fxEPA
United States
Environmental Pratt
Ag«ncy
Office of
Drinking Water
Washington, OC 20460
May 1385
EPA 570/9^4-007
Underground injection Control
Federal Financial
Demonstrations for
Owners and Operators
of Class II Injection Wells
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ACKNOWLEDGMENT
This summary was prepared for the U.S. Environmental
Protection Agency under Contract No. 68-01-6827. Mr.
George Denning, EPA Project Officer, and Mr. A. Roger
Anzzolin, EPA Assignment Manager, provided valuable
guidance to the project. Technical support to prepare this
summary was provided by Jasbinder Singh of Policy Planning
& Evaluation, Inc., of McLean, Virginia.
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UNDERGROUND INJECTION CONTROL PROGRAM
FEDERAL FINANCIAL RESPONSIBILITY DEMONSTRATIONS
FOR OWNERS AND OPERATORS
OF CLASS II INJECTION WELLS
A SUMMARY
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TABLE OF CONTENTS
Page No.
A. INTRODUCTION I
B. APPLICABILITY 2
C. FINANCIAL RESPONSIBILITY OPTIONS 3
D. FINANCIAL COVERAGE CRITERIA 4
E. SUBMISSION OF APPLICATION 6
I. Selection of Mechanism 7
2. Information Submitted 7
F. FINANCIAL INSTRUMENTS II
I. Surety Bond II
2. Letter of Credit 12
3. Trust Fund 13
4. Standby Trust Fund 14
G. DESCRIPTION OF THE FINANCIAL TEST 15
I. Financial Ratio Alternative 15
2. Bond Rating Alternative 16
H. USE OF STATE MECHANISMS 17
I. COST OF FINANCIAL MECHANISMS 17
APPENDIX A-FEDERALLY ADMINISTERED UNDERGROUND
INJECTION CONTROL PROGRAMS-CLASS II
INJECTION WELLS 19
APPENDIX B-EPA REGIONAL OFFICES 22
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FEDERAL FINANCIAL RESPONSIBILITY DEMONSTRATIONS
FOR OWNERS AND OPERATORS
OF CLASS II INJECTION WELLS
A. INTRODUCTION
Under the Safe Drinking Water Act of 1974 (SDWA), the U.S. Environmental
Protection Agency (EPA) has established an Underground Injection Control (UIC)
program. As a part of this program, Class II oil and gas operators, whether authorized by
rule or by permit, are required to "... maintain financial responsibility and resources to
close, plug, and abandon the underground injection operation ..." in accordance with an
approved plugging and abandonment plan. This requirement is found in Sections I44.28(d)
and I44.52(a) (7) in the Code of Federal Regulations.'
To satisfy this requirement, operators must demonstrate financial responsibility by
submitting a financial mechanism that meets the approval of the EPA Regional
Administrator. An applicant may choose one of several mechanisms to demonstrate
financial assurance: a financial instrument, such as. a surety bond, trust fund, or letter of
credit; or a financial statement.
This booklet explains what operators and owners (applicants) should do to comply
with these requirements. It discusses the following five basic elements:
• financial responsibility options;
• types of financial coverages;
• procedures for demonstrating financial responsibility;
• submission requirements; and
• requirements of the financial instruments and statements.
'The UIC program regulations are found in Parts 124, 144, 145, 146, and 147 of Title 40
of the Code of Federal Regulations (cited as 40 CFR Parts 124, 144, 145, 146, 147) and
are available from the Regional EPA offices.
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Furthermore, this booklet explains the criteria and guidelines EPA will use to
evaluate the major types of possible financial responsibility demonstrations that apply to
owners and operators of Class II wells. Each demonstration will be evaluated on a case-
by-case basis with close cooperation between the applicant and EPA. Surety associations
and other organizations providing financial services also may find this booklet useful in
their business with Class II applicants. All information in this booklet is offered only as
guidance to the operator or owner; this booklet contains no new binding regulations, and
no new requirements for submitting informatiort to EPA. Any method of demonstrating
financial responsibility, which fulfills the UIC regulation and which is acceptable to
EPA's Regional Administrator, may be used.
