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903R84001
*i PRCV^0
Regional Center Ioi hnvjronnienul Intormanon
US EPA Region III
1650 Arch St
Philadelphia, PA 19103
OPERATORS COMPLIANCE MANUAL
FOR CLASS I INJECTION WELLS
IN PENNSYLVANIA
Prepared by:
Pennsylvania UIC Team
Water Supply Branch
Environmental Protection Agency
Region III
Philadelphia, PA
With the Assistance of:
SMC Martin Inc.
900 W. Valley Forge Road
P. 0. Box 859
Valley Forge, PA 19482
Task #17
EPA Level of Effort
Contract #68-01-6288
May 1984
Ref: #8417-040-94013
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TABLE OF CONTENTS
B. Permit Authorization for Existing and
New Class I Wells
I I. Introduction 1
• II. The Underground Injection Control Program 2
_ III. Injection Well Classifications 4
IV. Regulation Methods 8
I A. General UIC Program Regulations 8
I
Permit Application Procedure,
• Deadlines, and Durations 10
B Transfer of Permit 13
Emergency Permit 13
| C. Rule Authorization for Existing
Class I Wells 13
V. Technical Requirements and Policies for
Existing and New Class I Wells 16
• A. Casing and Cementing Requirements 16
• B. Well Logging Requirements 16
C. Plugging and Abandonment Procedures 18
I D. Financial Responsibility 21
E. Corrective Action and Area of Review 22
• F. Operating Requirements 23
IWelIhead Injection Pressure 23
Prohibition of Annular Injection 23
Annulus Fluid and Pressure 23
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TABLE OF CONTENTS (Continued)
I Page
• G. Monitoring Requirements 23
H. Reporting Requirements 24
24
Retention of Records 24
Confidentiality of Information 25
I. Authorization Procedures for New
Class I Wells 25
•Quarterly Report
Retention of Rec
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* VI. Emergency Notification Procedures 27
I VIII. EPA's Enforcement Program 28
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APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
LIST OP APPENDICES
Summary Table of Requirements for
Class I Wells
UIC Permit Package
UIC Forms
Ground-Water Flow Equation
List of EPA Region III Staff
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I. INTRODUCTION
The purpose of this operators' compliance manual is to
explain and familiarize the owners and operators of Class I
wells in Pennsylvania with the Underground Injection Control
(UIC) program regulations. It should help all Class I
owners and operators to gain and maintain compliance with
the UIC program.
This manual consists of five sections. The first
section gives an overview of the UIC program and its purpose.
The second section describes permit regulations followed by
regulations by rule. The main section of the manual includes
a description of technical requirements such as construction
requirements, monitoring requirements, mechanical integrity, etc,
Finally, the operators' compliance manual is completed with
the EPA's enforcement program.
1. Background
Most areas of the United States are underlain by geological
formations or strata that are capable of yielding usable
quantities of water. Such geological formations are called
aquifers.
Ground water is usually assumed to be of high quality
and is often used with little or no treatment. Contamination
is usually discovered when the consumer becomes ill and, in
many cases, the only practical solution is to search for
another souce of fresh water. Because of the slow movement
of ground water, it may be decades or even centuries before
the aquifer is once more usable. In some cases, the contami-
nation can never be reversed and the resource may be lost
forever. The effort to clean up the nation's surface waters
is hampered if the base flow of the stream is already contami-
nated .
In several cases, the known or suspected cause of
contamination has been injection wells. Improper well
design, construction, operation, or abandonment can threaten
ground water in a variety of ways.
Congress recognized these potential threats to ground
water when, in the Safe Drinking Water Act of 1974, it
instructed the Environmental Protection Agency (EPA) to
establish a national program to prevent underground injec-
tions which endanger drinking water resources. Between 1974
and the present, EPA has been working with state agencies,
public interest groups, industry, and well owners and operators
to design the UIC program.
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II. THE UNDERGROUND INJECTION CONTROL PROGRAM
The intent of the UIC program is to eliminate or diminish
the threats posed by most types of wells by promoting proper
management of the wells.
The UIC regulations will protect all aquifers or portions
of aquifers
1) a. which supply any public water system; or
b. contain a sufficient quantity of ground water
to supply a public water system; and
i) currently supply drinking water for
human consumption; or
ii) contain fewer than 10,000 mg/1 (ppm)
total dissolved solids; and
2) Which is not an exempted aquifer.
However, procedures are available to allow for exempting
certain aquifers from underground sources of drinking water
(USDW) status if they meet certain criteria as specified in
the regulations.
It should be understood that all injection operations
whether injecting into a USDW or into an exempted USDW must
comply with the various construction, operating, monitoring,
and reporting requirements specified in the UIC regulations.
The UIC program is independent of any state or local
requirements and can be divided into three major parts: regu-
latory, technical, and administrative requirements. Under
Part 144 of the UIC program, injection wells may be regulated
through authorization under rules or permits. Each regulatory
method is appropriate in certain situations; however, permits
are considered to attain a greater degree of control and are
required for new activities or an existing facility whose
status and circumstance changes to warrant a permit, or a
facility which by its nature merits greater regulatory
control. The technical criteria and standards under Parts 146
and 147 address the construction, monitoring, operating and
reporting requirements of most types of injectin wells. The
technical requirements are designed to insure that injected
fluids are contained within the well and the intended injec-
tion zone. Part 147, Subpart NN contains provisions specific
to Pennsylvania injection operations. Finally, Part 124 of
the UIC program contains EPA procedures for issuing, modifying,
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and terminating UIC permits. The general administrative
procedural requirements of the UIC permit program are
outlined in this part. This manual will address:
o The Regulatory Requirements
Regulation by Permit
Regulation by Rule
o The Technical Requirements
Casing and Cementing Requirements
Well Logging Requirements
Plugging and Abandonment Requirements
- Corrective Action and Area of Review
Operating Requirements
Monitoring Requirements
Reporting Requirements
Authorization Procedures for New Class
Wells
o EPA's Enforcement Program
o Emergency Notification Procedures
This document is a guide and not the text of the law.
3
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III. INJECTION WELL CLASSIFICATIONS
To implement the proposed technological controls, EPA
characterized well injection activities into five classes.
Each class includes wells with similar functions, construction,
and operating features so that technical requirements can be
applied to the entire class. The following descriptions of
injection well classes are taken from Part 146 Subpart A of
the UIC regulations and the specified numbers are the most
current estimates. Injection well classifications are given
in Table 1. Definitions for terms used in the description
of injection wells are listed in the glossary.
A. Class I: Wells used by generators, owners, or
operators to inject industrial, hazardous, and
municipal wastes beneath the deepest formation
containing, within one-quarter mile of the well
bore, an underground source of drinking water.
Commonly referred to as deep waste disposal wells.
No active Class I wells exist in Pennsylvania.
B. Class II: Wells used to dispose of nonhazardous
fluids which are brought to the surface in con-
nection with oil and gas production and treatment;
to inject fluids for enhanced recovery of oil and
natural gas; or for the storage of hydrocarbons
which are liquid at standard temperature and
pressure. Approximately 3,000 Class II wells
exist currently in Pennsylvania.
C. Class III: Wells which inject fluids for the
extraction of minerals, including mining of sulfur
by the Frasch process, in situ production of
uranium or other metals from unmined ore bodies,
and solution mining from salts or potash. No
Class III wells are known to exist in Pennsylvania.
D. Class IV: Wells used to dispose of hazardous
wastes or radioactive wastes into or above (within
one-quarter of a mile) a formation that contains
an underground source of drinking water, and those
wells which might inject hazardous wastes into
exempted aquifers. No known Class IV wells exist
in Pennsylvania.
E. Class V: Injection wells not included in Classes I
through IV such as geothermal, subsidence and mine
fire control, ground-water heat pump wells, storm-
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TABLE 1
EPA CLASSIFICATIONS AND TYPES OF INJECTION WELLS
WELL CODE
CLASS/TYPE
CLASS I
II
1M
IX
CLASS II
2A
2D
2H
2R
2X
CLASS III
3M
3S
3U
3X
CLASS IV
4H
CLASS V
5A
SB
5D
5F
5G
51
5N
5R
55
5T
5W
5X
52
PRIMARY FUNCTION
OF INJECTION WELLS
INDUSTRIAL, MUNICIPAL, AND NUCLEAR STORAGE WELLS THAT
INJECT BELOW DEEPEST UNDERGROUND SOURCE OF DRINKING
WATER
Industrial disposal well
Municipal disposal well
Other Class I wells
OIL AND GAS PRODUCTION AND STORAGE-RELATED INJECTION
WLLLS
Annular injection well
Produced fluid disposal well
Hydrocarbon storage well
Enhanced recovery injection well
Other Class II wells
SPECIAL PROCESS INJECTION WELLS
Solution mining well
Sulfur mining well by Frasch process
Uraniuir mining well
Other Class III wells
HAZARDOUS FACILITY WELLS THAT INJECT INTO OR ABOVE
AN UNDERGROUND SOURCE OF DRINKING WATER AND INTO
EXEMPTED AQUIFERS
Hazardous facility injection well
ALL OTHER WELLS THAT INJECT INTO OR ABOVE AN UNDERGROUND
SOURCE OF DRINKING WATER
Air conditioning/cooling water return well
Salinity barrier well
Storm water drainage well
Agricultural drainage well
Other drainage wells
In situ gassification wells
Nuclear waste disposal cr storage well
Recharge well
Subsidence control well
Geothermal well
Waste disposal well
Other Class V wells
Industrial wastewater disposal well
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water drainage, and multiple-dwelling cesspools.
