&EPA	Geologic Sequestration of Carbon
United States	T")inX1flp
Environmental Protection	iviuaiuv/
Agency
Underground Injection Control (UIC)
Program Class VI Well Recordkeeping,
Reporting, and Data Management
Guidance for Owners and Operators

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Office of Water (4606M)
EPA 816-R-16-005
September 2016

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Disclaimer
The Class VI injection well classification was established by the Federal Requirements Under
the Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic
Sequestration (GS) Wells (75 FR 77230, December 10, 2010), referred to as the Class VI Rule,
which establishes a new class of injection well (Class VI).
The Safe Drinking Water Act (SDWA) provisions and the United States Environmental
Protection Agency (EPA) regulations cited in this document contain legally-binding
requirements. In several sections, this guidance document makes suggestions and offers
alternatives that go beyond the minimum requirements indicated by the Class VI Rule. This is
intended to provide information and suggestions that may be helpful for implementation efforts.
Such suggestions are prefaced by "may" or "should" and are to be considered advisory. They are
not required elements of the Rule. Therefore, this document does not substitute for those
provisions or regulations, nor is it a regulation itself, so it does not impose legally-binding
requirements on the EPA, states, or the regulated community. The recommendations herein may
not be applicable to each and every situation.
EPA and state decision makers retain the discretion to adopt approaches on a case-by-case basis
that differ from this guidance where appropriate. Any decisions regarding a particular facility
will be made based on the applicable statutes and regulations. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use. This guidance
may change in the future without a formal notice and comment period.
While the EPA has made every effort to ensure the accuracy of the discussion in this document,
the obligations of the regulated community are determined by statutes, regulations, or other
legally binding requirements. In the event of a conflict between the discussion in this document
and any statute or regulation, this document would not be controlling.
Note that this document only addresses issues covered by the EPA's authorities under SDWA.
Other EPA authorities, such as Clean Air Act (CAA) requirements to report carbon dioxide
injection activities under the Greenhouse Gas Reporting Program, are not within the scope of this
document.
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Executive Summary
The EPA's Federal Requirements Under the Underground Injection Control (UIC) Program for
Carbon Dioxide (CO 2) Geologic Sequestration (GS) Wells, codified in the U.S. Code of Federal
Regulations (CFR) [40 CFR 146.81 etseq.], known as the Class VI Rule, establishes a class of
injection well, Class VI, and sets minimum technical criteria for Class VI injection wells for the
purposes of protecting underground sources of drinking water (USDWs). This document is one
of a group of guidance documents developed to support owners or operators of Class VI wells
and the UIC Program permitting authorities.
Under the Class VI Rule, owners or operators of Class VI wells are required to site, construct,
and operate their wells according to the specific technical criteria that address specific GS
activities: site characterization; area of review (AoR) delineation and corrective action; well
construction and operation; financial responsibility; testing and monitoring; reporting and
recordkeeping; post-injection site care (PISC) and site closure; and emergency and remedial
response. Recordkeeping, reporting, and data management are important components of the UIC
Program, helping to ensure that the activities and operations regulated under the program are
conducted as planned, are compliant with the regulations and permit conditions, and, ultimately,
are sufficiently protective of USDWs.
This guidance is intended to describe specific information that owners or operators of Class VI
wells are required or recommended to submit during each GS activity under the Class VI Rule. It
closely references other UIC Program Class VI guidance documents for technical details and its
content complements the information in the UIC Program Class VI Implementation Manual for
Permitting Authorities. This document will help owners or operators understand the type and
format of information the EPA is seeking in order to make risk-based permitting decisions.
Additionally, the Class VI Rule, at 40 CFR 146.91(e), requires owners or operators of Class VI
wells to submit all required reports, submittals, and notifications to the EPA in an approved
electronic format. Therefore, this guidance document also provides recommendations for the use
of the EPA's centralized, integrated electronic reporting and data management system, the
Geologic Sequestration Data Tool (GSDT). The Introduction describes the purpose and
organization of the document and provides background information on the GSDT. The GSDT
provides a framework in which owners and operators should electronically submit information.
Section 2 provides overarching information on the GSDT. Sections 3 through 6 describe
reporting, recordkeeping, and data management activities that take place in the different phases
of a Class VI project's life cycle.
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Table of Contents
Disclaimer	i
Executive Summary	ii
Table of Contents	iii
List of Tables	v
List of Figures	v
Acronyms and Abbreviations	vi
Definitions	vii
1	Introduction	1
1.1	Purpose of Guidance	1
1.2	Class VI Project Phases and Reporting Requirements	3
2	Electronic Reporting and the GSDT	7
2.1	Electronic Reporting under the Class VI Rule	7
2.2	Introduction to the GSDT	8
2.3	GSDT Registration and Access	9
2.4	Project Communications and the Administrative Record	10
2.5	Recordkeeping Requirements	12
3	Pre-Construction Phase Reporting and Recordkeeping	13
3.1	Class VI Permit Applications	14
3.1.1	Site Characterization	16
3.1.2	AoR and Corrective Action	17
3.1.3	Financial Responsibility Demonstration	20
3.1.4	Well Construction and Operation	22
3.1.5	Pre-Operational Testing Program	23
3.1.6	Testing and Monitoring	24
3.1.7	Injection Well Plugging	26
3.1.8	PISC and Site Closure	26
3.1.9	Emergency and Remedial Response	28
3.2	Injection Depth Waivers	29
3.3	Aquifer Exemption Expansions	31
4	Pre-Operation Phase Reporting and Recordkeeping	33
4.1	Site Characterization	35
4.2	AoR and Corrective Action	37
4.3	Injection Well Construction	39
4.4	Pre-Operational Testing	40
4.5	Other Project Plans	41
4.6	Financial Responsibility	42
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5	Injection Phase Reporting and Recordkeeping	44
5.1	Semi-Annual Reports of Testing and Monitoring Results	46
5.1.1	Carbon Dioxide Stream Monitoring Results	47
5.1.2	Operational Monitoring Results	48
5.1.3	Description of Exceedances or Shut-Offs	49
5.1.4	Other Testing and Monitoring Results	50
5.2	Well Testing Notifications and Results	54
5.3	Project Plan Amendments and Other Periodic Reporting	55
5.3.1	AoR Reevaluations and Corrective Action	56
5.3.2	Other Project Plan Amendments	57
5.3.3	Financial Responsibility Updates	59
5.4	Emergency and Remedial Response and Other Occasional Reporting	59
5.4.1	Emergency and Remedial Response	60
5.4.2	Notifications of Adverse Financial Conditions	61
6	Post-Injection Phase Reporting and Recordkeeping	62
6.1	Injection Well Plugging	64
6.1.1	Pre-Plugging Submissions	64
6.1.2	Well Plugging Report	66
6.2	PISC Reporting	66
6.2.1	PISC and Site Closure Plan	67
6.2.2	PISC Monitoring Results	67
6.2.3	Non-Endangerment Demonstration	68
6.3	Site Closure Reporting	69
6.3.1	Pre-Site Closure Submissions	69
6.3.2	Site Closure Report	71
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List of Tables
Table 3-1. Summary of submittals to be made during the pre-construction phase	13
Table 4-1. Summary of submittals to be made during the pre-operation phase, to support the
determination to authorize injection	33
Table 5-1. Summary of submittals to be made during the injection phase	44
Table 6-1. Summary of submittals to be made during the post-injection phase	62
List of Figures
Figure 1-1. Sections of this guidance document and other supporting documentation that
apply to each of the Class VI project phases	4
Figure 2-1. The GS Data Tool registration and ESA process	9
Figure 2-2. The GSDT reporting modules, mapped to project phases and Class VI Rule
requirements	11
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Acronyms and Abbreviations
AoR
Area of Review
CAA
Clean Air Act
CBI
Confidential business information
CFR
Code of Federal Regulations
CROMERR
Cross-Media Electronic Reporting Regulation
CO2
Carbon dioxide
EPA
Environmental Protection Agency
ESA
Electronic Signature Agreement
FR
Federal Register
GIS
Geographic information system
GS
Geologic Sequestration
GS3
Geologic Sequestration Software Suite
GSDT
Geologic Sequestration Data Tool
JRP
Joint Requirements Planning
LAS
Log ASCII Standard
MIT
Mechanical integrity test
PDF
Portable document format
PISC
Post-injection site care
PNNL
Pacific Northwest National Laboratory
PWSS
Public Water System Supervision
QA/QC
Quality assurance/quality control
QASP
Quality Assurance and Surveillance Plan
SDWA
Safe Drinking Water Act
TDS
Total dissolved solids
UIC
Underground Injection Control
USDW
Underground source of drinking water
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Definitions
Key to definition sources:
1: Class VI Rule Preamble.
2: 40 CFR 144.3.
3: 40 CFR 146.81(d).
4: This definition was developed for the purposes of this document.
5: 40 CFR 144.6(f) and 144.80(f).
Annulus means the space between the well casing and the wall of the borehole; the space
between concentric strings of casing; or, the space between casing and tubing.1
Aquifer exemption means a process by which an aquifer or portion of an aquifer is removed
from SDWA protection to allow injection that would otherwise be prohibited, where certain
requirements [40 CFR 146.4] are met. 4
Area of review (AoR) means the region surrounding the GS project where USDWs may be
endangered by the injection activity. The AoR is delineated using computational modeling that
accounts for the physical and chemical properties of all phases of the injected carbon dioxide
stream and displaced fluids, and is based on available site characterization, monitoring, and
operational data as set forth in 40 CFR 146.84.3
Carbon dioxide plume means the extent underground, in three dimensions, of an injected
carbon dioxide stream.3
Carbon dioxide stream means carbon dioxide that has been captured from an emission source
(e.g., a power plant), plus incidental associated substances derived from the source materials and
the capture process, and any substances added to the stream to enable or improve the injection
process. This subpart [subpart H of 40 CFR 146] does not apply to any carbon dioxide stream
that meets the definition of a hazardous waste under 40 CFR Part 261.3
Casing means pipe material placed inside a drilled hole to prevent the hole from collapsing. The
two types of casing in most injection wells are (1) surface casing, the outer-most casing that
extends from the surface to the base of the lowermost USDW and (2) long-string casing, which
extends from the surface to or through the injection zone.1
Cement means material used to support and seal the well casing to the rock formations exposed
in the borehole. Cement also protects the casing from corrosion and prevents movement of
injectate up the borehole. The composition of the cement may vary based on the well type and
purpose; cement may contain latex, mineral blends, or epoxy.1
Class I well means a well that injects hazardous waste, other industrial and municipal waste, and
radioactive wastes beneath the lowermost formation containing, within one quarter mile of the
well bore, an underground source of drinking water.4
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Class II well means a well that injects fluids (1) brought to the surface in connection with
natural gas storage operations or conventional oil or natural gas production, (2) for enhanced
recovery of oil or natural gas, and (3) for storage of hydrocarbons which are liquid at standard
temperature and pressure.4
Class V well means a well designed and constructed for injection, but not included in the
definitions of Class I, II, III, IV, or VI wells. Class V wells inject non-hazardous fluids into or
above a USDW and are typically shallow, on-site disposal systems; however, this class also
includes some deeper injection operations. There are approximately 20 subtypes of Class V
wells.4
Class VI wells means wells that are not experimental in nature that are used for GS of carbon
dioxide beneath the lowermost formation containing a USDW; or, wells used for GS of carbon
dioxide that have been granted a waiver of the injection depth requirements pursuant to
requirements at 40 CFR 146.95; or, wells used for GS of carbon dioxide that have received an
expansion to the areal extent of an existing Class II enhanced oil recovery or enhanced gas
recovery aquifer exemption pursuant to 40 CFR 146.4 and 144.7(d).5
Computational code refers to a series of interrelated mathematical equations solved by
computer to represent the behavior of a complex system. For the purposes of GS, computational
models represent, at a minimum, the flow and transport of multiple fluids and components in
varying phases through porous media. Computational codes offer the ability to predict fluid flow
in the subsurface using scientifically accepted mathematical approximations and theory. The use
of computational codes is necessary because the mathematical formulations describing fluid flow
are complicated and in many cases, non-linear. Several codes have been specifically developed
or tailored for injection activities similar to GS, and can be used for this purpose.4
Computational model means a mathematical representation of the injection project and relevant
features, including injection wells, site geology, and fluids present. For a GS project, site specific
geologic information is used as input to a computational code, creating a computational model
that provides predictions of subsurface conditions, fluid flow, and carbon dioxide plume and
pressure front movement at that site. The computational model comprises all model input and
predictions (i.e., output)4
Confining zone means a geologic formation, group of formations, or part of a formation
strati graphically overlying the injection zone(s) that acts as barrier to fluid movement. For Class
VI wells operating under an injection depth waiver, confining zone means a geologic formation,
group of formations, or part of a formation stratigraphically overlying and underlying the
injection zone(s).3
Corrective action means the use of UIC Program Director-approved methods to ensure that
wells within the AoR do not serve as conduits for the movement of fluids into USDWs.3
Enhanced gas recovery means the process of injecting a gas (i.e., carbon dioxide) into a gas-
bearing formation to displace available gas to allow it to be produced.4
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Enhanced oil recovery means the process of injecting carbon dioxide into an oil reservoir to
thin (decrease the viscosity of) extractable oil, which is then available for recovery.4
Enhanced recovery means either enhanced oil recovery or enhanced gas recovery.4
Fluid means any material or substance which flows or moves, whether in a semisolid, liquid,
sludge, gas, or other form or state.2
Formation or geological formation means a layer of rock that is made up of a certain type of
rock or a combination of types.1
Geologic sequestration (GS) means the long-term containment of a gaseous, liquid, or
supercritical carbon dioxide stream in subsurface geologic formations. This term does not apply
to carbon dioxide capture or transport.3
Geologic Sequestration Data Tool (GSDT) means the EPA's centralized, integrated electronic
reporting and data management system for Class VI projects.4
GS project means an injection well or wells used to emplace a carbon dioxide stream beneath
