Report on Underground Injection Control Program

Burden Reduction Efforts

Introduction

EPA’s Office of Ground Water and Drinking Water (OGWDW) is requesting
OMB approval to renew the Underground Injection Control (UIC)
Information Collection Request (ICR) to allow the continued collection
of information under the UIC Program.  

In its “Terms of Clearance” for the current ICR, the Office of
Management and Budget (OMB) asked OGWDW to report on its efforts to
reduce burden on owners and operators of injection wells.    

The following report responds to OMB’s request and describes EPA’s
efforts to assess the burden on well operators associated with the UIC
Program’s requirements and the efforts to identify potential burden
reduction opportunities in the UIC Program. 

UIC  Burden Estimates

There are approximately 38,768 owners and operators of UIC wells who
must collect information and periodically report to the State or EPA on
well activities. The total annual burden on owners and operators of
injection wells estimated in the approved ICR (EPA ICR number 0370.19;
January 18, 2005) is 1,122,522 hours.  EPA has revised these estimates
as part of the process of renewing the UIC ICR and expects the total
annual owner/operator burden between 2007 and 2010 to be approximately
840,985 hours.  

EPA expects a net reduction in operator burden of 281,537 hours between
2007 and 2010. This reduction reflects a combination of programmatic
changes and adjustments to the UIC inventory, rather than changes in the
reporting forms or frequency of reporting.  Programmatic changes include
activities associated with the Revision to Federal UIC Requirements for
Class I Municipal Wells in Florida (“the Florida Rule”) and reduced
activity as a result of the 1999 Revisions to the Underground Injection
Control Regulations for Class V Injection Wells (“the Class V
Rule”).  In addition, the burden estimate is expected to change to
reflect adjustments to the inventory for Classes II and V.  

Table 1 provides additional detail.

Table 1: Change in Annual Well Owner/Operator Burden 

Between Approved and Renewal ICRs

Type of Change	Change (hours)	Reason for Change 

Florida Rule

	1,472	Additional burden associated with compliance with 2005 Rule. 
Operators of certain Class I municipal wells in Florida will apply to
modify their permits in order to be able to continue injecting.

Abatement of Class V Rule activities 	-71,669	The burden associated with
permitting and closure of motor vehicle waste disposal wells (MVWDWs)
and closure of large capacity cesspools is largely complete.  Most
activities in the 2007 to 2010 clearance period will be associated with
rule-required sampling by MVWDW operators who opted to apply for a
permit.

Inventory adjustments	-211,339	For Class V injection wells, the Agency
predicted an increase in the number of Class V wells during the 2004 to
2006 period because of the significant increase due to requirement to
locate and document large capacity cesspools and motor vehicle waste
disposal wells as part of the 1999 Class V Rule.  For the 2007 to 2010
period the Agency expects a decrease in these activities as most of the
wells subject to permitting and closure should have been identified.  

For Class II injection wells during 2004 to 2006, the Agency predicted
an increase in Class II activities based on consultations with EPA
regions and states.  Based on consultations on activities between 2007
and 2010, some wells are expected to temporarily close and fewer permits
are likely to be received in the future.  

Total Change	-281,536

	

Past Efforts to Address Operator Burden

 convened a burden reduction workgroup to analyze the data needs of the
UIC Program and identify possible ways to reduce burden.  The workgroup
consisted of representatives of 11 states and all 10 EPA regions (see
Table 2 below).  

Table 2: 7520 Workgroup Members

EPA Regions 

David Delaney; Region I 

John Kushwara; Region II

Roger Reinhart and Maria Conicelli; Region III 

Nancy Marsh and Frank Baker; Region IV 

Valoria Robinson; Region V

Ray Leissner; Region VI

Kurt Hildebrandt; Region VII 

Carol Bowden and Nathan Wiser; Region VIII 

Gregg Olson and George Robin; Region IX 

Grover Partee; Region X 

EPA Headquarters

Richard Lawrence, Al Havinga, and Don Olson; OECA

James Curtin; OGC

Denny Cruz, (Workgroup Leader), Robyn Delehanty and Bruce Kobelski;
OGWDW	States

Lindsay Taliaferro; Ohio

Richard Ginn, Ben Knape, and Marty Barnes; Texas 

Mike Stettner; California

Dave Watkins; West Virginia

Mark Slifka; Idaho

Richard Deuerling; Florida 

Michel Phillips and Bur Filson; Illinois

Stan Belieu; Nebraska

George Hudak; Montana

Bob Lucht; Wyoming

Larry Fiddler; Oklahoma





, allowing electronic entry and transmission of data from primacy
agencies to EPA.

Current Efforts to Address Operator Burden 

In 2006, in response to OMB requests, EPA stepped up its efforts to
investigate and assess possibilities for burden reduction.  EPA convened
a study group composed of representatives from EPA headquarters and
Regions to assess whether burden could be further reduced. This study
group continues to evaluate burden reduction possibilities and complete
recommendations will be made available in late 2007.  A discussion of
the areas this group is examining follows.  

Combining/Revising the Reporting Forms

It may be possible to   SEQ CHAPTER \h \r 1 combine several of the 7520
reporting forms into a single multi-purpose form.  These forms include
the Completion forms (7520-9 and 7520-10), the Well Rework form
(7520-12), and the Plugging and Abandonment Plan (7520-14).  EPA is
evaluating whether combining the forms would result in any burden
reduction.