The number of these wells in Pennsylvania is
unknown at this time, but it is estimated that
more than 20,000 wells exist.
The type of controls and requirements applicable to the
different injection well classes are listed in Table 2.
Specific requirements of Class I well types are given in
Table 6 to reflect the various requirements of existing and
new types of Class I wells.
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IV. REGULATION METHODS
In order to provide the operators with a background on
the regulatory methods of the UIC program, the following
section will discuss:
o General UIC Program Regulations
o Permit Authorization for Existing and New Class I
Wells
o Rule Authorization for Existing Class I Wells
A. GENERAL UIC PROGRAM REGULATIONS
The UIC program regulations under Section 144.11 state
that "any undeground injection, except as authorized by
permit or rule issued under the UIC program, is prohibited."
Sections 144.11 and 144.12 also state that "construction of
any well required to have a permit is prohibited until the
permit has been issued" and "no operator or owner shall
construct, operate, maintain, convert, plug, abandon or
conduct any other injection activity in a manner that allows
a movement of fluid containing any contaminant into under-
ground sources of drinking water (USDW)." If hydrogeologic
studies or monitoring of water quality in a USDW indicates
the movement or potential movement of contaminants into a
USDW from Class I wells, EPA can prescribe additional
requirements for construction, corrective action, operation,
monitoring or reporting (including closure of the injection
well) to prevent contaminant movement.
In the UIC program, all injection operations must be
authorized by EPA either through a rule or a permit. Under
the UIC program, a rule is a regulation that sets forth the
standards and conditions under which an activity may be
conducted. A permit is a specific authorization to an
individual to carry on an activity under the conditions and
limitations specified in the permit. Table 3 lists the
various regulations of the UIC program and their publication
dates.
B. PERMIT AUTHORIZATION FOR EXISTING AND NEW CLASS I WELLS
This section covers the following aspects of permit
regulations:
o Who must apply for a permit
o When and where to apply
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TABLE 3
SUMMARY OF UIC REGULATORY DEVELOPMENTS
Part 146 - UIC
Criteria and Standards
Part 146 - Technical Amendments
part 146 - Final Amendments
Part 144 - UIC
Administrative Requirements
Part 144 - Amendments, General Provisions
for EPA-Administered Programs:
Part 147 - UIC
State Specific Requirements
Effective Date of the UIC Program
Comprehensive Publication of all
of the Above
Federal Register
June 24, 1980
August 27, 1981
February 3, 1982
April 1, 1983
May , 1984
May , 1984
Future ??
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o Permit application procedures, deadlines, and
duration
o Change in ownership
o Emergency permit
The principal regulatory method that EPA will use to
regulate the objectives of the source of drinking water
(SDWA) is the permit. All new Class I wells must be authorized
by permit before injection may begin. All existing Class I
wells (wells which began injection before the effective date
of the UIC program) are regulated by rule but must obtain a
permit upon a written notice from EPA and within the time
frame specified by EPA. Table 4 lists the initial procedures
for obtaining a permit for Class I wells. Comprehensive
summaries of requirements are found in Appendix A.
Permit Application Procedures, Deadlines, and Durations
In applying for a permit, the applicant should submit a
completed EPA Form 7520-6 "UIC Permit Application" with all
required attachments. This form and its instructions are
reproduced in Appendix B to demonstrate the range of informa-
tion required, but highlights of responsibilities are included
in Table 5. The form must be signed by a policy-level
officer of the company or individuals authorized by their
companies in writing. Applications must contain a statement
that the signing official has satisfied himself that the
information provided is correct.
In Pennsylvania, the applicant must identify and submit
with the permit application a list of names and addresses of
all owners of record of the land within one-quarter mile of
the site.
The required information will be reviewed by EPA prior
to the issuance of a permit for construction or conversion
of a new Class I well.
Within the UIC program, a permit to construct and test
an injection well is distinct from the authorization to
inject fluids. These approvals are two separate decision
points within the permitting process.
The application deadline for new Class I wells is
within a reasonable time prior to construction.
Permit duration for Class I wells is effective for a
fixed term not to exceed ten years. When a permit is due to
expire, the operator is required to apply for a new permit.
In federally-administered states as Pennsylvania, the condi-
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TABLE 4
INITIAL PROCEDURES FOR
OBTAINING A PERMIT
Who must Apply
When to Apply
Where to Apply
Forms Needed
Operator only, if the operator and
owner are not the same person.
At least 30 days before construction
is expected to begin
Water Management Division Director (3WM40)
Attn: Water Supply Branch Chief
U.S. EPA Region III
6th & Walnut Streets
Philadelphia, PA 19106
(Appendix E lists
EPA Region III staff
members, their titles, and
telephone numbers for reference.)
EPA Form 7520-6 must be signed
by a policy-level officer or
authorized individual of the
company. Application must contain
a statement that the information
provided is correct.
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TABLE 5
RESPONSIBILITIES APPLICABLE
TO ALL UIC PERMITS
CONDITION
Duty to Comply
Duty to Reapply
Duty to Halt or Reduce Activity
Duty to Mitigate
Duty to Properly Operate and
Maintain the Facilities
Duty to Meet Permit Conditions
Pending Approval of
Change of Status
Non-Transference of Property Rights
Duty to Provide Information
Duty to Allow Inspection & Entry
Duty to Monitor Activities
and Maintain Records
Duty to Report Changes and Submit
Required Reports
Duty to Report Within 24 Hours
Any Non-Compliance Which May Endanger
Health or Environment
COMMENT
You must comply with all the conditions of
the permit. Failure to comply constitutes a
violation of the SWDA and is grounds for
enforcement action and/or fines.
You must apply for and obtain a new permit
to continue the specified injection activity
upon the expiration date of your current
permit.
You may have to halt or reduce the level of
infection in order to maintain compliance
with the SWDA
You must take all reasonable steps to
minimize or correct any adverse impacts on
the environment resulting from any permit
violations.
You must properly operate and maintain the
equipment and facilities used in conjunction
with your injection well permit.
Should you request permit modification,
reissuance, revocation or other changes in
permit status, all permit conditions will
still apply until approval of the requested
action.
The permit does not convey any property
rights or exclusive privilege to the holder.
You must furnish, within a reasonable time,
any information which the issuing authority
requests to determine compliance or to
determine cause for changing the status of
the permit.
You must allow an authorized representative
of the issuing agency, access to the
injection well premises and to records
maintained under conditions of the permit.
You must take representative samples and
measurements of your injection activities
and maintain the records of the operation of
your facility in accordance with prescribed
procedures set forth by the permitting
authority.
You must notify the issuing agency as soon as
possible of any planned changes in the
permitted facility:
Physical alterations
Anticipated non-compliance
Transfer of ownership or operator
status.
Additionally, you are obligated to provide
monitoring reports at specified intervals
and reports on compliance or non-compliance
with any progress requirements on compliance
schedule. Records must be retained until
five years after completion of any Plugging
and Abandonment of any injection well.
You must report any information about a
non-compliance that may endanger health or
the environment within 24 hours of the time
you become aware of the circumstances.
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tions of an expired permit continue until the effective date
of the new permit if a permittee submits a timely, complete
application for a new permit and the EPA does not issue a
new permit before or on the expiration date of the previous
permit.
Change in Ownership; A permit may be transferred by the
permittee to a new owner or operator only if the permit has
been modified or revoked and reissued, or a minor modifica-
tion made to identify the new permit and incorporate such
other requirements as may be necessary under the Safe
Drinking Water Act.
A written agreement containing a specific date for
transfer of permit responsibility, coverage, and liability
between the current and new permittee should be submitted to
the EPA [144.21(d)]. The owners or operators should inform
the Regional EPA Administrator within 30 days of transfer of
ownership [144.28(D] .
Emergency Permit
The EPA may grant a temporary emergency permit for a
specific underground injection well which has not been
authorized by rule or permit if the following will otherwise
result:
o An imminent and substantial hazard to human health
or the environment. Permit issued no longer than
needed to prevent hazard.
o Provisions for an emergency permit require that a
timely application for permit could not practically
have been made and the injection well will not
result in the contamination of USDWs.
A temporary emergency permit may be either oral or
written. If oral, a written temporary emergency permit must
follow within five calendar days. A temporary permit may be
subject to other limitations or requirements deemed by the
EPA to insure prevention of aquifer contamination.