B. APPLICABILITY
Federal financial responsibility requirements apply to owners and operators in all
states and U.S. territories. This booklet applies only to owners/operators of Class II
injection wells in those states, territories, or Indian lands that have Federally
administered UIC programs. It is not applicable to operators in states which have been
approved by EPA to assume primary enforcement responsibility. EPA administers the
program only for states which have either not applied to administer the program, or
which have not submitted a program meeting the requirements of the Safe Drinking
Water Act. See 40 CFR Part 147 for detailed information about whether EPA or the
state administers the UIC program for the state in question.
Operators applying for a new permit should submit evidence of financial
responsibility which is effective at the time of permit issuance. A new owner or new
operator requesting, a permit transfer should demonstrate financial responsibility by the
effective date of permit transfer. Operators authorized under rule in the states marked
with an asterisk in Appendix A are required to show evidence by June 24, 1985. The
operators in the remaining states listed in Appendix A are required to show financial
responsibility by December 29, 1985. Owners and operators who are not certain of their
need to comply with these financial requirements or the UIC regulations should contact
the appropriate EPA regional office. Appendix B lists the EPA offices, their addresses,
and telephone numbers.
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C. FINANCIAL RESPONSIBILITY OPTIONS
As stated in the introduction, the applicant may choose one of several mechanisms
to demonstrate financial responsibility. The two basic types of mechanisms are:
I. Financial Instruments — Agreements such as surety bonds, letters of
credit, and trust funds. Through these instruments a third party, such as a
surety or bank, guarantees the availability of a specified amount of funds
for plugging the applicant's wells,
2. Financial Statements — Financial statement data which demonstrate the
company's financial strength.
The applicant has several options for demonstrating financial responsibility. The
first is to submit a financial instrument that guarantees funds that cover the cost of
plugging all of the applicant's injection wells. This option is known as full coverage. If
the coverage amount of the financial instrument meets or exceeds the plugging cost
specified in the Plugging and Abandonment Plan (EPA Form 7520-14), then financial
responsibility is demonstrated.
A second option is to submit information, such as financial statements, which
demonstrate the likelihood of future successful operation and proper well abandonment.
This option is known as financial statement coverage. An applicant's eligibility to use
this option depends on his ability to satisfy certain criteria. By meeting these basic
criteria and passing the financial test, an applicant shows a low risk of abandoning his
injection wells and successfully demonstrates financial responsibility.
A third option exists for applicants that meet some, but not all, of the criteria for
the second option. In this case EPA will allow the applicant to submit a financial
instrument for a coverage amount that is less than the total cost of plugging all injection
wells. The coverage under this option, known as blanket coverage, is specified by the
EPA regional office and generally will not be less than the cost of plugging ten injection
wells.
Thus, depending on an applicant's circumstances, three types of coverage are
available and can be summarized as follows:
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Coverage — A financial instrument that guarantees funds equal to the
Wfal plugging cost of all wells. This plugging^cost corresponds to the
amount in the Plugging and Abandonment Plan submitted to EPA (EPA
F%rm 7520-14). This option is available to any applicant.
• -Financial Statement Coverage — Financial statements and other
information that is evidence of'the applicant's ability to plug his wells in
the future. This verification is based on meeting various criteria including
passing a financial test.
• Blanket Coverage — A financial instrument that guarantees funds
amounting to an EPA-specified portion of the plugging cost of all wells.
Generally, the minimum blanket coverage amount is equal to the cost of
plugging ten injection wells. This option is available to applicants that
pass certain criteria, but do not qualify for the financial statement
coverage option.
The criteria applied by EPA to qualify an applicant for either blanket coverage or
financial statement coverage are described in the next section.
