United States Office of Ground Water EPA/816-R-99-014x
Environmental and Drinking Water (4601) September 1999
Protection Agency
The Class V Underground Injection
Control Study
Appendices
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Appendix A
Information Collection Request
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The Class V Underground Injection Control Study April 1, 1998
The Class V
Underground Injection Control Study
I CR# 1834.01
April 1,1998
U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water
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The Class V Underground Injection Control Study April 1, 1998
Contents
A.1 Identification of the Information Collection
A.1 .a Title of the Information Collection 1
A.1 .b Short Characterization/Abstract 1
A.2 Need for and Use of the Collection
A.2.a Need/Authority for the Collection 3
A.2.b Practical Utility/Users of the Data 4
A.3 Nonduplication, Consultations, and Other Collection Criteria
A.S.a Nonduplication 5
A.S.b Public Notice Required Prior to ICR Submission to OMB 6
A.S.c Consultations 6
A.S.d Effects of Less Frequent Collection 10
A.S.e Guidelines 10
A.S.f Confidentiality 10
A.S.g Sensitive Questions 10
A.4 The Respondents and the Information Requested
A.4.a Respondents and SIC Codes 11
A.4.b Information Requested 15
A.5 The Information Collected-Agency Activities, Collection Methodology and
Information Management
A.S.a Agency Activities 18
A.S.b Collection Methodology and Management 18
A.S.c Small Entity Flexibility 19
A.S.d Collection Schedule 22
A.6 Estimating the Burden and Cost of the Collection
A.S.a Estimating Respondent Burden 23
A.S.b Estimating Respondent Costs 25
Capital/Start-up and Operating and Maintenance (O&M) Costs 26
A.S.c Estimating Agency Burden and Cost 27
Estimating Agency Costs 27
Capital/Start-up and Operations and Maintenance Costs 28
A.S.d Estimating the Respondent Universe and Total Burden and Cost 28
A.S.e Bottom Line Burden Hours and Costs 29
A.S.f Reasons for Change in Burden 29
A.S.g Burden Statement 29
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The Class V Underground Injection Control Study April 1, 1998
Appendices
Appendix A: 1997 Consent Decree with the Sierra Club 31
Appendix B: Executive Summary 32
Appendix C: Request for Data 33
Appendix D: Federal Register Notice 34
Exhibits
Exhibit A-4-1: Subclasses of Class V Injection Wells 16
Exhibit A-4-2: Subclasses for Site Visits 18
Exhibit A-6-1: Respondent Collection of Existing Data Burden Hours 24
Exhibit A-6-2: Respondent Site Visit Burden Hours 25
Exhibit A-6-3: Respondent Collection of Existing Data Hours and Costs 26
Exhibit A-6-4: Respondent Site Visit Burden Hours and Costs 26
Exhibit A-6-5: Total Respondent Burden Hours 28
Exhibit A-6-6: Total Respondent Cost 29
Exhibit A-6-7: Bottom Line Burden Hours and Costs 29
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The Class V Underground Injection Control Study April 1, 1998
Part A of the Supporting Statement
A.1 Identification of the Information Collection
A.1 .a Title of the Information Collection
The title of this Information Collection Request (ICR) is The Class V Underground
Injection Control Study (ICR# 1834.01).
A.1.b Short Characterization/Abstract
The Environmental Protection Agency (EPA) Office of Ground Water and Drinking
Water (OGWDW) will collect information on Class V injection wells. This information
collection will be conducted to meet the requirements of the Safe Drinking Water Act
(SDWA) and EPA's modified consent decree with the Sierra Club.1 The consent decree
requires EPA to study Class V wells to determine if additional regulations for Class V
injection wells are necessary to protect Underground Sources of Drinking Water (USDWs).
The Sierra Club alleged that EPA had not satisfied the requirements of §1421 of the Safe
Drinking Water Act (SDWA). Section 1421 requires EPA to publish proposed and final
regulations which will prevent underground injection that endangers USDWs. EPA will
collect information to complete the study and to determine the necessity for additional
regulations. If EPA determines that additional regulations are necessary, then the
information from this collection will also be used to develop them.
This study will characterize the risk posed to USDWs nationwide by each subclass
of Class V wells. To design the study, the Agency convened a workgroup of EPA and
State Underground Injection Control (UIC) representatives. This workgroup will monitor the
implementation of the study and help generate the final report of the study's findings. All
methodologies have been, and will continue to be, developed through the consensus of the
workgroup. Key elements of these methodologies will be peer reviewed. EPA will collect
the following information on each subclass of Class V well: (1) State regulatory and
permitting requirements, contamination incidents, and injectate constituents and
concentrations; and (2) information on the number and location of wells. Two types of data
collection will be used: (1) collection of existing information from State agencies, EPA
Regional offices, organizations and businesses by mail, telephone, and file searches; and
(2) enumeration of the number and types of wells in study areas collected by site visits to
those areas. Data collected during this study will be analyzed and stored in databases
1Sierra Club v. Carol M. Browner. Civil Action No. 93-2644 NHJ, 1997. (Appendix A).
1
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The Class V Underground Injection Control Study April 1, 1998
maintained by OGWDW. For a more detailed discussion of the study design, refer to
Appendix B, "Executive Summary."
It is estimated that this information collection will have a total respondent burden of
1,634.25 hours and a total respondent cost of $45,557.50. There will be no capital/start-up
or operation and maintenance (O&M) costs, and the collection will involve a one-time
response of approximately 28 minutes each from 3,448 respondents. This is a one-time
voluntary submission of information with no periodic reporting requirements.
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The Class V Underground Injection Control Study April 1, 1998
A.2 Need for and Use of the Collection
A.2.a Need/Authority for the Collection
EPA is authorized to collect the data under §1421 of the SDWA. Section 1421 of
the SDWA2 requires EPA to promulgate regulations which prevent underground injection
that endangers USDWs. In January 1997, EPA entered into a consent decree with the
Sierra Club,3 which alleged that EPA failed to comply with this section. According to
section 2.c of the consent decree, EPA is required to conduct a study of Class V wells.4
Specifically, section 2.c states:
No later than September 30, 1999, EPA shall complete a study of all Class
V Wells not included in the rulemaking described in Paragraphs 2.a and
2.b.5
Based on the outcome of the study, EPA is required, by April 30, 2001, to publish a
notice in the Federal Register either: (1) proposing regulations fully implementing §1421
with respect to all such Class V injection wells; (2) proposing a decision that no further rule
making is necessary in order to fully discharge the Administrator's rule making obligations
under §1421 with respect to such wells; or (3) proposing regulations fully implementing
§1421 with respect to some of these remaining Class V injection wells, and proposing a
decision that no further rule making is necessary to fully discharge the Administrator's rule
making obligations under §1421 with respect to all other Class V injection wells not
covered by Paragraphs 2.a and 2.b. The promulgation of regulations fully implementing
§1421 is required by May 31, 2002.
2§1421 of the Safe Drinking Water Act (SDWA) 42 U.S.C.300h(a)(1). (Appendix B).
3Sierra Club v. Carol M. Browner. Civil Action No. 93-2644 NHJ, 1997.
4For the highest risk Class V wells, the Consent Decree requires EPA to publish final regulations
by July 31, 1999.
Paragraph 2.a requires, in part that: The Administrator shall sign a notice to be published in the
Federal Register proposing to discharge the Administrator's rulemaking obligations under
section 1421 of the SDWA, 42 U.S.C. 300h, with respect to those Class V injection wells
determined to be highest risk by the Administrator and for which additional study is not
necessary. Paragraph 2.b requires that by July 31, 1999 the Administrator publish a
notice in the Federal Register fully discharging his/her rulemaking obligations in
accordance with the requirements in the above paragraph.
