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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                                                     903R84004
                      TABLE  OF CONTENTS


                                                      Page

I.        Introduction                                  1


II.       The Underground  Injection Control Program      2


III.      Injection Well Classifications                 4


IV.       Regulation  Methods                            8

          A.    General UIC Program Regulations           8

          B.    Permit Authorization for Existing and
               New Class I Wells                         8

                 Permit Application Procedure,
                   Deadlines, and Durations             10
                 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

          D.    Financial Responsibility                 21

          E.    Corrective  Action and Area of Review     22

          F.    Operating Requirements                   23

                 Wellhead  Injection Pressure            23
                 Prohibition of Annular Injection       23
                 Annulus Fluid and Pressure             23

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               TABLE OF CONTENTS (Continued)


                                                      Page

          G.   Monitoring Requirements                  23

          H.   Reporting Requirements                   24

                 Quarterly Report                       24
                 Retention of Records                   24
                 Confidentiality of Information         25

          I.   Authorization Procedures for New
               Class I Wells                            25


VI.       Emergency Notification Procedures             27


VIII.     EPA's Enforcement Program                     28

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                     LIST OF APPENDICES
APPENDIX A          Summary Table of Requirements for
                    Class I Wells
APPENDIX B          UIC Permit Package


APPENDIX C          UIC Forms


APPENDIX D          Ground-Water Flow Equation


APPENDIX E          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 also
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 I
               Wells

     o    EPA's Enforcement Program

     o    Emergency Notification Procedures

This document is a guide and not the text of the law.

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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
  56
  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
WELLS

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
Uranium 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 dispose! cr storage well
Recharge well
Subsidence control well
Geothermal well
Waste disposal well
Other Class V wells
Industrial wastewater disposal welJ

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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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TABLE 2.  TYPE OF CONTROLS  APPLICABLE  TO ALL INJECTION WELL CLASSES
TYPE OF CONTROL
AREA OF REVIEW AND
CORRECTIVE ACTION
MECHANICAL INTEGRITY
REQUIREMENTS
CONSTRUCTION REQUIREMENTS
MONITORING
REPORTING
FORM OF REGULATION
CLASS I
Yes
Yes
Fixed
Continuous
Quarterly
By Permit
CLASS II
Permitted wells
only
Yes
Variable
Periodic
Annual
By Rule or
Permit
CLASS III
Yes
Yes
Variable
Continuous
Quarterly
By Permit
CLASS IV
N/A
N/A
Banned
Varied
Quarterly
By Rule
CLASS V
To be
Defined
To be
Defined
To be
Defined
To be
Defined
To be
Defined
By Rule
or permit

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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-
                              10

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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.
                              11

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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
Mainta in 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  i Entry
Duty to Monitor Activities
and Maintain Records
Duty to Report  Changes  and  Submit
Required Reports
Duty to Report Within  24  Hours
Any Non-Compllance 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
injection 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
tights 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.
                                    12

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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(L)].

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:
                             13

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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.
                              14

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                                                                TABLE  6

                                                  GENERAL REQUIREMENTS OF  EXISTING  AND
                                                       NEW TYPES OP CLASS  I WELLS
Ul
                  Control

                  Form of
                   Regulation

                  Construction
                   Requirements
                  Operating
                   Requirements
                   Fracture Gradient

                  Monitoring
                  Mechanical Integrity
                   Requirements
                  Reporting
                  Area of Review
                  Nell togging
                   Requirements
     Existing Wells

By rul. until th. •ffvetiv* lUt. of tlM UIC prO9r«n
•y p«nit «ft«r th« •ffactlv. date of tlw UIC ptoqtm

- surface casingi cemented
  back to the surface.
- Long string casing and
  tubing} cemented back to
  the injection zone.
- packer

0.733 psi/ft.
Permit condition
- analyses of injection
  fluid.
- installation of recording
  devices to monitor  injection
  pressure, flow rate, volume,
  and annulus.

- Mechanical integrity test
  performed initially and
  once every five years
  during the life of  the well.

- Quarterly monitoring report
- 24 hours noncompliance report
- 180-day notice of abandonment
  (by Rule)
  No later than one year after
  promulgation of the UIC
  program in the state on a
  form provided by EPA  (by
  permit.

