CLASS III COST ANALYSIS
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF DRINKING WATER
APRIL 30, 1980
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CLASS III COST ANALYSIS
This document presents a discussion of the costs which will be
incurred by industry and State governments by implementing the Class
III program requirements of the Underground Injection Control program.
The discussion also responds to comments received as a result of the
proposed regulations, and, for simplicity, is presented in a format
which parallels the report "Analysis of Costs - Underground Injection
Control Regulations, Class I and Class III Wells," Temple, Barker
and Sloane, Inc., May 1979. Other supporting information is contained
in "Development of Procedures for Subclassification of Class III
Injection Wells," Geraghty and Miller, Inc., April 1980.
Costs to Operators
The TBS report contained an inventory of Class III well sites under
the UIC program; this inventory is updated in the G&M report and is
summarized in Table 1 and Figure 1. This revision to the inventory
alters the: operator costs presented by TBS because most costs were
calculated on a well site basis. The following sections discuss
the cost impact of the inventory update and revisions made to the
regulations as the result of public comment.
Geothermal Wells
There are 6 sites containing 25 wells located in California and
Oregon; it is anticipated that there will be 50 wells in operation by
1985. Current industry practice involves casing and cementing, and
operation in conformance to Department of Energy regulations. The
UIC program will not alter the operation of the wells, but the
operators will have to shew initial mechanical integrity of wells as
part of their UIC permit application and will have to report operating
data to the UIC regulating agency quarterly.
Preparing the application for a UIC permit is estimated to require
one work-month (at $1700/work month) per site to reformat existing
information including cementing records for each well. Operators will
submit quarterly reports to UIC regulating agencies with a time
requirement of 1 day per report. The time required would be 6 sites
x 4 reports/year x 5 years = 120 days. The estimated labor cost is
$75/ work day.
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Figure 1. Principal Locations of Class III Injection Well Sites.
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Table 1
ESTIMATED AND PROJECTED NUMBER OF CLASS III SPECIAL PROCESS
INJECTION WELLS AND SITES
Sulfur Mining (Frasch Process)
Solution Mining of Salt
Sites
Wells
(Projected)
1979/1980 1979/1980 1985
8-10
80
500 a/
1,000 b/
500 - 600
1,100
In-situ Leaching
Uranium
Copper and other metals c/
35 6,300
2-3 10-20
18,000
30 - 50
In-situ Combustion c/
Coal
Lignite
Oil shale
Tar sand
30
300
Geothermal Energy
140 +
25 d/
7,785+
50
25,500+
a/ Replace 300-500 wells per year.
b/ Replace, about 100 wells per year. May include some convertad
oil and gas wells.
c/ Pilot and experimental studies only.
d/ Mostly in California and Oragon.
3
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Salt Solution Mining
Summary of Costs to Operators
(thousands of 1977 dollars)
Number of sites
Number of wells
One time costs
80
1,000
Permitting
Testing
Remedial
action
Monitoring
wells
subtotal
$ 204
519
1 , 500
3,000
Recurring Costs
Monitoring $180
Reporting 165
$5,223
subtotal
Total
$345
$5,568
Solution Mining of Potash
Solution mining cf potash is conducted at one site with 1 extraction
and 17 injection veils in Moan, Utah. Initial permitting will require
approximately $30,000 of consultant services. No initial mechanical
integrity testing will be required. Quarterly reporting requirements
will force the hiring of an additional employee at an annual cost of
$20,000. Operator costs cf compliance are summarized below.
Solution Monitoring of Potash
Summary of Cost to Operators
(thousands of 1977 dollars)
Number of sites
Number of wells
One time costs
Permitting $30
Testing 0
subtotal $30
1
17
Recurring Costs
Monitoring $ 0
Reporting 100
subtotal
$100
Total
$130
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Class III
Summary Costs to Operators
(Thousands of 1977 dollars)
One
Geothermal Uells
Permitting
Testing
Subtotal
Total
In-Situ Gasification
Permitting
Testing
Subtotal
Total
In-Situ Uranium Leaching
Permitting
Testing
Subtotal
Total
In-Situ Copper Leaching
Permitting
Testing
Monitoring wells
Subtotal
Total
Frasch Sulfur Mining
Permitting
Testing
Subtotal
Total
Salt Solution Mining
Permitting
Testing
Remedial action
Monitoring wells
Subtotal
Total
Potash
Permitting
Testing
Subtotal
time
$
$
$
$
$
$
$
$
$
$
$
1,
3,
$5,
$
$
costs
10
0
10
10
0
10
60
0
60
31
0
300
331
34
0
34
204
519
500
000
223
30
0
30
Monitoring
Reporting
Monitoring
Reporting
Monitoring
Reporting
Monitoring
Reporting
Monitoring
Reporting
Monitoring
Reporting
Monitoring
Reporting
Total
Totals $5,698
Grand Total, Cost to operators
Recurring Costs
$ 0
9
$ 9
$ 0
1^
$ 11
$ 0
53_
$ 53
$ 18
9
$ 0
15
$ 15
$180
165
$345
$ 0
100
$100
$560
$ 19
21
$ 113
$ 358
$ 49
$5,568
$ 130
$6,258
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Class III
State Program Costs
State governments will incur certain costs in developing, implementing
and operating the UIC program. One time costs for program development,
and program hearings, and recurring costs for enforcement and annual report
preparation are unchanged in the ana.lysis; for details on their development
see Chapter III of the TBS report.
Permit application handling and hearing costs are related to the
number and type of permits handled. The following table summarizes the
time requirements for permitting and hearings:
Class III Wells
State Program Time Requirement Assumption
Practice Total Number Work days/site - Proportion cf permits
of sites for permitting requiring hearing
Geothermal 6 5-10 0
In-Situ Gasification 7 10-20 0
In-Situ-Uranium Leaching 35 20-40 50
In-Situ-Copper Leaching 3 20-40 50
Frasch Sulfur Mining 10 30-40 25
Salt Solution Mining 80 10-30 15
Potash Solution Mining l_ 10-30 0
142
Using the information above, the following is the cost to state government.
One-Time State Work Year Estimates
Program Element Work-year required
Program Development 2.8
Program Hearing 0.9
Permitting 20.7
Permit Hearing 3.0
27.4
State personnel will be required to review the quarterly reports which
are submitted by the operators. It is estimated that 7 work hours per report
will be required for this review. Recurring costs are summarized in the
following table.
P.ecurring Work Year Estimate.s
Program Elements Work-years required
Quarterly reports 2.2
Enforcement 6.3
Annual Report 1.0
Annual Total 9.5 work years/year
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State personnel costs are estimated to be $22,500 per 220 day work
yezr plus 15% for overhead. Total State costs are summarized below.
Total State Program Costs
(thousands of 1977 dollars)
Onetime Costs
Program Development $ 72
Program Hearings 23
Permitting 536
Permit Hearings 78
Subtotal $709
Recurring Costs
Quarterly Reports $ 285
Enforcement 815
Annual Reports 130
Subtotal $1,230
Total $1,939
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