];
4
°
Area
of
Review
Methods:
methods
and
calculations
used
to
determine
the
area
of
review
(
AoR)
[
Classes
I,
II,
and
III];

°
Maps
of
Wells/
Area
of
Review:
a
tabulation
of
all
wells
within
the
AoR
(
within
1/
4
mile
of
the
well,
or
within
2
miles
of
a
Class
I
hazardous
well)
that
penetrate
the
injection
zone
or
the
confining
zone
[
Classes
I,
II,
and
III];

°
Corrective
Action
Plan:
a
plan
for
corrective
action
for
wells
within
the
AoR
that
are
not
properly
plugged
[
Classes
I,
II,
and
III];

°
Geological
and
Hydrogeological
Data:
maps
and
cross
sections
of
USDWs,
and
data
(
including
maps
and
cross
sections)
on
the
local
and
regional
geology
of
the
confining
zone
[
Classes
I
and
III];
names
and
depths
of
USDWs
[
Class
II];

°
Operating
Data:
a
description
of
the
proposed
operation,
including
rates
and
volumes
of
fluids
to
be
injected,
injection
pressures,
and
sources
and
constituent
analyses
of
injection
fluids
[
Classes
I,
II,
and
III];

°
Formation
Testing
Program:
a
description
of
the
proposed
formation
testing
program
[
Classes
I
and
III,
optional
for
Class
II];

°
Stimulation
Program:
a
description
of
the
proposed
stimulation
program
[
Classes
I
and
III,
optional
for
Class
II];

°
Injection
Procedures:
a
description
of
the
proposed
injection
procedure
[
Classes
I
and
III,
optional
for
Class
II];

°
Construction
Details:
construction
plans,
including
schematic
drawings
of
the
surface
and
subsurface
details
of
the
system
[
Classes
I
and
III];

°
Changes
in
Injected
Fluid:
expected
changes
in
pressure,
native
fluid
displacement,
and
direction
of
movement
of
injected
fluid
[
Classes
I
and
III];

°
Plans
for
Well
Failures:
plans
for
contingency
action
in
the
case
of
shut­
ins
or
well
failures
[
Classes
I
and
III,
optional
for
Class
II];
Information
Collection
Request
19
°
Ambient
Monitoring
Program:
planned
ambient
monitoring
program,
including
the
location
of
monitoring
wells
and
monitoring
devices,
and
the
proposed
sampling
frequency
[
Classes
I
and
III,
optional
for
Class
II];

°
Plugging
and
Abandonment
Plan:
plans
for
closing
the
well,
including
type
and
placement
of
plugs
to
be
used
[
Classes
I,
II,
and
III];
and
°
Financial
Assurance:
evidence
of
financial
responsibility
for
closure,
such
as
surety
bonds
or
financial
statements
[
Classes
I,
II,
III].

Upon
approval
of
the
permit
application,
the
operator
may
begin
construction
of
the
well.
Following
construction,
the
operator
of
a
new
well
must
submit
a
completion
report
prior
to
being
authorized
to
inject.
Completion
reports
must
include
the
following
elements:

°
The
results
of
deviation
checks,
other
logs
and
tests
[
Classes
I,
II,
and
III];

°
Demonstration
of
mechanical
integrity
(
i.
e.,
the
results
of
a
casing
pressure
test;
radioactive
tracer
survey
of
the
bottom­
hole
cement;
and/
or
temperature,
noise,
or
other
logs
to
check
for
movement
along
the
borehole)
[
Classes
I,
II,
and
III];

°
Anticipated
maximum
injection
pressure
and
flow
rate
[
Classes
I,
II,
and
III];

°
The
results
of
formation
fluid
sampling,
and
testing
of
the
injection
and
confining
zones
[
Classes
I,
II,
and
III];

°
Actual
injection
procedure
[
Classes
I,
II,
and
III];

°
Report
on
hydrogeological
compatibility
and
the
compatibility
of
well
materials
[
Class
I];
and
°
The
status
of
corrective
action
at
improperly
abandoned
wells
within
the
AoR
[
Classes
I,
II,
and
III].

Operators
of
Class
I
hazardous
waste
wells
must
adhere
to
more
stringent
permit
application
requirements
than
those
required
of
other
classes
of
wells.
Operators
seeking
an
exemption
from
the
prohibition
from
injecting
any
of
the
Class
I
listed
hazardous
wastes
must
submit
the
following
information
in
addition
to
the
information
described
above:

°
No
Migration
Petition.
Operators
of
Class
I
hazardous
waste
injection
wells
must
demonstrate,
usually
by
computer
modeling,
that
their
wastes
will
not
endanger
USDWs.
The
operator
must
provide
sufficient
information
to
demonstrate
that
the
hazardous
constituents
of
wastes
will
not
migrate
from
the
disposal
site.
In
particular,
the
petition
must
prove
that
the
waste
will
not
reach
the
roof
of
the
injection
zone
or
a
conduit
within
the
injection
zone
within
10,000
years.
This
is
known
as
the
Fluid
Flow
Petition.

°
Hydrogeological
Compatibility/
Compatibility
of
Well
Material
Report.
Operators
of
Class
I
hazardous
waste
wells
must
demonstrate
hydrogeological
compatibility
(
i.
e.,
determine
that
the
waste
stream
and
its
anticipated
reaction
products
will
be
compatible
with
both
the
geologic
material
of
the
injection
zone
and
any
previously
injected
fluids),
and
compatibility
of
well
materials
(
i.
e.,
demonstrate
that
the
waste
stream
will
be
compatible
with
the
well
materials
that
come
in
contact
with
the
waste).

°
Waste
Analysis
Plan.
Class
I
hazardous
waste
well
operators
must
develop
and
follow
an
approved
written
waste
analysis
plan
that
describes
procedures
for
obtaining
a
detailed
chemical
and
physical
analysis
of
a
representative
sample
of
their
waste.
The
waste
analysis
plan
must
specify
(
1)
the
parameters
within
which
the
waste
will
be
analyzed
and
the
rationale
for
selecting
these
parameters;
(
2)
the
test
methods
that
will
be
used
to
test
for
these
parameters;
and
(
3)
the
sampling
method
that
will
be
used
to
obtain
a
representative
sample
of
the
waste
to
be
analyzed.

°
Other
Information.
Operators
of
Class
I
hazardous
waste
wells
must
also
submit
a
description
of
the
hydrogeological
and
geochemical
conditions
at
the
site;
the
physicochemical
nature
of
the
waste
stream;
and
proof
of
conformance
with
AoR
requirements.

Class
V
facilities
generally
are
rule­
authorized.
Operators
of
Class
V
motor
vehicle
waste
disposal
wells
in
ground
water
protection
areas
or
other
sensitive
ground
water
areas
must
apply
for
a
permit
to
continue
injecting.
Permitting
authorities
may
also
require
other
Class
V
operators
to
apply
for
a
permit
to
commence
or
to
continue
injecting.
Typically,
the
permit
application
process
for
Class
V
operators
is
less
complex
than
for
other
well
classes
 
operators
are
typically
required
to
submit
a
description
of
the
activities
requiring
a
permit,
inventory
information,
topographic
maps,
and
a
plugging
and
abandonment
plan
which
includes
a
demonstration
of
financial
responsibility
for
closure.
Operators
are
also
required
to
sample
their
injectate
and
submit
the
results
of
analysis.

Monitoring
and
Testing
Requirements
All
Class
I,
II,
and
III
operators
must
observe
injection
pressure,
rate,
and
cumulative
volume
and
demonstrate
mechanical
integrity.
Requirements
for
other
monitoring
and
testing
activities
vary
by
class.
The
following
are
the
specific
monitoring
and
testing
activities
for
each
class:


Monitor
injection
pressure,
flow
rate,
and
cumulative
volume
of
injected
fluids
[
continuously
for
Class
I,
weekly
for
Class
II
disposal
wells
(
II­
D),
monthly
for
Information
Collection
Request
21
5
Substitute
MIT
methods
(
e.
g.,
review
of
cementing
records)
may
be
approved
by
the
Director.
Class
II­
R,
and
semi­
monthly
for
Class
III];
temperature
of
injected
fluids
and
annulus
pressure
between
the
tubing
and
the
long
string
casing
[
Class
I];


Conduct
chemical
monitoring
of
injectate
as
described
in
a
waste
analysis
plan
or
as
specified
by
the
permitting
authority
[
Classes
I,
II,
and
permitted
Class
V
motor
vehicle
waste
disposal
wells];


Conduct
annual
sludge
monitoring
[
Class
V
motor
vehicle
waste
disposal
wells];


Test
for
internal
and
external
mechanical
integrity
of
the
well
casing,
via:

 
casing
pressure
test
[
annually
for
Class
I
hazardous;
every
five
years
for
Class
I
nonhazardous,
Class
II,
and
Class
III
salt
solution
mining]

 
radioactive
tracer
survey
of
the
bottom­
hole
cement
[
annually
for
Class
I
hazardous];

 
temperature,
noise,
or
other
logs
to
test
for
movement
of
fluid
along
the
borehole
[
every
five
years
for
Class
I
and
Class
III
(
salt
solution
mining)]
5;


Conduct
ambient
monitoring,
including
a
pressure
fall­
off
test
[
annually
for
Class
I];
and

Monitor
wells
completed
in
the
injection
zone
and
in
overlying
USDWS
[
semimonthly
for
active
Class
III
wells,
monthly
for
Class
III
facilities
in
restoration].
6
In
accordance
with
the
Paperwork
Reduction
Act
of
1995,
the
reporting
requirements
covered
by
this
information
collection
are
consistent
with
the
reporting
and
recordkeeping
activities
currently
in
practice
by
the
respondents.
For
example,
respondents
generally
may
report
required
information
in
either
electronic
or
hard­
copy
format,
whichever
is
compatible
with
their
facility
practices.
Reporting
and
Recordkeeping
Requirements
All
permitted
and
rule­
authorized
wells
must
report
to
state
or
DI
agencies
on
the
results
of
required
monitoring
and
testing.
6
In
addition,
operators
must
notify
the
permitting
authority
of
any
planned
changes
to
the
facility;
changes
that
may
result
in
noncompliance;
progress
in
meeting
the
milestones
of
a
compliance
schedule;
any
loss
of
mechanical
integrity
or
other
indication
of
possible
endangerment
of
a
USDW
within
24
hours;
or
any
noncompliance
with
permit
conditions.

Scheduled
reporting
requirements
include
the
following:

°
Class
I
hazardous
facility
operators
report
quarterly
on
monitoring
results;
and
annually
on
MITs
and
to
update
their
plugging
and
abandonment
cost
estimates.

°
Class
I
nonhazardous
facility
operators
are
required
to
report
quarterly
on
injectate
monitoring;
annually
on
ambient
monitoring;
and
on
MITs
every
five
years.

°
Class
II
operators
must
report
monitoring
data
annually;
and
on
MITs
every
five
years.

°
Class
III
operators
report
quarterly
on
monitoring,
and
on
MITs
every
five
years.

°
Class
V
motor
vehicle
waste
disposal
well
operators
must
report
quarterly
on
injectate
monitoring
and
annually
on
sludge
monitoring.

For
rule­
authorized
wells
in
DI
states,
the
Regional
Administrator
may
require
operators
to
submit
additional
information,
as
needed,
to
determine
if
a
well
poses
a
hazard
to
USDWs.
Such
information
may
include:
evidence
of
ground­
water
monitoring,
including
periodic
reports
of
such
monitoring;
periodic
reports
on
analysis
of
injected
fluids;
and
a
description
of
the
geologic
strata
through
and
into
which
injection
is
taking
place.

Operators
must
maintain
monitoring
information,
calibration
and
maintenance
records,
required
reports,
application
data,
and
monitoring
results
for
three
years;
and
keep
their
most
recent
plugging
and
abandonment
cost
estimate
for
one
year.
Information
Collection
Request
23
Closure
Requirements
When
closing
their
wells,
operators
must
submit
to
the
permitting
authority
a
plugging
and
abandonment
report
which
indicates
that
the
well
was
plugged
in
accordance
with
the
plugging
and
abandonment
plan.
Operators
who
choose
to
plug
in
a
manner
different
from
the
one
specified
in
their
plugging
and
abandonment
plan
must
first
submit
and
obtain
approval
for
a
revised
plugging
and
abandonment
plan.

Class
I
hazardous
waste
well
operators
must
also
conduct
a
pressure
fall­
off
test
and
demonstrate
mechanical
integrity
before
plugging
the
well
and
report
the
results
of
these
tests
with
their
closure
reports.

(
4)(
b)(
2)
Data
Items
Including
Recordkeeping,
Required
from
State
and
DI
Programs
Primacy
and
DI
agencies
submit
information
on
wells
within
their
jurisdiction
to
Headquarters
via
the
7520
forms.
Each
of
the
forms
that
agencies
must
submit
as
respondents,
the
reporting
frequency,
and
the
data
items
reported
are
listed
in
Exhibit
4­
3
and
are
addressed
in
Section
2(
b).
Copies
of
the
forms
are
provided
in
Appendix
B.
Exhibit
4­
3
State
Reporting
Forms
Form
Frequency
Information
Collected
Permit
Review
and
Issuance
(
7520­
1)
Annual
Information
on
permit
determinations
(
i.
e.,
the
number
of
permits
issued
and
not
issued,
and
permit
modifications),
permit
file
reviews,
the
number
of
ruleauthorized
wells
reviewed,
AoR
reviews,
and
corrective
action
performed.

Compliance
Evaluation
(
7520­
2A)
Semi­
annual
Enforcement
actions,
including
administrative
actions
and
civil
and
criminal
actions.

Compliance
Evaluation
­
Significant
Noncompliance
(
7520­
2B)
Semi­
annual
Injection
wells
identified
as
being
in
significant
noncompliance
(
SNC)
with
statutory
requirements,
and
enforcement
actions
against
SNCs
and
returns
of
wells
to
compliance;
contamination
of
USDWs;
and
closures.

Mechanical
Integrity
Test/
Remedial
Actions
(
7520­
3)
Annual
Results
of
inspections
and
MITs,
and
remedial
actions
conducted
for
any
test
failures.

Quarterly
Exceptions
List
(
7520­
4)
Quarterly
Wells
that
have
remained
in
significant
noncompliance
for
two
or
more
consecutive
quarters
and
have
not
been
returned
to
compliance
or
been
subject
to
a
formal
enforcement
action.

Inventory
of
Wells
Information
Form
(
7520­
16)
[
Formerly
7500­
48]
Annual
Inventory
information,
including
the
facility
name;
the
legal
contact
of
the
facility;
and
well
information,
including
type,
number,
and
operating
status
of
injection
wells.