the lowermost formation containing a USDW; or, wells used for GS of carbon dioxide that have
been granted a waiver of the injection depth requirements pursuant to requirements at 40 CFR
146.95; or, wells used for GS of carbon dioxide that have received an expansion to the areal
extent of an existing Class II enhanced oil recovery or enhanced gas recovery aquifer exemption
pursuant to 40 CFR 146.4 and 144.7(d). It includes the subsurface three-dimensional extent of
the carbon dioxide plume, associated area of elevated pressure, and displaced fluids, as well as
the surface area above that delineated region.3
Injectate means the fluids injected. For the purposes of the Class VI Rule, this is also known as
the carbon dioxide stream.1
Injection depth waiver refers to a waiver of the Class VI injection depth requirements by the
UIC Program Director and the EPA Regional Administrator pursuant to provisions at 40 CFR
146.95.4
Injection zone means a geologic formation, group of formations, or part of a formation that is of
sufficient areal extent, thickness, porosity, and permeability to receive carbon dioxide through a
well or wells associated with a GS project.3
Mechanical integrity means the absence of significant leakage within the injection tubing,
casing, or packer (known as internal mechanical integrity), or outside of the casing (known as
external mechanical integrity).1
Mechanical integrity test (MIT) refers to a test performed on a well to confirm that a well
maintains internal and external mechanical integrity. MITs are a means of measuring the
adequacy of the construction of an injection well and a way to detect problems within the well
system.1
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Model means a representation or simulation of a phenomenon or process that is difficult to
observe directly or that occurs over long time frames. Models that support GS can predict the
flow of carbon dioxide within the subsurface, accounting for the properties and fluid content of
the subsurface formations and the effects of injection parameters.1
Owner or operator means the owner or operator of any facility or activity subject to regulation
under the UIC program.2
Packer means a mechanical device that seals the outside of the tubing to the inside of the long-
string casing, isolating an annular space.1
Phased corrective action refers to a provision of the Class VI Rule [40 CFR 146.84(b)(2)(iv)]
afforded to Class VI injection well owners or operators to defer some identified corrective action
needed within the AoR, but farther away from the injection well, until after injection has
commenced, but prior to carbon dioxide plume and pressure front movement into that particular
area.4
Post-injection site care (PISC) means appropriate monitoring and other actions (including
corrective action) needed following cessation of injection to ensure that USDWs are not
endangered, as required under 40 CFR 146.93.3
Pressure front means the zone of elevated pressure that is created by the injection of carbon
dioxide into the subsurface. For GS projects, the pressure front of a carbon dioxide plume refers
to the zone where there is a pressure differential sufficient to cause the movement of injected
fluids or formation fluids into a USDW.3
Primacy (primary enforcement responsibility) means the authority to implement the UIC
Program. To receive primacy, a state, territory, or tribe must demonstrate to the EPA that its UIC
program is at least as stringent as the federal standards; the state, territory, or tribal UIC
requirements may be more stringent than the federal requirements. The EPA may grant primacy
for all or part of the UIC program, e.g., for certain classes of injection wells.4
Site closure means the point/time, as determined by the UIC Program Director following the
requirements under 40 CFR 146.93, at which the owner or operator of a GS site is released from
PISC responsibilities.3
Total dissolved solids (TDS) refers to the measurement, usually in mg/L, for the amount of all
inorganic and organic substances suspended in liquid as molecules, ions, or granules. For
injection operations, TDS typically refers to the saline (i.e., salt) content of water-saturated
underground formations.1
Tubing refers to a small-diameter pipe installed inside the casing of a well. Tubing conducts
injected fluids from the wellhead at the surface to the injection zone and protects the long-string
casing of a well from corrosion or damage by the injected fluids.4
Underground Injection Control (UIC) Program refers to the program that the EPA, or an
approved state, is authorized to implement under SDWA that is responsible for regulating the
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underground injection of fluids by well injection. This includes setting the federal minimum
requirements for construction, operation, permitting, and closure of underground injection wells.4
Underground Injection Control (UIC) Program Director refers to the chief administrative
officer of any state or tribal agency or the EPA Region that has been delegated to operate an
approved UIC program.4
Underground source of drinking water (USDW) means an aquifer or its portion which
supplies any public water system; or which contains a sufficient quantity of ground water to
supply a public water system; and currently supplies drinking water for human consumption; or
contains fewer than 10,000 mg/L TDS; and which is not an exempted aquifer.2
Well bore refers to the hole that remains throughout a geologic (rock) formation after a well is
drilled.4
Workover refers to any maintenance activity performed on a well that involves ceasing injection
or production and removing the wellhead.4
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1 Introduction
To ensure the protection of underground sources of drinking water (USDWs), the United States
Environmental Protection Agency (EPA) established minimum federal requirements for the
proper management of carbon dioxide injection and storage under the authority of Part C of the
Safe Drinking Water Act (SDWA) on December 10, 2010. The Federal Requirements Under the
Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic
Sequestration (GS) Wells, found at 75 FR 77230 and hereafter referred to as the Class VI Rule,
establishes a new class of injection wells, Class VI, for the injection of carbon dioxide for GS.
The Class VI Rule defines technical criteria for the safe deployment of Class VI projects,
including site characterization; area of review (AoR) delineation and corrective action; well
construction and operation; financial responsibility; testing and monitoring; reporting and
recordkeeping; well plugging, post-injection site care (PISC) and site closure; and emergency
and remedial response. It requires well owners or operators to collect, generate, and report
specific information needed to inform permitting and compliance decisions related to siting,
constructing, operating, monitoring, and closing a Class VI well [40 CFR 146.81 et seq.].
Pursuant to Section 1445 of SDWA, owners or operators subject to requirements under SDWA
must establish and maintain records, conduct monitoring, and provide any information that the
Administrator or a representative, such as a UIC Program Director, may require by regulation to
comply with the Act. Therefore, reporting and recordkeeping are important components of the
UIC Program to ensure that activities and operations regulated under the program are conducted
as planned, are compliant with the regulations and permit conditions, and, ultimately, are
sufficiently protective of USDWs.
1.1 Purpose of Guidance
This guidance is one of a group of guidance documents that describe Class VI well operations
that are protective of USDWs and in compliance with the Class VI Rule. This document is
designed to provide guidance to Class VI injection well owners or operators and their
representatives regarding recordkeeping, reporting, and management of data associated with
Class VI projects.
Specifically, the purpose of this guidance document is to provide:
•	A comprehensive description of the reporting and recordkeeping requirements of the
Class VI Rule, for each phase of a Class VI project (see Section 1.2 for a discussion of
the Class VI project phases).
•	A description of the reporting process, as guided by the EPA's Geologic Sequestration
Data Tool (GSDT). The GSDT is an electronic reporting tool for Class VI owners,
operators, and permitting authorities, developed by the EPA to facilitate compliance with
40 CFR 146.91(e).
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• Information on how the reporting, recordkeeping, and data management activities will
ensure USDW protection and support compliance determinations. The GSDT supports
the creation and maintenance of a comprehensive administrative record for each project,
which supports the EPA's permitting and compliance decisions.
The EPA recommends that this guidance document be used by owners or operators for support in
navigating the reporting and recordkeeping requirements of the Class VI Rule. The tables and
text boxes provided throughout the document give an overview of associated reporting
processes/GSDT workflows, identify resources that owners or operators can use when
developing their submissions, and can serve as
a check to ensure that regulatory requirements
have been met. In addition to these quick
reference items, the document provides the
basis for the reporting requirements of each
project phase (as described in the text of this
document), which is critical to ensuring
efficiency in permitting and operations
throughout the life of an injection project. The
EPA's experience with issuing Class VI
permits has informed the suggestions that are
made throughout this document, and every
effort has been made to maximize efficiency
while adhering to the Class VI Rule and
ensuring USDW protection.
As noted above, this document is one of a
complementary suite of technical guidance
documents that address various aspects of
permitting and operating a Class VI injection
well. This document focuses specifically on
the reporting process for Class VI projects:
what information to submit, when and how to
submit it, and in what format the EPA
recommends that it be submitted. Other Class
VI guidance documents (see the box at right)
provide recommendations for conducting the
activities necessary to generate this information, and references to these other documents are
noted in the text where appropriate. As they are finalized, all of the Class VI guidance documents
will be made available on the EPA's website at http://www epa.gov/uic/class-vi-euidance-
documents and https://www.epa.gov/uic/guidance-documents-underground-iniection-control-
financial-respoiisibilities.
The EPA has also developed the UIC Program Class VI Implementation Manual for Permitting
Authorities, which describes requirements and provides recommendations specific to the
activities of UIC Program Directors. This Implementation Manual may also be useful to owners
or operators, helping them to understand the review and oversight process that will follow their
submissions, and anticipate what the permitting authority will need to inform its review.
Class VI Guidance Documents
for Owners or Operators
•	UIC Program Class VI Well Site
Characterization Guidance
•	UIC Program Class VI Well Area of
Review Evaluation and Corrective Action
Guidance
•	UIC Program Class VI Financial
Responsibility Guidance
•	UIC Program Class VI Well Construction
Guidance
•	UIC Program Class VI Well Testing and
Monitoring Guidance
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site Closure
Guidance
•	UIC Program Class VI Well Project Plan
Development Guidance
•	UIC Program Class VI Well Injection
Depth Waivers Guidance
•	UIC Program Guidance on Transitioning
Class II Wells to Class VI Wells
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1.2 Class VI Project Phases and Reporting Requirements
The Class VI Rule requires owners or operators to submit information throughout the lifetime of
a Class VI project to demonstrate protection of USDWs and maintain regulatory compliance. A
Class VI project consists of four main phases: (1) the pre-operational phase prior to construction
(also referred to as the pre-construction phase), (2) the pre-operational phase prior to operation
(also referred to as the pre-operation phase), (3) the injection phase, and (4) the post-injection
phase. Figure 1-1 (on the following page) illustrates these project phases, the milestones that
separate them, and the sections of this guidance document that provide reporting
recommendations for each. As shown in the figure, the GSDT user guides and related resources
apply throughout all four phases of a Class VI project's life cycle. The paragraphs below
summarize the key activities that take place during each project phase, along with the associated
requirements for reporting, recordkeeping, and data management.
The pre-construction phase begins with the submission of a Class VI permit application. The
Class VI Rule, at 40 CFR 146.82(a), requires prospective owners or operators to submit a permit
application prior to the issuance of a permit for the construction of a new Class VI well or the
conversion of an existing well to a Class VI well. The permit application (see Section 3.1) is a
comprehensive collection of proposed project
information, including a characterization of the site, an
AoR delineation supported by computational modeling,
proposed well construction and operation details, a
demonstration of financial responsibility, and five
project-specific plans (the AoR and Corrective Action
Plan, the Testing and Monitoring Plan, the Injection
Well Plugging Plan, the PISC and Site Closure Plan,
and the Emergency and Remedial Response Plan).
Owners or operators seeking to convert existing Class
I, Class II, or Class V experimental technology wells to
Class VI must demonstrate that the wells were
engineered and constructed to meet the requirements at
40 CFR 146.86(a) and to ensure protection of USDWs, in lieu of requirements at 40 CFR
146.86(b) and 146.87(a).1 Permit applicants seeking a waiver of the requirement to inject below
the lowermost USDW must also submit a supplemental report as required at 40 CFR 146.95(a).
This injection depth waiver application report (see Section 3.2) must be submitted concurrent
with the permit application, pursuant to 40 CFR 146.82(d). In addition, owners or operators
seeking to expand the areal extent of an existing aquifer exemption will need to apply to the UIC
Program Director pursuant to the requirements at 40 CFR 144.7(d)(1). Recommendations for
submittals associated with aquifer exemption expansions are presented in Section 3.3.
Pre-Construction Phase Reporting
•	Class VI permit application
40 CFR 146.82(a)
•	Injection depth waiver application
report, if applicable
40 CFR 146.95
•	Aquifer exemption expansion
request, if applicable
40 CFR 144.7(d) and 146.4(d)
1 While the Class VI Rule, at 40 CFR 146.81(c) and 146.82(a), specifically lists Class I, Class II, and Class V
experimental technology wells as examples of wells that can transition to Class VI, EPA may also consider other
types of wells (e.g., monitoring or stratigraphic test wells) for conversion to Class VI provided they meet all of the
applicable regulatory requirements. When EPA considers other types of wells for conversion to Class VI, those
wells are subject to the same regulatory requirements as those well types listed as examples in 40 CFR 146.81(c)
and 146.82(a).
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PRE-CONSTRUCTION
PRE-OPERATION
INJECTION
POST-INJECTION
I Permit
application
\ submitted
5
f Permit
I issued or J
\ denied
Section 3:
Pre-Construction Phase
Reporting and
Recordkeeping
[ Auth.to^V
issued or
denied
Section 4:
Pre-Operation Phase
Reporting and
Recordkeeping
Cessation
of injection
Section 5:
Injection Phase
Reporting and
Recordkeeping
Records
•eceived fc
Director
Section 6:
Post-Injection Phase
Reporting and
Recordkeeping
H
H
GSDT user guides and additional resources
H
i
Figure 1-1. Sections of this guidance document and other supporting documentation that apply to each of the Class VI project phases.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
4