- Must identify any known wells
  in the area of review  which
  penetrate the injection zone.

New wells only
     New Wells

Permit
- surface casing} cemented
  back to the surface.
- Long string casing and
  tubing; cemented back to
  the injection zone.
- packer

0.733 psi/ft.
Permit condition
  analyses of injection
   fluid.
  installation of recording
   devices to monitor  injection
   pressure, flow rate, volume,
   and annulus.

  Mechanical integrity test
  performed initially  and
  once every five years
  during the life of the well.

  Quarterly monitoring report
  24 hours noncompliance report
  Notice of abandonment no
  later than one year  after
  promulgation of the  program
  in the state on a fora
  provided by EPA.
- Must  identify any known well*
  in the area  of review which
  penetrate  the injection tone.

Appropriate  logs and tests
required during the drilling
and construction of 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
                             16

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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

     Internal pressure

     Axial loading
 8
Estimated maximum and
average injection pressure

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.
                               17

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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(Cj(2)(±JJ

     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.
                              18

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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.
                            19

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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.
                         20

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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 a 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.
                               21

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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:
                              22

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     1.   Wellhead Injection Pressure  [46.3(a)(l)]

          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.

G.   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.
                             23

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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:
                             24

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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.
                              25

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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.
                               26

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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
                              27

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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.
                             29

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                               TABLE 10

                        THE UIC PERMIT PROCESS
Action
Required:

Action by:
    r
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

Revise
Draft,
Reopen
Comment
Period
t

1 	


Give Public Notice
of Hearings, Hold
Hearings
EPA
4
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
                                 30

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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.
                               31

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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.
                              32

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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.
                              33

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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.
                               34

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           APPENDIX A
SUMMARY TABLE OF REQUIREMENTS FOR
          CLASS I WELLS

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                         Requirements for Operators of Class  I  Injection Wolls
     WHAT DO I HAVE TO DO ?
HOW OFTEN ?
ACCORDING TO WHAT SCHEDULE
            USING WHICH FORM t
 (1)   Subnit Inventory Information
 (2)  Apply for a pernit
 (3)   Subait Plug & Abandonment
      Plan

 (4)   Submit Financial
      Responsibility Demonstration

 (5)   Monitor and Record Nature
      of the Injection Fluid

 (6)   Observe Injection
      Pressure,  Flowrate, 6
      Cumulative Volume and
      annulus
 (7)   Record Injection Pressure,
      Flowrate,  & Cumulative
      Volume

 (8)   submit  quarterly
      Monitoring Report

 (9)   Perform Mechanical
      Integrity  Test

(10)   Notify EPA of date
      scheduled  for each
      Mechanical Integrity Test
Once, unless permit
application submitted

Once, reviewed every
5 years
Once, then update
when requested

Once, then update
when requested

Once, then any
time it changes
ASAP but NLT June
,1985
Monthly
3  times  a year
Once, then every
5 years

Each time a well
is tested
Existing: when notified  by
Director, but NLT June    ,1985
New: NLT 60 days prior to
construction

ASAP but NLT June    ,1985
or with Permit Application

ASAP but NLT June    ,1985
or with Permit Application

ASAP but NLT June    ,1985
                        Beginning ASAP
                        but  NLT June     ,1985
Beginning ASAP but NLT
June   ,1985.
April  30,  August 31,
and December  31

With Completion Report,  then
as scheduled in permit.

At least 30 days in advance
Inj. Well Inventory  Form
(7500-48)

Permit Application Form
(7520-6) and Attachments
            Plug & Abandonment Plan
            Form (7520-14)

            By letter or other
            appropriate format

            Annual Diaposal/Inj. Well
            Monitoring Report (7520-11)
             Annual Disposal/Inj. Well
             Monitoring Report (7520-11)
             Annual Disposal/InJ. Well
             Monitoring Report (7520-11)
             By letter or  telephone

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      WHAT DO I  HAVE TO DO?
 HOW OFTEN?
ACCORDING TO WHAT SCHEDULE
USING WHICH FORM?
(II)  Submit Report  of  Mechanical      Each  time  a well
      Integrity Test Results          Is tested
(12)  Perform 6 report  on
      Corrective Action in
      Area of Review

(13)  Retain records of all
      Monitoring
(14)  Notify EPA of date any well
      is scheduled for plugging