5.
Information
Collected:
EPA
Activities,
Collection
Methodology,
and
Information
Management
Section
5(
a)
describes
state
oversight
of
operators
and
EPA
activities
with
respect
to
program
management.
Section
5(
b)
describes
how
EPA
will
manage
the
information
collected;
Section
5(
c)
discusses
how
this
information
collection
addresses
the
needs
of
small
businesses;
and
Section
5(
d)
presents
EPA's
justification
for
the
collection
schedule.

5(
a)
State
and
Agency
Activities
5(
a)(
1)
State
Activities
Under
Section
1422
of
the
SDWA,
states
that
adopt
UIC
regulations
at
least
as
stringent
as
the
federal
requirements
may
be
granted
primacy
for
the
UIC
Program.
Under
Section
1425,
state
programs
that
regulate
oil
and
gas
must
demonstrate
that
their
program
"
represents
and
Information
Collection
Request
25
effective
program
to
prevent
underground
injection
which
endangers
drinking
water
sources"
in
order
to
be
granted
primacy.

In
addition
to
the
reporting
activities
described
in
Section
4(
b)(
2),
state
primacy
agencies
are
responsible
for
overseeing
the
permitting
of
wells
within
their
states.
Primacy
agents
receive
and
review
permit
applications
from
operators,
solicit
and
respond
to
public
comments,
and
issue
final
decisions
on
permit
applications.
States
also
review
completion
reports
and
associated
testing
results
to
verify
that
new
wells
have
been
constructed
in
accordance
with
construction
standards.

State
agencies
review
injectate
and
ambient
monitoring
data
submitted
by
operators;
they
also
review
MITs
and
pressure
fall­
off
tests.
Many
states
witness
some
or
all
MITs
and
plugging
and
abandonments.
State
primacy
agencies
also
respond
to
occasional
reporting
submitted
by
operators,
conduct
periodic
permit
reviews,
and
respond
to
operators'
requests
for
permit
modifications.

5(
a)(
2)
Agency
Activities
EPA
regions
oversee
injection
wells
in
those
states
that
do
not
have
approved
primacy
programs.
The
regions
perform
the
same
activities
as
state
primacy
agents.
In
addition,
regional
offices
review
no­
migration
petitions
submitted
by
Class
I
hazardous
facility
operators
in
both
primacy
and
DI
states.
Regional
staff
review
reports
on
MITs
and
pressure
fall­
off
tests
performed
in
the
DI
programs,
and
in
some
cases,
tests
on
wells
in
primacy
states.
DI
programs
also
review
closure
reports
required
of
operators
when
they
abandon
their
wells.

EPA
Headquarters
activities
consist
of
compiling
the
regional
summary
information
on
permit
reviews
and
issuance;
compliance
evaluation,
enforcement
and
inspections
information,
and
inventory
data
reported
on
the
7520
forms.
EPA
enters
this
data
into
a
computerized
database
that
is
accessible
to
the
Regions
so
that
they
may
verify
it
for
accuracy.

5(
b)
Collection
Methodology
and
Management
The
Mission
Needs
Assessment
conducted
in
1987­
88
identified
individual
data
systems
at
the
program
implementation
(
state
and
DI)
level
as
the
most
important
components
of
the
UIC
data
management
system.
These
state
systems
maintain
detailed
data
about
each
well
regulated
by
the
UIC
Program.
This
data
is
the
source
of
summary
information
submitted
to
the
Regions
and
EPA
Headquarters
for
oversight
and
program
management.

To
ensure
that
states
meet
the
information
requirements
in
the
minimum
data
set,
the
UIC
Program
developed
a
prototype
data
system
to
assist
interested
states
in
enhancing
their
current
data
collection
and
information
management
capabilities.
The
prototype
has
the
following
capabilities:
°
Incorporates
UIC
minimum
data
set;

°
Tracks
on
a
well­
by­
well
basis;
and
°
Establishes
relationships
between
individual
wells
and
daily
activities.

The
Well
Activities
Tracking,
Evaluation
and
Reporting
System
(
WATERS)
is
an
optional
system
that
enables
users
to
easily
compile
and
produce
the
reports
EPA
requires.
The
system,
which
tracks
individual
wells,
is
the
product
of
a
cooperative
effort
between
EPA,
several
regions,
and
several
state
programs.
The
system
generates
the
7520
forms
based
on
the
well­
specific
information
it
contains.
These
reports
can
be
printed
or
submitted
to
EPA
on
disk.
WATERS
Version
2
was
distributed
to
all
states
and
Regions
in
FY
1994.

OGWDW
is
assessing
the
feasibility
of
allowing
state
and
federal
UIC
programs
to
report
electronically
the
information
currently
submitted
on
the
7520
forms.
Electronic
reporting
involves
transmitting
UIC
data
in
a
standard
electronic
format
that
can
be
readily
incorporated
into
the
Headquarters
UIC
databases
without
manual
data
entry.
Electronic
reporting
supports
the
Agency's
effort
to
streamline
the
UIC
Program
by
reducing
the
reporting
burden
on
the
states
and
improving
EPA's
data
collection
methods.
Electronic
reporting
offers
an
opportunity
to:

°
Reduce
data
entry;
°
Reduce
mailing
costs;
°
Reduce
the
routine
process
of
handling
paperwork
in
the
reporting
process;
°
Reduce
or
eliminate
the
need
to
store
large
quantities
of
paper
documents;
and
°
Increase
the
accuracy
of
reports
submitted
to
OGWDW
and
OECA.

Reporting
alternatives
under
consideration
include
e­
mail,
a
World
Wide
Web
site,
a
File
Transfer
Protocol
site,
Lotus
Notes,
and
a
bulletin
board.

5(
c)
Small
Entity
Flexibility
Few,
if
any,
small
businesses
are
operators
of
Class
I
or
Class
III
injection
wells.
In
contrast,
many
Class
II
and
Class
V
operators
affected
by
this
collection
are
small
entities.
This
collection
reduces
to
the
extent
practicable
and
appropriate
the
burden
on
persons
that
provide
information
to
or
for
EPA,
including
with
respect
to
small
entities,
as
defined
by
the
Regulatory
Flexibility
Act
[
5
USC
601(
6)],
the
use
of
such
techniques
as:


Establishing
differing
compliance
or
reporting
requirements
or
timetables
that
take
into
account
the
resources
available
to
those
who
are
to
respond;


The
clarification,
consolidation,
or
simplification
of
compliance
and
reporting
requirements;
or
Information
Collection
Request
27

An
exemption
from
coverage
of
the
collection
of
information,
or
any
part
thereof.

Class
I
The
size
standard
the
Small
Business
Administration
uses
to
define
"
small
business"
varies
by
SIC
code.
Class
I
wells
typically
involve
the
following
SIC
codes:


Major
Group
13:
Oil
and
gas
extraction

Major
Group
28:
Chemicals
and
allied
products

Major
Group
26:
Paper
and
allied
products

Major
Group
29:
Petroleum
and
coal
products

Major
Group
32:
Stone,
clay
and
glass
products

Major
Group
33:
Primary
metal
industries

Major
Group
36:
Electrical
and
electronic
machinery

Major
Group
37:
Transportation
equipment

Major
Group
45:
Transportation
by
air

Major
Group
49:
Electric,
gas,
and
sanitary
services

4953
Hazardous
waste
disposal

Major
Group
89:
Services
not
elsewhere
classified

Major
Group
99:
Nonclassifiable
establishments
The
small
business
size
standards
for
firms
in
these
SIC
code
groups
vary
from
500
to
1,500
employees,
except
for
SIC
code
4953,
for
which
the
size
standard
is
$
3.5
million
or
less
in
revenues.
Most
of
the
firms
that
own
or
operate
Class
I
injection
wells
clearly
exceed
both
the
500­
employee
and
the
1,500­
employee
standards.
Examples
include
Allied
Chemical,
Bethlehem
Steel,
Dow
Chemical,
DuPont,
Exxon,
General
Electric,
Monsanto,
Shell,
and
USX.
The
hazardous
waste
disposal
firms
that
own
and
operate
Class
I
wells
(
SIC
code
4953)
are
believed
to
exceed
the
$
3.5
million
revenue
standard.

Class
II
Oil
and
gas
extraction
firms
fall
into
three
SIC
categories:

°
SIC
code
1311
(
crude
petroleum
and
natural
gas);

°
SIC
code
1321
(
natural
gas
liquids);
and
°
SIC
code
1381
(
drilling
oil
and
gas
wells).

All
of
these
categories
have
small
business
size
standards
of
500
employees.
According
to
Dun
and
Bradstreet
Market
Analysis
Profile,
more
than
90
percent
of
the
firms
in
these
SIC
codes
are
small
businesses,
using
the
500­
employee
standard.
Even
though
many
of
the
operable
Class
II
injection
wells
are
owned
and
operated
by
large
businesses,
industry
observers
believe
that
as
many
as
half
of
the
Class
II
wells
are
owned
and
operated
by
firms
that
are
well
below
the
500­
employee
size
standard.

Section
1421
of
the
SDWA
states
that
regulation
of
Class
II
wells
must
be
kept
to
a
minimum,
while
at
the
same
time
assuring
that
USDWs
will
not
be
endangered.
Recognizing
this
intent,
EPA
has
minimized
reporting
requirements
for
Class
II
wells
in
the
following
ways.
First,
while
operators
of
Class
I
and
Class
III
wells
report
injection
fluid
characteristics
quarterly,
Class
II
operators
report
that
information
annually.
Second,
Class
I
monitoring
requirements
include
the
installation
and
use
of
continuous
recording
devices
to
monitor
injection
pressure,
flow
rate,
volume,
and
annulus
pressure
[
40
CFR
146.13].
In
contrast,
Class
II
operators
are
only
required
to
observe
injection
pressure,
flow
rate,
and
cumulative
volume
and
to
record
these
measurements
at
least
monthly
[
40
CFR
146.23].

The
UIC
regulations
[
40
CFR
146.14,
146.24,
146.34]
define
the
information
the
UIC
Program
Director
must
consider
in
authorizing
Class
I,
II,
and
III
wells,
respectively.
Less
information
is
required
of
Class
II
wells
than
other
types
of
wells.
For
permitting
of
Class
I
and
Class
III
wells,
maps
and
cross
sections
detailing
geologic
structure
may
be
required,
whereas
Class
II
well
operators
must
provide
only
a
description
of
geologic
conditions.
Finally,
while
the
permitting
authority
may
require
Class
I
operators
to
provide
detailed
construction
procedures,
including
a
cementing
program;
logging
procedures;
deviation
checks;
and
a
drilling,
testing,
and
coring
program,
Class
II
well
operators
need
not
submit
this
information.

EPA
has
also
recognized
the
needs
of
operators
of
Class
II
wells
in
other
ways.
For
example,
oil
and
gas
wells
are
often
temporarily
abandoned,
especially
by
small
businesses
that
operate
at
marginal
production
rates.
To
accommodate
this
situation,
the
regulations
specify
that
cessation
of
operation
does
not
require
plugging
(
and
associated
information
collection)
until
two
years
have
elapsed.

Class
III
Operators
of
this
class
of
wells
fall
into
the
following
categories:

°
SIC
Major
Group
10
(
metal
mining)
and
°
SIC
Major
Group
14
(
mining
and
quarrying
of
non­
metallic
minerals).

The
applicable
size
standard
for
both
groups
is
500
or
fewer
employees.
According
to
the
preamble
to
the
UIC
regulations
of
1980
(
45
FR
42472),
the
operators
of
these
wells
are
large,
diversified
corporations,
well
above
the
size
standard
of
500
employees.
There
is
no
reason
to
believe
that
there
has
been
any
material
change
in
the
size
of
the
firms
since
that
analysis
was
done.
Information
Collection
Request
29
Class
V
EPA
estimates
that
the
majority
of
facilities
affected
by
the
Class
V
rule
will
be
small
businesses.
To
reduce
the
impact
of
the
rule
on
small
entities,
EPA
has
attempted
to
keep
recordkeeping,
reporting,
and
other
administrative
requirements
to
a
minimum
in
order
to
provide
regulatory
relief
to
small
entities
while
protecting
drinking
water
supplies.
EPA
also
convened
a
Small
Business
Advocacy
Review
Panel,
as
required
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA),
to
explore
options
for
minimizing
economic
impacts
on
small
entities.

The
economic
analysis
prepared
for
the
final
rule
includes
a
complete,
final
Regulatory
Flexibility
Analysis
addressing
all
activities,
including
reporting
and
recordkeeping
activities,
required
of
small
entities.

The
monitoring
and
testing
requirements
for
permitted
facilities
are
fairly
minimal
compared
to
the
other
classes
of
wells.
Most
other
Class
V
facilities
do
not
have
collection
requirements
other
than
to
provide
inventory
information.

5(
d)
Collection
Schedule
EPA
developed
the
schedule
for
information
collection
and
reporting
to
minimize
the
amount
of
information
collected
while
ensuring
that
enough
information
is
given
for
appropriate
and
timely
oversight,
evaluation,
and
enforcement.
The
rationale
for
operator
and
state
reporting
frequencies
is
described
below.
A
complete
description
of
the
collection
requirements
can
be
found
in
Section
4.

5(
d)(
1)
Operator
Reporting
In
determining
the
reporting
schedule
for
each
class
of
wells,
EPA
considered
the
potential
for
each
class
to
contaminate
USDWs.
Operators
of
Class
I,
III,
and
some
Class
V
wells
must
report
monitoring
results
quarterly;
Class
II
operators
report
annually.
The
regular
reporting
of
these
data
is
essential
to
protecting
USDWs.

5(
d)(
2)
State
Reporting
In
response
to
the
President's
April
24,
1995
directive
to
reduce
regularly
scheduled
reporting
frequencies
by
one­
half,
except
in
cases
where
such
action
would
not
adequately
protect
the
environment,
in
FY
1996
EPA
reduced
the
frequency
of
certain
state
UIC
reporting.
EPA
has
also
discontinued
the
requirement
that
states
submit
the
grant
utilization
form
(
7520­
5).
Exhibit
5­
1
summarizes
the
revised
reporting
frequencies
for
the
7520
forms.
Exhibit
5­
1
Revised
State
Reporting
Frequencies
Number
Form
Old
Frequency
New
Frequency
7520­
1
Permit
Review
and
Issuance
Quarterly
Annual
7520­
2A
Compliance
Evaluation
Quarterly
Semi­
annual
7520­
2B
Compliance
Evaluation
for
Significant
Noncompliance
Quarterly
Semi­
annual
7520­
3
Mechanical
Integrity
Test/
Remedial
Actions
Quarterly
Annual
7520­
4
Quarterly
Exceptions
List
Quarterly
Quarterly
7520­
5
Summary
of
UIC
Grant
Utilization
Annual
Discontinued
7520­
16
Inventory
of
Injection
Wells
Annual
Annual
7520­
1
Permit
Review
and
Issuance
Permits
are
the
core
of
the
UIC
Program,
and
annual
permit
information
is
used
for
program
management
purposes.
The
Program
uses
permit
information
to
evaluate
events
that
delay
or
accelerate
the
permitting
process.
Delays
in
the
permitting
process
may
result
in
the
states'
inability
to
meet
program
objectives
and
prevent
states
from
meeting
schedules.
A
permitting
process
that
is
too
lengthy
could
have
a
detrimental
impact
on
industry.
Conversely,
favorable
developments
may
occur
that
enable
the
states
to
meet
time
schedules
and
goals
sooner
than
anticipated.
Both
occurrences
have
a
potential
for
shifts
in
workload
and
resource
distribution.