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The pre-construction phase includes an iterative evaluation process, during which permit
applicants may be required to make subsequent submissions in response to requests for
additional information from the UIC Program Director. These requests would be made to achieve
compliance with the rule requirements and/or to provide clarification to the permitting authority;
the Class VI Rule, at 40 CFR 146.82(a)(21), provides the Director discretion to request
additional information to inform his or her evaluation. When all of the information identified at
40 CFR 146.82(a) has been submitted and evaluated, the UIC Program Director will evaluate it
and determine whether to issue a Class VI permit that authorizes the owner or operator to
construct a Class VI well (or to convert an existing well to Class VI, if applicable).
The pre-operation phase is the period during which the owner or operator and UIC Program
Director comply with the requirements under 40 CFR 146.82(c) and previously established
permit conditions. Before an owner or operator may inject carbon dioxide, the UIC Program
Director must consider information generated in
conjunction with drilling and construction, and the
EPA expects that owners or operators will submit
all of the information necessary to support the
Director's review when that information has not
otherwise been made available to the Director. This
information, specified at 40 CFR 146.82(c),
includes the results of logs, surveys, and tests
conducted pursuant to 40 CFR 146.87; a final AoR
delineation; site characterization updates based on
data gathered during drilling and testing; final well
construction information; and final project plans. In
addition, updates to financial responsibility cost
estimates and/or financial instruments may take
place during this phase. Section 4 presents
recommendations for pre-operation submittals.
Similar to the pre-construction phase, the UIC
Program Director's evaluation of Class VI Rule
compliance during the pre-operation phase may
require an iterative process with submission of
additional information and/or clarification by the
owner or operator. When all of the required
information has been submitted and evaluated, the UIC Program Director will determine whether
to authorize injection operations. Issuance of the final decision to authorize injection marks the
end of this phase.
Pre-Operation Phase Reporting
Site characterization updates
40 CFR 146.82(c)(2)-(3)
Amended AoR and Corrective Action
Plan, including final AoR delineation and
corrective action status
40 CFR 146.82(c)(1), (6), (9)
Injection well construction updates
40 CFR 146.82(c)(3), (5)
Pre-operational testing results
40 CFR 146.82(c)(4), (7), (8)
Amendments to other project plans
40 CFR 146.82(c)(9)
Any other information requested
by the UIC Program Director
40 CFR 146.82(c)(10)
Financial responsibility updates
40 CFR 146.85
During the injection phase—when the actual injection operation takes place—owners or
operators are required to submit information at certain intervals to demonstrate compliance with
the Class VI requirements. Pursuant to 40 CFR 146.91(a)-(d), owners or operators must submit
semi-annual reports of testing and monitoring results; 30-day advance notifications of well tests;
well test results within 30 days of each test; and notifications of emergency situations within 24
hours of their occurrence.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
5