D. FINANCIAL COVERAGE CRITERIA
EPA will use several criteria to determine whether an applicant can use blanket or
financial statement coverage. These criteria will help EPA identify those operator that
are likely %> properly plug their wells. Operators that meet all of the criteria are not
required t» obtain a financial instrument, but instead will be allowed to demonstrate
their financial responsibility through a financial statement. However, if an operator fails
to meet certain criteria, then he should submit a financial instrument for full coverage.
For example, if an operator has a history of abandoning wells without plugging them,
then EPA-fvobably will request that he submit a financial instrument providing full
coverage. An operator meeting other criteria may be allowed to submit a financial
instrument providing blanket coverage. EPA will use the following six criteria to
determine4he likelihood of proper well abandonment.
I. History of plugging wells — Has the applicant plugged his wells in
accordance with regulations in the past? If the applicant has plugged
wells properly in the past then he is likely to do so in the future.
2. Remaining economic life of production fields/leases — Is the applicant
producing from at least one field or lease with an estimated remaining
economic life exceeding five years within the state or territory? If the
remaining economic life of at least one field is more than five years, an
operator is more likely to remain in business until another periodic review
by EPA.
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3. Number of years in business — Has the applicant been in the oil business
more than five years? The financial performance of a business has more
significance after five years of operation.
4. Number of production fields — Is the applicant producing from more than
one field within the state or territory? A company producing from several
production fields is less likely to deplete all its resources simultaneously.
Hence, it is more likely to remain in business until another periodic review
by EPA.
5. Number of injection wells — Is the applicant operating more than ten
injection wells? Since the usual minimum blanket coverage amount will be
for ten injection wells, applicants considering that option should operate
more than ten wells.
6. Financial condition — Does the company pass the financial test
requirements given in Section G? A company in strong financial condition
is more likely to be able to plug its wells in the future.
EPA generally will use the criteria and the guidelines outlined below to determine
the options available to the applicant.
• Companies in business less than five years may submit;
A financial instrument providing full coverage; or
A financial instrument providing blanket coverage, if they have a history
of plugging wells, produce from at least one field or lease with an
estimated remaining economic life exceeding five years, and operate ten
or more injection wells (meet Criteria I, 2, and 5 above).
• Companies with one or no production fields may submit;
A financial instrument providing full coverage; or
A financial instrument providing blanket coverage, if they have a history
of plugging wells, produce from at least one field or lease with an
estimated remaining economic life exceeding five years, have been in
business five or more years, operate ten or more injection wells, and pass
the financial test (meet Criteria I, 2, 3, 5, and 6 above).
• Companies in business five years or longer with two or more production
fields or leases may submit;
A financial instrument providing full coverage; or
Financial.statements, if they have a history of plugging wells, produce
from two or more fields at least one of which has an estimated remaining
economic life exceeding five years, have been in business five or more
years, and pass the financial test (meet Criteria I, 2, 3, 4, and 6 above).
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E. SUBMISSION OF APPLICATION
The applicant's procedure for demonstrating financial responsibility will depend on
which financial coverage option and financial mechanism is selected. The applicant
therefore should:
• Select the preferred type of financial mechanism and the corresponding
financial coverage; and
• Obtain and submit the appropriate information and financial mechanism.
I. Selection of Mechanism
The applicant should first determine the financial coverage options for which he
thinks he can qualify. If the applicant cannot submit the information needed to verify
qualification (described in the preceding section), EPA may request the applicant to
apply under another option.
Next, the applicant should select a financial responsibility mechanism for which
he qualifies. He may want to review the mechanisms and consult various providers of
financial instruments. Brief descriptions of the various financial mechanisms are found
in Section F.
If the applicant has selected a financial instrument for full coverage, the
coverage amount would be based on the cost estimate to plug the well(s) given in the
Plugging and Abandonment Plan (EPATorm 7520-14). If the applicant has selected the
blanket coverage option, he should contact the EPA office in his region to ascertain the
coverage amount. At that time, the applicant should know the plugging cost estimate in
his own Plugging and Abandonment Plan. If qualification for an option depends on
financial statements, the applicant should meet the financial test requirements described
in Section G.