7520­
2A
Compliance
Evaluation;
7520­
2B
Significant
Non­
compliance
The
justification
for
semi­
annual
reporting
of
compliance
information
is
based
on
EPA
efforts
to
be
routinely
and
frequently
informed
of
violations
to
regulations
in
effect
under
Section
1421
of
the
SDWA.
EPA
must
be
kept
informed
in
order
to
(
a)
oversee
and
encourage
states'
actions
on
resolving
violations
or
enforcing
against
violators,
and
(
b)
to
take
direct
federal
action
where
appropriate
state
actions
have
not
occurred
in
a
timely
manner
or
have
not
been
successful.

EPA
would
be
unable
to
effectively
carry
out
the
Congressional
direction
for
federal
enforcement
on
violators
if
it
only
had
access
to
data
annually.
Prior
to
1987,
states
provided
EPA
with
the
above
information
on
an
annual
basis.
States
then
agreed
to
voluntarily
supply
the
data
on
a
quarterly
basis
when
it
became
obvious
that
EPA
Headquarters
could
not
direct
an
effective
federal
enforcement
program
using
data
received
only
once
a
year.
EPA
has
recently
determined
that
semi­
annual
reporting
of
this
information
is
sufficiently
frequent
to
track
compliance
information.
Information
Collection
Request
31
7520­
3
Inspections/
Mechanical
Integrity
Testing
Inspections
are
the
principal
method
of
identifying
instances
of
noncompliance.
Annual
inspection
information
is
used
to
monitor
states'
performance
on
inspections.
Inspections
have
resulted
in
criminal
indictment
and
imprisonment
of
well
owners.
Annual
inspection
information
assures
that
inspections
are
being
performed
on
a
continual
basis
throughout
the
year.

The
MIT
is
the
principal
method
used
to
determine
whether
a
well
is
environmentally
sound.
Annual
MIT
information
is
used
to
evaluate
the
MIT
program.
Operators
must
record
and
submit
information
on
the
types,
frequencies,
results,
and
remedial
actions
taken
on
a
series
of
MIT
tests.

7520­
4
Quarterly
Exceptions
List
EPA
needs
quarterly
information
on
SNCs
that
have
been
out
of
compliance
for
two
or
more
consecutive
quarters.
The
Agency
uses
this
information
to
determine
whether
timely
and
appropriate
actions
have
been
taken
by
primacy
authorities
and
to
track
enforcement
activities,
as
these
wells
pose
the
greatest
threat
to
USDWs.

7520­
16
Inventory
of
Injection
Wells
Annual
reporting
on
inventory
data,
as
required
by
40
CFR
144.8,
is
necessary
for
effective
oversight
of
the
UIC
Program.
Primacy
states,
Regions,
and
EPA
Headquarters
need
to
be
routinely
and
frequently
informed
of
changes
in
the
number
and
operating
characteristics
of
injection
wells
to
monitor
and
regulate
underground
injection
effectively
and
to
continue
protecting
USDWs
from
contamination.
7
Contractor
hours
are
not
included
in
the
operator
burden
estimates.

8
Several
state
primacy
agencies
and
EPA
regional
offices
solicited
operator
input
on
burden
hours
and
costs.
6.
Burden
and
Cost
of
the
Collection
This
section
contains
EPA's
estimates
of
respondent
burden
hours
and
costs
associated
with
UIC
paperwork
requirements,
and
federal
burden
hours
and
costs
for
reviewing
respondent
submissions.
Section
6(
a)
provides
estimates
of
burden
hours
for
all
respondent
types,
including
state
primacy
agencies.
Section
6(
b)
contains
estimates
of
respondent
costs
for
the
information
collection.
Section
6(
c)
summarizes
federal
burden
and
costs
as
users
of
respondent
data.
Section
6(
d)
describes
the
respondent
universe
and
the
total
burden
and
cost
of
this
collection
to
respondents.
Section
6(
e)
covers
aggregate
burden
hours
and
costs
for
all
respondents,
and
Section
6(
f)
explains
the
reasons
for
the
change
in
estimated
respondent
burden
hours
and
costs
from
the
1998
UIC
Program
ICR.
The
burden
statement
for
this
information
collection
is
in
Section
6(
g).

6(
a)
Respondent
Burden
EPA
has
calculated
respondent
burden
hours
for
each
information
collection,
reporting,
and
recordkeeping
activity
required
of
well
operators
and
state
primacy
agencies.
Because
required
data
items
vary
by
well
class,
separate
operator
and
state
burden
estimates
have
been
prepared
for
each
class.
Exhibits
6­
1A
through
6­
6
contain
detailed
estimates
of
the
number
of
respondents
and
unit
burden
hours
for
required
paperwork­
related
activities.

EPA
recognizes
that
many
UIC
information
collection
activities
are
performed
by
contractors.
The
operator
unit
burdens
reported
in
this
section
represent
a
composite
of
operator
time
to
both
perform
an
information
collection
activity,
and
to
supervise
a
contractor
when
the
contractor
performs
the
activity.
7
The
mix
of
operator
versus
contractor
labor
varies
by
activity
and
by
well
class.
Contractor
costs
are
included
in
the
estimates
of
operator
unit
costs.

Operator
burden
hours
are
derived
from
estimates
provided
by
UIC
Program
officers
at
EPA
Headquarters,
staff
in
EPA
regional
offices,
and
selected
operators
[
See
Section
3(
c)].
8
Estimates
of
the
number
of
respondents
are
based
upon
the
1995
injection
well
inventory
or
projections
based
on
data
from
key
UIC
states.
The
following
sections
provide
additional
information
on
the
burden
estimates
in
the
exhibits.

6(
a)(
1)
Burden
Associated
with
Class
I
Wells
EPA's
estimate
of
the
annual
paperwork
burden
on
operators
for
permitting,
monitoring
and
testing,
reporting
and
recordkeeping,
and
closing
their
facilities
and
state
burden
for
administering
Class
I
hazardous
and
Class
I
nonhazardous
programs
are
presented
in
Exhibits
6­
1A
and
Exhibit
6­
1B,
respectively.
Legal,
managerial,
technical,
and
clerical
staff
hours
are
shown;
Column
A
presents
the
total
unit
burden
for
each
activity.
Information
Collection
Request
33
Class
I
facility
operators
rely
on
contractors
to
assist
them
with
most
information
collection
activities,
including
initial/
start­
up
activities
(
e.
g.,
permit
applications,
completion
reports,
and
no­
migration
petitions);
monitoring
and
testing
(
e.
g.,
ambient
monitoring,
pressure
fall­
off
tests,
and
MITs);
closure­
related
reporting;
and
other
paperwork
activities
(
e.
g.,
permit
and
petition
modifications).
The
operator
burdens
presented
in
Column
A
of
Exhibits
6­
1A
and
6­
1B
largely
reflect
the
time
to
provide
contractor
oversight
and
furnish
information
to
contractors.
The
costs
associated
with
contractor
labor
and
other
contractor
services
are
presented
in
Column
C
of
Exhibits
6­
1A
and
6­
1B.

EPA
estimates
that
70
percent
of
the
new
Class
I
permits
issued
will
be
for
newly
constructed
wells
at
existing
facilities,
and
that
much
of
the
information
these
applicants
are
required
to
submit
is
likely
to
have
been
developed
in
connection
with
permitting
other
wells
and,
therefore,
already
exists
for
the
facility.
EPA
assumes
the
remaining
30
percent
of
permits
will
be
issued
for
wells
at
new
facilities,
and
the
burden
associated
with
applying
for
a
permit
will
be
greater.
Thus,
the
unit
burdens
presented
in
this
ICR
are
a
composite
of
the
burdens
for
permitting
new
wells
at
both
new
and
existing
facilities.

EPA
assumes
that
some
activities
required
of
Class
I
permit
applicants
are
customary
business
practices.
The
burden
presented
in
this
ICR
is
the
incremental
time
and
cost
for
presenting
the
information
in
a
format
acceptable
to
permitting
authorities
and
for
using
EPAapproved
tests.


Knowledge
of
subsurface
geology
is
necessary
to
site
a
well
and
locate
a
subsurface
zone
suitable
for
injection.
EPA
assumes
that
50
percent
of
the
geological
characterization
required
of
permit
applicants
is
customary
business
practice.
Most
of
the
incremental
ICR
burden
is
attributable
to
the
requirement
for
submitting
detailed
maps
of
local
geology.


Operators
would
customarily
develop
and
conduct
formation
testing
and
stimulation
programs
for
the
same
reasons
they
would
develop
geological
data.
EPA
estimates
that
50
percent
of
the
required
program
development
and
testing
is
customary
business
practice.


Operators
would
probably
develop
and
retain
contingency
plans
to
reduce
potential
liability
should
a
well
failure
occur,
and
develop
closure
plans
to
reduce
potential
liability
when
they
close
their
facility.
EPA
assumes
that
25
percent
of
the
burden
to
develop
these
plans
is
customary
business
practice.


Facility
engineers
would
normally
prepare
construction
schematics
and
operating
data
during
the
planning
and
design
of
an
injection
facility;
EPA
estimates
that
75
percent
of
the
burden
associated
with
compiling
this
data
is
customary
business
practice.

As
part
of
their
overall
industrial
process,
operators
would
normally
develop
injectate
composition
data
and
test
the
compatibility
of
the
waste
stream
with
well
materials.
EPA
assumes
that
50
percent
of
the
time
and
cost
to
develop
a
waste
analysis
plan
and
to
conduct
waste
compatibility
testing
is
customary
business
practice.


During
construction,
operators
would
probably
conduct
deviation
checks
and
other
logs
to
verify
that
drilling
is
progressing
within
expected
parameters.
EPA
estimates
that
50
percent
of
the
requirement
to
conduct
deviation
checks
and
other
logs
and
tests
is
customary
business
practice.


Operators
would
routinely
observe
injection
pressure,
flow
rate,
volume,
and
temperature,
and
analyze
the
chemical
composition
of
their
wastes
to
verify
the
proper
operation
of
their
wells,
EPA
assumes
that
nearly
all
of
the
burden
for
continuous
monitoring
and
75
percent
of
the
burden
to
perform
chemical
analyses
of
their
injectate
is
customary
business
practice.

(
6)(
a)(
1)(
A)
Class
I
Hazardous
Facilities
Operator
activities
associated
with
Class
I
hazardous
facilities
include:
permitting
and
start­
up
related
reporting;
permit
renewals
and
modifications
of
permits
or
petitions;
monitoring;
reporting
and
recordkeeping;
and
closure­
related
paperwork.

Initial
Permitting/
Start­
up
EPA
estimates
that,
of
the
new
Class
I
hazardous
waste
facility
operating
permits
issued
each
year,
most
will
be
for
new
wells
at
existing
facilities.
Thus,
in
some
cases,
operators
will
adapt
existing
materials
for
their
permit
applications.
Note
that
for
permitting
activities,
the
unit
burdens
are
expressed
on
a
per­
application
basis.

EPA
estimates
that
the
operator
burden
associated
with
applying
for
Class
I
hazardous
waste
injection
permits
will
be
394
hours
per
permit.
(
This
unit
burden
incorporates
the
above
assumptions
about
customary
business
practices.)
Exhibit
6­
1A
contains
burden
estimates
for
specific
components
of
the
permit
application.
EPA's
calculation
of
operator
burden
and
contractor
labor
costs
above
customary
business
practices
is
based
on
the
following
assumptions:


Operators,
rather
than
contractors,
will
gather
the
facility
description
and
location
information
necessary
to
complete
the
permit
application
form;


AoR
studies
in
support
of
the
application
will
encompass
portions
of
previous
AoR
studies
at
the
facility;


The
burden
for
developing
a
corrective
action
plan
assumes
that
10
percent
of
operators
will
be
required
to
revise
their
corrective
action
plan
at
the
request
of
the
permitting
authority;
and
Information
Collection
Request
35

The
requirement
that
operators
of
active
hazardous
waste
facilities
gather
and
submit
site
investigation
information
[
40
CFR
144.31(
g)(
3)]
duplicates
RCRA
requirements
and
is
not
included
in
this
burden
estimate.

EPA
estimates
that
the
burden
on
Class
I
hazardous
facility
operators
associated
with
preparing
and
submitting
completion
reports
will
be
49
hours
per
facility.
The
burden
to
perform
specific
activities
related
to
completion
reports
is
presented
in
Exhibit
6­
1A.
As
with
permitting
activities,
EPA
anticipates
that
much
of
the
testing
reported
in
the
completion
report
would
normally
be
performed
in
the
course
of
business.

In
addition
to
submitting
permit
applications,
operators
of
newly
constructed
hazardous
Class
I
wells
will
submit
no­
migration
petitions
to
the
EPA
Regional
Administrator.
EPA
assumes
that
no­
migration
petition
requirements
impose
an
additional
569
burden
hours
on
each
operator.
EPA
anticipates
that
operators
already
have
compiled
much
of
the
extensive
data
required
to
support
a
no­
migration
petition
in
the
process
of
permitting
and
preparing
petitions
for
existing
wells
at
their
facilities,
during
the
permit
application
process,
or
as
a
customary
business
practice.

Permit
Renewals
and
Modifications
Class
I
operating
permits
are
valid
for
up
to
ten
years,
after
which,
operators
must
apply
to
renew
their
permits.
Additionally,
from
time
to
time,
operators
of
Class
I
hazardous
facilities
may
need
to
modify
their
permits
or
their
no­
migration
petitions.
Paperwork
submittals
include:
permit
renewals,
permit
modifications,
and
petition
modifications.

EPA
anticipates
that
the
burden
associated
with
renewing
permits
for
a
Class
I
hazardous
facility
will
be
71.5
hours
per
renewal.
Requirements
for
permit
renewals
vary
among
states
and
regions,
ranging
from
submitting
a
letter
of
intent
to
continue
operating
the
facility
to
an
application
similar
in
scope
to
one
for
a
new
permit.
EPA
assumes
that,
for
renewal
applications,
Class
I
hazardous
facility
operators
will
be
required
to
submit
facility
identification
information
and
those
attachments
that
have
changed
or
been
updated
since
their
last
application,
such
as
the
AoR,
corrective
action
plan,
closure
plan,
waste
identification
information,
and
financial
responsibility
information.
EPA
assumes
that
Class
I
hazardous
facility
operators
will
not
be
required
to
submit
no­
migration
petitions
in
support
of
permit
renewal
applications.