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Periodically throughout the injection phase,
owners or operators must reevaluate the project's
AoR and, if necessary, amend one or more of their
project plans [40 CFR 146.84(e), 146.90(j), and
146.94(d)], Owners or operators must also update
financial responsibility information annually and
under certain other conditions [40 CFR
146.85(a)(5)(ii)]. See Section 5 of this document
for recommendations related to injection phase
submittals.
The post-injection phase begins with the
cessation of injection activities. During this phase,
owners or operators must plug the injection well,
perform post-injection monitoring activities,
demonstrate that no additional monitoring is
needed to ensure that the site does not pose an
endangerment to USDWs, and close the site, pursuant to 40 CFR 146.92 and 146.93. Because
injection wells may be converted to monitoring wells after injection has ceased, injection well
plugging is not required to take place at the beginning of the post-injection phase. However,
pursuant to 40 CFR 146.93(f)(1), the site closure report must include documentation of
appropriate injection well and monitoring well
plugging as specified in 40 CFR 146.92 and
146.93(e) regardless of when the injection well
plugging took place.
As necessary during the post-injection phase, the
owner or operator will also perform AoR
reevaluations and potentially amend the associated
project plans, provide updates on financial
responsibility, and conduct emergency and
remedial response activities. Reporting associated
with this phase of the Class VI project is
described in Section 6 and includes: submitting a notice of intent to plug the well; submitting an
injection well plugging report; submitting an amended PISC and Site Closure Plan; reporting the
results of PISC monitoring; performing a non-endangerment demonstration; and submitting a
site closure report. The post-injection phase ends when the site is closed and the UIC Program
Director receives the site closure report; owners or operators must also deliver post-injection
records to the UIC Program Director following a 10-year retention period, as required by 40 CFR
146.93(h).
Injection Phase Reporting
Semi-annual reports of testing and
monitoring results
40 CFR 146.91(a)
Well test notifications and results
40 CFR 146.91(b), (d)
Project plan amendments and other
periodic reporting
40 CFR 146.84(e)(4); 146.85; 146.90(j);
146.93(a)(4); 146.94(d)
Emergency and remedial response and
other occasional reporting
40 CFR 146.85(d); 40 CFR 146.88(f)(4)-
(5), 146.91(c), 146.94(b)-(c)
Post-Injection Phase Reporting
•	Injection well plugging submissions
40 CFR 146.92(c)-(d)
•	PISC submissions, including the non-
endangerment demonstration
40 CFR 146.93(a)-(b)
•	Site closure submissions
40 CFR 146.93(d), (f)
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
6