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A.2.b Practical Utility/Users of the Data
The results of this study will be used by EPA to determine whether additional
regulations are needed for Class V wells and to develop regulations for those wells that
pose significant threats to USDWs. Specifically, EPA will use the following information
from this study:
• Current regulatory and permitting requirements and contamination incidents
to determine the appropriate level of new regulation, if necessary.
According to §1421(b)(3)(B) of the SDWA, EPA shall not prescribe
regulations that unnecessarily disrupt existing State regulations.
• Sampling data that characterize well injectate to estimate the risk that Class
V well types (subclasses) pose to USDWs.
• The number of wells to determine the nationwide prevalence of each Class V
subclass. This information will be used in combination with the risk
characterization of each well subclass to determine the need for additional
regulations.
• The location of wells to determine the population currently using ground
water in the vicinity of these wells.
• The data on industrial wells, automotive service station wells and cesspools
will assist EPA in determining whether current Class V regulatory efforts
should continue to focus on Source Water Protection Areas or be
extended statewide.
EPA will compile the results of the study in a final report that will be available to the
public. The report will include information on the number, location, and risk of each
subclass of Class V injection well. The information will have practical utility for the States
as well as EPA. UIC Programs can use the information for regulatory program
development, public education, and outreach.
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The Class V Underground Injection Control Study April 1, 1998
A.3 Nonduplication, Consultations, and Other Collection Criteria
The following sections verify that this information collection satisfies the Office of
Management and Budget's (OMB's) nonduplication and consultation guidelines, and other
collection criteria.
A.S.a Nonduplication
The information required to complete the study on Class V injection wells is not
duplicative of information otherwise available to EPA. Some of the sources consulted to
verify this are:
7987 Report to Congress-Class V Injection Wells. EPA consulted its 1987
Report to Congress-Class V Injection Wells, which provides information on
each type of Class V injection well. The report, however, does not provide
information that EPA needs to assess the nationwide risk that Class V
injection wells pose to USDWs. In addition, the report does not provide
reliable data on the number of wells by subclass.
• 1996 Underground Injection Control (UIC) Program Inventory. EPA
consulted the 1996 UIC Program Inventory which provides State-by-State
data on the number of Class V injection wells. Like the 1987 Report to
Congress, however, the information is incomplete.
• Literature Review. EPA thoroughly reviewed available literature on Class V
injection wells. The amount of information available in the literature varies
widely depending on the type of injection well. Additionally, the literature
generally presents case studies that cannot be generalized to an entire
subclass of wells. With the exception of the ICR for the Class V regulation,
there are no studies that estimate the number of wells, or assess the risk of well
subclasses on a national basis. Some information is available. For a few
subclasses, the literature provides information on whether wells pose threats to
USDWs in certain geographic areas.
Shallow Injection Well Initiative (Class V) Reports-Demonstration
Projects. From 1991-1994, EPA conducted a series of projects designed
to inventory Class V wells in selected areas, determine the threat to USDWs
from Class V wells, and determine the best methods to manage the wells.
While these studies provide useful information, some focus on a single
injection facility while others provide inventory information that does not
differentiate between subclasses of injection wells. The inventories generally
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The Class V Underground Injection Control Study April 1, 1998
were conducted to assess the validity of inventory methods. For example,
an inventory of Class V injection wells in New Jersey was conducted by
mailing a questionnaire to 688 businesses or towns. Only 275 of the
questionnaires were returned, however, and the accuracy of the responses
may be questionable.
• Drinking Water Contamination by Shallow Injection Wells-100
Contamination Incidents. This 1991 EPA report summarized approximately
100 contamination incidents from Class V injection wells that were either
described in the academic literature or were known to government officials.
The information in this report, however, is not only dated, but it also does not
identify the location or incidence of the well subclasses nationwide.
These sources of information have been used in designing the study and for
background information on Class V wells.
A.S.b Public Notice Required Prior to ICR Submission to OMB
EPA published a notice in the Federal Register (62 Federal Register 243) on
December 18, 1997 announcing a 60-day public comment period. (Appendix D). All
comments were considered in determining the respondent burden estimate.
A.3.c Consultations
In the spring and summer of 1997, EPA met with UIC Program staff in selected
States and EPA Regional UIC offices to obtain information on Class V UIC Programs.
These meetings were held to discuss alternative methodologies for conducting the Class
V UIC study; collect information from States on UIC program priorities, regulations and
permitting requirements for Class V wells, and contamination incidents; and to review the
quality of estimates of the number of Class V wells in each State. State and Regional UIC
staff discussed their program priorities and the steps they take to address priority Class V
subclasses.
EPA held meetings in Massachusetts, Ohio, South Carolina, Iowa, EPA Region 3
(which implements the UIC Programs in Pennsylvania, Virginia, and the District of
Columbia), and EPA Region 9 (which implements UIC Programs in Arizona, California,
Hawaii, and for Native American communities, American Samoa, and Guam). A list of the
participants is provided below.7
7People who participated in both the site visits and the Class V workgroup are listed once in the
table of Class V workgroup participants on the following pages.
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The Class V Underground Injection Control Study April 1, 1998
STATE AND REGIONAL CONSULTATION MEETING PARTICIPANTS
NAME
REGION 3 MEETING
Karen Johnson
Mark Nelson
Roger Reinhart
REGION 9 MEETING
Laura Tom Bose
Joaquin Cruz
Shannon Fitzgerald
Elizabeth Janes
Ephraim Leon-Guerrero
Gregg Olson
Alisa Wong
Russ Land
AFFILIATION
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 3
U.S. EPA Region 9
U.S. EPA Region 9
U.S. EPA Region 9
U.S. EPA Region 9
U.S. EPA Region 9
U.S. EPA Region 9
U.S. EPA Region 9
Nevada Dept. Of
Environmental Protection
PHONE
(215)566-5445
(215)566-5445
(215)566-5462
(415)744-1835
(415)744-1839
(415)744-1830
(415)744-1834
(415)744-1305
(415)744-1828
(415)744-1842
(702) 687-4670
MASSACHUSETTS MEETING
Dave Delaney
Dave Terry
Tom Lamonte
Ron Stelline
U.S. EPA Region 1
Massachusetts Dept. of
Environmental Protection
Massachusetts Dept. of
Environmental Protection
Massachusetts Dept. of
Environmental Protection
(617)565-4884
(617)292-5529
(617)292-5529
(617)292-5889
OHIO MEETING
Ross Micham
Mary Lou Rochotte
Valerie Orr
U.S. EPA Region 5
Ohio EPA
Ohio EPA
SOUTH CAROLINA MEETING
Nancy Marsh
U.S. EPA Region 4
(312)886-4237
(614)664-2270
(614)664-2270
(404) 562-9450
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NAME
Jim Hess
Rob Devlin
AFFILIATION
South Carolina Dept. Of
Health and Environmental
Control
South Carolina Dept. Of
Health and Environmental
Control
PHONE
(803) 734-4672
(803) 734-4672
IOWA MEETING
Dean W. Lemke
Jack Reissen
Dennis Alt
James L. Baker
Iowa Dept. Of Agriculture
and Land Stewardship
Iowa Dept. of Natural
Resources
Iowa Dept. of Natural
Resources
Iowa State University
(515)281-6146
(515)281-5029
(515)281-8998
(515)294-4025
In addition to holding these meetings, EPA convened a UIC Class V Study
Workgroup. The workgroup includes representatives of EPA Headquarters, EPA
Regions, and several State UIC Programs. The Class V Study Workgroup developed the
basic framework for the study and the strategies for obtaining information. The approach
for the study presented in this ICR is based on workgroup consensus. The workgroup will
assist in the implementation of the study. In addition, the workgroup will help design the
final report. The workgroup members are listed below.