(15)  Submit post-closure report

(16)  Plug an inactive well
(17)  Report endangeraent to USDW
      or any nonconpllance or mal-
      function which may endanger
      a USDW

(18)  Report change of ownership

(19)  Comply with Operating
      Requirements
Once
Each time well is
tested
Once


Once

Once


At each occurrence
At each occurrence

All the time
 If Failed; Within 24 hours. .
            Within 5 days. . .
 If Passed; Annually
For at least 3 years
45 days prior to scheduled
date of plugging

N.L.T. 15 days after plugging

After 2 years of inactivity
unless certain steps are taken
                                                          By telephone
                                                          By Letter
                                                          Annual Disposal/Inj. Well
                                                          Monitoring Report
                                                          (Form 7520-11)
According to schedule in permit    By letter
Within 24 hours. .
and within 5 days.
N.L.T. 30 days before transfer

Beginning A.S.A.P. but
N.L.T. June   , 1985
or according to permit
 Annual Disposal/Inj. Wei
 Monitoring Report
 (Form 7520-11)

 By letter or telephone
 Plugging & Abandonment
 Plan Form (7520-14)
 By telephone
 By letter
 Application  to Transfer
 Permit  (7520-7)
      Note:  ASAP • As soon as possible
              NLT - No later than

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    APPENDIX B
UIC PERMIT PACKAGE

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                                                                         form ApprovfO. umg no 4v»i/-W»4. t*tnrti y-jx-ae
  Form
  LIIC
                        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
        ~ _ _  _       UNDERGROUND INJECTION CONTROL
       & F PA             PERMIT APPLICATION
       ^^ •" " *^        ICottKtrtun&r tnt wthorltv oftht S»f» Drinking
                             WittrAct Section* 1421. 1422.4O CFK 144)
                                                                         . EPA ID NUMBER
                                                                                                      T/A
                                  MAD ATTACHED INSTRUCTIONS BifOHt STARTING
                                           FOR OFFICIAL USE ONLY	
                Oat* Received
                                 Permit/Well Number
                                                                            GQfFUflOfttt
  II. FACILITY NAME AND ADDRESS

  Facility Name
                                                       . OWNER/OPERATOR AND ADDRESS
                                                     Owner/Operator Nam*
  Street Address
                                                     Street Address
  City
                                Stm
  IV. OWNERSHIP STATUS War* '*'!


  DA. Federal  De.Stata      Dc.Pri««a

  D D. Public   O E. Othar (£*pt»in)
  vi. wea STATUS r^«f» •*•)
  DA.
   Operating
                Data Started
                           D B Modification/Converaten   D C. Prepoeed
  VII. TYPE OF PERMIT REQUESTED (Mirk y »ndtfxttity jfr^Quirtd)
                                                      Named) of fiehKal or prejectfs)
                          Number of Exitt-
                          Number of Pro-
  D A. Individual DB.Area
  VIII. CLASS AND TYPE OF WELL (tn n\
                                                                    0. Number of well* per type (if eree permit)
 A. Clashes)
(*nt»r cod**))
  B.Type(s)
(«nt»r codjtll
C. If claaa ia "other" or type is code V wplain
                                                                            X. INDIAN LANDS (M»rtt V

                                                                             DY-   DNO
IX LOCATION OF WELUS) OR APPROXIMATE CENTER OF FIELD OR PROJECT
                              Townthio end Renoe
               0*0  Min I Sec
                                               Feet from I Line
 XI. ATTACHMENTS
    (Complete the following questions on • separate *heet(s) and number accordingly; see instructions)
    FOR CLASSES I. II, III (and other classes) complete and submit on separate sheets) Attachments A—U (pp 2-6) as
    appropriate. Attach 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 that, based on my inquiry of
    those individuals  immediately responsible  for obtaining the  information,  I believe that the
    information is true, accurate, and complete, lam aware that there are significant penalties for
    submitting false information, including the possibility of fine and imprisonment. (Kef. 40 CFR
    1*4.32)
 A. Name end Title /Type or Print}
                                                                               B. Phone No. (Am Cod* v*Ho.)
 C. Signature
                                                                               D. Data Signed
EPA Form 762O-4 (2-84)