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2 Electronic Reporting and the GSDT
Under the Class VI Rule at 40 CFR 146.91(e), owners or operators are required to submit data
generated and collected during the lifetime of a Class VI project directly to the EPA in an
approved electronic format. The EPA developed the GSDT to facilitate compliance with this
electronic reporting requirement. The requirement applies regardless of whether the project is
located in a jurisdiction with primary enforcement responsibility (primacy) for Class VI wells,
and UIC Program Directors of primacy states, tribes, and territories are encouraged to use the
GSDT to eliminate duplicative reporting for owners and operators. The following subsections
provide more information about electronic reporting in the context of the Class VI program, the
key components and capabilities of the GSDT, and the recordkeeping requirements of the Class
VI Rule.
2.1 Electronic Reporting under the Class VI Rule
Given the complex nature of Class VI well operations and the more comprehensive requirements
of the Class VI Rule compared to those for other UIC well classes, a centralized and integrated
reporting system that is managed by the EPA is essential for effective oversight of Class VI
projects and management of GS data.
Centralized electronic reporting and data management offers several advantages, including:
•	Reducing the burden on permit applicants/owners or operators for data submittal while
also assisting with recordkeeping.
•	Creating an instantaneous submission process, which is essential for the time-sensitive
reporting required under the Class VI Rule, such as 24-hour emergency notifications.
•	Facilitating collaboration among owner or operator project team members and between
owners or operators and permitting authorities.
•	Supporting consistency and continuity for projects with long lifetimes.
•	Developing a complete, accurate, and reproducible administrative record for project
permitting and compliance decisions.
•	Reducing the burden on permitting authorities that receive and manage data.
In addition, centralized electronic reporting and recordkeeping facilitates transparency and
supports the EPA's ability to respond to information requests from Congress, the public, and
other interested parties. This characteristic is consistent with the recommendations of the Report
of the Interagency Task Force on Carbon Capture and Storage: "State UIC primacy agencies'
efforts could be aided by a national data system that would promote regulatory certainty,
efficiency, and accountability, while allowing transparency of all geologic sequestration related
information."2
2 Interagency Task Force on Carbon Capture and Storage. 2010. Report of the Interagency Task Force on Carbon
Capture and Storage, p. C-8. Available on the Internet at: hltp://vvww.cpa.gov7climatcchangc/Downloads/ccs/CCS-
T ask-Forcc-Rcport-2010. pdf.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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To determine the optimal way to address these electronic reporting needs, the EPA conducted a
Joint Requirements Planning (JRP) process in 2011. During a JRP process, stakeholders and
content experts participate in structured meetings to collaboratively identify, define, create, and
refine user requirements. The EPA held JRP stakeholder meetings with participants from two
groups: potential EPA users (particularly those from the EPA regional offices) and potential state
and owner or operator users. The EPA then developed an Alternatives Analysis and conducted a
cost-benefit evaluation of data system alternatives based on the information received from these
stakeholders. Ultimately, the EPA determined that the most cost-effective alternative with the
greatest operational value was a tool that relied on an existing system called the Geologic
Sequestration Software Suite (GS3), which was developed by the Pacific Northwest National
Laboratory (PNNL). The GSDT was developed using GS3 as a starting point.
2.2 Introduction to the GSDT
The Class VI Rule is organized according to key UIC Program elements, such as AoR and
corrective action, financial responsibility, testing and monitoring, etc. Owners or operators of
Class VI wells will submit information for these various topic areas throughout the life of their
projects, as described in Section 1.2. To facilitate the efficient submittal of Class VI information,
the GSDT utilizes a modular structure for reporting that corresponds to topic areas within the
Class VI Rule (see the box below). The GSDT modules are structured to reflect the Class VI
Rule requirements (as shown in Figure 2-2 in
Section 2.4), and Sections 3 through 6 of this
guidance document refer to the GSDT modules to
describe information requirements and associated
recommendations for information type and format.
Class VI permit applicants, owners, and operators
all access the GSDT through a centralized landing
page, from which they can launch each of the
reporting modules. The modules themselves consist
of structured electronic forms that reflect the Class
VI Rule requirements. Within the GSDT reporting
modules, owners or operators provide information
in three main ways: selections via check boxes,
radio buttons, or drop-down menus; direct entry
into text fields; and file uploads.
In some modules, the GSDT also provides
templates that users can download, populate,
upload, and submit. This helps users ensure that
they have included all the necessary information to
fulfill the applicable Class VI Rule requirements,
while providing them the flexibility to tailor
submissions to their particular projects.
Each reporting module has a user guide that describes the specific technical procedures
necessary to populate and submit data using that module. These user guides can be downloaded

