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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