UNDERGROUND INJECTION CONTROL CLASS V WORKGROUP
NAME AFFILIATION
EPA HEADQUARTERS STAFF
Clive Davies U.S. EPA Headquarters
Anhar Karimjee U.S. EPA Headquarters
EPA REGIONAL STAFF
Dave Delaney
Norma Ortega
Mark Nelson
U.S. EPA Region 1
U.S. EPA Region 2
U.S. EPA Region 3
PHONE
(202)260-1421
(202) 260-3862
(617)565-4884
(212)637-4234
(215)566-5461
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NAME
Jeanne Dove
Napoleon Kotey
Rebecca Harvey
Helen Lenart
Ross Micham
John Taylor
Kurt Hildebrandt
Valois Shea-Albin
Elizabeth Janes
Jonathan Williams
AFFILIATION
U.S. EPA Region 4
U.S. EPA Region 4
U.S. EPA Region 5
U.S. EPA Region 5
U.S. EPA Region 5
U.S. EPA Region 5
U.S. EPA Region 7
U.S. EPA Region 8
U.S. EPA Region 9
U.S. EPA Region 10
STATE REPRESENTATIVES
Sarah Pillsbury
David Watkins
Richard Deurling
Jamie Crawford
Melonie Elvebak
Mary Lou Rochotte
Steve Musick
Mike Cochran
Scott Radig
Mark Slifka
New Hampshire Dept. of
Environmental Services
West Virginia Dept. of
Environmental Protection
Florida Dept. of
Environmental
Regulations
Mississippi Dept. of
Environmental Quality
Minnesota Pollution
Control Agency
Ohio EPA
Texas Natural Resources
Conservation
Commission
Kansas Dept. of Health
and Environment
North Dakota Dept. Of
Health
Idaho Dept. of Water
Resources
PHONE
(404)562-9415
(404) 562-9461
(312)886-6594
(312)353-6058
(312)886-4237
(312)886-4299
(913)551-7413
(303)312-6312
(415)744-1834
(206)553-1369
(603)271-1168
(304)558-2108
(904) 488-3601
(601)961-5354
(612)296-7764
(614)644-2770
(512)239-4514
(913)296-5560
(701)221-5210
(208) 327-7887
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The Class V Underground Injection Control Study April 1, 1998
EPA also consulted with Dan Fraser, a registered Professional Engineer, former
Administrator of a State drinking water program, and former president of the Association
of State Drinking Water Administrators. Mr. Fraser conducted a single-site field test of the
methodology for conducting site visits where staff counted the number and type of wells in
a geographic area. He evaluated the burden estimates in this ICR, and his comments
were incorporated into this document.
EPA will also issue a general call for any sampling data, data on injectate constitu-
ents, or any other information that may be useful in determining the risk from Class V wells.
This call for information will be posted on the Internet web sites of EPA and various
professional and academic organizations. A letter requesting information will also be
mailed to these same organizations.
A.S.d Effects of Less Frequent Collection
This is a one-time data collection activity and does not involve periodic reporting or
record keeping.
A.S.e Guidelines
This collection does not violate guidelines for information collection activities
specified by OMB.
A.3.f Confidentiality
No assurances of confidentiality will be provided to those who participate in the
data collection effort.
A.S.g Sensitive Questions
This information collection does not ask questions pertaining to sexual behavior or
attitudes, religious beliefs, or other matters usually considered private.
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The Class V Underground Injection Control Study April 1, 1998
A.4 The Respondents and the Information Requested
A.4.a Respondents and SIC Codes
As explained in the Executive Summary (Appendix B), there are two broad types of
data collection for this study.
First, data will be collected from State agencies and other organizations
using a variety of collection methods—mail, phone, and file search. The
objective of this effort will be to collect existing data on wells by subclass,
including inventories, contamination incidents, State regulatory and permit-
ting requirements, and injectate constituents and concentrations.
Second, there will be site visits to census blocks or block groups to deter-
mine the number and types of wells in those areas.
Respondents to the Data Collection by Mail. Telephone, and File Search for Existing Data
The following list shows the SIC codes of State agencies, organizations, and
businesses that may respond to efforts to assemble existing data.
SIC CODE CATEGORY POTENTIAL RESPONDENTS
1311-1389 Oil and Gas Extraction Oil Companies
Natural Gas Companies
3585 Manufacturing of Air Conditioning Manufacturers of Heat Pumps and Air
and Warm Air Heating Equipment Conditioning Units
and Commercial and Industrial
Refrigeration Equipment
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SIC CODE CATEGORY
8611 Business Associations
8621 Professional Membership
Organizations
8733 Noncommercial Research
Organizations
9199 Government, Not Elsewhere
Classified
9311 Public Finance, Taxation and
Monetary Policy
9431 Administration of Public Health
Programs
POTENTIAL RESPONDENTS
Corporate Commissions
National Ground Water Protection
Council
International Ground Source Heat
Pump Association
National Water Resources
Association
Geothermal Heat Pump Consortium
Automobile Dealers/Service Station
Associations
Automotive Parts Manufacturers
Associations
Plastics Industry Associations
Petroleum Associations
Crematoria Associations
Carwash Associations
Transportation Associations
Contractors/Builders Associations
Veterinary Associations
National Funeral Directors
Association
Oceanic Studies Institute
Geothermal Resources Council
Electric Power Research Institute
Public Works Departments
State Tax Commissions
State Health Departments
Local Health Departments
County/City Sanitarians
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SIC CODE CATEGORY
9511
9512
9631
9641
9651
Air and Water Resource and
Solid Waste Management
Land, Mineral, Wildlife and Forest
Conservation
Regulation and Administration of
Communications, Electric, Gas
and Other Utilities
Regulation of Agricultural
Marketing and Commodities
Regulation, Licensing and
Inspection of Miscellaneous
Commercial Sectors
POTENTIAL RESPONDENTS
State Environmental Quality
Agencies
State Water Quality Divisions
State Ground and Drinking Water
Programs
State Coastal Commissions
State Oceanic Divisions
State Hazardous Waste Divisions
State Underground Storage Tank
Programs
State Site Remediation Programs
State Bureaus of Land Management
State Geological Surveys
State Oil and Gas Divisions
State Energy Divisions
State Departments of Agriculture
State Bureaus of Mines
State Departments of Mining and
Economic Geology
State Environmental Permitting
Programs
State UIC Programs
There are 37 States that have primary enforcement responsibility (Primacy) for their
UIC Programs. These programs are likely to be among the best sources of State-level
information. For Direct Implementation (Dl) States (those States without Primacy for their
Class V UIC programs), the corresponding agency is the UIC Program in the EPA
Regional office.
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The Class V Underground Injection Control Study April 1, 1998
Other State Agencies
If the UIC Programs do not have all of the necessary information on all types of
injection wells, EPA will contact other State agencies. For example, EPA will contact
State mining divisions to get information on mining backfill wells and agricultural
departments for information on agricultural drainage wells.
Other Entities
If information is not available from State agencies or EPA Regional offices, EPA
will contact non-governmental entities. For example, the Oceanic Studies Institute may
have information on aquaculture return flow wells.
Respondents to the Data Collection by Site Visits
EPA plans to use a mathematical model to estimate the number of agricultural
drainage wells, storm water drainage wells, large-capacity septic systems, and certain
lower risk industrial wells. The model also may be used for other subclasses if data
collection by mail, telephone and file search proves unsuccessful for those well types. The
following potential respondents (listed with their corresponding SIC codes) will participate
in the site visits.