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2. Information Submitted
Finally, the applicant should obtain the required information and documents and
submit them to EPA. This step could involve obtaining a bond from a surety agent,
requesting financial statement information from the firm's accounting department, or
obtaining a letter of credit and standby trust fund from a bank.
The following list describes information that could be required by EPA,
depending on the financial coverage option selected by the applicant. A particular option
may not require all of the information contained in this list. The applicant should consult
the table following this list for the information that EPA could require to be submitted
under a particular coverage option.
a. History of Plugging Wells; An applicant may be requested to furnish prior
proof of plugging and abandoning his injection wells by submitting plugging
records of injection activities.
b. Remaining Economic Life of a Field; An applicant should provide a
certification by a registered professional engineer or a certified
professional geologist that the remaining economic life of at least one
field exceeds five years. This statement should be co-signed by the
Manager of Field Operations or a person with similar authority.
c. Statement of Years in Business; An applicant should submit a statement
of the company's original date of operation and number of years in
business certified by a person of sufficient authority in the company.
d. Number of Production Fields and Number of Injection Wells; An applicant
should provide a list of producing fields or leases and their location in the
state (region), number of production wells associated with injection well
operations, and number of injection wells. This information should be
certified by a person of sufficient authority in the company or a consulting
engineer.
e. Estimated Cost of Plugging Wells; The estimate should correspond to the
cost of plugging wells described in the Plugging and Abandonment Plan
submitted to EPA (EPA Form 7520-14). This estimate could be obtained
from a service company.
f. Financial Statement Informoiion; An applicant not submitting a financial
instrument submits a financial statement for the most recent fiscal year.
The statement should be accompanied by:
a letter from the Chief Financial Officer (CFO), or the person
of sufficient authority to legally bind the company, that includes
required financial information for the financial test;
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a report expressing an opinion on the financial statements
prepared by an independent certified public accounting firm; and
a verification of the information in the letter from the CFO
prepared by an independent certified public accounting firm.
g. Financial Instruments; An applicant must submit a financial instrument
that provides adequate coverage and meets EPA UlC^requirements. The
financial instrument options are:
(1) a Surety Bond and a Standby Trust Fund;
(2) a Letter of Credit and a Standby Trust Fund; or
(3) a Trust Fund.
Section F contains descriptions of these financial instruments.
Model forms for the requested 'information and documents are available from
the EPA regional offices. However, an applicant may use any documents or financial
instruments which comply with EPA regulations and are acceptable to the Regional
Administrator. Table I summarizes the items requested for each of the three financial
coverage options. An (X) indicates that the information or document should be submitted
to satisfy the requirements of the indicated financial coverage option.
All necessary certifications and representations should be submitted before a
financial mechanism can be evaluated by EPA. If the applicant submits items and
information that meet EPA criteria, then he has satisfied the financial responsibility
requirements. Typical information which EPA may request the applicant to submit is
detailed in the following sections.
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TABLE I
TYPICAL INFORMATION
TO BE SUBMITTED
Information and Documents
a. History of Plugging Wells
b. Remaining Economic Life of a
Field
c. Statement of Years in
Business
d. Number of Production Fields
and Number of Injection
Wells
e. Estimated Cost of Plugging
Weils
f. Financial Statements
g. Financial Instruments
Full
Coverage
X
X
Financial
Statement
Coverage
X
X
X
X
X
X
Blanket
Coverage
X
X
X
X
X
X1
X
'Companies in business less than five years need not submit financial
statements.
Note: The EPA Regional Administrator may require that the financial
statements be submitted on an annual basis.