GSDT Reporting Modules for

Owners or Operators
•
Project Information Tracking

(for submitting/organizing general

project data and permit applications)
•
AoR and Corrective Action
•
Financial Responsibility Demonstration
•
Pre-Operational Testing
•
Project Plan Submissions
•
Alternative PISC Timeframe

Demonstration
•
Injection Depth Waivers and Aquifer

Exemption Expansions
•
Non-Endangerment Demonstration
•
Injection and Post-Injection Phase

Reporting
•
Information Request

(for responding to permitting authority

requests for additional information)
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
8

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from within the modules and accessed from the operator landing page of the GSDT. Permitting
authorities can also provide copies of the user guides to permit applicants/owners or operators.
Because the GSDT modules may be updated over time (e.g., in response to user feedback), this
guidance document focuses on the content and timing of submittals, with more specific technical
recommendations described in the GSDT user guides and other resources. For the most up-to-
date information on particular fields/actions within the GSDT, owners or operators should refer
to the user guides or contact their permitting authority.
In light of the nearly universal use of computerized systems (particularly for wells as technically
complex as Class VI wells), the EPA anticipates that most owners or operators will be able to
submit data electronically using the GSDT. However, the EPA recognizes that there may be
some circumstances where it will be necessary to submit data non-electronically or via an
alternative electronic method. For example, the GSDT is not designed to receive confidential
business information (CBI). Owners or operators who would like to claim information as CBI or
otherwise discuss the possibility of submitting data outside of the GSDT should contact their
permitting authority for further information and instructions. If any owners or operators cannot
submit the required data using the GSDT, they should work with their UIC Program Director to
identify an appropriate alternate reporting format or procedure to ensure regulatory compliance.
2.3 GSDT Registration and Access
The GSDT is for authorized users only and requires registration in compliance with the EPA's
Cross-Media Electronic Reporting Regulation (CROMERR) and 40 CFR 144.32(a), under which
UIC permit applications or other submittals by corporations must be signed by a responsible
corporate officer or other authorized personnel. For permit applicants/owners or operators, there
is a three-step process for establishing access to the GSDT (see Figure 2-1). This process
includes establishing an Electronic Signature Agreement (ESA) to designate the authorized
personnel who will submit information via the GSDT over the life of a Class VI well.
Step 1:
The prospective owner or operator downloads the GSDT Registration Form
from https://epa.velo.pnnl.gov/operators, fills out the form, and
returns it by email to GSDataTool@epa.gov.
*
Step 2:
EPA assigns account credentials for the project and sends them to the owner
or operator at the contact email address provided in the registration form.
The owner or operator downloads an ESA form from the landing page of the GSDT.
*
Step 3:
The owner or operator's responsible corporate officer(s) or other designated individual(s)
sign, notarize, and return the ESA form(s) to EPA in hard copy. These individuals will be
authorized to electronically submit information pursuant to 40 CFR 144.32(a).
Figure 2-1. The GS Data Tool registration and ESA process.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
9

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GSDT accounts are issued on a per-project basis, meaning that there is one set of credentials for
each project. This also means that data associated with a project is managed collectively
regardless of the number of injection wells proposed for the project. (However, pursuant to 40
CFR 144.33, each injection well must be permitted separately with distinct Class VI permit
numbers, and each well will be issued a unique UIC permit.) The project-level approach within
the GSDT allows permit applicants/owners or operators to efficiently submit combined
information that applies to all wells within a project (e.g., computational modeling results for
AoR delineation).
Because only one set of credentials will be issued to an organization for a particular project, it is
the owner or operator's responsibility to make sure that only appropriate individuals have access
to the credentials. All users authorized by the owner or operator organization will need to
establish an ESA with the EPA before they can make submissions using the GSDT.
2.4 Project Communications and the Administrative Record
An administrative record is a collection of documents that forms the basis for an EPA decision,
including the provisions of a draft or final permit where the EPA is the permitting authority (see
40 CFR 124.9 and 124.18). The administrative record for a Class VI permit decision will include
all components of the permit application—including any supporting documentation or responses
to requests for additional information—once the permit is issued. By capturing and preserving all
submissions, the GSDT supports the development of this record in an efficient and transparent
manner. The EPA continues to build the record throughout the life of a Class VI project to
document all of the materials that support compliance and oversight decisions.
The EPA encourages permit applicants/owners or operators to communicate with their
permitting authorities throughout the lifetime of a Class VI project and acknowledges that
different modes of communication (such as email, conference calls, etc.) may be appropriate in
different situations. Note that any information supporting the permitting decision (e.g., files sent
in response to questions or requests for additional information from the permitting authority) is
considered to be part of the administrative record by the EPA. For this reason, the EPA
recommends using the GSDT for all submissions of permitting- and compliance-related
materials. The Information Request module of the GSDT was designed specifically to facilitate
this type of information sharing in a way that preserves a clear and complete record while
tracking the submission of additional information by owners or operators.
Most modules within the GSDT are designed to be used during multiple Class VI project phases
(see Figure 2-2). This allows owners or operators to come back to modules that they have
already populated and provide updated information when necessary. For example, an owner or
operator who needs to submit annual financial responsibility updates will only need to update
those fields in the Financial Responsibility Demonstration module that have changed since the
last submission. All submissions are time-stamped and preserved by the system so that the
GSDT contains a comprehensive log for the administrative record.
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Data Management Guidance for Owners and Operators
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Class VI Project Phases and Associated Reporting Activities
GS Data Tool
Reporting Module
Project
Information Tracking
AoR and
Corrective Action
Financial Responsibility
Demonstration
Project Plan
Submissions
Alternative PISC
Timeframe
Demonstration
Pre-Operational
Testing
Injection and
Post-Injection
Phase Reporting
Non-Endangerment
Demonstration
Injection Depth Waivers
and Aquifer Exemption
Expansions
co2
l|—r—^ 1
Pre-Construction
Pre-Operation
Injection
Post-Injection
¦
Permit application
40 CFR 146.82(a)
Permit application updates and other
pre-operation information
40 CFR 146.82(c)
Updates to basic project
information
N/A
Updates to basic project
information
N/A
Proposed AoR and Corrective Action Plan,
including AoR delineation and corrective
action information
40 CFR 146.82(a)(4); 146.84(c)
Amended AoR and Corrective Action Plan,
including final AoR delineation and
corrective action status
40 CFR 146.82(C)(1),(6),(9)
AoR revaluations and associated AoR
and Corrective Action Plan amendments
40 CFR 146.84(e)
AoR reevaluations and associated AoR
and Corrective Action Plan amendments
40 CFR 146.84(e)
Financial responsibility demonstration,
including cost estimate and financial
instruments
40 CFR 146.82(a)(14); 146.85(a)(5)(i)
Financial responsibility cost estimate
and instrument updates
40 CFR 146.85(a)(5)(H), (c)(2)-(4), (e)
Notice of adverse financial conditions
40 CFR 146.82(C)(9)
Financial responsibility cost estimate and
instrument updates
40 CFR 146.85(a)(5)(H), (c)(2)-(4), (e)
Notice of adverse financial conditions
40 CFR 146.85(d)
Financial responsibility cost estimate and
instrument updates
40 CFR 146.85(a)(5)(H), (c)(2)-(4), (e)
Notice of adverse financial conditions
40 CFR 146.85(d)
Other proposed project plans
40 CFR 146.82(a)(15)-(17), (19); 146.84(b);
146.90; 146.92(b); 146.93(a)
Other project plan amendments
40 CFR 146.82(c)(9)
Other project plan amendments
40 CFR 146.90Q); 146.93(a)(4); 146.94(d)
Other project plan amendments
40 CFR 146.92(c); 146.93(a)(3)-(4), (d); 146.94(d)
Alternative PISC timeframe
demonstration, as part of a proposed
PISC and Site Closure Plan
40 CFR 146.82(a)(18); 146.93(c)
Updated alternative PISC timeframe
demonstration, as part of an amended
PISC and Site Closure Plan
40 CFR 146.82(c)(9)
Updated alternative PISC timeframe
demonstration, as part of an amended
PISC and Site Closure Plan
40 CFR 146.93(a)(4)
Updated alternative PISC timeframe
demonstration, as part of an amended
PISC and Site Closure Plan
40 CFR 146.93(a)(4)
Proposed pre-operational logging and
testing program
40 CFR 146.82(a)(8)
Schedule of pre-operational logging and
testing activities
40 CFR 146.87(f)
Pre-operational logging and testing results
40 CFR 146.82(c)(4), (7)-(8); 146.87(a)-(f)