SIC CODE CATEGORY POTENTIAL
RESPONDENTS
9532 Administration of Urban Planning Local Planning Departments
and County and Rural
Development
9641 Regulation of Agricultural County Extension Agents
Marketing and Commodities
The model predicts the number of wells by subclass in a geographic area as a
function of certain independent variables (e.g., the number of storm water wells may be a
function of population density, presence or absence of storm sewers, and the presence or
absence of karst, fractured bedrock, and poorly drained soils). Data for the independent
variables will be derived from the census and other sources that can be linked to census
geographical units. Data for the dependent variable (number of wells by subclass) will be
obtained from the site visits.
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The Class V Underground Injection Control Study April 1, 1998
To collect the information on the dependent variable for the model, EPA plans to
conduct up to 150 site visits to geographic areas (census blocks, block groups, or
combinations of block groups). In each area, contractor site visit teams will enumerate the
number of wells by subclass.
Government Officials
The site visit teams will contact government officials prior to (or at the time of) the
site visit. The site visit teams will come equipped with some information on the local area
(e.g., maps), but the visits will be facilitated if the teams can obtain better local maps,
aerial photos of the area, and other information on likely sites for injection wells. Therefore,
the teams will request such information from government officials. These officials may be
from a State agency. More likely, they will be from a local planning department or a county
extension service.
Protocol may dictate that other government officials (in addition to the government
officials who will be collecting and providing information) be notified of the site visits.
Since EPA will not be asking these officials any questions, they are not considered in the
estimation of respondent burden.
Private Individuals
The site teams may contact private individuals during the site visits. A
comprehensive list of the potential respondents and their SIC codes is not included in this
request because of the wide range of individuals that will be contacted. Those consulted
may include store owners, farm owners, car wash managers, laundromat owners, school
principals, church officials, mall owners, and other private individuals who own or have
information about Class V wells on a particular piece of property. These individuals will be
consulted for only a few minutes and are not required to submit any additional information
subsequent to the site visit.
A.4.b Information Requested
This information collection does not impose a record keeping burden. No
adjustments need to be made to current record keeping practices, and the collection does
not increase record keeping requirements.
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Collection of Existing Data by Mail, Telephone, and File Searches
For each subclass of well listed in Exhibit A-4-1, EPA will request:
• Current regulatory and permitting requirements, including permit application
procedures; siting, construction, operation, monitoring, and reporting
requirements; plugging and abandonment procedures.
• Injectate constituents and concentrations, including details on sampling (e.g.,
what entity conducted the sampling, when, under what conditions—such as
wet weather, and whether the sample was statistically representative).
• Information on contamination incidents including the date of the incident; a
brief description of the incident and remedial action taken.
• Number of wells including the source of the data and the date that the
inventory was last updated.
Location of each well, using latitude and longitude, county, or zip code.
Exhibit A-4-1
Subclasses of Class V Injection Wells
Electric power return flow wells
Direct heat return flow wells
Heat pump/AC return flow wells
Aquaculture waste disposal wells
Wastewater treatment effluent wells
Aquifer recharge wells
Aquifer storage and recovery wells
Salt water intrusion barrier wells
Subsidence control wells
Mining, sand, and other backfill wells
Motor vehicle waste disposal wells
Experimental wells
Special drainage wells
Non-contact cooling water return flow wells
Solution mining wells
In-situ fossil fuel recovery wells
Spent brine return flow wells
Agricultural drainage wells
Storm water drainage wells
Large-capacity septic systems
Aquifer remediation wells
Cesspools
Industrial wells
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The Class V Underground Injection Control Study April 1, 1998
Industrial wells, motor vehicle waste disposal wells, and cesspools are currently
being addressed by other EPA regulatory efforts. In order to assist EPA in determining
where these regulations should apply (in Source Water Protection Areas vs. statewide),
EPA will collect all of the above information except the number and location of the wells.
The number and location of these wells are not needed because estimates were
developed for other Class V efforts.
EPA will also gather ground water and drinking water contaminant occurrence data
from the States. EPA will be able to gather most of this information from Federal
agencies, but will need to contact State drinking water programs and geological surveys to
complete this portion of the collection.
To assemble the information requested, respondents will need to access their files
(both hard-copy and electronic). EPA has prepared a letter that specifies the information
to be requested from these respondents (Appendix C). This letter will be followed by
telephone calls from EPA contractor staff to answer questions and assist the respondents.
Respondents can submit copies of relevant hard-copy or electronic files, or they can invite
contractor staff to come to their offices and search their files. To reduce burden, EPA will
accept information in any form. To further reduce burden, EPA anticipates traveling to
more than half of the States to collect this information by searching State agency files.
EPA is pre-testing this data collection methodology and will report on the results of this
pre-test.
Data Collection by Site Visits
A model will be created to estimate the number of wells nationwide for the well
subclasses presented in Exhibit A-4-2 (refer to Appendix B for a description of the model).
If data are insufficient for other well subclasses, EPA may use the model for up to three
additional well subclasses. To construct this model, EPA will conduct up to 150 site visits
to geographic areas (census blocks, block group, or combinations of block groups).
Governmental respondents will be asked to provide detailed maps of the area for review
and to share any information that they have on the potential location of injection wells.
Private respondents will be property owners, who may be asked a few brief questions
(e.g., whether a potential injection well is connected to a sewer). For much of the data
collection, there will be no respondents at all. The purpose of the site visits is to inspect
the area, identify injection wells, and enumerate the wells by subclass. Indeed, the most
likely interaction with people during the site visits will be asking for permission to inspect a
well. We believe that this type of interaction does not constitute burden under the
Paperwork Reduction Act.
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The Class V Underground Injection Control Study April 1, 1998
Exhibit A-4-2
Subclasses for Site Visits
Agricultural drainage wells
Stormwater drainage wells
Large-capacity septic systems
A.5 The Information Collected-Agency Activities, Collection
Methodology and Information Management
A.S.a Agency Activities
EPA activities associated with the Class V UIC Study will consist of the following:
• Creating a letter requesting data from State agencies and EPA
regional offices. This will specify the information we expect to obtain
using mail, telephone, and file searches.
• Contacting the respondents and explaining the information request.
• Conducting site visits.
• Auditing information to assess quality.
• Compiling and storing the data.
• Analyzing the data.
• Preparing a report of the findings and conclusions.
A.S.b Collection Methodology and Management
Collection of Existing Information by Mail, Telephone, or File Searches
The most likely respondents for this type of information collection will be State
agencies or EPA Regional offices. Occasionally, EPA will use this method to collect
information from organizations. Based on advice from the UIC Class V Workgroup and
conversations with State officials, EPA believes that flexibility is vital to efficient collection.
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The Class V Underground Injection Control Study April 1, 1998
Therefore, EPA is prepared to use several methods to collect the information. EPA has
created a letter request for data (Appendix C). States can respond by mail, telephone, or
e-mail. EPA is prepared to accept the data in any format that the State chooses.
Contractor staff will use telephone follow-up to clarify information. Finally, if the State
prefers, EPA is prepared to send contractor staff to State agencies to conduct file
searches. This variety of methods ensures that EPA has taken every effort to reduce
burden on these respondents.
EPA will review data quality, particularly data on inventory, by checking it against
existing estimates of inventory. The information will be compiled using personal
computers and database software. After analysis, the results will be combined in a single
report, which will be made available to the public in hard copy and over the Internet.
Collection of Site Visit Data
The collection process for site visit data will be to enumerate the number and types
of injection wells identified in each study area. Data quality and consistency will be
ensured by extensive training of staff prior to site visits and by quality assurance reviews by
a site visit coordinator. The site teams will be de-briefed frequently by the site visit
coordinator to assess their progress.