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F. FINANCIAL INSTRUMENTS
Financial instruments are designed to assure continued availability of plugging
resources under a variety of circumstances that can occur during well life. These
circumstances include: a change in financial mechanism by an applicant; a change in
ownership of wells; proper plugging and abandonment of wells; and improper plugging and
abandonment of wells. Financial mechanisms submitted by an applicant should meet
specific requirements mentioned below. Sample forms of the instruments are available
upon request from the EPA regional offices. Instruments similar to these model forms
and meeting the regulatory requirements also are acceptable to EPA.
I. Surety Bond
A surety bond is a guarantee by a surety company that obligations specified in
the bond will be fulfilled. Two types of surety bonds are allowed. One kind, the
Financial Guarantee Bond, guarantees that the surety company will fund a standby trust
fund (described below) in the amount guaranteed by the bond. The other kind of bond, a
Performance Bond, guarantees that if the owner or operator does not properly plug
specified wells, the surety company will perform these duties or pay the amount of the
bond into the standby trust fund.
When either kind of surety bond is used, a standby trust fund also must be
established. The purpose of the standby trust fund is to receive any funds that may
eventually be paid by the surety company. (Standby trust funds are explained in Section
4.) Both the bond and the standby trust agreement should be submitted as evidence of
financial assurance.
A surety bond should:
• Be issued by a surety company on the U.S. Treasury list (Circular 570) of
acceptable sureties on Federal bonds.
• Specify the wells it covers; hence, if new wells are started, a new bond
will be required by EPA.
• Guarantee that if the owner or operator does not properly plug specified
wells, the surety company will pay the amount of the bond into a standby
trust fund. Hence, a standby trust fund where the beneficiary is EPA must
also be established. (See Section 4 for further information.)
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• Provide for a 120-day notice of cancellation to the owner or operator and
EPA.
• Provide for payment of its face value into the standby trust fund if the
owner or operator does not provide substitute assurance to EPA within 90
days of such notice.
The owner or operator may cancel the bond only after written consent by the
EPA Regional Administrator. Such consent may be given after a substitute financial
assurance is provided or the obligations guaranteed have been fulfilled. An owner or
operator interested in obtaining a surety bond should consult his insurance agent. The
agent should be able to help the owner or operator assess the availability and costs of a
surety bond for his facility, including possible requirements for collateral.
2. Letter of Credit
A letter of credit guarantees the availability of funds to a specified party
subject to the conditions in the agreement. The letter of credit, normally issued by a
bank, should provide for payment of funds into a standby trust fund. The payment of the
credit amount occurs if the operator fails to plug his injection wells as required. Both a
standby trust fund and a letter of credit should be established. The letter of credit
should:
• Be issued by a bank or other institution whose operations are regulated and
examined by a state or Federal agency.
• Require that funds in it be deposited into the operator's standby trust fund
if the owner or operator fails to fulfill plugging requirements. Hence, an
operator using a letter of credit must also submit to EPA a standby trust
agreement, of which EPA is the sole beneficiary. (See Section 4 for
further information.)
• Identify the covered wells.
• Provide for a 120-day notice of nonrenewal from the issuing institution.
• Provide that the Regional Administrator may draw upon the letter of
credit if the owner or operator does not provide substitute assurance
within 90 days.
• Provide that the operator may cancel the letter of credit only with the
EPA Regional Administrator's written consent.
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Commercial banks and some savings and loan institutions and credit unions meet
the qualifications in the regulations for institutions which may issue letters of credit.
3. Trust Fund
Another financial assurance option is the trust fund. The owner/operator
establishing a trust fund deposits funds equivalent to the required financial coverage into
the trust fund. The trustee's responsibilities generally will include: (I) investing the
funds; (2) providing an annual valuation to the owner or operator and to EPA; and
(3) accepting further deposits or releasing funds as wells are plugged or new wells
drilled. In investing the funds the trustee will follow the general guidance of the owner
or operator as long as it is in accordance with the trust provisions.