EPA
estimates
the
operator
burden
for
overseeing
contractor
activities
associated
with
preparing
and
submitting
a
request
for
a
permit
modification
is
10
hours
per
facility,
and
the
burden
associated
with
modifying
a
no­
migration
petition
is
195
hours.
Monitoring/
Testing
As
indicated
above,
EPA
assumes
that
operators
of
Class
I
hazardous
facilities
would
routinely
observe
injection
pressure,
flow
rate,
volume,
and
temperature
in
the
normal
course
of
business.
EPA
estimates
an
incremental
annual
burden
of
5.7
hours
per
facility
beyond
customary
business
practice.

Class
I
hazardous
facility
operators
must
also
monitor
the
chemical
composition
of
their
wastes
according
to
the
waste
analysis
plan
submitted
with
their
permit
application.
As
with
monitoring
of
injection
pressure,
flow
rate,
and
volume,
EPA
assumes
that
operators
would
perform
some
chemical
monitoring
during
the
course
of
business.
EPA
estimates
the
additional
annual
burden
for
chemical
monitoring
is
38
hours
per
facility
per
quarter
for
operators
to
collect
samples
and
send
them
to
commercial
laboratories
for
analysis.
In
addition,
EPA
assumes
that,
for
various
reasons,
permitting
authorities
will
require
10
percent
of
facilities
to
conduct
additional
monitoring
under
40
CFR
146.68(
a)(
3),
and
that
the
total
burden
will
be
7.6
hours
per
facility
per
quarter.
EPA
assumes
that
all
monitoring
will
be
conducted
quarterly.

Class
I
hazardous
facility
operators
must
conduct
a
pressure
fall­
off
test
every
year;
EPA
estimates
that
the
annual
burden
associated
with
this
requirement
will
be
9
hours
per
facility.
EPA
estimates
that
the
total
burden
associated
with
required
annual
ambient
monitoring
at
Class
I
hazardous
facilities
will
be
2.3
hours
per
facility.

The
burden
associated
conducting
annual
MITs
(
i.
e.,
conducting
a
casing
pressure
test
and
radioactive
tracer
survey),
and
five­
year
MITs,
which
also
include
temperature,
noise,
or
other
logs
to
check
for
movement
along
the
borehole
is
estimated
to
be
38
hours
per
facility.

Finally,
operators
must
conduct
casing
inspection
logs
when
their
wells
are
worked
over;
EPA
estimates
the
total
annual
burden
will
be
19
hours
per
log.

Reporting
and
Recordkeeping
Operators
of
Class
I
hazardous
facilities
will
spend
104
hours
per
facility
reporting
the
results
of
required
monitoring
and
testing
each
year:
this
includes
25
hours
per
report
for
quarterly
monitoring
reports,
and
4
hours
to
report
on
the
results
of
MITs.
In
addition,
EPA
assumes
that
5
percent
of
operators
will
spend
3
to
6
hours
annually
submitting
occasional
reports
(
e.
g.,
on
changes
to
the
facility;
planned
workovers;
noncompliance
or
anticipated
noncompliance;
or
events
triggering
alarms
or
shutdown
devices).
Operators
will
also
spend
one
hour
submitting
revised
plugging
and
abandonment
cost
estimates.

EPA
estimates
the
annual
recordkeeping
burden
for
Class
I
hazardous
facilities
to
be
5
hours.
Operators
must
maintain
monitoring
information,
calibration
and
maintenance
records,
required
reports,
application
data,
and
monitoring
results
for
three
years;
and
keep
their
most
recent
plugging
and
abandonment
cost
estimate
for
one
year.
Information
Collection
Request
37
Closure
EPA
anticipates
that
one
Class
I
hazardous
well
will
close
during
each
year
of
the
life
of
this
ICR,
and
the
total
annual
burden
associated
with
closure
is
72
hours.
This
includes
2
hours
to
notify
the
Regional
Administrator
prior
to
closing,
6
hours
to
perform
pressure
fall­
off
tests,
20
hours
for
MITs,
and
40
hours
for
a
closure
report.
EPA
assumes
that
the
operator
will
not
revise
the
closure
plan
or
the
post­
closure
care
plan.
The
operator
will
also
spend
4.5
hours
on
thirdparty
notification
activities,
such
as
notifying
state
or
local
zoning
or
drilling
authorities
and
the
Regional
Administrator
following
closure.

6(
a)(
1)(
B)
Class
I
Nonhazardous
Facilities
Paperwork
requirements
for
operators
of
Class
I
nonhazardous
facilities
include
permitting
and
start­
up
related
reporting,
permit
renewals
and
modifications,
monitoring
and
testing,
reporting
and
recordkeeping,
and
closure­
related
paperwork
activities.

Initial
Permitting/
Start­
up
As
was
the
case
for
Class
I
hazardous
facilities,
EPA
estimates
that
the
majority
of
the
new
nonhazardous
waste
injection
permits
issued
each
year
will
be
for
new
wells
at
existing
facilities.
Unit
burdens
are
reported
on
a
per­
application
basis.

Requirements
associated
with
permit
applications
add
252
hours
to
the
customary
business
activities
of
Class
I
nonhazardous
facility
operators.
Column
A
of
Exhibit
6­
1B
presents
EPA's
estimates
of
burdens
for
specific
components
of
a
permit
application.
Class
I
nonhazardous
waste
permit
applicants
must
submit
much
of
the
same
information
as
operators
of
hazardous
facilities.
EPA
assumes
that
the
burden
on
nonhazardous
facilities
is
the
same
as
that
for
Class
I
hazardous
waste
facilities,
with
the
exception
of
the
following:


Class
I
nonhazardous
facility
operators
will
study
a
smaller
AoR.
Consequently,
the
burden
for
the
AoR
study
and
for
developing
a
corrective
action
plan
for
wells
in
the
AoR
will
be
lower
for
these
operators.


Development
of
injectate
testing
programs
will
be
less
burdensome
for
nonhazardous
facility
operators,
due
to
the
less
hazardous
nature
of
their
injectate.


Nonhazardous
facility
operators
are
not
required
to
develop
waste
analysis
plans
or
plans
to
reduce
the
quantity
or
toxicity
of
their
injectate;
nor
are
they
required
to
gather
and
submit
hazardous
waste
release
information.

EPA
estimates
that
the
unit
burden
on
Class
I
nonhazardous
facility
operators
for
preparing
and
submitting
completion
reports
is
47
hours.
This
unit
burden
varies
from
that
for
Class
I
hazardous
facilities,
as
Class
I
nonhazardous
facility
operators
are
not
required
to
submit
information
on
the
calculated
AoR.
Burden
estimates
for
specific
activities
associated
with
completion
of
new
wells
are
presented
in
Column
A
of
Exhibit
6­
1B.

Permit
Renewals/
Modifications
As
with
hazardous
facility
operators,
EPA
assumes
that
applicants
for
nonhazardous
injection
permit
renewals
will
submit
only
those
attachments
to
the
application
form
that
have
changed
since
the
original
application.
Each
renewal
application
will
take
an
estimated
21
hours.
EPA
estimates
the
operator
burden
associated
with
contractor
oversight
to
prepare
and
submit
a
request
for
a
permit
modification
to
be
8
hours.

Monitoring/
Testing
EPA
assumes
that
operator
staff
will
observe
and
record
injection
pressure,
flow
rate,
volume
and
temperature
and
sample
their
injectate
periodically
as
normal
business
activities;
however
to
comply
with
UIC
requirements,
operators
spend
more
time
on
these
activities
than
they
normally
would.
Class
I
nonhazardous
facility
operators
will
spend
38
hours
per
quarter
to
monitor
their
injectate;
5.7
hours
to
monitor
injection
pressure,
flow
rate,
and
volume;
1.9
hours
to
conduct
ambient
monitoring;
and
7.6
hours
to
conduct
an
annual
pressure
fall­
off
test.
In
addition,
approximately
32
operators
will
spend
38
hours
to
demonstrate
mechanical
integrity
(
i.
e.,
five­
year
MIT).

Reporting
and
Recordkeeping
Operators
will
spend
16
hours
per
facility
reporting
quarterly
on
the
chemical
and
physical
characteristics
of
injectate,
flow
rate,
and
volume.
Class
I
nonhazardous
facility
operators
will
spend
25
hours
per
facility
to
report
on
the
results
of
ambient
monitoring
and
the
pressure
fall­
off
test.

EPA
assumes
that
Class
I
nonhazardous
facility
operators
will
spend
one
hour
each
year
to
update
and
submit
plugging
and
abandonment
cost
estimates.
EPA
also
assumes
that
operators
will
spend
4
to
6
hours
submitting
additional
reports
(
e.
g.,
of
changes
to
the
facility;
planned
workovers;
noncompliance
or
anticipated
noncompliance;
or
events
triggering
an
alarm
or
shutdown).

EPA
estimates
the
annual
recordkeeping
burden
on
Class
I
nonhazardous
facilities
to
maintain
monitoring
information,
calibration
and
maintenance
records,
required
reports,
application
data,
and
monitoring
results
for
three
years
will
be
4
hours
per
facility.

Closure
EPA
estimates
the
annual
burden
on
operators
of
Class
I
nonhazardous
facilities
associated
with
closure
is
2
hours,
for
notifying
the
Director.

(
6)(
a)(
1)(
C)
Burden
on
Primacy
Agencies
Associated
with
Class
I
Wells
Information
Collection
Request
39
State
primacy
agencies'
burden
as
users
of
data
associated
with
implementing
Class
I
programs
arise
from
program
oversight,
reviewing
and
responding
to
permit
applications
and
completion
reports,
monitoring
and
testing
data,
and
closure
reports
submitted
by
operators
within
their
states.
State
burden
associated
with
oversight
of
Class
I
programs
is
presented
in
Column
A
of
Exhibits
6­
1A
and
6­
1B.

EPA
estimates
that
states
will
spend
from
20
to
62
hours
per
permit
application
reviewing
applications
for
hazardous
or
nonhazardous
Class
I
wells
(
depending
on
whether
the
permit
is
issued
or
denied),
and
30
hours
reviewing
requests
for
permit
modifications
or
renewals.
EPA
regional
offices
review
all
no­
migration
petitions
and
petition
modification
requests
submitted
by
operators
of
Class
I
hazardous
waste
injection
facilities;
however,
state
primacy
agencies
assist
the
regions
with
this
review.
States
spend
28
hours
per
no­
migration
petition
application
and
10
hours
per
petition
modification
request
on
this
assistance.

State
primacy
agencies
spend
from
2
to
8
hours
per
report
reviewing
monitoring
and
MIT
data
or
occasional
reports
submitted
by
operators
(
details
are
presented
in
Exhibits
6­
1A
and
6­
1B).
States
spend
one
hour
reviewing
plugging
and
abandonment
reports
submitted
by
operators
of
Class
I
nonhazardous
waste
facilities,
and
11
hours
reviewing
reports
and
testing
results
associated
with
closure
of
hazardous
waste
facilities.

6(
a)(
2)
Burden
Associated
with
Class
II
Wells
EPA's
estimate
of
the
annual
paperwork
burden
on
operators
for
permitting,
monitoring
and
testing,
reporting
and
recordkeeping,
and
closing
wells,
and
state
burden
for
administering
Class
II
programs,
are
presented
in
Exhibit
6­
2.
Legal,
managerial,
technical,
and
clerical
staff
hours
are
shown;
Column
A
presents
the
total
unit
burden
for
each
activity.

(
6)(
a)(
2)(
A)
Class
II
Operators
Initial
Permitting/
Start­
up
EPA
anticipates
that
28
percent
of
Class
II
permit
applications
will
be
for
area
permits
and
73
percent
will
be
for
individual
permits.
On
average,
each
area
permit
application
will
cover
3.1
wells.
EPA
estimates
that
85
percent
of
the
applications
will
be
approved.
EPA
or
state
primacy
agencies
will
deny
applications
that
do
not
meet
construction
standards
and
others
will
be
withdrawn
by
owners.
9
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).
The
average
burden
for
preparing
permit
application
forms
and
the
supporting
documentation
is
approximately
32
hours
per
application.
The
time
that
a
particular
operator
will
spend
on
a
permit
application
will
likely
vary
from
approximately
6
hours
to
more
than
50
hours,
depending
on
the
specific
state
submission
requirements,
the
operator's
level
of
experience,
whether
the
application
is
for
an
individual
or
an
area
permit,
the
use
of
contractors,
and
other
factors.
The
following
paragraphs
summarize
the
burdens
for
various
components
of
a
Class
II
permit
application.
EPA
estimates
that
operators
will
spend
2.5
hours
per
applicant
to
read
the
application
directions
and
fill
out
the
permit
application
form.
With
respect
to
the
supporting
documentation,
EPA
assumes
that
operators
would
normally
prepare
a
well
schematic
and
some
geological,
hydrogeological,
and
operating
data
in
the
course
of
business,
and/
or
utilize
existing
data
for
the
project.
For
area
permits,
the
operator
generally
submits
supporting
data
for
a
representative
well.
Exhibit
6­
2
provides
estimates
of
the
time
beyond
customary
business
practice
required
to
prepare
the
attachments
to
a
Class
II
permit
application.
EPA
estimates
that
permit
applicants
will
spend
an
average
of:


9.5
hours
to
prepare
geological
data
on
injection
and
confining
zones;


6
hours
to
prepare
plugging
and
abandonment
plans;


2.5
hours
to
determine
the
name
and
depth
to
the
bottom
of
USDWs;


3
hours
to
prepare
schematics
of
the
wells;


2
hours
to
prepare
proposed
operating
data;
and

2
hours
to
prepare
financial
responsibility
information.

Based
on
previous
studies
of
state
AoR
practices
and
requirements,
EPA
projects
that
state
primacy
agencies
and
EPA
Regions
will
determine
that
a
complete
AoR
is
not
necessary
for
approximately
60
percent
of
Class
II
permit
applicants.
9
A
complete
AoR
study
may
not
be
performed
because
the:


AoR
is
entirely
overlapped
by
the
AoRs
of
wells
previously
studied.


State
primacy
agency
has
cross­
referenced
AoR
studies,
ensuring
AoR
coverage.


Operator
has
been
granted
a
state
variance
based
on
factors
relating
to
geologic
setting,
and/
or
well
conditions.