There may be technical obstacles to collecting accurate information about the
number and types of wells in each study area. Verification that a well is an injection well,
for example, requires some demonstration that the well does not drain to surface water or
is not connected to a sewer. Our site visit teams will be trained in methods of physical
inspection, and they will work with local officials who know the location of collector sewers.
Enumeration of wells by subclass will require judgments about well types. For example,
how will one distinguish agricultural drainage wells from stormwater wells? Finally, there
may be legal obstacles to the collection of accurate information. Obtaining complete and
reliable data may require access to private property. Our site visit teams will be led by
experienced professionals, most of whom are former State regulators who have faced
these types of problems before and they will be trained on issues related to access.
The data from site visits will be compiled, stored, and made public in the same
manner as information collected by mail, telephone, and file searches.
A.5.c Small Entity Flexibility
In developing this collection effort, EPA considered the requirements of the Small
Business Regulatory Enforcement Fairness Act (SBREFA) and attempted to minimize,
wherever possible, the burden of the information collection on small entities. Small entities
19
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The Class V Underground Injection Control Study April 1, 1998
include "small businesses," "small organizations," and "small government jurisdictions."
These terms are defined below:8
Small business-Any business that is independently owned and operated
and not dominant in its field as defined by the Small Business Administration
(SBA) regulations under Section 3 of the Small Business Act.
Small organization - Any non-profit enterprise that is independently owned
and operated and not dominant in its field.
Small governmental jurisdiction- Governments of cities, counties, towns,
townships, villages, school districts, or special districts with populations of
fewer than 50,000. This definition may also include Indian tribes.
EPA has attempted to reduce, to the maximum extent practicable, the burden on
small entities. As discussed above, there are two types of data collection—collecting
existing information by mail, telephone, and file searches; and conducting site visits. Small
entities will be virtually unaffected by the first type of data collection. Respondents include
State governments and businesses or organizations dominant in their field.
Site visit teams will impose a minimal burden on small entities. Respondents will
be asked simple questions about their injection wells. EPA assumes that questions may
be asked to as many as 20 people per site visit. Since there is no reliable way to estimate
how many of these entities will be small, we will assume that all are small when we
calculate burden. A representative from each entity may be asked to spend 15 minutes
responding to simple questions (e.g. Is this well connected to a sewer?). At 15 minutes
per respondent, the total burden for 150 site visits is 750 hours.9
The Agency considered an alternative approach to this estimation task.
The alternative approach was to conduct a statistical survey to estimate the number of
certain types of Class V wells in the nation. This survey would involve the selection of a
sample of geographic areas in the country and site visits to these areas to count the
number of wells in each subclass. A sampling statistician estimated that EPA would need
visits to approximately 560 sites to achieve the desired level of precision. This would
create approximately four times more burden than the modeling approach that the Agency
8These definitions were taken from section 601 of the Regulatory Flexibility Act (RFA).
9Fifteen minutes (0.25 hours) multiplied by 150 sites multiplied by 20 respondents per site equals
750 hours.
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The Class V Underground Injection Control Study April 1, 1998
selected. The modeling approach, which was supported by the UIC Class V Study
Workgroup, reduces the burden on small entities by significantly reducing the number of
site visits (from 560 to 150).
The objective of small entity flexibility requires that EPA also consider less
burdensome collection mechanisms, even if only a few respondents are small entities. To
reduce burden on small entities, EPA took the following steps in designing the approach
for site visits:
• All respondents will be notified that their participation in the study is
voluntary. This includes small businesses and local governments that qualify
as small entities.
• For small businesses and organizations, the burden will be extremely limited.
As indicated above, EPA anticipates that questions can be answered in 15
minutes. At an average rate of $14.50 per hour,10 a 15-minute question will
create a cost of $3.63 per entity. Since this average cost amounts to much
less than 1 percent of all sales, annual operating expenditures, or revenues
of all small businesses or organizations, the information collection will not
have a significant impact on small entities.11 The only option that would
reduce this burden is to avoid asking any questions of these respondents.
This would be perceived as discourteous, and it eliminates only a negligible
burden.
• For local officials, the information requests will be limited in scope (e.g.,
copies of local maps and information on injection wells in the study area).
The burden is estimated to be 2 hours per respondent. The government
officials in approximately one-third of the sites (50 of 150) will be from State
governments and thus will not be small entities. The local officials in the
other 100 sites will most likely be from county health departments.
According to the National Association of County and City Health Officials, 66
1t>This rate is a non-unionized labor rate that was derived from the Engineering News Record in
1993 and that was used in the 1997 ICR for the Public Water System Supervision
Program. The rate represents the average for a wide range of labor rates for individual
respondents.
11According to the EPA Interim Guidance for Implementing the Small Business Regulatory
Enforcement Fairness Act, an impact of less than 1 percent of revenues, sales, or
operating expenditures means that the collection does not have a significant impact on a
substantial number of small entities.
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The Class V Underground Injection Control Study
April 1, 1998
percent of the nation's local health departments are small entities (i.e., they
serve populations of fewer than 50,000 persons). Thus, of the 100 sites with
local government officials, we assume that 66 will be from small entities. For
those small entities, the burden will be 2 hours per site. At $40 per hour, this
is a total cost of $80—a negligible amount as a percentage of total county
government revenues.
A.S.d Collection Schedule
To comply with the schedule set forth in the consent decree with the Sierra Club,
EPA intends to complete the data collection and site visits in December 1998. Then EPA
will review the data and prepare a final report, which must be completed and made
available to the public no later than September 30, 1999. The following table summarizes
major milestones in the Class V project.
Class V Study Schedule
Date/Deadline
May 25, 1998
June 8, 1998
December 14, 1998
December 15, 1998
September 30, 1999
Study Milestone
Projected OMB approval of collection
Begin site visits
Data collection completed
Model finalized
Report deadline
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The Class V Underground Injection Control Study April 1, 1998
A.6 Estimating the Burden and Cost of the Collection
A.G.a Estimating Respondent Burden
The following are the burden estimates used to compute total respondent burden.
Collection of Existing Information by Mail, Telephone, or File Searches.
• EPA estimates that it may take the State UIC Program official as long as 6
hours to assemble information in response to the request for data and an
additional 30 minutes to submit it to EPA. EPA assumes that one-half of the
States will elect to allow contractor personnel to conduct a file search, in
which case there is no collection burden. Therefore, as shown in Exhibit A-
6-1, we assume that one-half of the 37 primacy States (or 19 States) will
face an information collection burden.
• Other State agencies will generally have information on fewer well
subclasses than State UIC Programs. EPA estimates that it may take these
other State agencies 1.5 hours to assemble information in response to the
request for data and an additional 15 minutes to submit it to EPA. Assuming
4 agencies respond in each of the 56 States and territories, there are 224
potential respondents.
• The respondent at an organization or business will have information on even
fewer well subclasses than other State agencies. Therefore, EPA assumes
that they can assemble the information in 1 hour and submit it to EPA in 15
minutes. EPA assumes that 55 such organizations or businesses will be
requested to submit data.
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The Class V Underground Injection Control Study April 1, 1998
Exhibit A-6-1: Respondent Collection of Existing Data Burden Hours
(A)
Activity
(B)
Hours
(C)
Respondents
(D)
Total Hours
State DIG Program
Assemble information
Submit information
6.00
0.50
19
114.00
9.50
Other State Agencies
Assemble information
Submit information
1.50
0.25
224
336.00
56.00
Private Organizations & Businesses
Assemble information
Submit information
Total
1.00
0.25
55
298
55.00
13.75
584.25
Data Collection by Site Visits
• State or local government officials will be asked to assemble information
(e.g., local maps or aerial photos) for the site visit teams. At most, EPA
assumes that this activity may take 2 hours. The team will pick up the maps
when they arrive at the study area. As shown in Exhibit A-6-2, the total
burden is 300 hours (2 hours per respondent multiplied by 150 sites
multiplied by one respondent per site).