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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 Classas
                 Wall Class and Typa Codas
  Walls 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 walls (not included in Type "6," "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
      •xisting
II new well
      existing
III new well
      existing
Other
Classes
EPA Form 7620-6 (2-84)
            Attachmants to Parmft Application
 Attachments
 A. B. C.O. 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, Q, R - U; optional — J. K. O. 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
                                                                        page 2 of 5

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»!•••• »IM «r tr»» «Hti •» gLITg ty»»wtH»» Ii. th»
only. INSTRUCTIONS ON REVERSE.
vvEPA
             U.S. ENVIRONMENTAL PROTECTION ACpNrv
                  OmCE OF DRINKING WATER
              INVENTORY OF INJECTION WELLS
                 (TM» Intontelton In collKtarf under
               m* Mrtftorirr of fh» S»fe Drlnftlnf »iif«r AcM
IV. FACILITY MAKE AMD LOCATION
                                                                                                   owsto. is
                  I. DATE PREPARED
                    fmo., day, & year)
                                                       A. NAME
                                                                ii 11 ii  1111111111111  irn
n i ii  ii  11  n  n  M  1111  in M 11111
                    B. STREET ADDRESS OR ROUTE NUMBER
       1111II11111111111111111
                       C. CITY ON TOWN
                                                     O.ST.
V. LEGAL CONTACT! TYPE, MAKE, PHONE, MAILING ADDRESS, AMD OWNERSHIP
      A. TYPE fmrft 'XV
      | 1. OWNCR
         It.QPKNATON
                                                                              O. INDIAN LAND (•••»» 'X')
                                                                                                     C. PHONE f«r«« emfe * no.1
                                                 B. NAME <<•»<. Inn. «, mi|
     nrmi 11111111111111111
INI
                                                                 P. PRIVATB

                                                                 ». «TAT«
                                                                             M. PUWUIC
                                                    U o
                                                                                         . oTMr.R r«**ciiyj
 VI. WELL INFORMATIO
 WILL OPERATION STATUSt
                          UC = UNDER CONSTRUCTION             AC = ACTIVE             TA = TEMPORARILY ABANDONED
                   PA • PERMANENTLY ABANDONED AND APPROVED BY STATE     AN * PERMANENTLY ABANDONED AND NOT APPROVED BY STATE
     A. CLASS
    AND TYPE
         B. TOTAL
        MO. Or WELLS
                             c. WELL OPERATION STATUS
                          uc
                               AC
                                     TA
                                           PA
                                                 AN
                                        O. COMMENTS r«P«"m*Q
  I*

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                                                                         INSTRUCTIONS
Section I.     Enter dste In order of month, dsy, and year.

Section II.    In the first two position*. Insert the appropriate U.S. Postal Services State
             Code.  In the remaining position*, Insert the appropriate DUNS, GSA. or
             State Facility Number, preceded by a one position alphabetic  identifier:
             D - DUNS Number
             G - GSA Number
             S — State Facility Number

             Example:  A Federal facility (GSA - 123436799) located in Virginia would
             be entered as:  VAGI 23456789.

             Transaction type.

                Place an 'X' In this boa and enter the Facility ID Number.

                Place an 'X* In this bom and fill In all appropriate information.


                Place an 'X' In this bom, enter the Facility ID Number, and fill in the
                 information  to be changed.

              Facility Name and Location

                 Insert the official or legal name of the facility.
Sadie* III.

   Deletion:

   First time
   entry.

   Change of
   entry:

Section IV.

   Hem A:

   Item B. C,
   D. and E
                 Self-Emplanatory.
   Item F:      Insert the numeric county code acquired fro* the Federal Information
                Processing Standards Publication (PIPS Pub 6-1) June IS. 1970.
                prepared by the U.S. Department of Commerce. National Bureau of Stand-
                ards.  For Alaska, use the Census Division Code developed by the U.S.
                Census Bureau.

   Item G:      Place an 'X' in the bom if the facility Is located on an Indian reeervatlo*.

Section V.     Legal Contact.

   Item A:      Place an 'X' in the appropriate bom to Indicate the type of legal contract
                For wells operated by a lease, the operator Is the legal contact.

   Items B. C:  Self-Emplanatory.

   Item D:      If the legal contact la an Individual,  give the name of his/her business
                organization to expedite mail distribution.