Well
is
located
in
a
unitized
project,
and
many
of
the
elements
of
AoR
studies
were
previously
performed
during
unitization.
Information
Collection
Request
41
10
EPA
estimates
that
some
operators
will
utilize
contract
AoR
services.
The
unit
burden
for
operators
assumes
that
operators
will
perform
about
67
percent
of
the
AoR
burden
themselves
and
contract
out
for
the
remaining
33
percent.

11
Alabama,
Alaska,
California,
Colorado,
Illinois,
Indiana,
Kansas,
Louisiana,
Missouri,
Nebraska,
New
Mexico,
Ohio,
Oklahoma,
and
Utah
perform
some
or
all
of
the
tasks
involved
in
an
AoR
study.
Previous
EPA
studies
also
have
found
that
many
state
primacy
agencies
perform
all
or
most
of
the
tasks
involved
in
the
AoR
study.
In
these
cases,
the
operator
typically
submits
only
a
map
of
the
AoR
and
a
list
of
wells
in
the
AoR.
EPA
projects
that
approximately
19
percent
of
applicants
will
submit
an
AoR
map
and
an
AoR
study
as
part
of
the
permit
application.
Each
AoR
map
and
study
will
require
an
average
of
5
hours
of
operator
time.
10
Another
22
percent
of
applicants
will
submit
an
AoR
map
and
a
listing
of
the
wells
in
the
AoR,
and
the
state
primacy
agency
will
perform
most
or
all
of
the
tasks
involved
in
the
AoR
study.
11
The
operator
time
to
prepare
the
map
and
listing
of
wells
is
about
one
hour.

Based
on
the
historical
incidence
of
corrective
action,
EPA
estimates
that
90
percent
of
permit
applicants
will
submit
brief
corrective
action
plans
demonstrating
that
corrective
action
is
not
necessary
to
address
potential
conduits
to
USDWs
in
the
AoR.
Each
of
these
plans
will
require
one
hour
to
prepare.
The
remaining
10
percent
of
applicants
will
submit
more
complex
corrective
action
plans
to
address
specific
problems
identified
by
the
AoR
study.
Each
comprehensive
corrective
action
plan
will
take
approximately
25
hours
to
prepare.
Thus,
the
average
time
to
prepare
a
corrective
action
plan
is
3.4
hours.
EPA
regional
or
state
primacy
staff
will
require
20
percent
of
applicants
to
revise
their
complex
corrective
action
plans.
Each
revised
plan
will
take
about
11.3
hours
to
prepare.

Unless
exempted
by
the
Director,
operators
in
DI
programs
are
required
to
submit
a
list
of
landowners
within
¼
mile
of
the
facility
boundary.
EPA
estimates
that
these
applicants
will
each
take
1.2
hours
to
research
property
ownership
records
and
prepare
the
list.
This
unit
burden
assumes
that
operators
will
supply
about
30
percent
of
the
effort,
and
the
remaining
70
percent
will
be
performed
by
contractors.

Prior
to
obtaining
approval
to
begin
injection,
operators
must
submit
completion
reports
for
each
new
Class
II
well.
With
the
completion
report,
operators
must
submit
results
of
MITs
and
any
well
logs
and
tests
required
by
the
Director.
Operators
will
take
approximately
4
hours
per
well
to
fill
out
the
completion
form
and
gather
the
supporting
documentation.
The
MIT
will
require
approximately
1.7
hours
of
operator
time,
given
current
MIT
practices
for
various
completion
types.

Most
operators
will
submit
logs
for
offset
wells
in
their
projects.
EPA
projects
that
Directors
will
require
some
permit
applicants
to
perform
and
report
on
new
well
logs
and
tests,
12
This
estimate
is
based
on
operator
data
from
Texas,
Oklahoma,
and
Kansas.
such
as
cement
bond,
temperature,
or
density
logs.
Directors
are
more
likely
to
require
additional
logs
and
tests
for
II­
D
wells
than
for
II­
R
wells.
EPA
assumes
that
operators
will
perform
additional
logs
and
tests
for
50
percent
of
new
II­
D
wells
and
5
percent
of
new
II­
R
wells.
Each
of
the
logs
and
tests
will
take
approximately
2.4
hours
of
operator
time,
primarily
to
supervise
contractors.

Permit
Reviews/
Modifications
Class
II
permits
are
valid
"
up
to
the
operating
life
of
the
facility"
[
40
CFR
144.36].
While
the
regulations
do
not
require
permit
renewals,
most
permits
are
reviewed
every
five
years.
These
reviews
may
be
formal
compliance
reviews
or
informal
reviews,
usually
conducted
in
conjunction
with
reviews
of
MIT
results.
Operators
may
be
required
to
respond
to
any
issues
raised
during
the
permit
review.
For
purposes
of
calculating
operator
burden,
EPA
assumes
that
each
operator
will
take
3
hours
to
respond
to
issues
raised
during
the
review.

Operators
occasionally
submit
requests
for
permit
modifications
in
response
to
changes
in
well
ownership
or
injection
practices,
to
add
wells
to
existing
area
permits,
and
for
other
reasons.
EPA
expects
that
the
average
time
to
prepare
each
request
is
4
hours.

Monitoring/
Testing
For
purposes
of
estimating
the
number
of
respondents
for
monitoring
and
testing,
EPA
assumes
that
the
typical
Class
II
operator
has
approximately
10
wells.
12
An
operator
with
wells
in
multiple
states
is
treated
as
separate
operators,
since
the
operator
would
have
to
submit
separate
reports
to
each
state
primacy
agency
or
EPA
regional
office.

In
general,
all
operators
located
in
DI
programs
and
operators
of
commercial
II­
D
wells
in
primacy
states
are
required
to
submit
annual
injectate
analyses.
EPA
estimates
that
approximately
10
percent
of
Class
II
operators
submit
annual
injectate
analyses
each
year.
EPA
assumes
that
operators
submit
samples
for
approximately
20
percent
of
their
wells.
Each
operator
takes
2
hours
(
1
hour
per
well)
per
year
to
sample
and
analyze
their
injectate.
This
includes
the
time
for
operators
to
analyze
their
injectate
or,
in
some
cases,
send
it
to
a
commercial
laboratory
for
analysis.

Most
operators
are
required
to
observe
injection
pressure,
flow
rate,
and
cumulative
volume
weekly
for
II­
D
wells
and
monthly
for
II­
R
wells.
EPA
anticipates
that
operators,
especially
operators
of
II­
R
wells,
perform
periodic
observations
of
pressure,
flow
rate,
and
cumulative
volume
as
a
customary
business
practice.
Thus,
the
incremental
time
to
perform
these
observations
is
about
0.83
hours
per
operator
(
0.08
hours,
or
5
minutes,
per
well)
per
month.
This
represents
the
time
to
record
the
data
on
a
field
report.
Information
Collection
Request
43
EPA
assumes
that
20
percent
of
operators
will
perform
MITs
on
their
wells
each
year.
Each
operator
will
spend
17.0
hours
(
1.7
hours
per
well)
performing
MITs.
The
unit
burden
assumes
that
contractors
perform
many
of
the
tasks
involved
in
an
MIT.

Reporting
and
Recordkeeping
Each
year,
Class
II
operators
spend
about
5
hours
to
prepare
annual
monitoring
reports.
These
reports
include
summaries
of
monthly
or
weekly
observations
of
flow,
pressure,
and
cumulative
volume.
In
addition,
20
percent
of
operators
will
spend
10
hours
per
operator
to
prepare
reports
on
MITs
performed.

From
time
to
time,
operators
submit
other
reports
or
notify
UIC
staff
of
various
events.
These
include
notifications
of
planned
changes
to
the
injection
facility,
permit
transfers,
progress
in
achieving
compliance
milestones,
and
noncompliance
or
malfunctions
which
may
endanger
a
USDW.
EPA
estimates
that
approximately
6
percent
of
operators
submit
one
of
these
occasional
reports
each
year.
Operators
will
spend
an
average
of
5
hours
to
prepare
each
report.

Operators
of
rule­
authorized
wells
in
DI
states
may
be
required
to
gather
and
submit
groundwater
monitoring
data,
analyses
of
injected
fluids,
a
description
of
geologic
strata,
and
other
items
as
requested.
EPA
projects
that
each
request
will
take
30
hours
to
prepare.
In
addition,
operators
of
rule­
authorized
wells
will
spend
one
hour
per
operator
to
notify
the
Region
prior
to
performing
MITs.

Operators
will
spend
about
4
hours
per
operator
to
maintain
records
on
permitting,
monitoring,
and
testing.

Closure
EPA
does
not
have
complete
data
on
the
number
of
Class
II
wells
that
are
plugged
and
abandoned
annually.
However,
based
on
recent
trends
in
the
overall
Class
II
inventory,
EPA
projects
that
approximately
6.5
percent
of
operators
will
plug
and
abandon
all
of
their
wells
each
year.
Each
operator
will
spend
about
3.0
hours
(
0.3
hours
per
well)
to
notify
UIC
officials
prior
to
abandoning
the
wells.

In
addition,
EPA
assumes
that
operators
in
DI
programs
which
elect
to
plug
their
wells
in
a
manner
different
from
the
one
specified
in
their
plugging
and
abandonment
plans
will
spend
4
hours
to
prepare
revised
plugging
and
abandonment
plans.
In
addition,
operators
which
plug
wells
in
DI
programs
will
spend
6
hours
to
prepare
and
submit
plugging
and
abandonment
reports.
Other
Activities
DI
programs
may
require
some
operators
of
wells
with
lifetime
permits
to
submit
revised
financial
responsibility
demonstrations.
EPA
estimates
that
10
percent
of
operators
in
DI
programs
will
each
take
2
hours
to
prepare
and
submit
revised
financial
data.

(
6)(
a)(
2)(
B)
Burden
on
Primacy
Agencies
Associated
with
Class
II
Wells
Class
II
primacy
agencies
review
and
respond
to
permit
applications
and
permit
reviews/
modifications,
and
monitoring
and
testing
data
submitted
by
operators
within
their
states.
State
burden
associated
with
each
activity
involved
in
the
oversight
of
Class
II
programs
is
presented
in
Column
A
of
Exhibit
6­
2.

EPA
estimates
that
states
will
spend
23.5
hours
per
permit
application
reviewing
Class
II
injection
well
applications.
Primacy
agency
staff
spend
one
hour
to
determine
whether
to
reissue,
modify,
or
revoke
each
permit
during
the
five­
year
review
process.
Primacy
agencies
spend
four
hours
reviewing
each
request
for
a
permit
modification
or
renewal.

State
primacy
agencies
spend
from
2
to
10
hours
per
report
reviewing
monitoring
and
MIT
data
or
occasional
reports
submitted
by
Class
II
operators
(
see
details
in
Exhibit
6­
2).

6(
a)(
3)
Burden
Associated
with
Class
III
Wells
Exhibit
6­
3
contains
EPA's
estimate
of
the
annual
paperwork
burden
on
operators
for
permitting,
monitoring
and
testing,
reporting
and
recordkeeping,
and
closing
their
facilities,
and
state
burden
for
administering
Class
III
programs.
Legal,
managerial,
technical,
and
clerical
staff
hours
are
shown;
Column
A
presents
the
total
unit
burden
for
each
activity.

(
6)(
a)(
3)(
A)
Class
III
Operators
Permitting/
Start­
up
A
Class
III
operator
will
spend
an
average
of
119
hours
to
prepare
a
new
permit
application
form
and
required
attachments.
Reading
the
directions
and
filling
out
the
application
form
account
for
11
hours
of
the
total.
Exhibit
6­
3
provides
estimates
of
the
operator
time,
in
addition
to
customary
business
practice,
required
to
prepare
each
component
of
the
permit
application.
EPA
estimates
that
permit
applicants
will
spend
an
average
of:


32
hours
to
prepare
AoR
maps
and
studies;


22
hours
to
prepare
maps
and
cross
sections
of
USDWs
within
the
AoR,
and
of
local
and
regional
geology;
Information
Collection
Request
45
13
Some
operators
will
be
required
by
the
state
primacy
agency
to
submit
a
new
permit
application,
but
the
burden
has
not
been
accounted
for
in
this
ICR.

16
hours
to
prepare
monitoring
plans;


9
hours
to
prepare
proposed
operating
data,
formation
testing
and
stimulation
programs,
and
injection
procedures;


8
hours
to
prepare
plugging
and
abandonment
plans;


5
hours
to
prepare
schematics
of
the
wells;
and

3.5
hours
to
demonstrate
financial
responsibility.

In
addition,
EPA
estimates
that,
when
requested
by
the
Director,
revised
corrective
action
plans
will
take
10.0
hours
each.
Two
applicants
in
DI
programs
will
spend
1.2
hours
each
to
gather
a
list
of
landowners
adjacent
to
the
facility.

Operators
completing
wells
must
perform
a
two­
part
MIT
and
submit
a
completion
form.
The
burden
associated
with
preparing
completion
reports
is
difficult
to
determine.
Operators
of
Class
III
facilities,
especially
uranium
mining
facilities,
typically
develop
their
projects
in
multiple
phases
under
the
same
area
permit.
EPA
estimates
that
at
least
21
Class
III
wells
will
be
constructed
at
salt
solution
and
brine
mining
facilities
each
year
and
an
unknown
number
of
wells
will
be
constructed
at
uranium
facilities.
In
addition,
EPA
estimates
that
Directors
will
require
operators
to
perform
and
submit
logs
and
tests
during
construction
for
three
of
the
wells.

Permit
Renewals,
Reviews,
and
Modifications
EPA
estimates
that
20
percent
of
operators
each
year
will
have
a
formal
or
informal
review
of
their
permits.
Each
operator
will
take
4
hours
to
respond
to
any
issues
raised
during
the
review.
13
In
addition,
Class
III
operators
will
take
an
average
of
28
hours
to
prepare
requests
for
permit
modifications.

Monitoring/
Testing
EPA
anticipates
that
operators
of
salt
solution
mining
facilities
will
submit
annual
analyses
of
their
injectate.
On
average,
each
operator
will
take
8
hours
per
year
to
sample
and
analyze
their
injectate
in­
house.

Operators
of
Class
III
facilities
will
monitor
injection
pressure,
flow
rate,
or
volume
of
injected
fluids
semi­
monthly,
or
meter
injected
and
produced
fluid
volumes
continuously.
EPA
expects
that
operators
perform
this
activity
periodically
as
a
customary
business
practice
to
ensure
efficient
operation
of
their
facilities,
and
that
the
incremental
collection
burden
is
approximately
14
Some
operators
may
be
allowed
to
submit
cementing
records
in
lieu
of
performing
temperature
or
noise
logs.
4.2
hours
per
operator
over
a
two­
week
period.
This
represents
the
time
needed
to
fill­
out
field
reports.