• Private individuals will be contacted during each of the site visits. It is
estimated that each of these individuals will be asked questions that can be
answered in 15 minutes. As shown in Exhibit A-6-2, the total burden is 750
hours.
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The Class V Underground Injection Control Study
Exhibit A-6-2: Respondent Site Visit Burden Hours
April 1, 1998
(A)
Activity
Government officials
Assemble information
(B)
Hours
2.00
Private Individuals
Respond to questions
Total
0.25
(C)
Respondents
150.0012
3,000.00
3,150.00
(D)
Total Hours
(D=B*C)
300.00
750.00
1,050.00
A.G.b Estimating Respondent Costs
Estimating Labor Costs
This ICR uses labor rates that are consistent with other recent information
collections approved by OMB. The average annual hourly cost (including overhead) is
$40.00 for State and local officials,13 $30.00 for private organizations and businesses,14
and $14.50 for private individuals.15
Exhibits A-6-3 and A-6-4 show the total cost for each type of data collection. The
estimates of total hours shown in column B of these exhibits come from column D of
Exhibits A-6-1 and A-6-2.
This is the maximum number of sites to be visited. It includes the optional additional 50 sites if
the models are expanded to include additional subclasses of wells.
13This labor rate for State employees was developed with the States and has been used in several
recent ICRs including the pending 1997 Information Collection Request for the Public
Water System Supervision Program.
14This technical labor rate is consistent with the rate from the 7996 Underground Injection Control
Program ICR.
15This non-unionized labor rate was derived from the Engineering News Record in 1993 and was
also used in the 1997 ICR for the Public Water System Supervision Program. The rate
represents a wide range of labor rates for individual respondents. Respondents, for
example, may be from lower-paid service occupations.
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The Class V Underground Injection Control Study April 1, 1998
Exhibit A-6-3: Respondent Collection of Existing Data Hours and Costs
(A)
Activity
(B)
Total Hours
(C)
Rate per hour ($)
(D)
Total Cost($)
(D=B*C)
State UIC Program Department
Assemble information
Submit information
114.00
9.50
$40.00
$40.00
$4,560.00
$380.00
Other State Agencies
Assemble information
Submit information
336.00
56.00
$40.00
$40.00
$13,440.00
$2,240.00
Private Organizations & Businesses
Assemble information
Submit information
Total
55.00
13.75
$30.00
$30.00
$1,650.00
$412.50
$22,682.50
Exhibit A-6-4: Respondent Site Visit Burden Hours and Costs
(A)
Activity
(B)
Total Hours
(C)
Rate per hour ($)
(D)
Total Cost ($)
(D=B*C)
Government officials
Assemble information
300.00
$40.00
$12,000.00
Private Individuals
Respond to question
Total
750.00
$14.50
$10,875.00
$22,875.00
Capital/Start-up and Operating and Maintenance (O&M) Costs
There will be no capital/start-up nor O&M costs associated with this information
collection. The collection does not require any capital investments nor does it require any
continual O&M costs since the collection requires only a one-time submission of
information.
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The Class V Underground Injection Control Study April 1, 1998
A.6.c Estimating Agency Burden and Cost
EPA's burden consists of information collection (1) by EPA Headquarters, and (2)
from EPA regional offices responsible for Direct Implementation (Dl) States. It also
includes the cost of contractor activities associated with the information collection.
Estimating Agency Costs
EPA Headquarters
The collection will involve the equivalent of 1.5 full-time employees from EPA
Headquarters for the duration of the collection. These employees will be paid on average
at a GS 12 Step 5 pay level ($38.25/hour using the salary associated with this grade and
step, multiplied by a benefits factor of 1.616). The equivalent of 1.5 FTEs is 2,080 hours for
the duration of the eight-month collection effort. Total hours (2,080) multiplied by $38.25
per hour amounts to a total labor cost of $79,560.
EPA Regions
EPA estimates that each Region will spend 6.5 hours on the assembly and
submission of information for each of its Dl States. There are 19 Dl States. At 6.5 hours
per Dl State multiplied by 19 States, the total hour burden of the collection is 123.50 hours.
At a GS 11 Step 5 pay level17 (rounded off to $32.00/hour using the calculation method
described above) this will amount to a total labor cost to EPA Regions of $3,952.00.
EPA Contractor
The contractor will assist EPA in the data collection and site visits. The contractor
will also provide technical support in the development and execution of the data collection
effort. To perform these functions EPA has contracted for a total of 27,500 professional
hours. At an average rate of $56.84 per hour, the total cost for the contractor is
$1,563,100.
16This factor is from the ICR Handbook: EPA's Guide to Writing Information Collection Requests
Under the Paperwork Reduction Act of 1995 (December 1996).
17EPA Regional staff are paid at a lower rate than staff at EPA Headquarters.
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The Class V Underground Injection Control Study
Capital/Start-up and Operations and Maintenance Costs
April 1, 1998
There will be no capital/start-up nor O&M costs associated with the information
collection.
A.G.d Estimating the Respondent Universe and Total Burden and Cost
Exhibit A-6-5 presents the respondent universe and total respondent burden. The
total number of burden hours is equivalent to the total number of respondents multiplied by
the hours that each respondent will be involved in the collection. EPA estimates that there
will be 3,448 respondents to the collection for a total of 1,634.25 hours. The average
burden per respondent, based on these estimates, is 28 minutes.
Exhibit A-6-5: Total Respondent Burden Hours
State UIC Program
Other State Agencies
Private Organizations and
Businesses
Government Officials
Private Individuals
Total
Respondents
19.00
224.00
55.00
150.00
3,000.00
3,448.00
Hours/Respondent
6.50
1.75
1.25
2.00
0.25
Avg: 0.47397
Total Hours
123.50
392.00
68.75
300.00
750.00
1,634.25
The total respondent costs for the information collection are presented in Exhibit A-
6-6. The total cost represents the number of respondents multiplied by the average cost of
the collection to each respondent. The total cost of the collection is $45,557.50.
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The Class V Underground Injection Control Study
Exhibit A-6-6: Total Respondent Cost
April 1, 1998
State UIC Program
Other State Agencies
Private Organizations and
Businesses
Government Officials
Private Individuals
Total
Respondents
19.00
224.00
55.00
150.00
3,000.00
3,448.00
Total Cost($)
$4,940.00
$15,680.00
$2,062.50
$12,000.00
$10,875.00
$45,557.50
Cost/Respondent
$260.00
$70.00
$37.50
$80.00
$3.63
Avg: $13.212732
A.6.e Bottom Line Burden Hours and Costs
Exhibit A-6-7 summarizes the bottom line burden hours and costs of this information
collection. The total hour burden for both respondents and EPA is 31,337.75 hours at a total
cost of $1,692,169.50.
Exhibit A-6-7: Bottom Line Burden Hours and Costs
Respondents
EPA
Total
Burden Hours
1,634.25
29,703.50
31,337.75
Total Cost($)
$45,557.50
$1,646,612.00
$1,692,169.50
A.G.f Reasons for Change in Burden
There is no change in burden because this ICR does not modify an existing ICR.
A.G.g Burden Statement
EPA is required to collect this information as part of its consent decree with the
Sierra Club, which was amended in 1997. EPA is authorized to collect this information
under §1421 of the SDWA, 42 USC §300h. Responses to this collection request are
voluntary.