C. RULE AUTHORIZATION FOR EXISTING CLASS I WELLS
Injection into existing Class I wells (wells which
began injection before the effective date of the UIC program)
is authorized by rule. However, upon the effective date of
the UIC program, the operator must obtain a permit. In the
EPA-administered program for Pennsylvania, the rule authoriza-
tions for Class I wells are summarized as follows:
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Comply with the appropriate operating, monitoring,
reporting, and mechanical integrity requirements
of rule authorization, as well as construction,
corrective action, retention of records and
financial requirements.
Apply for a permit upon written notice from EPA
and within the time frame specified by EPA. The
agency intends to permit these wells within one
year of the effective date, and
Comply with all the operating, monitoring, reporting,
and abandonment requirements in the permit condi-
tions on the schedule established by the permit.
Inventory Requirements
Owners or operators of all injection wells authorized
by rule must submit the following inventory information to
EPA no later than one year after the effective date of the
UIC program unless a complete permit application is submitted.
This information will be used by the EPA for well inventories,
inspections, and compliance activities. The owner/operator
shall provide at least the following information by letter
or on the national form "Inventory of Injection Wells" OMB
No. 158-R0170 supplied by the EPA (known as an IWIS form,
per Appendix C):
1. Facility name and location
2. Name, address, and telephone number of legal
contact
3. Ownership of facility (public, private, state,
federal, municipal, other)
4. Nature and type of injection wells (i.e., Class I)
5. Operating status of injection wells (active,
abandoned [temporarily or permanently], under
construction)
Table 6 lists general requirements of existing and new
Class I wells.
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V. TECHNICAL REQUIREMENTS AND POLICIES FOR EXISTING
AND NEW CLASS I WELLS
This section covers technical requirements governing
new Class I wells. Requirements for existing wells authorized
by rule are similar but not identical to permit-authorized
well requirements. They include:
o Casing and cementing requirements
o Well logging requirements
o Plugging and abandonment procedures
o Corrective action requirements and area of review
o Operating requirements
o Monitoring requirements
o Authorization procedures for new Class I wells
A. CASING AND CEMENTING REQUIREMENTS
All Class I wells must inject into a formation which is
within one-quarter mile of the well bore and is below the
lowermost formation containing USDWs. Class I injection
wells must have proper casing and cementing designed for the
life expectancy of the well and to protect USDWs.
Class I injection wells must have a surface casing
extending from the surface to a depth of at least 50 feet
below the base of the lowermost USDW and must be cemented
back to the surface by recirculating the cement.
All Class I injection wells must have a long string
casing and tubing extending to the injection zone and cemented
back to 50 feet above the base of the next largest casing
string.
With the exception of those municipal wells injecting
noncorrosive wastes, all Class I wells should inject fluids
through tubing with a packer set immediately above the
injection zone. Table 7 lists factors that must be con-
sidered for casing, cementing, packer, and tubing requirements.
B. WELL LOGGING REQUIREMENTS
After a permit for a new well has been issued, appropriate
logs and other tests should be conducted during the drilling
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TABLE 7
FACTORS CONSIDERED FOR CASING, CEMENTING
PACKER AND TUBING REQUIREMENTS
Casing and Cementing Requirements
1. Depth to the injection zone;
2. Depth to the bottom of all
USDWs;
3. Injection pressure
4. External pressure
5. Internal pressure
6. Axial loading
7. Estimated maximum and
average injection pressure
8. Hole size
9. Size and grade of all
strings:
a. wall thickness
b. diameter
c. nominal weight
d. length
e. joint specification
f. construction material
10. Corrosiveness of injected
fluid, formation fluids, and
temperature;
11. Lithology of injection and
confining intervals;
12. Physical and chemical
characteristics of the
formation fluid;
13. Type or grade of cement.
Packer and Tubing Requirements
1. Depth of setting;
2. Characteristics of injection
fluid such as:
a. chemical content
b. corrosiveness
c. density
3. Injection pressure
4. Annular pressure
5. Rate, temperature, and
volume of injected
fluid;
6. Size of casing.
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and construction of new Class I wells. A descriptive report
should be prepared and forwarded to the EPA office.
Minimal requirements for logs and tests are as follows:
1. Deviation checks on all holes constructed. Such
checks should be at sufficiently frequent intervals
to assure that vertical avenues for fluid migration
in the form of diverging holes are not created
during drilling.
2. Table 8 is a guideline listing type of logs and
tests required for surface casing intended to
protect USDWs and for intermediate and long
strings of casings intended to facilitate
injection.
C. PLUGGING AND ABANDONMENT PROCEDURES [(144.21 (C)(5) and
144.22(A)(5); 144.28(C)(2)(i)J
1. Plugging and Abandonment Plan
All owners and operators of Class I wells are
required to submit a plan for plugging and abandon-
ment to the EPA Regional Administrator no later
than one year after promulgation of the UIC program
in the state on a form provided by EPA. The
owners/operators must submit any proposed revision
to the plan no later than 45 days prior to pluggin
the abandonment [144.28(J)(2)].
The plan should include:
o An estimate of the cost of plugging the well
or wells;
o Records of any tests or measures made;
o The amount, size, and location (by depth) of
casing left in the well;
o The volume of mud used;
o If an attempt is made to part any casing, a
complete report of the method used and the
results obtained;
o A certification from the person who has
performed the plugging operation verifying
the accuracy of the report.
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TABLE 8
Situation
For surface casing
to protect underground
sources of drinking
water
B. For intermediate and
long strings of casing
intended to facilitate
injection.
2
3
Type of Logs & Tests
Resistivity, spontaneous
potential, and caliper logs
before the casing is
installed.
A cement bond, temperature,
or density log after casing
is set and cemented.
Resistivity, spontaneous
potential, porosity, and
gamma ray logs before the
casing is installed.
Fracture logs
A cement bond, temperature
or density log after the
casing is set and cemented.
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b. Plugging Procedures
Prior to abandoning Class I wells, the well should
be plugged with cement in a manner which will not
allow the movement of fluids either into or between
USDWs.
Placement of the cement plugs should be accomplished
by one of the following methods:
1) The Balance Method
2) The Dump Bailer Method
3) The Two-Plug Method
4) An alternative method approved by the EPA
During plugging and abandonment procedures, the
well should be in a state of static equilibrium
with the mud weight equalized top to bottom.
c. Plugging and abandonment report [144.28(K)]
After plugging a well, within 15 days the owner or
operator should submit a plugging and abandonment
report to the EPA office including:
o A statement that the well was plugged in
accordance with the plan earlier submitted to
EPA, or
o Where the actual plugging differed from the
plan, an updated version of the plan speci-
fying the different procedures used.
d. Temporary abandonment
Existing regulations provide that an abandoned
well must be plugged, but the "temporary and
intermittent discontinuation of activities" will
not be considered abandonment. Any well not used
for longer than two years will be considered
"temporarily abandoned and/or intermittent" unless
the owner or operator could demonstrate to the EPA
that the well would be used in the future and that
appropriate steps had been taken to prevent endanger-
ment to USDWs. If such demonstration could not be
made, the well would have to be plugged.
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The temporarily abandoned wells must still comply
with all technical requirements applicable to
operating wells, unless any such requirements are
waived by the EPA. The owner/operator of a tempo-
rarily abandoned well must demonstrate the mechani-
cal integrity of the well at least once every five
years. Requirements to monitor and report the
injection pressure, flow rate, and nature of
fluids could be waived. The owner/operator must
give notice to the EPA before resuming injection
activities.
e. Backup Wells
The backup wells must be maintained as fully-
operating wells, since this very utility is their
capacity for use as an alternative to the primary
well at a moment's notice. The owner/operator
must send reports on these wells just as from
fully-operating wells, even if they reflect only
very intermittent use. Requirements to monitor
and report the injection pressure, flow rate, and
nature of fluids could be waived.
For such wells which are improperly sealed,
completed, or abandoned, a plan composed of
necessary steps or modifications to prevent
movement of fluid into USDWs must be submitted to
EPA as part of the permit application. The plan
will be reviewed by EPA. Where the plan is
adequate, it will be incorporated into the permit
as £ responsibility. Otherwise, the applicant
must review the plan and make the necessary
corrections.
D. FINANCIAL RESPONSIBILITY [144.28(d)(1)]
Each owner or operator of a Class I well, whether
authorized by permit or by rule, is required to maintain the
financial resources to close, plug, and abandon the well(s)
and submit evidence acceptable to EPA, of such financial
responsibility. For wells authorized by rule, it is required
that owners or operators submit such evidence within one
year of the UIC program's effective date in conjunction with
the submission of other operating requirements.
EPA has determined that with respect to wells used to
dispose of hazardous waste, the RCRA financial responsi-
bility criteria would appear to be appropriate.