Semi-annual reports of testing and
monitoring results
40 CFR 146.91(a)
Well test notification and results
40 CFR 146.91(b),(d)
Emergency and remedial
response reporting
40 CFR 146.88(f)(4)-(5); 146.91(c); 146.94(b)-(c)
PISC monitoring results
40 CFR 146.93(b)
Well plugging/site closure notifications
and reports
40 CFR 146.92(c)-(d); 146.93(d),(f)
Emergency and remedial
response reporting
40 CFR 146.88(f)(4)-(5); 146.91(c); 146.94(b)-(c)
Non-endangerment demonstration
40CFRl46.93(b)(2)-(3)
Injection depth waiver application
40 CFR 146.82(d); 146.95(a)
Aquifer exemption expansion request
40 CFR 144.77(d); 146.4(d)

Figure 2-2. The GSDT reporting modules, mapped to project phases and Class VI Rule requirements.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
11

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2.5 Recordkeeping Requirements
Under the requirements outlined at 40 CFR 146.91(f), owners or operators of Class VI injection
wells must retain records as follows:3
•	All data collected under 40 CFR 146.82 for a Class VI permit application must be
retained throughout the life of the Class VI project and for 10 years following site
closure.
•	Data on the nature and composition of all injected fluids collected under 40 CFR
146.90(a) must be retained until 10 years after site closure. The UIC Program Director
may require the owner or operator to deliver the records at the conclusion of the retention
period.
•	All other monitoring data collected under 40 CFR 146.90(b) through (i) must be retained
for 10 years after it is collected.
•	Well plugging reports, post-injection data (including, if applicable, data and information
used to develop the alternative PISC timeframe demonstration), and site closure reports,
must be retained for 10 years following site closure.
The UIC Program Director also has the authority, pursuant to 40 CFR 146.91(f)(5), to require the
owner or operator to retain records for longer than 10 years after site closure.
In compliance with CROMERR, materials submitted to the GSDT are time-stamped and
preserved in a read-only format. These processes allow the EPA to build a comprehensive
administrative record for each Class VI project (see Section 2.4) and support recordkeeping for
both the owner or operator and the permitting authority. However, note that owners or operators
must still comply with the recordkeeping requirements of the Class VI Rule, i.e., they must retain
copies of all submittals as required by 40 CFR 146.91(f).
While the GSDT maintains a record of all previous submittals, allowing the permitting authority
to build a comprehensive administrative record, the reporting modules available to owners or
operators only display the current version of each submittal. In other words, owners or operators
will only be able to access their most recently submitted information via the GSDT modules, and
they cannot go back to review older submissions within the GSDT. Independent recordkeeping
by owners or operators will ensure that they have access to the content of all previous
submissions that may have been superseded by newer information.
3 For the purposes of the recordkeeping requirements discussed throughout this section, "data collected" is inclusive
of both submitted data and data that support a permit applicant's decision-making process.
UIC Program Class VI Well Recordkeeping, Reporting, and
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12

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3 Pre-Construction Phase Reporting and Recordkeeping
Prospective owners or operators (i.e., permit applicants) must submit certain information before
receiving a permit to begin construction of a new Class VI well or the conversion of an existing
Class I, Class II, or Class V experimental technology well to a Class VI well [40 CFR
146.82(a)], This submittal, which makes up the Class VI permit application, includes information
related to site characterization, AoR delineation, corrective action, injection well construction,
operating information, and other topic areas. In addition to the permit application, owners or
operators seeking a waiver of the injection depth requirement must also concurrently submit a
waiver application report [40 CFR 146.95(a)], Owners or operators of existing Class II wells that
have made the business decision to transition to Class VI and that are operating under an aquifer
exemption may also need to submit information requesting the expansion of the areal extent of
that aquifer exemption [40 CFR 144.7(d)],
The submittals to be made during this project phase are summarized in Table 3-1 and described
in more detail in the subsections below. Note that, pursuant to 40 CFR 146.91(f)(1), all data
collected for Class VI permit applications must be retained throughout the life of the Class VI
project and for 10 years following site closure. While not required, the EPA recommends that
owners or operators retain associated information related to injection depth waivers for the same
timeframe. Additionally, where an owner or operator received a Class VI aquifer exemption
expansion, the EPA recommends that the owner or operator retain aquifer exemption-related
documents4 indefinitely, particularly where the exempted aquifer may be used for injection in the
future.
The EPA recommends that all prospective owners or operators contact their permitting authority
before preparing a Class VI permit application, both to establish access to the GSDT (including
its templates and other resources) and to discuss any project-specific considerations that may
affect the preparation or review of the permit application.
Table 3-1. Summary of submittals to be made during the pre-construction phase.
Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Class VI permit
application [40 CFR
146.82(a)]
Project Information
Tracking module (which
contains a checklist of
other modules to use for
more detailed
submissions; see
subsections below)
Basic project information
- directly entered into the
module
Permit application
narrative - uploaded file,
with supplemental
uploaded items as
necessary (see below)
Detailed data
submissions - other GSDT
modules (see below)
Prior to well construction
or conversion, per 40 CFR
146.82(a)
4 The regulatory authority is an additional resource for aquifer-exemption records, retaining them indefinitely.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
13