   Item E, F,
   G, and H:    Self—Explanatory.

   Item I:       Place an 'X' In the appropriate bom to Indicate the type of ownership.

Section VI.    Wall Information.

   Item A:      Enter In these two positions the class and type of Injection wells to b«
                Inventoried at this facility.  Use the  e*>st pertinent code selected from
                the list below. For example: 2R for  enhanced recovery Injection wells
                and 3M for solution mining wells, etc.

   Item B:      Enter the total number of Injection welt* for each specified class/type.

    Item C:      Insert the number of wells for each class/type under each operation statn
           WELL CODE     PRIMARY FUNCTION
           CLASS/TYPE    OF INJECTION WELLS

            Class I         Industrial. Munlclpol. and
                            Nuclear Storage Wells That
                            ln|ect Below Deepest Under*
                            Ground Source of Drinking
                            Water.

               II             Industrial disposal well

               IM            Municipal disposal well

               IN            Nuclear waste disposal or
                             storage well

               IX            Other Cleas 1 wells

            Class II        Oil and Gas Production and
                            Storage Related ln|ectlon
                            Wells

               2A            Annular Injection well

               2D            Produced fluid disposal well
                                                          CLASSIFICATIONS AND TYPES OF INJECTION WELLS

                                                                WELL CODE     PRIMARY FUNCTION
                                                                CLASS/TYPE    OF INJECTION WELLS

                                                                   2X             Other Class II wells

                                                                 Class III        Special Process Injection
                                                                                 Wells

                                                                   3G             fn situ  gasslflcstlon wells

                                                                   3M             Solution mining well

                                                                   3S             Sulfur mining well by Frasch
                                                                                  process

                                                                   3T             Geothermal well

                                                                   3U             Uramlum mining well

                                                                   3X             Other Class HI wells

                                                                 Class IV        Haxardous Facility Wells That
                                                                                 Inject into or above an Under-
                                                                                 ground Source  of Drinking
                                                                                 Water

                                                                   4H             Hazardous facility injection well
                               WELL CODE
                               CLASS/TYPE

                                 Closs V
                                   SA


                                   SB

                                   SD

                                   SF

                                   SG

                                   5R

                                   ss

                                   5W

                                   sx
PRIMARY FUNCTION
OF INJECTION WELLS

 All Other Wells That Inject
 Into or above an Undorgraum
 Source of Drinking Water

  Air conditioning/cooling
  water return well

  Salinity barrier well

  Storm water drainage well

  Agricultural drainage well

  Other drainage wells

  Recharge well

  Subsidence control well

  Waale disposal well

  Other Class V wells

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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 % 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.  COR R ECTIVE 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
     in 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.

D.  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.)

E.   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.

F.   MAPS AND CROSS SECTIONS OF GEOLOGIC STRUCTURE OF AREA - Submit maps and cross sections
     detailing 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.)

G.  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 Form7K20-6 (2-84)                                                                             Page 4 of 5

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     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 STATU S — Mark Box A if the well(s) were operating as injection wells on the effective date of the UIC Progra m
 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 PERMIT — 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 pan 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.

 1.    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 tre 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.)
 0.   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 — Discuss the planned monitoring program. This should be 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(bX5), 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, a'nd 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.
              (2-84)                                                                            ^9« 6 of 5

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   APPENDIX C
UIC PROGRAM FORMS

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                                                                        Form Approved. OMB No. 2OOO-OO42. Approv»l txptrta 9-30-86
                                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           I                    WASH.NGTON. DC 20460

                  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
 .
                                        STATE
                                                  COUNTY
                                                                                          PERMIT NUMBER
                                        SURFACE LOCATION DESCRIPTION

                                              V40F        ViOF
                         Vt SECTION
                                         TOWNSHIP
                                                             RANGE
                                        LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
                                         Surface
                                                  .ftfrom(N/S).
                   . Una of quarter section
                                                             . Lin* of quarter section
    WELL ACTIVITY