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E. CORRECTIVE ACTION AND AREA OF REVIEW
Applicants for new Class I injection well permits must
identify the location of all known wells within the area of
review which penetrate the injection zone. In addition, for
Class I wells which will operate at pressures higher than
the injection zone fracture pressure, all known wells within
the area of review penetrating formations affected by the
increase in pressure must be identified. The area of review
for an injection well or project is the lateral distance
where the injection zone pressures may cause the migration
of injection and/or formation fluids into a USDW. This zone
of endangerment can be determined by using a ground-water
flow equation or a fixed radius. The modified Theis ground-
water flow equation from Section 146.06 of the UIC regulations
is listed in Appendix D. This equation has several limita-
tions in its application to area of review procedures;
however, any appropriate ground-water flow model may be
proposed for EPA approval in a permit application. The area
of review may also be a fixed radius. In the case of an
individual well, the fixed radius around the well of not
less than one-fourth (1/4) mile should be used. For an area
permit, a fixed width of not less than one-fourth mile
circumscribing the area may be used.
For wells identified in the area of review which are
improperly sealed, completed, or abandoned, a plan composed
of necessary steps or modifications to prevent movement of
fluid into USDWs must be submitted to the EPA as part of the
permit application. This plan may include recasing, rece-
menting, or replugging of a faulty well. The EPA will
review and approve or disapprove of the plan based on several
factors such as, but not limited to, volume of injected
fluid, geology of the area, and potentially affected popula-
tion. If the plan is approved, it will be incorporated into
the permit as a permit condition. If the plan is not approved,
EPA may prescribe another plan as a permit condition or may
deny the application.
Corrective action may require a lower injection pres-
sure limitation to prevent the pressure in the injection
zone from exceeding the hydrostatic pressure at the site of
any improperly completed or abandoned well within the area
of review. The lower injection pressure limitation may be
made part of a compliance schedule in the permit and last
until all other corrective action is completed.
F. OPERATING REQUIREMENTS
Minimal requirements for Class I wells are:
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1. Wellhead Injection Pressure [46.3(a)(l)j
Except during stimulation, the wellhead injection
pressure should not exceed calculated maximum.
This is to prevent fractures or propagation of
existing fractures in the injection zone during
the injection. In addition, the injection pressure
should not in any case initiate fractures in the
confining zone or cause the movement of injection
or formation fluid into USDW. The maximum wellhead
injection pressure equation rule-authorized Class I
disposal wells in Pennsylvania uses a fracture
gradient value of 0.733 psi/ft. The maximum
wellhead injection pressure equation for these
wells in Pennsylvania is as follows:
Pm = (0.733 - 0.433 Sg)d
where
Pm = Injection pressure at the wellhead in Psi
Sg = Specific gravity of injection fluid (unitless)
d = Injection depth in feet
Also, operators must submit data to EPA on actual
field measured parameters defining the fracture
pressure or gradient for the formation into which
injection is taking place.
2. Prohibition of Annular Injection [46.3(a)(2)]
Injection between the outermost casing protecting
USDW and the wellbore is prohibited.
3. Annulus Fluid and Pressure [46.3(a)(3)]
The annulus between tubing and the long string of
casings should be filled with a noncorrosive fluid
and should be maintained with a positive pressure.
The operator may inject at higher pressures if
requested, approved, and permitted by EPA.
MONITORING REQUIREMENTS [144.28(g)(1)(i); 146.14(A)(7)(iii)]
Monitoring requirements for Class I wells are as follows:
1. Frequent analysis of the injection fluid.
2. Observation of injection pressure, flow rate, and
cumulative volume and annulus between the tubing
and the long string casing at least within the
following frequencies.
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o
o
o
o
3. Observation of the wells in the area of review to
monitor fluid movements into and pressure in the
USDWs.
Installation of monitoring wells is not required;
however, EPA has the authority to require them when appro-
priate [144.28(G)(1)(iii)].
4. A demonstration of mechanical integrity performed
initially and once every five years during the
life of the injection well. EPA will notify
owners and operators in writing of the schedule
for these tests.
In conducting and evaluating the mechanical integ-
rity test, the owner/operator and the EPA shall
apply methods and standards generally accepted in
the industry. The owner/operator's report to the
EPA must include a description of the test(s), the
methods used, and the results of the test.
D. REPORTING REQUIREMENTS
1. A quarterly monitoring report should be submitted
to the EPA office summarizing all required
monitoring. This report should include:
a. The physical, chemical, and other relevant
characteristics of injection fluids.
b. Monthly average, maximum, and minimum values
for injection pressure, flow rate and volume,
and annular pressure.
c. Reporting the results of the mechanical
integrity tests, any other tests of the
injection well conducted by the owner or
operator if required by the EPA office, and
any well workover.
2. Retention of Records
The owner or operator of Class I wells shall
retain records of all monitoring information
including the following:
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a. Calibration and maintenance records and all
original strip chart recordings for continu-
ous monitoring instrumentation, and copies of
all required reports for a period of at least
three years from the date of the sample,
measurement, or report. This period may be
extended by request of the EPA at any time;
and
b. The nature and composition of all injected
fluids until three years after the completion
of any plugging and abandonment procedures
specified under UIC regulations. In Pennsyl-
vania, the owner or operator shall continue
to retain the records after the three-year
retention period unless he delivers the
records to the EPA or obtains written approval
from the EPA to discard the records.
3. Confidentiality of Information
Any information submitted to EPA under the
UIC program including applications, notices,
reports, and other material may be claimed as
confidential by the submitter. A claim of confi-
dentiality must be made at the time of information
submission in the manner prescribed on the appli-
cation form or instructions, or by stamping the
words "confidential business information" on each
page containing such information. If no claim is
made at the time of submission, EPA may make the
information available to the public without further
notice.
Claims for confidentiality for the following
information will be denied:
(1) The name and address of any permit applicant
or permittee, and
(2) Information about the existence, absence, or
level of contaminants in drinking water.
I. AUTHORIZATION PROCEDURES FOR NEW CLASS I WELLS
The general procedure required for authorizing new
Class I wells are listed in Table 9. The permit application
is reproduced in Appendix B, with various other UIC forms in
Appendix C.
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TABLE 9. INITIAL AUTHORIZATION PROCEDURES FOR A
NEW CLASS I WELL
If you plan to drill and construct a new Class I
produced fluid disposal well, you must:
1. Complete and submit a UIC permit application (EPA
Form 7520-6) during the planning phase of the
injection well as far in advance as possible.
2. Wait for EPA permit approval before drilling the
injection well. EPA will respond to the permit
application with a project decision schedule.
3. Upon EPA's approval to construct the well and
after drilling, testing, and completion of
injection well, submit "Completion Reports" (EPA
Forms 7520-9 and 10) to EPA and wait for EPA
review of report for approval to commence
injection approval. Completion report includes
initial mechanical integrity testing results.
4. Upon approval to inject, you may begin operating
and you must comply with all operating,
monitoring, and reporting requirements specified
in the permit.
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VI. EMERGENCY NOTIFICATION PROCEDURES
The owner or operator of an injection well, whether
authorized by rule or by permit, shall report any noncompli-
ance which may endanger health or the environment including:
o Any monitoring or other information which indi-
cates that a contaminant may endanger a USDW; or
o Any noncompliance with a permit condition or
malfunction of the injection system which may
cause fluid migration into or between USDW(s).
The emergency report shall be provided orally within
24 hours from the time the owner or operator becomes aware
of the circumstances. A written submission shall also be
provided within five days of the time the owner or operator
becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, including
exact dates and times, and if the noncompliance has not been
corrected, the anticipated time it is expected to continue
and the steps taken or plan to reduce, eliminate, and prevent
recurrence of the noncompliance.
To report any noncompliance or malfunction of an injec-
tion system, immediately telephone:
Charles Kleeman at (215) 597-2537
or
George Hoessel at (215) 597-903
Written reports of emergency or noncompliance should be
sent to the EPA Staff persons listed above at the following
address:
Pennsylvania Implementation Section (3WM43)
Water Supply Branch
U.S. EPA Region III
6th & Walnut Streets
Philadelphia, PA 19106
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VII. EPA'S ENFORCEMENT PROGRAM
Enforcement Capabilities
The EPA has several mechanisms for identifying non-
compliance activities. In addition to well inventories and
public concern, site inspections by EPA authorities during
construction and operation is an important enforcement
mechanism. Any owner or operator must allow the EPA or an
authorized representative, upon the presentation of creden-
tials to:
1. Enter the premises at the injection facility
location or site of record retention;
2. Have access to and copy any records that are kept
under permit conditions;
3. Inspect any facilities, equipment, practices or
operations required or regulated under a permit at
a reasonable frequency; and
4. Sample or monitor at a reasonable frequency any
substances or parameters at any location to assure
compliance.
Enforcement action by EPA may be taken for several
noncompliance activities such as: 1) failure to apply for a
required permit, 2) failure to comply with permit conditions
or requirements of rule authorization, 3) expired permits,
and 4) improper action to minimize or correct any adverse
impact on the environment resulting from noncompliance.