EPA
estimates
that
operators
of
approximately
9
salt
solution
mining
facilities
will
perform
two­
part
MITs
on
all
of
their
wells
each
year.
14
The
burden
is
estimated
to
be
108
hours
per
operator.

All
uranium
operators
monitor
water
quality
at
selected
monitoring
wells
completed
in
the
injection
zone
and
overlying
freshwater
aquifers.
Approximately
3
active
facilities
monitor
semimonthly
approximately
7
facilities
which
are
performing
aquifer
restoration
monitor
monthly.
EPA
estimates
that
the
typical
uranium
facility
has
about
110
monitoring
wells.
As
with
pressure,
flow,
and
volume
monitoring,
operators
will
perform
about
two­
thirds
of
this
monitoring
as
a
customary
business
practice
to
identify
potential
excursions
from
the
injection
zone.
EPA
assumes
that
UIC
requirements
increase
the
monitoring
burden
to
these
operators
by
about
30.5
hours
per
monitoring
period.

Reporting
and
Recordkeeping
Operators
of
Class
III
facilities
will
incur
a
burden
of
30
hours
per
facility
per
quarter
for
quarterly
reporting
on
monitoring
and
any
MITs
performed.
Finally,
about
10
percent
of
operators
will
spend
6
hours
per
year
on
occasional
reporting
activities.
EPA
estimates
that
each
Class
III
operator
spends
approximately
3.4
hours
on
recordkeeping
annually.

Closure
EPA
estimates
that
Class
III
operators
which
close
their
projects
will
take
2
hours
to
prepare
written
notifications
to
the
Director.

(
6)(
a)(
3)(
B)
Burden
on
Primacy
Agencies
Associated
with
Class
III
Wells
For
the
Class
III
Program,
primacy
agency
staff
review
and
respond
to
permit
applications,
permit
reviews/
modifications,
and
monitoring
and
testing
data
submitted
by
operators.
State
burden
associated
with
each
activity
involved
in
the
oversight
of
Class
III
programs
is
presented
in
Column
A
of
Exhibit
6­
3.

Depending
on
whether
the
permit
is
issued
or
denied,
EPA
estimates
that
states
will
spend
between
20
and
85
hours
reviewing
each
application
for
a
permit
to
inject
waste
into
a
Class
III
well.
Primacy
agency
staff
spend
4
hours
determining
whether
to
reissue,
modify,
or
revoke
each
permit
during
the
five­
year
review
process,
and
20
hours
reviewing
each
request
for
a
permit
modification
or
re­
issuance.
Class
III
primacy
agencies
spend
from
4
to
24
hours
per
report
Information
Collection
Request
47
reviewing
monitoring
and
MIT
data
or
occasional
reports
submitted
by
operators
(
see
details
in
Exhibit
6­
3).

6(
a)(
4)
Burden
Associated
with
Class
IV
and
Endangering
Class
V
Wells
Paperwork
burden
on
operators
of
Class
IV/
Endangering
Class
V
wells
and
on
states
for
administering
Class
IV/
Endangering
Class
V
programs
is
presented
Exhibit
6­
4.
Legal,
managerial,
technical,
and
clerical
staff
hours
are
shown;
Column
A
presents
the
total
unit
burden
for
each
activity.

(
6)(
a)(
4)(
A)
Class
IV
and
Endangering
Class
V
Operators
Class
IV
wells
and
Class
V
wells
that
are
found
to
be
endangering
USDWs
are
banned
from
injection,
and
owners
of
these
wells
are
required
to
close
them
and
submit
plugging
and
abandonment
reports
to
states
or
DI
programs.
EPA
estimates
that
the
burden
associated
with
this
one­
time
requirement
will
be
10
hours
per
well
(
See
Exhibit
6­
4).
Because
these
wells
are
banned,
there
are
no
permitting
or
monitoring
requirements.

(
6)(
a)(
4)(
B)
Burden
on
Primacy
Agencies
Associated
with
Class
IV
and
Endangering
Class
V
Wells
State
burden
associated
with
Class
IV
and
Endangering
Class
V
wells
involves
review
by
primacy
agency
staff
of
closure
plans
submitted
by
operators.
EPA
estimates
the
state
burden
to
be
one
hour
per
review.

6(
a)(
5)
Burden
Associated
with
Class
V
Wells
EPA's
estimate
of
the
annual
paperwork
burden
on
operators
and
states
associated
with
Class
V
wells
is
presented
in
Column
A
of
Exhibit
6­
5.

(
6)(
a)(
5)(
A)
Class
V
Operators
Activities
for
Class
V
well
operators
include
submitting
inventory
information
and
compliance
with
the
Class
V
Rule
by
owners
of
motor
vehicle
waste
disposal
wells
and
largecapacity
cesspools.

Inventory
Activities
Recent
efforts
by
the
Regions
and
state
primacy
agencies
to
address
the
potential
threats
to
USDWs
posed
by
Class
V
wells
will
likely
increase
compliance
with
the
inventory
requirement.
Each
Class
V
well
operator
will
take
one
hour
to
prepare
and
submit
inventory
information
to
the
appropriate
Regional
or
state
primacy
agency.
Activities
Required
Under
the
Class
V
Rule
Under
the
Class
V
Rule,
facilities
that
wish
to
continue
operating
motor
vehicle
waste
disposal
wells
must
seek
waivers
from
the
ban
on
existing
motor
vehicle
waste
disposal
wells
and
apply
for
permits.
As
a
condition
of
the
permit,
facilities
must
submit
all
monitoring
reports
to
the
UIC
Director.
Motor
vehicle
waste
disposal
wells
and
large­
capacity
cesspools
that
close
are
required
to
submit
pre­
closure
notifications.
Note
that
the
clearance
period
for
the
Class
V
ICR
(
EPA
ICR
no.
1874.02,
August
19,
1999)
expires
on
November
30,
2002,
two
months
into
Year
2
of
this
information
collection.
This
ICR
includes
the
Class
V
burden
estimated
to
be
incurred
between
December
2002
and
September
30,
2004.

Operators
of
Large­
Capacity
Cesspools
Operators
of
facilities
with
large­
capacity
cesspools
will
need
to
become
familiar
with
the
Class
V
requirements
and
prepare
and
submit
a
pre­
closure
notification
to
their
primacy
agency.
EPA
assumes
that
each
facility
will
require
a
total
of
4.5
hours
to
complete
these
activities.

Operators
of
Motor
Vehicle
Waste
Disposal
Wells
Owners
and
operators
of
facilities
with
motor
vehicle
waste
disposal
wells
must
notify
the
UIC
Program
Director
at
least
30
days
prior
to
well
closure.
Primacy
States
may
develop
their
own
pre­
closure
notification
requirements
or
use
the
Class
V
Well
Pre­
Closure
Notification
Form,
EPA
Form
7520.

All
owner/
operators
of
facilities
with
motor
vehicle
waste
disposal
wells
must
determine
if
their
wells
are
located
in
either
a
ground
water
protection
area
or
other
sensitive
ground
water
area.
If
a
well
is
located
within
one
of
these
areas,
the
owner/
operator
will
either
close
the
well
(
see
preceding
paragraph)
or
seek
a
waiver
and
apply
for
a
permit.
The
specific
information
required
in
a
permit
application
will
be
defined
by
the
appropriate
Primacy
States
or
EPA
regions.
For
purposes
of
this
analysis,
EPA
has
assumed
that
the
permit
requirements
will
be
similar
to
those
required
in
existing
UIC
permit
applications
(
40
CFR
144.31)
including:
a
description
of
activities
requiring
a
permit,
inventory
information,
topographic
maps,
and
a
brief
description
of
the
business.
Owner/
operators
will
be
required
to
sample
injectate
and
sludge
and
submit
these
results
with
their
permit
applications.
The
unit
burdens
associated
with
these
activities
are
presented
in
Column
A
of
Exhibit
6­
5.

(
6)(
a)(
5)(
B)
Burden
on
Primacy
Agencies
Associated
with
Class
V
Wells
State
primacy
agencies'
burden
associated
with
Class
V
wells
includes
reviewing
inventory
information,
processing
permit
applications,
and
reviewing
and
responding
to
monitoring
data
submitted
by
operators
within
their
states.
State
burden
associated
with
oversight
of
Class
V
programs
is
presented
in
Column
A
of
Exhibit
6­
5.

EPA
estimates
that
states
will
spend
0.5
hours
per
Class
V
facility
reviewing
inventory
information.
EPA
estimates
that
states
will
review
applications
submitted
by
operators
of
Information
Collection
Request
49
facilities
with
motor
vehicle
waste
disposal
wells
and
large­
capacity
cesspools.
State
primacy
agencies
will
also
review
monitoring
reports
submitted
by
operators
(
details
are
presented
in
Exhibit
6­
5).

6(
a)(
6)
State
Respondent
Burden
State
burden
associated
with
program
oversight
and
compiling
and
reporting
data
using
the
7520
forms
is
presented
in
Column
A
of
Exhibit
6­
6.
The
7520
forms
are
presented
in
Appendix
B
of
this
ICR.
The
burden
on
states
associated
with
completing
the
7520
forms
ranges
from
2
to
280
hours
per
form.
The
largest
unit
burden
will
be
for
compiling
data
on
nearly
40,000
newly
permitted
or
inventoried
facilities
on
the
Inventory
of
Injection
Wells
form
(
7520­
16).
Most
of
these
are
new
facilities
added
to
the
Class
V
inventory
each
year.

EPA
estimates
that
the
annual
recordkeeping
burden
on
state
primacy
agencies
associated
with
the
7520
forms
and
the
inventory
form
will
be
40
hours
per
agency.
EPA
estimates
that
maintenance
of
inventory
data
will
account
for
the
bulk
of
the
recordkeeping
burden.

EPA
estimates
that,
in
each
primacy
program,
one­
half
of
an
FTE
is
devoted
to
implementing
their
state
Class
V
program.
Implementation
activities
states
may
perform
include
updating
state
regulations
as
needed
to
reflect
new
federal
rules
or
providing
guidance,
training,
or
other
information
to
well
operators.

6(
b)
Respondent
Cost
For
injection
well
operators,
the
unit
cost
for
each
activity
consists
of
the
cost
of
operator
labor
plus
non­
labor
costs.
For
state
primacy
programs,
the
unit
cost
consists
of
state
staff
labor
only.
Labor
costs
and
non­
labor
costs
to
operators
for
each
activity
are
presented
in
Columns
B
and
C,
respectively,
of
Exhibits
6­
1
through
6­
5.
Labor
costs
to
states
for
each
activity
are
presented
in
Column
B
of
Exhibits
6­
1
through
6­
6.
15
Based
on
Bureau
of
Labor
Statistics
Occupational
Employment
Statistics,
1999,
for
SIC
codes
28
(
chemicals
and
allied
products),
13
(
oil
and
gas
extraction),
and
148
(
nonmetallic
minerals
services);
increased
by
60
percent
to
account
for
overhead
costs.

16
From
Class
V
ICR.

17
Based
on
information
in
the
Office
of
Policy,
Planning,
and
Evaluation's
(
OPPE's)
December
1996
ICR
Handbook.
EPA
determined
operator
labor
cost
by
estimating
the
mix
of
legal,
managerial,
technical,
and
clerical
time
needed
to
perform
each
collection
activity.
For
Classes
I,
II,
and
III,
the
labor
cost
estimate
is
based
on
average
hourly
estimates
for
salary
and
overhead
of
$
88
for
legal
staff,
$
66
for
managerial
staff,
$
32
for
technical
staff,
and
$
22
for
clerical
staff.
15
For
Classes
IV
and
V,
hourly
salary
and
overhead
rates
are
estimated
to
be
slightly
less:
$
32
for
managerial
staff,
$
26
for
technical
staff,
and
$
18
for
clerical
staff
(
no
legal
staff
labor
is
assumed
for
these
operators).
16
Contractor
time
was
estimated
to
be
$
48
to
$
59
per
hour,
depending
on
the
activity.

For
this
ICR,
EPA
assumed
that
the
average
hourly
labor
rate
for
a
state
employee
is
$
33.14.
This
estimate
is
based
on
a
federal
GS­
9,
Step
10
salary
on
the
2001
federal
pay
scale,
increased
by
60
percent17
to
account
for
overhead
costs.

EPA
estimated
non­
labor
costs
from
data
provided
by
staff
in
EPA
Regions
and
state
primacy
agencies,
and
from
operators
and
other
sources.
There
are
no
capital/
start­
up
costs
attributable
to
this
information
collection
 
large
capital
expenditures
associated
with
underground
injection
(
e.
g.,
construction
costs
and
monitoring
equipment)
are
customary
business
practice.
All
non­
labor
costs
of
this
collection
are
operating
and
maintenance
costs,
such
as
the
cost
of
contractor
services
or
laboratory
fees
associated
with
injectate
or
ground
water
monitoring.


Class
I.
The
estimated
total
annual
paperwork
cost
for
all
Class
I
operators
is
$
22,589,495.
EPA
estimates
that
operators
of
Class
I
hazardous
facilities
will
spend
$
12,864,468
per
year
on
this
collection.
Labor
comprises
$
1,077,014
of
the
total,
and
non­
labor
costs
account
for
$
11,787,453.
Operators
of
nonhazardous
facilities
will
spend
$
9,725,028
per
year
 
$
2,204,887
for
operator
labor
and
$
7,520,141
for
non­
labor
costs.
The
annual
cost
to
states
of
administering
Class
I
programs
is
$
237,946;
of
this,
$
102,086
is
associated
with
reporting
by
operators
of
Class
I
hazardous
facilities
and
$
135,860
is
associated
with
Class
I
nonhazardous
facility
reports.
See
Columns
B
and
C
of
Exhibits
6­
1A
and
6­
1B
for
detailed
estimates
of
the
unit
costs
for
each
collection
activity.


Class
II.
The
annual
cost
to
operators
for
this
collection
is
$
28,647,150.
Operator
labor
accounts
for
$
17,690,360
of
the
total
and
non­
labor
costs
account
for
$
10,956,791.
The
cost
to
states
of
administering
Class
II
programs
is
$
6,443,531
annually.
Columns
B
and
C
of
Exhibit
6­
2
contain
detailed
estimates
of
the
unit
costs
for
each
collection
activity.
Information
Collection
Request
51

Class
III.
The
annual
cost
to
Class
III
operators
for
this
collection
is
$
2,371,562.
Operator
labor
accounts
for
$
1,884,303
of
the
total
and
non­
labor
costs
account
for
$
487,260.
The
annual
cost
to
states
of
administering
Class
III
programs
is
$
205,964.
Columns
B
and
C
of
Exhibit
6­
3
for
detailed
estimates
of
the
unit
costs
for
each
collection
activity.