EPA approves payments from the fund to the owner or operator in
reimbursement for costs of plugging as completed. If the cost of plugging appears to be
significantly higher than the value of the trust fund at the time plugging begins, EPA
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may delay releasing funds until plugging is completed and certified. EPA will approve
refunds if the value of the trust fund exceeds the estimated costs of plugging, or if other
financial assurance is substituted for the trust fund, or if plugging is completed and funds
still remain in the trust.
There are about 4,000 banks in the country, plus trust companies and some
savings and loan institutions, which are qualified to manage trust funds. Financial
institutions with which an owner or operator normally does business should be able to
assist him in establishing a trust fund for plugging, either by serving as trustee or by
referring him to trust institutions.
A trust fund should:
• Be established at a bank or other institution with authority to act as a
trustee and whose trust activities are examined andpegulated by a state
or Federal agency.
• Contain funds equal to the required financial coverage.
• Designate EPA as the beneficiary.
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• Specify the acceptable ways of investing money in the fund (by the
Trustee).
• Be accompanied by o "certificate of acknowledgment."
• Specify conditions
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An applicant should meet at least three of the following four ratio
requirements.
a. Current liabilities
Net worth < L0
and
Long term liabilities
Net worth < 2'°
b. Current assets less
current liabilities
Total assets
c. Net income plus
depreciation, depletion
and amortization
Total liabilities > °-lu
d. Net profit > 0
To demonstrate that he passes this test, the applicant submits the information
described in Section E under the financial statement coverage option. Initially he should
submit data only for the latest fiscal year. Only when he fails the test for that year
should he submit the data for the previous two years.. Upon failing the test or being
disallowed from using the test, the owner or operator should provide a bond or other
financial instrument for a coverage amount specified by EPA.
If an operator is a subsidiary of a large corporation, the financial statements of
the parent corporation may be submitted if the parent also guarantees that it will
provide funds sufficient to plug the subsidiary's wells. Such a guarantee should be from a
parent that directly owns at least 50% of the operator's voting stock. The parent
corporation is bound by the guarantee until released by EPA.^Jf the subsidiary is audited
as a separate entity, its financial statements may be submitted.
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2. Bond Rating Alternative
This alternative is available to those companies that have issued bonds to raise
capital. For the applicant to pass the financial test, a bond rating of the most recent
boncl issuance should be within the four highest categories of ratings by Standard and
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Poor's (AAA, AA, A, or BB) or Moody's (Aaa, Aa, A, or Baa). The applicant should submit
a statement of the firm's latest bond rating by one of these two rating services on an
annual basis.
H. USE OF STATE MECHANISMS
States in which EPA is administering the UIC program may have their own financial
responsibility requirements for plugging and abandonment of wells. Under certain
circumstances, owners or operators may use a State-required mechanism to satisfy the
Federal requirements, if it provides assurance at least equivalent to that of mechanisms
specified in the Federal regulations. The Agency will evaluate the equivalency of the
mechanism primarily on the basis of the certainty of availability of funds for the
required plugging and abandonment activities, and the amount of funds that will be made
available. Other factors also may be considered. The owner or operator should submit to
EPA evidence of having established the State-required mechanism, and a letter
requesting that it be considered acceptable for meeting the Federal requirements. The
Regional Administrator will evaluate the equivalency of the mechanism and determine
its acceptability.
I. COST OF FINANCIAL MECHANISMS
To determine which method of financial assurance is least costly, the owner or
operator should review all the mechanisms and consult various providers of financial
services.
For each mechanism, the owner or operator should consider any fees or premiums
charged, requirements for collateral to secure the mechanism, tax consequences, possible
effect on credit standing, and "opportunity cost" — the cost to him of using funds which
could otherwise be invested in ways that would bring a higher return.
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The financial test or corporate guarantee is probably the least expensive mechanism
for owners or operators who meet the requirements for these mechanisms. However,
there may be the additional burden of submitting these statements on an annual basis.