Penalties for Noncompliance
The severity of a penalty will be based on the serious-
ness of the violation and on a case-by-case basis at the
discretion of the EPA. Violators of the UIC regulations are
subject to either civil or criminal penalties. These penalties
are outlined in Section 1423 of the Safe Drinking Water Act
(SDWA). Any person who violates any UIC requirement shall
be subject to a civil penalty of not more than $5,000 for
each day of such violation. If a violation is willfully
committed, it is classified as a criminal violation and may
result in a fine of not more than $10,000 for each day of
such violation.
In the appeal of a draft or final permit, several
opportunities exist for the permit applicant to comment on
28
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his/her permit application. Table 10 illustrates the admin-
istrative process for permit issuance. Comments or appeals
from the permit applicant are allowed during the public
comment and hearing periods and within 30 days after the
final permit decision. Permit requirements, compliance
schedules, or penalties may be appealed through the EPA
Regional Council.
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TABLE 10
THE UIC PERMIT PROCESS
Action
Required:
Action by:
Prepare and Submit
Permit Application
Well Operator
Review and Analyze
Permit Application
EPA
Prepare Draft Permit
and Fact Sheet
EPA
Give Public Notice
of Draft Permit
Solicit Comments
EPA
Give Public Notice
of Hearings, Hold
Hearings
EPA
Hold Cross-Exam
Hearings If Required
EPA
Review Public Comments/
Hearing Transcripts
EPA
Prepare Final Permit,
Respond to Comments
EPA
Issue Final Permit
EPA
Prepare Final
Administrative Record
EPA
Appeal Decision
Interested Party
Rule on Appeal
EPA Adminstrator
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GLOSSARY
ABANDON - To cease efforts to produce oil or gas from a
well, or to plug a depleted formation and salvage all
material and equipment.
ABANDONED WELL - A well whose use has been permanently
discontinued or which is in a state of disrepair such
that it cannot be used for its intended purpose or for
observation purposes.
AQUIFER - A geological formation, group of formations, or
part of a formation that is capable of yielding a
significant amount of water to a well or spring.
AREA OF REVIEW - An area surrounding an injection well
within which all wells which penetrate the injection
zone must be reviewed and, if necessary, repaired in
order to prevent fluid migration.
CASING - A heavy metal (steel or iron) pipe or tubing of
varying diameter and weight, lowered into a borehole
during or after drilling in order to support the sides
of the hole and thus prevent the walls from caving; to
prevent loss of drilling mud into porous ground; or to
prevent water, gas, or other fluid from entering the
hole.
CATASTROPHIC COLLAPSE - The sudden and utter failure of
overlying "strata" caused by removal of underlying
materials.
CEMENTING - The operation whereby a cement slurry is pumped
into a drilled hole and/or forced behind the casing.
CONFINING BED - A body of impermeable or distinctly less
permeable material stratigraphically adjacent to one or
more aquifers.
CONFINING ZONE - A geological formation, group of formations,
or part of a formation that is capable of limiting
fluid movement above an injection zone.
CONTAMINANT - Any physical, chemical, biological, or radio-
logical substance or matter in water.
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GLOSSARY - Continued
EXEMPTED AQUIFER - An aquifer or its portion that meets the
criteria in the definition of "underground source of
drinking water" but which has been exempted according
to the procedures of UIC regulations.
FAULT - A surface or zone of rock fracture along which there
has been displacement.
FLOW RATE - The volume per time unit given to the flow of
gases or other fluid substance which emerges from an
orifice, pump, or turbine or which passes along a
conduit or channel.
FLUID - A material or substance which flows or moves whether
in a semisolid, liquid, sludge, or gas or any other
form or state.
FORMATION - A body of rock characterized by a degree of
lithology homogeneity which is prevailingly, but not
necessarily, tabular and is mappable on the earth's
surface or traceable in the subsurface.
FRACTURING - Application of pressure to the reservoir forma-
tion to create fractures through which oil or gas may
move to the well bore or injected waste move into the
formation.
GROUND WATER - Water below the land surface in a zone of
saturation.
HOMOGENEITY - The state of a reservoir or aquifer of having
a common property throughout, such as porosity.
INJECTION ZONE - A geological formation, group of formations,
or part of a formation receiving fluids through a well.
IN SITU PRODUCTION - The setting afire of some portion of
the reservoir in order that the gases produced by
combustion will drive oil ahead of it to the producing
wells. Also, the in-ground retorting of shale in order
to produce recoverable oil.
KEY WELL - A landmark well used to locate additional wells
on the property.
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GLOSSARY - Continued
MECHANICAL INTEGRITY - A condition of injection wells which
exists if there is no significant leakage in the well's
casing, tubing, or packer and no significant movement
of fluids between the outermost casing and the well
base.
PACKER - A device lowered into a well which can be expanded
to produce a watertight seal.
PLUGGING - The act or process of stopping the flow of water,
oil, or gas in "formations" penetrated by a borehole or
"well".
PLUGGING RECORD - A systematic listing of permanent or
temporary abandonments of water, oil, gas, test, explora-
tion and waste injection wells, which may contain a
well log, description of amounts and types of pluggina
material used, the method employed for plugging, a
description of formations which are sealed, and a
graphic log of the well showing formation location.
PROMULGATION - An action of putting into force a law or
regulation by formal proclamation.
PUBLIC WATER SYSTEM - Any water system which provides
15 service connections or serves 25 or more individuals
with an adequate supply of drinkable water.
STRATUM (PLURAL STRATA) - A single sedimentary bed or layer,
regardless of thickness, that consists of generally the
same kind of rock material.
SUBSIDENCE - The lowering of the natural land surface in
response to: Earth movements; lowering of fluid pressure;
removal of underlying supporting material by mining or
solution of solids, either artificially or from natural
causes; compaction due to wetting (hydrocompaction);
oxidation of organic matter in soils; or added load on
the land surface.
SURFACE CASING - The first string of well casing to be
installed in the well for the protection of fresh water
zones. Not to be confused with conducter pipe.
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GLOSSARY - Continued
TOTAL DISSOLVED SOLIDS ("TDS") - The total dissolved
(filterable) solids.
UNDERGROUND SOURCE OF DRINKING WATER ("USDW") - An "aquifer"
or its portion: (l)(i) which supplies or may supply
drinking water for human consumption; or (ii) in which
the ground water contains fewer than 10/000 mg/1 "total
dissolved solids"; and (2) which is not an "exempted
aquifer."
WELL - A bored, drilled, or driven shaft, or a dug hole
whose depth is greater than the largest surface
dimension.
WELL INJECTION - The subsurface emplacement of fluids
through a bored, drilled, or driven well; or through a
dug well, where the depth of the dug well is greater
than the largest surface dimension.
WELL LOG - A log obtained from a well, showing such infor-
mation as resistivity, radioactivity, spontaneous
potential, and acoustic velocity as a function of
depth.
WELL STIMULATION - Several processes used to clean the well
bore, enlarge channels, and increase pore space in the
interval to be injected thus making it possible for
wastewater to move more readily into the formation,
including (1) surging, (2) jetting, (3) blasting,
(4) acidizing, (5) hydraulic fracturing.
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APPENDIX A
SUMMARY TABLE OF REQUIREMENTS FOR
CLASS I WELLS
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APPENDIX B
UIC PERMIT PACKAGE
-------
Form
UIC
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
UNDERGROUND INJECTION CONTROL
PERMIT APPLICATION
fCo/tereo't/noV th» Mttoritv efthf £*/* Drinking
WtttrAa. Stelhnt 1421. 1422.40 CM 1441
. EPA ID NUMBER
T/A
KADATTACHtD INSTRUCTIONS ftffOftf STARTING
K>R OffICIAL USE ONLY
Data Received
Permit/Well Number
Contmenu
II. FACILITY NAME AND ADDRESS
Facility NWM
HI OWNER/OPERATOR AND ADDRESS
Owner/Operator Neme
Street Address
City
State I ZIP Cod*
City
SUM ZIP Codt
IV. OWNERSHIP STATUS (M»rk '*')
D A. Fwtonl D B. Sut« D C. Privn*
D D. Public D E. Other (C*t>l*in)
VI. WEU STATUS (Mirt V
D C. PropoMd
D B. Modificmion/ConvwBion
VII TYPE OF PERMIT REQUESTED (Mirk Y »ndspecify if r»quir»4)
NameU) of fieW(s| or proi«a(s)
Number of Prc-
Number of Exist
D A. Individual D B. ATM
VIII CLASS AND TYPE OF WELL ISM r»^»r«»;
D. Number of wells per type (if erea permit)
B. Type(s)
fviwer cod*(tl)
C. H class is "other" or type it code X' explain
A Clashes)
(»nt»r eodfftU
X. INDIAN LANDS (M»rt Vf
IX LOCATION OF WELUS) OR APPROXIMATE CENTER OF FIELD OR PROJECT
Township end Range
XI. ATTACHMENTS
(Complete the following questions on • separate aheet(s} and number accordingly; see instructions)
FOR CLASSES I. II. Ill (and other classes) complete and submit on separate sheets) Attachments A — U (pp 2-6) as
appropriate. Anach maps where required. List attachments by letter which are applicable and are included with
your application:
XII CERTIFICATION
/ certify under the penalty of law that I have personally examined and am familiar with the
information submitted in this document and all attachments and thai based on my inquiry of
those individuals immediately responsible for obtaining the information, I believe that the
Information is true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment, (fief. 40 CFR
1*4.32)
A. Name and Title fjypt or Print)
C. Signature
EPA Form 7B2O-* (2-84)
B. Phone No. (Am Codt antfMo./
D. Date Signed
-------
Class I
Type "I"
"M"
"W"
"X"
Class II
Type "D"
"R"
"H"
"X"
Class III
Type "G"
"S"
"U"
"X"
Other Classes
Wall Class and Type Codas
Wells used to inject waste below the deepest underground source of drinking water.