Reducing Frequency of Reporting

It may be possible to reduce reporting burden by reducing reporting
frequency.  The study group found that monitoring and testing had a
large number of respondents   These activities account for nearly half
of the total operator burden.  We have examined these areas for possible
burden reduction and have some areas to follow-up on whether burden can
be reduced.  As a possible next step, we could talk with states that run
the UIC programs and the regulated community.

  

  Table 3 summarizes the percent of total burden by activity. 

	

Table 3:  Annual Injection Well Operator Burden 

(by Activity Type)

	151,684	35% of total

Monitoring/ testing	493,093	46% of total

Reporting	123,125	12% of total

Recordkeeping	59,360	6% of total

Well closure	13,396	1% of total

Other	184	0.02% of total

Total	840,842	 

Source: ICR burden tables, last revised October 24, 2006.

                 *This is a one-time activity

Eliminating Data Elements from the 7520 Forms

The study group discussed the potential for eliminating some of the
reporting elements on the 7520 forms submitted by well owners/operators.
 Although it is too early to tell the exact number of elements that
could be eliminated, the study group acknowledged that some elements
could be eliminated.  The study group believes it is necessary to
continue to require many of the existing data elements to ensure that
injection wells are sited, constructed, and operated in an
environmentally protective manner, however, it is working to refine a
list of the elements that could be eliminated. Attachment 1 summarizes
the analysis to date of the potential for eliminating data elements.

Additional Burden Reduction Options 

Study group members made additional recommendations for burden
reduction.  The following is a description of these recommendations and
associated activities.

Maintain and transfer all operator data electronically.  Electronic
reporting of routinely-collected data would eliminate the need to
collect, record on paper, and submit information to the permitting
authority.  A first step toward this goal is developing a database for
transferring UIC data from regions and states to EPA Headquarters.
Headquarters is currently developing a national UIC database (with plans
to deploy it in 2007).  Following this, it may be possible to provide
well operators the option to report some information electronically. 
Headquarters estimates the database will reduce primacy agency burden. 
It is likely that electronic reporting may offer significant burden
savings to those operators with electronic data transfer capabilities as
well. 

Create an electronic permitting system.  Electronic submission of permit
application data could streamline the application review process.  This
option needs to be further explored.  EPA must consider the states’
ability to receive all of the required permit application attachments
electronically (e.g., well logs and schematics), whether some
information could be sent electronically, and the actual burden
reduction relative to the cost of setting up such a system (the number
of permit applications received each year by many states is limited and
not all applicants would be able to use an electronic system).

Allow electronic entry of inventory information.  Operators that do not
need to apply for a permit must submit basic inventory information about
their wells to the permitting authority using the Injection Well
Inventory form (7520-16) or an equivalent.  A web-based data entry
system could reduce burden to operators, especially those that submit
multiple inventory forms for similar wells.  (Regions and primacy
agencies would benefit as well, since this would eliminate data entry
from paper forms).  EPA plans to enable web site entry of inventory
information in 2007.  States are likely to be the first to use this
technology.  Further analysis is needed to assess how web-entered data
will be exported to other databases (e.g., state databases) as needed.

What Else Should the Agency Consider?

Where possible, examine whether operators submitting paperwork to DI
programs could responsibly retain more of their reporting paperwork at
their facilities and be made responsible for assuring that it is
accurate, complete and available, at all times for inspection by UIC
agencies.  OGWDW recognizes that some of state regulatory requirements
could be more stringent, making the implementation of some burden
reduction practices less likely.  

Attachment 1: Study Group Evaluation of Potential to Eliminate 7520
Form Elements

Element 

(Form number)	Members recommending  Potential Elimination

FINDS number

	10

Existing EPA permits 

	9

Ownership/ private, federal, other

	6

Formation testing program

	5

Injection procedures

	5

Changes in injection fluid

	5

Plans for well failure

	5

Stimulation program

	4

Corrective action plan

	3

Monitoring program

	3

Plugging and abandonment

	1

Elements on Form 7520-7

	Non-lat/long locational data

	7

Name and address of permittee

	2

All of form 7520-8 – monitoring information  

	Elements on Form 7520-9

	Description of surface equipment

	7

Monitoring system

	3

Well design and construction

	2

As-built diagrammatic sketch 

	1

Date drilling completed

	6

Injection zone stimulation

	4

Lease name

	3

Wire line logs, list each type

	3

Schematic or other drawing of surface & subsurface construction

	2

Status of corrective action on defective wells in the area of review

	2

Hole 

	1

Monthly monitoring information

	3

Method of emplacement of cement plugs 

	2

Open hole/or perforated intervals and intervals where casing will be
varied 	1

Transaction type

	6



  The UIC Program ICR estimates the burden to primacy states as well;
however, that burden is not included in the estimate of operator burden
reduction noted above.

Page   PAGE  1 

Please verify date

Please verify

Please add the names of the forms

This was deleted to avoid having to go back and justify why each element
is needed and the debate that might occur.

We may want to specify in a footnote that this is one time reporting, if
it is the only example.

Not sure the value added of this column.