The fees or premiums charged for letters of credit, trust funds, and surety bonds will
vary. They are determined by the issuing institutions on a case-by-case basis. The
amounts are usually in terms of percentages of the amount of the letter of credit or
bond. For a trust fund the amount is generally either a fixed fee or a percentage of
funds managed. The owner's or operator's financial condition, history, and size would be
important factors affecting these charges. These factors will also determine any
requirements for collateral.
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APPENDIX A
FEDERALLY ADMINISTERED UNDERGROUND INJECTION CONTROL PROGRAMS
CLASS II INJECTION WELLS
EPA REGION II
New York (including Indian lands except for Seneca)*
Puerto Rico
Virgin Islands
EPA REGION HI
District of Columbia*
Pennsylvania*
Virginia*
EPA REGION IV
Florida
Kentucky*
Mississippi
Tennessee*
EPA REGION V
Indiana*
Michigan (including Indian lands)*
Minnesota (including Indian lands)
Wisconsin (Indian lands only)
EPA REGION VI
Osage Mineral Reserve, Oklahoma
EPA REGION VII
Iowa (including Indian lands)*
Nebraska (Indian lands only)*
Kansas (Indian lands only)
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APPENDIX A (Continued)
EPA REGION VIII
Colorado (Indian lands only except for.
the Ute Mountain Reservation)*
Montana (including Indian lands)*
South Dakota (Indian lands only) -
EPA REGION IX
American Samoa*
Arizona (including Indian lands except Navajos)*
California (Indian lands only)*
Hawaii
Nevada (including Indian lands)*
Northern Mariana Islands*
Trust Territories*
EPA REGION X
Alaska (including Indian lands)*
Idaho (including Indian lands)*
Notes: (I) EPA is in the process of reviewing state applications to administer the
UIC program. Therefore, this list is subject to change.
(2) States and territories with an asterisk are required to demonstrate
financial responsibility by June 24, 1985. All other states and territories
are required to demonstrate financial responsibility by December 29,
1985.
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U.S. EPA REGIONAL MAP
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APPENDIX B
EPA REGIONAL OFFICES
Questions may be addressed to the following individuals at EPA Regional Offices.
Jerome Healey
Water Supply Branch Chief
EPA, Region I
JFK Federal Building
Room 2113, 21st Floor
Boston, MA 02203
(617)223-6486
Walter Andrews
Water Supply Branch Chief
EPA, Region II
26 Federal Plaza
Room 824, 8th Floor
New York, NY 10278
(212)264-1800
Joseph T. Piotrowski
Water Supply Branch Chief
EPA, Region III
841 Chestnut Street
13th Floor
Philadelphia, PA 19107
(215)597-8227
Donald J. Guinyard
Water Supply Branch Chief
EPA, Region IV
345 Court land Street
Room 305, 3rd Floor
Atlanta, GA 30365
(404)881-3781
Joe Harrison
Safe Drinking Water Branch Chief
EPA, Region V
230 S. Dearborn Street
12th Floor
Chicago, IL 60604
(312)353-2650
Oscar Cabra, Jr., PJ£.
Water Supply Branch Chief
EPA, Region VI
1201 Elm Street
Room 2930, 29th Floor
Dallas, TX 75270
(214)767-2618
Ralph N. Langemeier
Water Supply Branch Chief
EPA, Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913)236-2812
Roger Frenette
Drinking Water Branch Chief
EPA, Region VIII
999 18th Street
I Denver Place, 24th Floor
Denver, CO 80295
(303)844-1413
Steve Pardieck
Water Supply Branch Chief
EPA, Region IX
215 Fremont Street
5th Floor
San Francisco, CA 94105
(415) 974-8226
Richard R. Thiel, P.E.
Water Supply Branch Chief
EPA, Region X
1200 Sixth Avenue
Room 10-A, I Oth Floor
Seattle, Wl 98101
(206) 442-4092
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GPO : 1985 O - 481-863
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