Nonhazardous industrial disposal well
Nonhazardous municipal disposal well
Hazardous waste disposal well injecting below USDWs
Other Class I wells (not included in Type "I." "M." or "W")
Oil and gas production and storage related injection wells.
Produced fluid disposal well
Enhanced recovery well
Hydrocarbon storage well (excluding natural gas)
Other Class II wells (not included in Type "D," "R," or "H")
Special process injection wells.
Solution mining well
Sulfur mining well by Frasch process
Uranium mining well (excluding solution mining of conventional mines)
Other Class III wells (not included in Type "G." "S." or "U")
Wells not included in classes above.
Class V wells which may be permitted under {144.12
Wells not currently classified as Class I, II. III. or V.
Class
I new well
existing
II new well
existing
III new well
existing
Other
Classes
Attachments to Permit Application
Attachments
A. B. C. D. F. H — S. U
A. B. C. D. F. H - U
A. B. C. E. G. H. M. a R; optional — I. J. K, O. P. U
A. E. G. H. M. a R — U; optional — J. K. 0. P. Q
A. B. C. D. F. H. I. J. K. M — S. U
A. B. C, D. F. H. J. K. M — U
To be specified by the permitting authority
EPA Form 7520-6 (2-84)
page 2 of 5
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INSTRUCTIONS — Attachments to Form 4
Attachments to be submitted with permit application for Class I. II. Ill and other wells.
A. AREA OF REVIEW METHODS — Give the methods and. if appropriate, the calculations used to determine the size
of the area of review (fixed radius or equation). The area of review shall be a fixed radius of V4 mile from the well bore
unless the use of an equation is approved in advance by the Director.
B. MAPS OF WELLS/AREA AND AREA OF REVIEW —Submit a topographic map. extending one mile beyond the
property boundaries, showing the injection well(s) or project area for which a permit is sought and the applicable
area of review. The map must show all intake and discharge structures and all hazardous waste, treatment, storage,
or disposal facilities. If the application is for an area permit, the map should show the distribution manifold (if
applicable) applying injection fluid to all wells in the area, including all system monitoring points. Within the area of
review, the map must show the following-
Class I
The number, or name, and location of all producing wells, injection wells, abandoned wells, dry holes, surface
bodies of water, springs, mines (surface and subsurface), quarries, and other pertinent surface features, including
residences and roads, and faults, if known or suspected. In addition, the map must identify those wells, springs.
other surface water bodies, and drinking water wells located with one quarter mile of the facility property boundary.
Only information of public record is required to be included on this map;
Class II
In addition to requirements for Class I, include pertinent information known to the applicant. This requirement does
not apply to existing Class II wells;
Class III
In addition to requirements for Class I, include public water systems and pertinent information known to the
applicant.
C. CORRECTIVE ACTION PLAN AND WELL DATA —Submit a tabulation of data reasonably available from public
records or otherwise known to the applicant on all wells within the area of review, including those on the map
required in B, which penetrate the proposed injection zone. Such data shall include the following:
Class I
A description of each well's type, construction, date drilled, location, depth, record of plugging and/or completion,
and any additional information the Director may require. In the case of new injection wells, include the corrective
action proposed to be taken by the applicant under 40 CFR 144.55.
Class II
In addition to requirements for Class I, in the case of Class II wells operating over the fracture pressure of the
injection formation, all known wells within the area of review which penetrate formations affected by the increase
iin pressure This requirement does not apply to existing Class II wells.
Class III
In addition to requirements for Class I. the corrective action proposed under 40 CFR 144.55 for all Class III wells
MAPS AN D CROSS SECTIONS OF USDWs — Submit maps and cross sections indicating the vertical limits of all
underground indicating the vertical limits of all underground sources of drinking water within the area of review
(both vertical and lateral limits for Class I), their position relative to the injection formation and the direction of water
movement, where known, in every underground source of drinking water which may be affected by the proposed
injection. (Does not apply to Class II wells.)
NAME AND DEPTH OF USDWs (CLASS II) - For Class II wells, submit geologic name, and depth to bottom of all
underground sources of drinking water which may be affected by the injection.
MAPS AND CROSS SECTIONS OF GEOLOGIC STRUCTURE OF AREA - Submit maps and cross sections
detail.ng the geologic structure of the local area (including the lithology of injection and confining intervals) and
generalized maps and cross sections illustrating the regional geologic setting. (Does not apply to Class II wells.)
GEOLOGICAL DATA ON INJECTION AND CONFINING ZONES (CLASS II) - For Class II wells, submit
appropriate geological data on the injection zone and confining zones including lithologic description, geological
name, thickness, depth and fracture pressure.
EPA Form7520-6 (2-i4) p,Be 4 erf B
-------
INSTRUCTIONS — Form 4 — Underground Injection Control (UIC) Permit Application
Form 4 must be completed by all owners or operators of Class I, II, and III injection wells and others who may be directed to
apply for a UIC permit by the Director.
I. EPA I.D. NUMBER — Fill in your EPA Identification Number. If you do not have a number, leave blank.
II. FACILITY NAME AND ADDRESS - Name of well, well field or company and address.
III. OWNER/OPERATOR NAME AND ADDRESS - Name and address of owner/operator of well or well field.
IV. OWNERSHIP STATUS — Mark the appropriate box to indicate the type of ownership.
V. SIC CODES — List at least one and no more than four Standard Industrial Classification (SIC) Codes that best describe
the nature of the business in order of priority.
VI. WELL STATUS — Mark Box A if the well(s) were operating as injection wells on the effective date of the UIC Program
for the State. Mark Box B if the well(s) existed on the effective date of the UIC Program for the State but were not utilized
for injection. Box C should be marked if the application is for an underground injection project not constructed or not
completed by the effective date of the UIC Program for the State.
VII. TYPE OF PER MIT—Mark "Individual" or "Area" to indicate the type of permit desired. Note that area permits are at
the discretion of the Director and that wells covered by an area permit must be at one site, under the control of one person
and do not inject hazardous waste. If an area permit is requested the number of wells to be included in the permit must be
specified and the wells described and identified by location. If the area has a commonly used name, such as the "Jay
Field," submit the name in the space provided. In the case of a project or field which crosses State lines, it may be possible
to consider an area permit if EPA has jurisdiction in both States. Each such case will be considered individually, if the
owner/operator elects to seek an area permit.
VIII. CLASS AND TYPE OF WELL — Enter in these two positions the Class and type of injection well for which a permit
is requested. Use the most pertinent code selected from the list on the reverse side of Form 4. When selecting type X
please explain in the space provided.
IX. LOCATION OF WELL — Enter the latitude and longitude of the existing or proposed well expressed in degrees,
minutes, and seconds or the location by township, and range, and section, as required by 40 CFR146. If an area permit is
being requested, give the latitude and longitude of the approximate center of the area.
X. INDIAN LANDS — Place an "X" in the box if any part of the facility is located on Indian lands.
XI. ATTACHMENTS — Note that information requirements vary depending on the injection well class and status
Attachments for Class I, II, and III are described on pages 4 and 5 of this document and listed by Class on page 2. Place EPA
ID number in the upper right hand corner of each page.
XII. CERTIFICATION — All permit applications (except Class II) must be signed by a responsible corporate officer for a
corporation, by a general partner for a partnership, by the proprietor of a sole proprietorship, and by a principal executive
or ranking elected official for a public agency. For Class II, the person described above should sign, or a representative
duly authorized in writing.
EPA Form 7520-6 (2-84) Page 3 of 5
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H. OPERATING DATA — Submit the following proposed operating data for each well (including all those to be
covered by area permits):(1) average and maximum daily rate and volume of the fluids to be injected; (2) average and
maximum injection pressure; (3) nature of annulus fluid; (4) for Class I wells, source and analysis of the chemical,
physical, radiological and biological characteristics, including density and corrosiveness, of injection fluids. (5) for
Class II wells, source and analysis of the physical and chemical characteristics of the injection fluid, (6) for Class III
wells, a qualitative analysis and ranges in concentrations of all constituents of injected fluids. If the information is
proprietary, maximum concentrations only may be submitted, but all records must be retained.