D Brine Disposal
Q Enhanced Recovery
D Hydrocarbon Storage


Lease Name
                                                                     TYPE OF PERMIT
                  D Individual
                  D Area
                  Number of Wells
                                                                              Well Number
                                         Monitoring Location:
                                         (if manifold monitoring)
                                         Nature of Injection Fluid
                          INJECTION PRESSURE
            TOTAL VOLUME INJECTED
                                                     FLOW RATE
                                                     (BEL/ Day)
  MONTH   YEAR
                   AVERAGE PSIG
                                     MAXIMUM PSIG
                                                         BBL
                                                                       MCF
                                                                                      AVERAGE
                                                                                                     MAXIMUM
                                                CERTIFICATION

    / certify under the penalty of law that 1 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, 1 believe that the information is true, accurate, and complete. 1 am aware that there are
    significant penalties for submitting false information, including the possibility of fine and imprisonment. (Ret. 4O
    CFR 144.32).
 NAME AND OFFICIAL TITLE (Plnst type or print/
SIGNATURE
                                            DATE SIGNED
EPA Form 7520-11 '?-B4)

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                                                                               Approval expires 9-30-86
S EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
          WASHINGTON. DC 20460

    WELL REWORK RECORD
[NAME AND ADDRESS OF PERMITTEE

LOCATE WELL A
SECTION PLAT
NDO
6

UTUf
40 A
IE UNIT ON
CRES
N



















1 	 1












1
J 	 1
1
1 1
	 1
1
1
j J
1
i
1
J 	 |




1 	 1



i








E
STATE
COUNTY
NAME AND ADDRESS OF CONTRACTOR

PERMIT NUMBER
SURFACE LOCATION DESCRIPTION
V40F V40F U SECTION TOWNSHIP RANGE
LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
Surface
Location __^ ft. from (N/S) Lin* of quarter faction
and 	 ft. from (E/W) 	 Line of quarter faction
WELL ACTIVITY
O Brine Disposal
D Enhanced Recovery
O Hydrocarbon Storage
Lease Name

Total Depth Before Rework
Total Depth After Rework
Date Rework Commenced
Date Rework Completed
TYPE OF PERMIT
O Individual
O Area
Number of Wells
Well Number
• WELL CASING RECORD - BEFORE REWORK
f Casing
1 Sue
•
1
f
L
1
F
Depth






Cement
Sacks






Type






Perforations
From






To






Acid or Fracture
. Treatment Record






L WELL CASING RECORD - AFTER REWORK (Indicate Additions and Changes Only)
1 Casing
P Sue
1
•
1
r
L
1
Depth






Cement
Sacks






Type






Perforations
From






|~ DESCRIBE REWORK OPERATIONS IN DETAIL
L USE ADDITIONAL SHEETS IF NECESSARY

P
L
1

To






Acid or Fracture
Treatment Record






WIRE LINE LOGS. LIST EACH TYPE
Log Types Logged Intervals





                                            CERTIFICATION
       I certify under penalty of taw 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).
 Mi/IE AND OFFICIAL TITLE (Pletse type or print)
       SIGNATURE
                                                DATE SIGNED
 , Form 7620-12 (1-84)

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                                                                                         Form Approved. OMB No. 2000-0042
                                                                                         Approvtl txpiret 9-30-86
    EPA
      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                  WASHINGTON. DC 20460
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
                                               Telepi. .ie Number
  Address (Street City. State, and ZIP Code)
4. Surface Location Description of Injection Wetl(s)
State
                           County
                                     V4of
                                              14 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 a ware 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 (Ploase type or print)
                                            SIGNATURE
                                                                                        DATE SIGNED
PA Form 7620-9 (2-84)
                                                                                           CONTINUED ON REVERSE

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                    Attachments to be submitted with the Completion report:

I. Geologic Information

1. Lithology and Stratigraphy
4. Provide data on centralizers to include number, type
and depths.
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 TDS).