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The Class V Underground Injection Control Study April 1, 1998
The average estimated burden per respondent per year for this information
collection is approximately 28 minutes. These estimates include the time for assembly
and submission of information.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, disclose or provide information to or for a federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and verifying information,
processing and maintaining information, and disclosing and providing information; adjust
the existing ways to comply with any previously applicable instructions and requirements;
train personnel to be able to respond to a collection of information; and transmit or
otherwise disclose the information. An agency may not conduct or sponsor, and a person
is not required to respond to, a collection of information unless it displays a currently valid
OMB control number. The OMB control numbers for EPA's regulations are listed in 40
CFR Part 9 and 48 CFR Chapter 15.
Send comments on the Agency's need for this information, the accuracy of the
provided burden estimates, and any suggested methods for minimizing respondent
burden, including through the use of automated collection techniques, to the Director,
OPPE Regulatory Information Division, U.S. Environmental Protection Agency (2137), 401
M St., S.W., Washington, DC 20460; and to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th St., N.W., Washington, DC 20503,
Attention: Desk Officer for EPA. Please include the EPA ICR number and OMB control
number in any correspondence.
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The Class V Underground Injection Control Study April 1, 1998
Appendix A: 1997 Consent Decree with the Sierra Club
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The Class V Underground Injection Control Study April 1, 1998
Appendix B: Executive Summary
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The Class V Underground Injection Control Study April 1, 1998
A Class V injection well is any underground injection control (UIC) well which emplaces
fluids in the subsurface and does not meet the definitions for Class I-IV wells (40 CFR 146.5).
The information collected during the Class V Study will enable EPA to characterize the
nationwide risk Class V wells pose to underground sources of drinking water (USDWs). To
achieve this objective, EPA must have information on the number of wells by subclass and the
risk posed by each subclass.
Data Collection Activities
EPA has undertaken an extensive review of the literature on all well subclasses. To
supplement this, EPA proposes to ask for information from State UIC regulatory programs and
other State agencies. Some of the information requested from State respondents includes:
current regulatory and permitting requirements for each subclass, information on injectate
constituents and concentrations, and information on contamination incidents. EPA also hopes
to gather information from States on the number and location of wells for many subclasses.
EPA will request the number of wells by subclass and the location of each well.
Modeling to Estimate the Number of Wells
EPA believes that State data will be inadequate to estimate the number of wells in some
subclasses including agricultural drainage wells, large-capacity septic systems, and stormwater
drainage wells. EPA will construct a model to estimate the number of wells in these subclasses
nationwide. The model will be an equation that predicts the number of wells in a geographic
area and will enable us to estimate the number of wells nationally. EPA assumes that the
number of wells by subclass in any geographic area can be predicted as a function of certain
independent variables. In this model, these variables will be characteristics of that area. For
example, the number of stormwater wells may be a function of population density, the presence
or absence of storm sewers, and the presence or absence of karst, fractured bedrock, and
poorly drained soils.
Thus, the number of wells of subclass y (Wy) for a geographic area could be predicted
using the following formula:
Wy=a H-b., x., + b^H-. . . b^
where:
a=constant
b=coefficient
x=independent variables
Development of the model consists primarily of estimating the coefficients for each
independent variable. Data on the independent variables will be derived from the census and
other data sources that can be linked to census geographical units. Data for the dependent
variable (number of wells by subclass) will be obtained from site visits, another data collection
activity covered by this ICR. The coefficients will be calculated from a multiple regression
analysis of the data on number of wells gathered during site visits to as many as 150 geographic
areas across the country.
Appendix B - Page 1
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The Class V Underground Injection Control Study April 1, 1998
Risk Model
The risk model will characterize the risk posed by each subclass of wells. Risk will be a
function of the contaminants injected, the concentrations of those contaminants, geology and
whether the contaminants are injected directly into USDWs or are attenuated by soils, and the
population using groundwater sources for drinking water in the vicinity of these injection wells.
The starting point of the model will be the identification of constituents and their likely
concentrations along with characteristics such as persistence and adsorptive properties of the
constituents. Next, for each location where a particular well type occurs, EPA will estimate the
likely attenuation of the contaminant before it reaches a USDW based on location-specific soils
and geology. For contaminants that are injected directly into USDWs, EPA will not need to
estimate the likely attenuation by soils. Finally, EPA will determine the population served by
ground water in areas where these injection wells occur.
A draft risk model was developed based on workgroup consensus. The model will be
revised and applied to each subclass with full workgroup comment and input. EPA also
proposes to have our approach reviewed and evaluated by experts in risk modeling to ensure
that our final approach will be scientifically defensible, given the limitations of our data.
Appendix B - Page 2
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The Class V Underground Injection Control Study April 1, 1998
Appendix C: Request for Data
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The Class V Underground Injection Control Study April 1, 1998
State UIC Coordinator
State House Drive
State Capitol, State
Dear Mr. Coordinator:
EPA is conducting a nationwide study of Class V injection wells as required by a consent
decree with the Sierra Club. A copy of our study design is enclosed. We believe that much of
the information required for this study has already been collected by State UIC Programs.
Therefore, we are asking you to assist us by providing that information.
To reduce the data collection burden on you and your staff, we are not using a time-
consuming questionnaire. Instead, we will specify the types of information that we need, and we
will let you choose the least burdensome method of responding. For example, if your data
already are in a database, you could e-mail or send us an electronic copy of that database. If
you have already sent any of this information to your EPA regional office as part of a routine
reporting process, tell us. If your data are all in hard-copy format, you could copy your files and
forward them to us. If your files are too large, or if you don't have the resources to copy them,
we could send staff to review your files and extract the information. If you want to transform data
from your files into tables, that's fine. In short, choose the method that is least burdensome for
you.
If you have any questions, please call Ms. Anhar Karimjee, Study Manager, Regulatory
Implementation Branch, Office of Ground Water and Drinking Water, at (202) 260-3862. Her e-
mail address is karimjee.anhar@epamail.epa.gov.
Thank you for your assistance.
Sincerely,
Cynthia Dougherty
Director
Office of Ground Water and Drinking Water
Regulatory Implementation Branch
Appendix C - Page 1
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The Class V Underground Injection Control Study April 1, 1998
Underground Injection Control (UIC) Class V Well Study
OMB Number: XXXX-XXXX
Approval Expires: XX/XX/XX
EPA is required to collect this information as part of its consent decree with the Sierra Club, which was amended in 1997.
EPA is authorized to collect this information under § 1421 of the SDWA, 42 USC §300h. Responses to this collection are
voluntary. The public reporting and recordkeeping burden for this collection of information is estimated to average 2
hours per response. Burden means the total time, effort, or financial resources expended by persons to generate,
maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing
ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a
collection of information; search data sources; complete and review collection of information; and transmit or otherwise
disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection
of information unless it displays a currently valid OMB control number. Send comments on the Agency's need for this
information, the accuracy of the burden, including through the use of automated collection techniques to the Director,
OPPE Regulatory Information Division • U.S. Environmental Protection Agency (2137) • 401 M St., S.W. • Washington,
D.C. 20460.* Include the OMB control number in any correspondence. Do not send the completed form to this address.
Appendix C - Page 2
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The Class V Underground Injection Control Study April 1, 1998
Information Request
1. Contact information
Along with the information you provide, please include the following information about the
person(s) who can best answer questions about the data.
Name
Title
Address
Phone number
Fax number
E-mail address
2. Numbers and locations of Class V wells in your State
a. Number of wells by subclass
Class V wells we are studying are listed in the attached table. For all subclasses,
except motor vehicle waste disposal wells, cesspools and industrial wells, we want
to know the number of wells in your State. We are most interested in documented
inventories (e.g., from permitting records), but we will also accept estimates. In
fact, if you have an estimate that is much higher than your documented number,
we are interested in both.