I. FORMATION TESTING PROGRAM — Describe the proposed formation testing program. For Class I wells the
program must be designed to obtain data on fluid pressure, temperature, fracture pressure, other physical.
chemical, and radiological characteristics of the injection matrix and physical and chemical characteristics of the
formation fluids.
For Class II wells the testing program must be designed to obtain data on fluid pressure, estimated fracture
pressure, physical and chemical characteristics of the injection zone. (Does not apply to existing Class II wells or
projects.)
For Class III wells the program must be designed to obtain data on fluid pressure, fracture pressure, and physical
and chemical characteristics of the formation fluids if the formation is naturally water bearing. Only fracture
pressure is required if tne formation is not water bearing. (Does not apply to existing Class III wells or projects )
J. STIMULATION PROGRAM — Outline any proposed stimulation program.
K. INJECTION PROCEDURES — Describe the proposed injection procedures including pump, surge, tank, etc.
L. CONSTRUCTION PROCEDURES — Discuss the construction procedures (according to §146.12 for Class I,
§146.22 for Class II, and §146 32 for Class III) to be utilized. This should include details of the casing and cementing
program, logging procedures, deviation checks, and the drilling, testing and coring programs, and proposed annulus
fluid. (Request and submission of justifying data must be made to use an alternative to a packer for Class I.)
M. CONSTRUCTION DETAILS — Submit schematic or other appropriate drawings of the surface and subsurface
construction details of the well.
N. CHANGES IN INJECTED FLUID — Discuss expected changes in pressure, native fluid displacement, and
direction of movement of injected fluid. (Class III wells only.)
O. PLANS FOR WELL FAILURES — Outline contingency plans (proposed plans, if any. for Class II) to cope with all
shut-ins or well failures, so as to prevent migration of fluids into any USDW.
P. MONITORING PROGRAM —Discusstheplanned monitoringprogram.Thisshouldbe thorough, including maps
showing the number and location of monitoring wells as appropriate and a discussion of monitoring devices,
sampling frequency, and parameters measured. If a manifold monitoring program is utilized, pursuant to
§146 23(bK5). describe the program and compare it to individual well monitoring.
Q. PLUGGING AND ABANDONMENT PLAN — Submit a plan for plugging and abandonment of the well including
(1) describe the type, number, and placement (including the elevation of the top and bottom) of plugs to be used, (2)
describe the type, grade, and quantity of cement to be used, and (3) describe the method to be used to place plugs
including the method used to place the well in a state of static equilibrium prior to placement of the plugs Also for a
Class III well that underlies or is in an exempted aquifer, demonstrate adequate protection of USDWs Submit this
information on EPA Form 7520-14, Plugging and Abandonment Plan.
R. NECESSARY RESOURCES — Submit evidence such as a surety bond or financial statement to verify that the
resources necessary to close, plug or abandon the well are available.
S. AQUIFER EXEMPTIONS — If an aquifer exemption is requested, submit data necessary to demonstrate that the
aquifer meets the following criteria. (1) does not serve as a source of drinking water; (2) cannot now and will not in
the future serve as a source of drinking water, and (3) the TDS content of the ground water is more than 3.000 and
less than 10.000 mg/l and is not reasonably expected to supply a public water system. Data to demonstrate that the
aquifer is expected to be mineral or hydrocarbon producing, such as general description of the mining zone, analysis
of the amenability of the mining zone to the proposed method, and time table for proposed development must also be
included. For additional information on aquifer exemptions, see 40 CFR 144.7 and 146.04.
T. EXISTING EPA PERMITS — List program and permit number of any existing EPA permits, for example. NPDES,
PSD. RCRA. etc
U. DESCRIPTION OF BUSINESS — Give a brief description of the nature of the business.
'•"'•• »«?0-8 (2-S4)
-------
APPENDIX C
UIC PROGRAM FORMS
-------
farm Approved. OMB No. 2OOO-O042. Appro"! •xpin* 9-30-36
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
jj_ WASHINGTON, DC 204«0
ANNUAL DISPOSAL/INJECTION WELL MONITORING REPORT
NAME AND ADDRESS .OF EXISTING PERMITTEE
NAME AND ADDRESS OF SURFACE OWNER
LOCATE WELL AND OUTLINE UNIT ON
SECTION PLAT — 640 ACRES
W
STATE
COUNTY
PERMIT NUMBER
SURFACE LOCATION DESCRIPTION
V* OF 14 OF
% SECTION
TOWNSHIP
RANGE
LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
Surfaca
Location.
_ftfrom(N/S).
ft. froffi {
WELL ACTIVITY
D Brine Disposal
D Enhanced Recovery
O Hydrocarbon Storage
Laos* Nama
. Lin* of quartar saetion
-Una of guartar (action
TYPE OF PERMIT
O Individual
DAraa
Number of Wells.
Wall Number
Monitoring Location:
(if manifold monitoring) ^
Mature of Injection Fluid
INJECTION PRESSURE
TOTAL VOLUME INJECTED
FLOW RATE
(BBL/Day)
MONTH YEAR
AVERAGE PSIG
MAXIMUM PSIG
BBL
MCF
AVERAGE
MAXIMUM
CERTIFICATION
/ certify under the penalty of law that I have personally examined and am familiar with the information submitted in
this document and all attachments and that, based on my inquiry of those individuals immediately responsible for
obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ref. 40
CFR 144.32).
NAME AND OFFICIAL TITLE (Plfmst typ» or prim/
SIGNATURE
DATE SIGNED
EPA Form 7520-11 '7-84)
-------
Appro*ft expires 9-30-86
£EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
WELL REWORK RECORD
[ NAME AND ADDRESS OF PERMITTEE
NAME AND ADDRESS OF CONTRACTOR
LOCATE WELL AND OUTLINE UNIT ON
SECTION PLAT — 640 ACRES
..
1 1
1 1 I
1 1
1
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1
J
STATE
COUNTY
PERMIT NUMBER
SURFACE LOCATION DESCRIPTION
V* OF V* OF
tt SECTION
TOWNSHIP
RANGE
LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
Surface
Location.
.ftffom(N/S)_
.ft. from(E/W)
Line of quarter Metion
. Line of quarter section
WELL ACTIVITY
D Brine Disposal
O Enhanced Recovery
D Hydrocarbon Storage
Lease Name
Total Depth Before Rework
Total Depth After Rework
Date Rework Commenced
Date Rework Completed
TYPE OF PERMIT
D Individual
DArea
Number of Wells
Well Number
WELL CASING RECORD — BEFORE REWORK
T* Casing
| Size
•
1
|
L
1
f
Depth
Cement
Sacks
Type
Perforations
From
To
Acid or Fracture
Treatment Record
WELL CASING RECORD - AFTER REWORK (Indicate Additions and Changes Only)
Sue
Casing
Depth
Cement
Sacks
Type
Perforations
From
To
Acid or Fracture
Treatment Record
DESCRIBE REWORK OPERATIONS IN DETAIL
USE ADDITIONAL SHEETS IF NECESSARY
WIRE LINE LOGS, LIST EACH TYPE
Log Types
Logged Intervals
CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations, (fief. 40 CFR 122.22).
\Ml AND OFFICIAL TITLE (Please type or print/
SIGNATURE
DATE SIGNED
Form 7620-12 (1-84)
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Form Approved. OMB No 2OOO-OO42
Approval fxpirts 9-30-86
A EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 2046O
COMPLETION FORM FOR INJECTION WELLS
ADMINISTRATIVE INFORMATION
1. Permittee
Address (Permanent Mailing Address) (Street, City. State, and ZIP Code)
\ 2. Operator
Address (Street. City. State, and ZIP Code)
3. Facility Name
Telep, ,ie Number
Address (Street. City. State, and ZIP Code)
4. Surface Location Description of Injection Wetl(s)
State
County
V4of
V* section
Township
Range
Feet from (N/S)
Line of quarter section and
Feet from (E/W)
Line of quarter section
Submit with this Completion Form the attachments listed in Attachments for Completion Form.
CERTIFICATION
/ certify under the penalty of law that I have personally examined and am familiar with the information
submitted in this document and all attachments and that, based on my inquiry of those individuals
immediately responsible for obtaining the information, I believe that the information is true, accurate,
and complete. I am aware that there are significant penalties for submitting false information, including
the possibility of fine and imprisonment. (Ref. 40 CFR 144.32j.
NAME AND OFFICIAL TITLE (Plftse type or print)
SIGNATURE
DATE SIGNED
•PA Form 7520-9 (2-84)
CONTINUED ON REVERSE
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Attachments to be submitted with the Completion report:
I. Geologic Information
1. Lithology and Stratigraphy
A. Provide a geologic description of the rock units pene-
trated by name, age, depth, thickness, and lithology of
each rock unit penetrated.