(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.
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) Reverse

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                                                                                                 OMB No MOO
SERA
                        UNITED STATES E»MRONMENTAL PROTECTION AGENCY
                                   WASHINGTON. OC 20460

                  PLUGGING AND ABANDONMENT PLAN
NAME AMD ADDRESS Of FAOUTY
                                     NAME AND ADDRESS Of OWNER/OPERATOR
  LOCATE WELL AND OUTLINE UNIT ON
  SECTION  PLAT — MO ACMES
 W
          I    I
         -I—I-
          I    I
                                        STATE
                            COUNTY
                                                                                          PERMIT NUMBER
                                        SURf ACE LOCATION DESCRIPTION
                                               UOf        UOf
                                                 \k SECTION
                                                  TOWNSHIP
                                                                                 RANGE
                  LOCATE WELL M TWO OBJECTIONS FROM NEAREST LINES OF QUARTE* SECTION AND DRILLING UNIT
                             .fL*om.cf Plug Will &t Pt»e«d (men«sl
D«oln to Bonom of Tufting or Drill Pipe (ft, I
Sacts of Ccmwn To 8« UMd (••eft plug)
Slurry Velum* To S> Pumpod (cu ft.)
Calculated Toe ot Plug m.l
Slurry Wl. (Lb./G*l)
T«MC«m«rrl or OlfMr M»<«r «l (Clns HI)
                  LIST ALL OPEN HOLE AND/OR PERFORATED INTERVALS AND INTERVALS WHERE CASING WILL BE VARIED HI iny>
                                          To
                                                                                                    To
Estimated Cost to Plug Weils
                                    '  ,          CERTIFICATION

         /certify under the penalty of /aw that/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 fnfo;n,ation is true, accurate.
         and complete, lam aware that there are significant penalties for submitting fals* inioi mat ion. including
         the possibility of fine and imprisonment, (fief. 40 CfR 144.32)
NAME AND OFFICIAL TITLE (H»»t* Iff* or print!
                                                                                          uATE SIGNED

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                                                                                       Form Approved OMB No. 2000-0042
                                                                                               Approval expires 9-30-86
£EPA
    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
               WASHINGTON. DC 20460

 APPLICATION TO TRANSFER PERMIT
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
                                             UOF        14 OF
                             U SECTION
                      TOWNSHIP
              RANGE
                                      LOCATE WELL IN TWO DIRECTIONS FROM NEAREST LINES OF QUARTER SECTION AND DRILLING UNIT
                                        Surface
                                        Location.
         .ft.fram(N/S).
                                                              . Una of quarter Motion
                                              ft fram(E/W)
                                                              > of quarnf nction
    WELL ACTIVITY
O Class I
D Class II
  DBrine Disposal
  O Enhanced Recovery
  D Hydrocarbon Storage
D Class III
D Other
                                       Lease N.. te
                                                                   WELL STATUS
                              TYPE OF PERMIT
O Operating
O Modification/Conversion
D Proposed
D Individual
DArea
Number of Wells.
                                    Wall Number
NAME(S) AND ADDRESSES) OF NEW OWNER(S)
                 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 beiiet, 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. 4Q CF.1122.6).
NAME AND OFFICIAL TITLE (Plf*te typf or print)
    SIGNATURE
                                                                                      DATE SIGNED

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                                     Well Class and Type Codes

        Class I        Wells used to inject waste below the deepest underground source of drinking water.

     Type "I"        Nonhazardous industrial disposal well
         "M"        Nonhazardous municipal disposal well
         "W"        Hazardous waste disposal well injecting below USDW's
          "X"        Other Class I wells (not included in Type "I." "M," or "W")

       Class II        Oil and gas production and storage related injection wells.

    Type "D"        Produced fluid disposal well
          "R"        Enhanced recovery well
          "H"        Hydrocarbonn storage well (excluding natural gas)
          "X"        Other Class II wells (not included in Type "D." "R," or "H")

      Class III        Special process injection wells.

    Type "G"        Solution mining well
          "S"        Sulfur mining well by Frasch process
          "U"        Uranium mining well
          "X"        Other Class III wells (not included in Type "G," "S," or "U")

 Other Classes        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) Reverse

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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 = 4fT KH(h  - h   S  G) /2.3 Q
     r = radius of endangering influence from injection
          well (length)

     K = hydraulic condivity of the injection zone
          (length/time)

     H = thickness of the injection zone
          (length)

     t = time duration of injection (time)

     S = storage coefficient (dimensionless)

     Q = injection rate (volume/time)

   h,   = observed original hydrostatic head of

          injection zone (length) measured from

          the base of the lowermost underground

          source of drinking water

    h  = hydrostatic head of underground source

          of drinking water (length) measured

          from the base of the lowest underground

          source of drinking water

  S G  = specific gravity of fluid in the zone

          (dimensionless)

     fT = 3.142 (dimensionless)

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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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