Please explain, for each subclass, whether the number is documented or
an estimate. If it is an estimate, describe the methodology used to create
the estimate.
Thus, for example, the minimum information on this subject would be:
Name of subclass: Mining, sand, or other backfill wells
Number of wells: 321
Source of data: Permitting records
or
Name of sub-class: Aquifer recharge wells
Number of wells: 200
Source of data: Estimate
Methodology: Sample survey of one county
b. Location of wells
We would like to know the location of each well in your inventory (excluding motor
vehicle waste disposal wells, cesspools and industrial wells). We prefer latitude
and longitude coordinates, but we also could use other location information (e.g.,
zip code or county).
Appendix C - Page 3
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The Class V Underground Injection Control Study April 1, 1998
3. Injectate Information
For each of the subclasses of wells, we are interested in any available data on injectate
constituents. Specifically:
What types of constituents have you found in the injectate in each
subclass?
At what concentrations?
In other words, we are interested in any analysis of well injectate samples.
4. Regulatory Requirements
What statutory and regulatory requirements in your State apply to Class V wells? To put
it another way, what requirements exist at the State and local levels of government to
ensure that these wells do not pose risks to human health and the environment?
These requirements may be for permitting, siting, construction, operation, monitoring and
reporting, and so forth. They may be State regulations. They may be local regulations.
They may be a combination of both. For each subclass, send us copies of the
applicable requirements.
5. Contamination Incidents
Have there been any contamination incidents in your State attributed to Class V wells? If
possible, we would like to get information on the well subclass involved, the date of the
incident (or some other identifying information to assist in possible follow-up research),
and what happened.
6. Additional Sources of Information
We are interested in obtaining the most reliable information for this study. If there are
other sources in your State (e.g., other State agencies, universities) who have
information on Class V wells, please give us their name, address, and telephone
number.
Again, thank you for your assistance.
Appendix C - Page 5
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The Class V Underground Injection Control Study
Subclasses of Class V Injection Wells
April 1, 1998
Electric power return flow wells
Direct heat return flow wells
Heat pump/AC return flow wells
Aquaculture waste disposal wells
Wastewater treatment effluent wells
Aquifer recharge wells
Aquifer storage and recovery wells
Salt water intrusion barrier wells
Subsidence control wells
Mining, sand, and other backfill wells
Motor vehicle waste disposal wells
Experimental wells
Special drainage wells
Non-contact cooling water return flow wells
Solution mining wells
In-situ fossil fuel recovery wells
Spent brine return flow wells
Agricultural drainage wells
Storm water drainage wells
Large-capacity septic systems
Aquifer remediation wells
Cesspools
Industrial wells
Appendix C - Page 5
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The Class V Underground Injection Control Study April 1, 1998
Appendix D: Federal Register Notice
62 Fed. Reg. 243 (Dec. 18, 1997)
34
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The Class V Underground Injection Control Study April 1, 1998
Agency Information Collection Activities: Proposed Collection; Comment Request; Class V
Underground Injection Control Study
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
SUMMARY: In compliance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq.), this
document announces that EPA is planning to submit the following proposed Information
Collection Request (ICR) to the Office of Management and Budget (OMB): Class V
Underground Injection Control Study, EPA ICR #1834.01. Before submitting the ICR to OMB for
review and approval, EPA is soliciting comments on specific aspects of the proposed
information collection as described below.
DATES: Comments must be submitted on or before February 17, 1998.
ADDRESSES: To obtain a copy of the ICR without charge please contact the Office of Ground
Water and Drinking Water, EPA Headquarters, 401 M Street SW, Washington, DC 20460 or
contact the persons listed below.
FOR FURTHER INFORMATION CONTACT: Safe Drinking Water Hotline, (800) 426-4791,
e-mail: hotline-sdwa-group@epamail.epa.gov; or Anhar Karimjee, (202) 260-3862, fax (202)
260-0732, e-mail: karimjee.anhar@epamail.epa.gov.
SUPPLEMENTARY INFORMATION:
Affected entities: Entities potentially affected by this action are those which own, operate
or use Class V underground injection wells, or collect, record, or know of information on their
existence and/or their location including, but not limited to: State Environmental Water Quality
Agencies, State Oil and Gas Divisions, State Energy Divisions, State Departments of Health,
State Agricultural Agencies, State Coastal Commissions or Oceanic Divisions, State Mining
and Minerals Divisions, and State Hazardous Waste Divisions.
Title: Class V Underground Injection Control Study, EPA ICR #1834.01.
Abstract: The purpose of this information collection is to gather data on Class V
underground injection wells. The collection will be conducted by EPA's Office of Ground Water
and Drinking Water (OGWDW) as required by section 2c of the EPA's modified consent
decree with the Sierra Club (Sierra Club v. Carol M. Browner, Civil Action No. 93-2644 NHJ,
1997) in order to comply with section 1421 of the Safe Drinking Water Act (42 U.S.C. 300h).
These wells may pose a risk to underground sources of drinking water (USDWs) and therefore
EPA is collecting information necessary to determine whether a national regulation is
appropriate.
The collection will involve two components. First, a small number of initial site visits for
agricultural drainage wells, storm water drainage wells, large capacity septic systems, and
certain lower risk industrial wells will be conducted to count the number of those well types in
certain geologic settings. This data will then be used to create a mathematical model that will
eventually be used to estimate the number of wells in existence on a national scale. Once the
model is created, additional site visits will be conducted to calibrate the model.
The second component of the collection, for fourteen other well subclasses (electric
power return flow wells, direct heat return flow wells, heat pump/AC return flow wells,
Appendix D - Page 1
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The Class V Underground Injection Control Study April 1, 1998
aquaculture wells, wastewater treatment effluent, aquifer recharge wells, aquifer storage and
recovery wells, saltwater intrusion barrier wells, subsidence control wells, mining, sand and
other backfill wells, spent brine recovery wells, solution mining wells, in-situ fossil fuel recovery
wells and aquifer remediation wells), involves general data collection from State and local
agencies on the number of wells in existence and their location on a county level. EPA may
also, for some well subclasses in some States, ask for additional information such as
permitting requirements, contamination incidents and injectate constituents. The site visits and
the data collection component will provide EPA with an estimation of the number of wells, which
will provide, in part, the basis for determining whether national regulations for the well
subclasses are necessary, and if so, the extent of the regulations.
An agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB control number. The OMB
control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR Chapter 15.
The EPA would like to solicit comments to:
(i) evaluate whether the proposed collection of information is necessary for the proper
performance of the functions of the agency, including whether the information will have
practical utility;
(ii) evaluate the accuracy of the agency's estimate of the burden of the proposed
collection of information, including the validity of the methodology and assumptions
used;
(iii) enhance the quality, utility, and clarity of the information to be collected; and
(iv) minimize the burden of the collection of information on those who are to respond,
including through the use of appropriate automated electronic, mechanical, or other
technological collection techniques or other forms of information technology, e.g.,
permitting electronic submission of responses.
Burden Statement: It is estimated that this information collection will involve a total cost
burden to the Respondents of $72,073 and a total hour burden to the Respondents of 2,019
hours. There will be no capital, start-up or operation and maintenance costs but the collection
will involve a one time response, from 2,369 respondents, of approximately 0.85 hours. Burden
means the total time, effort, or financial resources expended by persons to generate, maintain,
retain, or disclose or provide information to or for a Federal agency. This includes the time
needed to review instructions; develop, acquire, install, and utilize technology and systems for
the purposes of collecting, validating, and verifying information, processing and maintaining
information, and disclosing and providing information; adjust the existing ways to comply with
any previously applicable instructions and requirements; train personnel to be able to respond
to a collection of information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information.
Appendix D - Page 2
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