B. Provide a description of the injection unit.
(1)Name
(2) Depth (drilled)
(3) Thickness
(4) Formation fluid pressure
(5) Age of unit
(6) Porosity (avg.)
(7) Permeability
(8) Bottom hole temperature
(9) Lithology
(10) Bottom hole pressure
(11) Fracture pressure
C. Provide chemical characteristics of formation fluid
(attach chemical analysis).
D. Provide a description of freshwater aquifers.
(1) Depth to base of fresh water (less than 10,000
mg/1 IDS).
(2) Provide a geologic description of aquifer units with
name, age, depth, thickness, lithology, and average total
dissolved solids.
II. Well Design and Construction
1. Provide data on surface, intermediate, and long string
casing and tubing. Data must include material, size,
weight, grade, and depth set.
2. Provide data on the well cement, such as type/class,
additives, amount, and method of emplacement.
3. Provide packer data on the packer (if used) such as
type, name and model, setting depth, and type of annu-
lar fluid used.
4. Provide data on centralizers to include number, type
and depths.
5. Provide data on bottom hole completions.
6. Provide data on well stimulation used.
III. Description of Surface Equipment
1. Provide data and a sketch of holding tanks, flow lines,
filters, and injection pump
IV. Monitoring Systems
1. Provide data on recording and nonrecording injection
pressure gauges, casing-tubing annulus pressure
gauges, injection rate meters, temperature meters, and
other meters or gauges.
2. Provide data on constructed monitor wells such as
location, depth, casing diameter, method of cementing,
etc.
V. Logging and Testing Results
Provide a descriptive report interpreting the results of
geophysical logs and other tests. Include a description
and data on deviation checks run during drilling.
VI. Provide an as-built diagrammatic sketch of the injec-
tion well(s) showing casing, cement, tubing, packer,
etc., with proper setting depths. The sketch should
include well head and gauges.
VII. Provide data demonstrating mechanical integrity
pursuant to 40 CFR 146.08.
VIII. Report on the compatibility of injected wastes with
fluids and minerals in both the injection zone and the
confining zone.
IX. Report the status of corrective action on defective
wells in the area of review.
X. Include the anticipated maximum pressure and flow
rate at which injection will operate.
EPA Form 7520-9 (2-84) Revaraa
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OMB Ho 2OOO
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Afprovit »xptr»s
3EPA
UNTIED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 2OMO
PLUGGING AND ABANDONMENT PLAN
NAME AND ADDRESS OF FACJUTY
NAME AND ADDRESS Of OWNER/OPERATOR
LOCATE WELL AND OUTLINE UNTT ON
SECTION PLAT - «40 ACHES
W
STATE
COUNTY
PERMIT NUMBER
SURFACE LOCATION DESCRIPTION
UOF UOF
* SECTION
TOWNSHIP
RANGE
LOCATE WELL M TWO 0MECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
TYK Of AUTHORIZATION
O Individual Permit
O Area Permit
Oriole
Number of Wells
WELL ACTIVITY
DCLASS I
O CLASS II
O Brine Disposal
O Enhanced Recovery
O Hydrocarbon Storage
O CLASS III
Name
Welt Number
CASING AND TUBING RECORD AFTER PLUGGING
SEE
WT(LB/rr) TO at PUT M WELL in> ro »t urr n wtu. ini MOLE set
METHOD OF EMPLACEMENT OF CEMENT PLUGS
D The Balance Method
G The Dump Bailer Method
D The Two-Plug Method
Dot her
CEMENTING TO PLUG AND ABANDON DATA
PLUG«1
PLUG*2
PLUG »3
PLUG»«
PLUG»5
PLUG
PLUG
Sut at Mote or Pip* m wfiicft Plug Will B« Pl«c»d docn«sl
D«Oiii to Bottom pi Tubing or Drill ftp* (ft ,
S*ct» o> Cunum Te B« U*»d (»«cti plug)
Slurry Vo
To
From
To
Esiimend Can to Plug Well*
' . CERTIFICATION
/ cart/fy under the penalty of lew that I have personally examined and am familiar with the information
submitted in this document and all attachments and that, based on my inquiry of those individuals
immediately responsible for obtaining the information. I believe that the frtfoimation is true, accurate.
and complete, lam aware that there are significant penalties for submitting /a/s? infoi mation, including
the possibility of fine and imprisonment. (Ref. 4O CFR 144.321
NAME AND OFFICIAL TITLE /!•<••«• ffp* or ftuni
t/ATE SIGNED
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Form Approved. OMB No 2OOO-OO4:
Approval expires 9-30-81
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
A F" r> A WASHINGTON. OC 20460
OC PA APPLICATION TO TRANSFER PERMIT
NAME AND ADDRESS OF EXISTING PERMrTTEE
W
LOCATE WELL AND OUTLINE UNIT ON
SECTION PLAT — 640 ACRES
N
1
1 1 ^_
\
4
_
_
s
E
STATE
COUNTY
NAME AND ADDRESS OF SURFACE OWNER
PERMIT NUMBER
SURFACE LOCATION DESCRIPTION
UOF UOF V* SECTION TOWNSHIP RANGE
LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
Suriac*
LoCVtron ft frwn fM/Sl 1 iftm «f ntimnmr fmntnn
•nd fi
t. from (E/w> Line of ouarar aaction
WELL ACTIVITY
D Class 1
D Class II
DBrirte Disposal
D Enhanced Reco
D Hydrocarbon St
D Class III
O Other
Lease N,. IB
NAME(S) AND ADDRESSEES) OF NEW OWNER(S)
WELL STATUS TYPE OF PERMIT
D Operating D Individual
O Modification/Conversion D Area
D Proposed Number of Wells
very
orage
Well Number
NAME AND ADDRESS OF NEW OPERATOR
Attach to this application a written agreement between the existing and new permittee containing a
specific date for transfer of permit responsibility, coverage, and liability between them.
The new permittee must show evidence of financial responsibility by the submission of surety bond, or
other adequate assurance, such as financial statements or other materials acceptable to the director
CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly
gather and evaluate the information submitted. Based on my inquiry of the person or persons who
manage the system, or those persons directly responsible for gathering the information, the informa-
tion submitted is, to the best of my knowledge ard bfcnet, true, accurate, and complete. I am aware that
there are significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations. (Ref. 4O Cf.~! 122.6).
NAME AND OFFICIAL TITLE (PI»M trpt or print)
SIGNATURE
DATE SIGNED
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Class I
Type "I"
"M"
"W"
"X"
Class II
Type "D"
"R"
"H"
"X"
Class III
Type "G"
"S"
"U"
"X"
Other Classes
Well Class and Type Codes
Wells used to inject waste below the deepest underground source of drinking water.
Nonhazardous industrial disposal well
Nonhazardous municipal disposal well
Hazardous waste disposal well injecting below USDW's
Other Class I wells (not included in Type "I." "M," or "W")
Oil and gas production and storage related injection wells.
Produced fluid disposal well
Enhanced recovery well
Hydrocarbonn storage well (excluding natural gas)
Other Class II wells (not included in Type "D," "R," or "H")
Special process injection wells.
Solution mining well
Sulfur mining well by Frasch process
Uranium mining well
Other Class III wells (not included in Type "G," "S," or "U")
Wells not included in classes above.
Class V wells which may be permitted under §144.12
Wells not currently classified as Class I, II, III, or V.
EPA Form 7520-7-) 12-83) Reverie
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APPENDIX D
GROUND-WATER FLOW EQUATION
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APPENDIX D
GROUND-WATER FLOW EQUATION
The modified Theis ground-water flow equation for
calculating the radius of endangering influence is given
below:
r = (2.25 KHt/S 10X) 1/2
where
x = 4TM
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This equation is applicable only in cases where the hydro-
static head differential between the injection zone and
underground source of drinking water zone is very small.
Erroneous values are calculated if the injection zone head
is much larger or smaller than the USDW zone head.
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APPENDIX E
LIST OF EPA REGION III STAFF
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APPENDIX E
LIST OF EPA REGION III STAFF
U.S. EPA Region III
6th & Walnut Streets
Philadelphia, PA 19106
Thomas P. Eichler, Regional Administrator
(215) 597-9814
Mail Code: 3RAOO
Greene A. Jones, Director, Water Management Division
597-9410
Mail Code: 3WMOO
Robert J. Blanco, Chief, Water Supply Branch
597-8227
Mail Code: 3WM40
John M. Capacasa, Chief, Pennsylvania Implementation Section
597-9928
Mail Code: 3WM43
Charles L. Kleeman, Team Leader, Direct Implementation Team
597-2537
Mail Code: 3WM43
George H. Hoessel, Environmental Protection Specialist
597-9031
Mail Code: 3WM43
Karen J. DeWald, Hydrologist
597-2702
Mail Code: 3WM43
Evelyn B. Shulz, Environmental Scientist
597-3425
Mail Code: 3WM43
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