Class
IV/
Endangering
Class
V.
The
total
annual
cost
of
this
collection
will
be
$
88,800,
all
of
which
will
be
labor
costs
associated
with
closure.
The
cost
to
states
of
administering
Class
IV/
Endangering
Class
V
programs
is
$
947
per
year.
See
Columns
B
and
C
of
Exhibit
6­
4
for
Class
IV/
Endangering
Class
V
unit
costs.


Class
V.
The
total
annual
information
collection
cost
for
Class
V
operators
will
be
$
2,418,932
 
$
1,353,840
of
this
cost
represents
operator
labor
and
the
remaining
$
1,065,092
is
non­
labor
costs.
The
annual
cost
to
states
of
administering
Class
V
programs
is
$
1,301,609.
Detailed
cost
estimates
for
each
activity
are
presented
in
Columns
B
and
C
of
Exhibit
6­
5.


States
as
Respondents.
EPA
estimates
that
the
total
costs
to
states
as
respondents
associated
with
this
information
collection
will
be
$
2,598,568
per
year.
All
of
this
cost
will
be
for
labor.
Columns
B
and
C
of
Exhibit
6­
6
present
detailed
cost
estimates
for
each
activity.

6(
c)
Agency
Burden
and
Cost
The
federal
burden
associated
with
use
of
UIC
Program
data
is
similar
to
the
state
burden
described
in
Section
6(
a)
above.
EPA
implements
the
UIC
program
for
all
well
classes
in
10
states
and
has
oversight
responsibility
in
six
states.
The
paperwork
requirements
are
the
same
as
those
for
the
state
primacy
programs.
In
addition,
EPA
reviews
all
no­
migration
petitions
submitted
by
Class
I
hazardous
facility
operators
in
both
primacy
and
DI
states.
The
total
annual
burden
for
federal
DI
programs
as
users
of
data
is
33,736
hours.
The
breakdown
of
DI
burden
by
well
class
is
as
follows:
6,126
hours
for
Class
I;
17,854
hours
for
Class
II;
381
hours
for
Class
III;
340
hours
for
Class
IV/
Endangering
Class
V;
and
9,034
hours
for
Class
V.
The
total
federal
burden
associated
with
review
of
operator
submissions
is
presented
in
Column
C
of
Exhibits
6­
7
through
6­
11.

EPA
assumes
the
average
hourly
labor
rate
for
salary
and
overhead
and
benefits
for
Agency
staff
to
be
$
33.14.
This
estimate
is
based
on
a
federal
GS­
9,
Step
10
salary
on
the
2001
federal
pay
scale,
increased
by
60
percent
to
account
for
overhead
costs.

The
annual
federal
cost
associated
with
this
collection
is
$
1,118,002.
The
breakdown
of
Agency
cost
associated
with
each
well
class
is
as
follows:
$
203,024
for
Class
I;
$
591,677
for
Class
II;
$
12,633
for
Class
III;
$
11,281
for
Class
IV/
Endangering
Class
V;
and
$
299,387
for
Class
V
wells.
Column
D
of
Exhibits
6­
7
through
6­
11
present
detailed
estimates
of
these
costs.
6(
d)
Respondent
Universe
and
Total
Burden
and
Costs
In
this
section,
EPA
describes
the
number
of
respondents
subject
to
each
paperwork
activity
outlined
in
Section
6(
a).
The
number
of
responses
for
each
activity
is
shown
in
Column
D
of
Exhibits
6­
1
through
6­
6.
This
number,
known
as
the
respondent
universe,
is
based
on
EPA's
assumptions
on
the
number
of
permittees
subject
to
each
paperwork
requirement,
e.
g.,
the
number
of
permit
applications
or
well
closures
expected,
or
the
percent
of
permittees
subject
to
monitoring
or
reporting
requirements
and
the
frequency
with
which
they
must
comply
with
those
requirements.
The
frequency
at
which
each
activity
is
performed
is
presented
in
the
burden
and
cost
tables
along
with
EPA's
description
of
each
activity.
Specific
assumptions
about
the
respondent
universe
for
each
well
class
are
described
below.

Class
I
EPA
inventory
data
indicate
that
there
are
486
Class
I
wells,
of
which
122
inject
hazardous
waste,
and
364
inject
nonhazardous
waste.

Class
I
Hazardous
According
to
EPA's
inventory,
there
are
64
Class
I
hazardous
waste
facilities,
with
a
total
of
122
wells,
an
average
of
1.9
wells
per
facility.
EPA
estimates
that
8
new
Class
I
hazardous
waste
facility
operating
permits
will
be
issued
each
year
(
6
for
one
new
well
at
an
existing
facility,
and
the
remaining
two
for
newly
constructed
facilities).
EPA
further
anticipates
that
12
Class
I
hazardous
facility
operators
will
renew
their
permits
each
year;
5
will
modify
their
permits
each
year;
and
6
operators
will
modify
their
petitions
each
year.
All
operators
of
Class
I
hazardous
waste
facilities
must
monitor
and
report
at
various
frequencies
(
see
Exhibit
6­
1A).
EPA
expects
that
one
Class
I
hazardous
well
will
close
during
each
year
of
the
life
of
this
ICR.

Class
I
Nonhazardous
EPA
estimates
that
there
are
192
Class
I
nonhazardous
waste
facilities,
with
a
total
of
364
wells,
an
average
of
1.9
wells
per
facility.
The
Agency
estimates
that
14
new
nonhazardous
waste
injection
permits
will
be
issued
each
year,
of
which
10
will
be
for
one
new
well
at
an
existing
facility.
EPA
anticipates
that
20
Class
I
nonhazardous
facility
operators
will
renew
their
permits
each
year,
and
9
Class
I
nonhazardous
facility
operators
will
modify
their
permits
each
year.
Every
operator
of
a
Class
I
nonhazardous
waste
facility
must
monitor
and
report
at
various
frequencies,
as
shown
in
Exhibit
6­
1B.
Based
on
inventory
data,
EPA
anticipates
that
one
Class
I
nonhazardous
well
in
a
primacy
state
will
close
each
year.
Information
Collection
Request
53
18
This
estimate
is
based
on
operator
data
from
Texas,
Oklahoma,
and
Kansas.

19
Alabama,
Alaska,
California,
Colorado,
Illinois,
Indiana,
Kansas,
Louisiana,
Missouri,
Nebraska,
New
Mexico,
Ohio,
Oklahoma,
and
Utah
perform
some
or
all
of
the
tasks
involved
in
an
AoR
study.
Class
II
EPA
assumes
that
the
typical
Class
II
operator
has
approximately
10
wells,
and
that
there
are
approximately
14,688
Class
II
owners/
operators.
18
EPA
anticipates
that
EPA
regional
offices
and
primacy
states
will
receive
approximately
4,900
applications
for
Class
II
wells
each
year
during
the
life
of
this
ICR.
Details
of
the
numbers
of
Class
II
operators
subject
to
each
paperwork
requirement
are
presented
in
Column
D
of
Exhibit
6­
2.

Based
on
previous
studies
of
state
AoR
practices
and
requirements,
EPA
projects
that
state
primacy
agencies
and
EPA
Regions
will
determine
that
a
complete
AoR
is
not
necessary
for
approximately
2,887
of
the
4,900
permit
applicants.
EPA
projects
that
approximately
924
applicants
will
submit
an
AoR
map
and
an
AoR
study
as
part
of
the
permit
application.
Another
1,089
applicants
will
submit
an
AoR
map
and
a
listing
of
the
wells
in
the
AoR,
and
the
state
primacy
agency
will
perform
most
or
all
of
the
tasks
involved
in
the
AoR
study.
19
EPA
estimates
that
490
applicants
will
submit
corrective
action
plans
to
address
specific
problems
identified
by
the
AoR
study.
EPA
regional
or
state
primacy
staff
will
require
98
operators
(
20
percent)
to
revise
their
corrective
action
plans.

Prior
to
obtaining
approval
to
begin
injection,
operators
must
submit
completion
reports
for
each
of
the
6,537
new
Class
II
wells
each
year.
Most
operators
will
submit
logs
for
offset
wells
in
their
projects.
EPA
assumes
that
operators
will
perform
additional
logs
and
tests
for
726
new
II­
D
wells
and
255
new
II­
R
wells.

EPA
estimates
that
approximately
73,439
class
II
wells
(
50
percent)
are
permitted,
and
that
the
permits
for
14,688
wells
are
reviewed
each
year.
In
addition,
EPA
expects
that
4,010
operators
will
submit
requests
for
permit
modifications.

In
general,
all
operators
located
in
DI
programs
and
operators
of
commercial
II­
D
wells
in
primacy
states
are
required
to
submit
annual
injectate
analyses.
EPA
estimates
that
approximately
1,469
Class
II
operators
will
submit
annual
injectate
analyses
each
year.

From
time
to
time,
operators
submit
reports
or
notify
UIC
staff
of
various
events,
such
as
planned
changes
to
the
injection
facility,
permit
transfers,
progress
in
achieving
compliance
milestones,
and
noncompliance
or
malfunctions
which
may
endanger
a
USDW.
EPA
estimates
that
approximately
881
operators
(
6
percent)
submit
one
of
these
occasional
reports
each
year.

EPA
projects
that
approximately
5
operators
of
rule­
authorized
wells
in
DI
states
may
be
required
to
gather
and
submit
groundwater
monitoring
data,
analyses
of
injected
fluids,
a
description
of
geologic
strata,
and
other
items
as
requested.

EPA
projects
that
approximately
1,044
operators
will
plug
and
abandon
all
of
their
wells
each
year.
In
addition,
EPA
assumes
that
approximately
1
operator
in
a
DI
program
will
elect
to
plug
its
wells
in
a
manner
different
from
the
one
specified
in
its
plugging
and
abandonment
plan.

Class
III
EPA
estimates
that
there
are
approximately
164
facilities
with
Class
III
wells
(
10
uranium
mining,
45
salt
solution
mining,
and
109
brine
mining/
other).
A
typical
uranium
facility
has
approximately
1,581
Class
III
wells,
a
typical
salt
mining
facility
has
11
wells,
and
a
typical
brine
mining/
other
facility
has
3
wells.

EPA
regional
offices
and
state
primacy
agencies
expect
to
receive
32
permit
applications
from
Class
III
operators
each
year.
EPA
estimates
that
approximately
2
Class
III
operators
will
close
their
projects
annually.

Operators
of
all164
Class
III
facilities
will
monitor
injection
pressure,
flow
rate,
or
volume
of
injected
fluids
semi­
monthly,
or
meter
injected
and
produced
fluid
volumes
continuously.
EPA
anticipates
that
the
45
operators
of
salt
solution
mining
facilities
will
submit
analyses
of
their
injectate
once
each
year,
and
approximately
9
operators
of
salt
solution
mining
facilities
will
perform
two­
part
MITs
on
all
of
their
wells
each
year.
All
10
uranium
operators
monitor
water
quality
in
the
injection
zone
and
overlying
freshwater
aquifers
either
semi­
monthly
or
monthly.

Class
IV/
Endangering
Class
V
EPA
anticipates
that
370
Class
IV
wells
and
endangering
Class
V
wells
will
close
each
year.
Because
information
on
both
types
of
wells
are
reported
to
EPA
jointly,
numbers
of
each
type
of
well
are
unavailable.
Based
on
the
Class
IV
inventory,
EPA
assumes
that
92
percent
of
Class
IV
and
endangering
Class
V
wells
are
in
DI
states.

Class
V
The
current
EPA
inventory
of
Class
V
wells
includes
approximately
200,000
wells.
This
number
is
imprecise,
and
it
is
estimated
that
perhaps
3
to
5
times
as
many
Class
V
wells
actually
exist.
EPA
anticipates
that
approximately
35,000
operators
of
Class
V
facilities
will
submit
inventory
information
each
year
over
the
life
of
this
ICR.

EPA
estimates
that,
in
the
period
between
expiration
of
the
current
Class
V
ICR
and
of
this
ICR,
228
owner/
operators
(
i.
e.,
an
average
of
76
per
year)
of
motor
vehicle
waste
disposal
Information
Collection
Request
55
well
facilities
will
apply
for
permits
and
be
subject
to
the
monitoring
requirements
of
the
Class
V
Rule,
and
that
63
motor
vehicle
waste
disposal
wells
(
an
average
of
21
per
year)
will
close.
EPA
also
assumes
that
666
large­
capacity
cesspools
(
an
average
of
222
per
year)
nationwide
will
close.
Little
is
known
about
the
average
number
of
Class
V
wells
per
operator,
so
EPA
conservatively
assumes
that
an
average
operator
has
only
one
well.

States
as
Respondents
EPA
assumes
that
56
primacy
agencies
in
40
states
will
prepare
and
submit
7520
forms.
This
number
reflects
the
fact
that,
in
some
states,
more
than
one
agency
oversees
UIC
activities
(
e.
g.,
states
typically
regulate
Class
II
wells
through
agencies
other
than
those
overseeing
other
classes
of
wells
for
which
they
have
primacy).
The
frequency
at
which
Primacy
agencies
complete
each
7520
form
is
presented
in
Exhibit
6­
6.

Column
E
of
Exhibits
6­
1
through
6­
6
presents
the
total
annual
burden
(
i.
e.,
the
hours
per
response
times
the
number
of
responses)
for
each
activity.
Column
F
of
each
exhibit
presents
the
total
annual
cost
for
each
activity
(
i.
e.,
the
sum
of
labor
costs
and
non­
labor
costs
per
response
times
the
number
of
responses).

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Respondent
Tally
Exhibit
6­
12
presents
the
total
respondent
burden
and
cost
by
aggregating
the
figures
from
all
respondent
types.
The
total
burden
over
the
three­
year
life
of
this
ICR
associated
with
the
UIC
Program
for
operators
and
states
is
3,275,836
hours
(
an
average
of
1,091,945
hours
per
year),
and
the
present
value
cost
will
be
$
200,713,515
(
an
average
of
$
66,904,505
per
year).
Exhibit
6­
12
Summary
of
Annual
Respondent
Burden
and
Costs
Respondent
Type
Number
of
Responses
Total
Hours/
Year
Total
Annual
Labor
Cost
Total
Annual
Non­
labor
Cost
Total
Annual
Respondent
Cost
Class
I
(
operators)
4,099
86,979
3,281,901
$
19,307,594
$
22,589,495
Class
I
(
states)
1,424
7,180
$
237,946
$
0
$
237,946
Class
II
(
operators)
281,292
589,384
$
17,690,360
$
10,956,791
$
28,647,150
Class
II
(
states)
48,093
194,434
$
6,443,531
$
0
$
6,443,531
Class
III
(
operators)
6,594
64,482
$
1,884,303
$
487,260
$
2,371,562
Class
III
(
states)
1,042
6,215
$
205,964
$
0
$
205,964
Class
IV
(
operators)
370
3700
$
88,800
$
0
$
88,800
Class
IV
(
states)
65
29
$
947
$
0
$
947
Class
V
(
operators)
38,917
39,259
$
1,353,840
$
1,065,092
$
2,418,932
Class
V
(
states)
39,668
21,872
$
1,289,829
$
11,781
$
1,301,609
UIC
Primacy
Agencies
724
78,412
$
2,598,569
$
0
$
2,598,569
Total
422,287
1,091,945
$
35,075,988
$
31,828,517
$
66,904,505
Agency
Tally
Exhibit
6­
13
presents
the
burden
and
cost
to
EPA
associated
with
responding
to
information
submitted
by
operators.
The
total
Agency
burden
over
the
three­
year
life
of
this
ICR
associated
with
the
UIC
Program
is
101,207
hours
(
33,736
per
year),
and
the
total
cost
is
$
3,354,005
($
1,118,002
per
year).
Information
Collection
Request
57
Exhibit
6­
13
Summary
of
Annual
Agency
Burden
and
Costs
Respondent
Type
Total
Number
of
Responses
Total
Hours/
Year
Total
Annual
Labor
Cost
Total
Annual
Non­
labor
Cost
Total
Annual
Agency
Cost
Class
I
350
6,126
$
203,024
$
0
$
203,024
Class
II
5,277
17,854
$
591,677
$
0
$
591,677
Class
III
74
381
$
12,633
$
0
$
12,633
Class
IV
340
340
$
11,281
$
0
$
11,281
Class
V
15,942
9,034
299,387
$
0
$
299,387
Total
21,983
33,736
$
1,118,002
$
0
$
1,118,002
6(
f)
Reasons
for
Change
in
Burden
and
Cost
Exhibits
6­
14
and
6­
15
present
current
estimates
of
annual
respondent
burden
hours
and
costs,
previous
burden
hours
and
costs,
and
the
difference
in
burdens
and
costs
between
the
1998
UIC
Program
ICR
and
this
ICR.

There
is
a
decrease
in
respondent
burden
of
43,329
hours
and
an
increase
in
respondent
cost
of
$
8,658,451.
The
cost
and
burden
estimation
methodologies
were
the
same
in
this
ICR
and
the
previous
program
ICR.
The
changes
in
specific
assumptions
that
affect
the
respondent
burden
and
cost
are
described
below.
Exhibit
6­
14
Change
in
Annual
Respondent
Burden
Respondent
Type
Previous
Respondent
Burden
Revised
Respondent
Burden
Net
Change
Reasons
for
Change
Class
I
(
operators)
87,808
86,979
­
828

Adjustment
Class
I
(
states)
7,398
7,180
­
218

Adjustment
Class
II
(
operators)
625,056
589,384
­
35,672

Adjustment
Class
II
(
states)
203,793
194,434
­
9,360

Adjustment
Class
III
(
operators)
76,327
64,482
­
11,846

Adjustment
Class
III
(
states)
6,228
6,215
­
13

Adjustment
Class
IV
(
operators)
3,700
3,700
0

Adjustment
Class
IV
(
states)
29
29
0

Adjustment
Class
V
(
operators)
74,532
39,259
­
35,273

Program
change
Class
V
(
states)
31,672
21,872
­
9,801

Program
change
UIC
Primacy
Agencies
18,731
78,412
59,681

Adjustment
Total
1,135,274
1,091,945
­
43,329
Change
in
Respondent
Burden
The
change
in
burden
(
shown
in
Exhibit
6­
14)
between
the
two
ICRs
reflects
the
following
revisions:


Inventories
of
most
well
classes,
except
Class
I
non­
hazardous
wells
have
decreased
since
1998.
The
net
effect
of
the
inventory
changes
is
a
reduction
in
burden
of
approximately
58,000
hours
per
year
to
states
and
operators.


The
assumptions
about
the
number
of
Class
V
wells
to
receive
permits
have
changed.
The
previous
Program
ICR
assumed
that
a
certain
number
of
Class
V
facilities
authorized
by
rule
would
be
called
in
for
permits.
This
number
was
significantly
greater
than
the
number
of
facilities
with
motor
vehicle
waste
disposal
wells
and
large­
capacity
cesspools
estimated
to
be
affected
by
the
Class
V
Rule,
thus
overestimating
the
impact
on
operators
of
Class
V
wells.
The
more
precise
estimates
of
affected
Class
V
facilities
used
in
the
Class
V
rule
ICR
are
reflected
herein.
This
change
reduces
the
annual
burden
to
operators
and
states
by
about
45,000
hours.
Information
Collection
Request
59

This
ICR
includes
the
burden
to
primacy
programs
associated
with
oversight
of
their
UIC
program
(
e.
g.,
training
and
new
rule
development),
which
was
omitted
from
the
previous
ICR.
This
added
approximately
58,000
hours
to
the
total
annual
burden
to
the
states.

Change
in
Respondent
Cost
As
Exhibit
6­
15
shows,
the
annual
cost
to
respondents
is
estimated
at
$
66.9
million,
an
increase
of
about
$
8.7
million
over
the
1998
Program
ICR.
The
cost
changes
reflect
changes
in
the
following
assumptions:


Inventory
changes
resulted
in
a
reduction
in
cost
to
states
and
operators
of
$
2.5
million
per
year.


Revisions
to
the
assumptions
reflecting
the
Class
V
Rule
decreased
the
annual
cost
to
Class
V
operators
and
states
by
$
1.5
million.


This
cost
to
primacy
programs
associated
with
oversight
of
their
UIC
programs
added
$
1.9
million
annually
to
the
total
cost
to
the
states.


The
labor
rates
for
Classes
I,
II,
and
III
in
this
ICR
reflect
Bureau
of
Labor
Statistics
Occupational
Employment
Statistics
for
1999,
which
are
higher
than
labor
estimates
for
1995.
The
labor
rates
for
Classes
IV
and
V
reflect
rates
used
in
the
Class
V
ICR,
which
are
lower
than
those
in
the
previous
UIC
Program
ICR.
Combined,
these
labor
rate
changes
added
$
3.9
million
annually
to
operator
labor
costs.


Non­
labor
costs
and
costs
of
contractual
services
to
operators
were
inflated
based
on
the
annual
changes
in
the
consumer
price
indices
between
1995
and
2000,
(
an
annual
rate
of
2.5
percent),
projected
out
to
2004.
This
adjustment
added
$
6.9
million
annually
to
non­
labor
costs.
Exhibit
6­
15
Change
in
Annual
Respondent
Costs
Respondent
Type
Previous
Respondent
Cost
Revised
Respondent
Cost
Net
Change
Reasons
for
Change
Class
I
(
operators)
$
18,543,106
$
22,589,495
$
4,046,389

Adjustment
Class
I
(
states)
$
221,926
$
237,946
$
16,020

Adjustment
Class
II
(
operators)
$
25,318,333
$
28,647,150
$
3,328,817

Adjustment
Class
II
(
states)
$
6,113,803
$
6,443,531
$
329,728

Adjustment
Class
III
(
operators)
$
2,285,453
$
2,371,562
$
86,109

Adjustment
Class
III
(
states)
$
186,852
$
205,964
$
19,112

Adjustment
Class
IV
(
operators)
$
97,125
$
88,800
­$
8,325

Adjustment
Class
IV
(
states)
$
857
$
947
$
90

Adjustment
Class
V
(
operators)
$
3,966,502
$
2,418,932
­$
1,547,570

Program
change
Class
V
(
states)
$
950,167
$
1,301,609
$
351,442

Program
change
UIC
Primacy
Agencies
$
561,930
$
2,598,569
$
2,036,639

Adjustment
Total
$
58,246,054
$
66,904,505
$
8,658,451
6(
g)
Burden
Statement
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
3,275,836
hours
(
an
average
of
1,091,945
hours
per
year),
and
the
present
value
cost
will
be
$
200,713,515
(
an
average
of
$
66,904,505
per
year).

The
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
2.59
hours,
or
$
158.43
per
response
annually.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
Information
Collection
Request
61
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Office
of
Environmental
Information,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
Ariel
Rios
Building,
1200
Pennsylvania
Ave.,
NW.,
Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW.,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
APPENDIX
A
ENVIRONMENTAL
PROTECTION
AGENCY
[
FRL­
6974­
1]

Agency
Information
Collection
Activities:
Proposed
Collection;
Comment
Request;
Underground
Injection
Control
(
UIC)
Program
AGENCY:
Environmental
Protection
Agency
(
EPA).

ACTION:
Notice.
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

SUMMARY:
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.),
this
document
announces
that
EPA
is
planning
to
submit
the
following
continuing
Information
Collection
Request
(
ICR)
to
the
Office
of
Management
and
Budget
(
OMB):
Underground
Injection
Control
Program,
EPA
ICR
No.
0370.13,
OMB
Control
No.
2040­
0042
which
expires
9/
30/
01.
Before
submitting
the
ICR
to
OMB
for
review
and
approval,
EPA
is
soliciting
comments
on
specific
aspects
of
the
proposed
information
collection
as
described
below.

DATES:
Comments
must
be
submitted
on
or
before
July
2,
2001.

ADDRESSES:
Persons
interested
in
getting
information
or
making
comment
about
this
ICR
(#
0370.13)
should
direct
inquires
to
Robert
E.
Smith,
U.
S.
Environmental
Protection
Agency;
Ariel
Rios
Building;
1200
Pennsylvania
Avenue,
NW,
Mail
Stop
4606;
Washington,
DC
20460.

FOR
FURTHER
INFORMATION
CONTACT:
Robert
E.
Smith,
Office
of
Ground
Water
and
Drinking
Water:
202­
260­
5559;
FAX
202­
401­
2345;
E­
mail:
robert­
eu@
epa.
gov.
Further
information
on
the
ICR
can
be
obtained
from
the
Safe
Drinking
Water
Hotline
at
(
703)
286­
1093,
E­
mail:
hotline­
sdwa@
epa.
gov.

SUPPLEMENTARY
INFORMATION:

Affected
entities:
Entities
potentially
affected
by
this
action
are
owners/
operators
of
underground
injection
wells
and
State
UIC
Primacy
Agencies
including,
Puerto
Rico,
the
U.
S.
Trust
Territories,
Indian
Tribes,
and
Alaska's
Native
Villages
and,
in
some
instances,
U.
S.
EPA
Regional
Offices.
Title:
Information
Collection
Request
for
the
Underground
Injection
Control
Program
(
OMB
Control
No.
2040­
0042;
EPA
ICR
No.
0370.13.),
expiring
September
30,
2001.
Abstract:
The
Underground
Injection
Control
(
UIC)
Program
under
the
Safe
Drinking
Water
Act
established
a
Federal
and
State
regulatory
system
to
protect
underground
sources
of
drinking
water
(
USDWs)
from
contamination
by
injected
fluids.
Owners/
operators
of
underground
injection
wells
must
obtain
permits,
conduct
environmental
monitoring,
maintain
records,
and
report
results
to
EPA
or
the
State
UIC
primacy
agency.
States
must
report
to
EPA
on
permittee
compliance
and
related
information.
The
information
is
reported
using
standardized
forms,
and
regulations
are
codified
at
40
CFR
parts
144
through
148.
The
data
are
used
to
ensure
the
protection
of
underground
sources
of
drinking
water
from
UIC
authorities.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
The
EPA
would
like
to
solicit
comments
to:
(
i)
Evaluate
whether
the
proposed
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
agency,
including
whether
the
information
will
have
practical
utility;
(
ii)
evaluate
the
accuracy
of
the
agency's
estimate
of
the
burden
of
the
proposed
collection
of
information,
including
the
validity
of
the
methodology
and
assumptions
used;
(
iii)
enhance
the
quality,
utility,
and
clarity
of
the
information
to
be
collected;
and
(
iv)
minimize
the
burden
of
the
collection
of
information
on
those
who
are
to
respond,
including
through
the
use
of
appropriate
automated
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology,
e.
g.,
permitting
electronic
submission
of
responses.
Burden
Statement:
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
In
the
UIC
Program
ICR
for
1998­
2001,
the
total
burden
associated
with
it
was
estimated
to
be
1,135,273
hours
per
year
and
the
total
cost
was
estimated
to
be
$
58,246,054
per
year.
EPA
expects
that
the
total
burden
for
the
continuing
UIC
Program
ICR
for
the
period
2001­
2004
will
be
approximately
the
same
except
for
inflation
for
the
cost
information.
This
is
because
little
or
no
significant
increase
in
the
UIC
well
population
is
anticipated
during
this
period.
EPA
also
considered
the
possible
impact
of
the
Class
V
Well
Phase
I
rulemaking
(
64
FR
68546,
11/
30/
99)
implementation
for
the
renewal
period.
While
this
rulemaking
has
separate
ICR
coverage
until
November
2002,
the
Program
ICR
will
include
slightly
increased
burden
and
cost
for
State
implementation
of
Class
V
Well
Phase
I
rulemaking
from
December
1,
2002
until
September
30,
2004.
Respondents/
Affected
Entities:
Owners/
Operators
of
UIC
wells,
State
Primacy
Agencies
including,
Puerto
Rico,
the
U.
S.
Trust
Territories,
Indian
Tribes,
and
Alaska's
Native
Villages
and
EPA
Regional
Offices.

Dated:
April
25,
2001.
Philip
S.
Oshida,
Acting
Director,
Office
of
Ground
Water
and
Drinking
Water.
[
FR
Doc.
01­
11092
Filed
5­
2­
01;
8:
45
am]
BILLING
CODE
6560­
50­
P­
P
APPENDIX
B
APPENDIX
B
Underground
Injection
Control
Forms
Number
Form
7520­
1
Permit
Review
and
Issuance/
Wells
in
Area
of
Review
7520­
2A
Compliance
Evaluation
7520­
2B
Compliance
Evaluation
­
Significant
Noncompliance
7520­
3
Mechanical
Integrity
Test/
Remedial
Actions
7520­
4
Quarterly
Exceptions
List
7520­
5
Summary
of
UIC
Grant
Utilization
7520­
6
UIC
Permit
Application
7520­
7
Application
to
Transfer
Permit
7520­
8
Injection
Well
Monitoring
report
7520­
9
Completion
Form
for
Injection
Wells
7520­
10
Completion
Report
for
Brine
Disposal,
Hydrocarbon
Storage,
or
Enhanced
Recovery
Well
7520­
11
Annual
Disposal/
Injection
Well
Monitoring
Report
7520­
12
Well
Rework
Record
7520­
14
Plugging
and
Abandonment
Plan
7520­
16
Inventory
of
Injection
Wells
APPENDIX
C
APPENDIX
C
40
CFR
Section
144
40
CFR
Section
146
40
CFR
Section
147
40
CFR
Section
148