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Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Class VI permit
application [40 CFR
146.82(a)], continued
Project Information
Tracking module (which
contains a checklist of
other modules to use for
more detailed
submissions; see
subsections below)
Additional information
requested by the UIC
Program Director -
uploaded file(s)
Prior to well construction
or conversion, per 40 CFR
146.82(a)
Injection depth waiver
application [40 CFR
146.82(d)]
Injection Depth Waivers
and Aquifer Exemption
Expansions module
A combination of
uploaded files and
references to previously
submitted materials
Concurrent with the
permit application, per 40
CFR 146.95(a)
Application to expand the
areal extent of an aquifer
exemption [40 CFR
144.7(d) and 146.4(d)]
Injection Depth Waivers
and Aquifer Exemption
Expansions module
A combination of
uploaded files and
references to previously
submitted materials
Concurrent with the
permit application
(recommended)
3.1 Class VI Permit Applications
Permit application requirements for Class VI wells are specified at 40 CFR 146.82(a) and are
summarized in the box below. To fulfill these requirements, a Class VI permit application must
include multiple types of information with varying levels of technical complexity. Ideally, when
considered together, the components of a Class VI permit application will present an integrated,
site-specific strategy for demonstrating site suitability and USDW protection. Recommendations
for submitting each of these components are provided in the following subsections.
The Project Information Tracking module of the GSDT helps prospective owners or operators to
successfully navigate the Class VI permit application process. To reduce the potential for
redundancy and to organize permit application components in a manner that facilitates efficient
review by the permitting authority, the EPA recommends that Class VI permit applicants submit
both:
1.	A narrative describing characterization of the proposed site and project, overall strategies
for project operations, and other general project information (compiled into a single file
and submitted using the Project Information Tracking module of the GSDT).
2.	Specific, detailed information required by certain Class VI Rule provisions (submitted
using other GSDT modules, which are tailored to the applicable Class VI Rule
requirements).
The Project Information Tracking module provides a narrative template that permit applicants
can download, complete, and upload back to the module. The EPA strongly recommends that
permit applicants use the template, which includes specific instructions and examples for each
section of the narrative. The Project Information Tracking module also provides a checklist of
other GSDT modules to be populated during the permit application process. Information
submitted with these other modules does not need to be repeated in the narrative, and the
UIC Program Class VI Well Recordkeeping, Reporting, and
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narrative template includes placeholders indicating where certain rule requirements can be
fulfilled directly in the GSDT. Because of this, the EPA recommends that permit applicants
review the relevant GSDT modules and/or user guides described below before developing the
narrative, to avoid duplicating efforts or information.
While the GSDT modules associated with the permit application can be submitted in any order,
the EPA recommends the following process. First, permit applicants should complete the general
project information sections of the Project
Information Tracking module (including the
project name, contact information, list of existing
permits, etc.). Second, they should populate and
submit the modules used to provide detailed
information. This includes both the modules
associated with the required permit application
components, such as the AoR and Corrective
Action module, and (if applicable) any optional
modules, such as the Alternative PISC Timeframe
Demonstration module. Third, they should finish
populating the 40 CFR 146.82(a) section of the
Project Information Tracking module (by
uploading the narrative and filling out the
checklist) and submit it.
For ease of submission and to facilitate the
permitting authority's evaluation, the EPA
recommends that the 40 CFR 146.82(a) narrative
be provided as a single portable document format
(PDF) file. Supplemental materials that
accompany the narrative but are not compatible
with this format, such as tabular data, high-
resolution images, or geographic information
system (GIS) files like shapefiles, may be
provided separately, using the module field
designated for "any other information requested
by the UIC Program Director."
Pursuant to 40 CFR 146.82, owners or operators
of Class I, Class II, or Class V experimental
technology wells that are converting to Class VI
may incorporate pre-existing information into
their permit applications by reference. However,
to be compliant with this regulatory requirement and the requirement to electronically report
information pursuant to 40 CFR 146.91(e), this referenced information must be current, readily
available to the UIC Program Director, sufficiently identified to allow retrieval, and available in
an electronic format. For example, certain maps and cross-sections included with a well's
original permit application may already be on file; if they meet the requirements at 40 CFR
146.82 and 146.91(e), these materials could be referenced in the Class VI permit application
Permit Application Requirements
•	Basic project information
40 CFR 146.82(a)(1), (20)
•	Site characterization information
40 CFR 146.82(a)(2)-(3), (5)-(6)
•	Proposed AoR and Corrective Action
Plan and associated modeling data
40 CFR 146.82(a)(4), (13)
•	Financial responsibility demonstration
40 CFR 146.82(a)(14)
•	Injection well construction data
40 CFR 146.82(a)(9), (11), (12)
•	Proposed pre-operational testing
program
40 CFR 146.82(a)(8)
•	Proposed operating data
40 CFR 146.82(a)(7), (10)
•	Proposed Testing and Monitoring Plan
40 CFR 146.82(a)(15)
•	Proposed Injection Well Plugging Plan
40 CFR 146.82(a)(16)
•	Proposed PISC and Site Closure Plan
40 CFR 146.82(a)(17), (18)
•	Proposed Emergency and Remedial
Response Plan
40 CFR 146.82(a)(19)
•	Any other information requested
by the UIC Program Director
40 CFR 146.82(a)(21)
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instead of being re-submitted. The EPA encourages applicants interested in referencing
information from previous permits to consult with their permitting authority and to consider the
benefits of ensuring a complete record of the project within the GSDT for the duration of a Class
VI project.
The EPA considers a permit application to be submitted when all associated components have
been received in a way that complies with 40 CFR 146.91(e). Because of the technical
complexity of a Class VI permit application, the EPA expects that the permitting process will be
an iterative one. Permitting authorities may need to ask clarifying questions, request additional
information, or discuss the content of the application with prospective owners or operators. (As
described in Section 2.4, the GSDT's Information Request module will facilitate written
communications between permit applicants and permitting authorities during this process.)
Permit applicants should contact their permitting authority with any specific questions about the
Class VI permit application review process.
3.1.1 Site Characterization
Site characterization information required under 40 CFR 146.82(a) includes information on the
geologic, geomechanical, and hydrogeologic characteristics of the proposed storage site
(including the proposed injection zone and overlying formations), as well as baseline
geochemical data and other information on USDWs in the AoR. This information is used to
demonstrate that the site meets the minimum criteria for suitability specified at 40 CFR 146.83,
and it also serves as the foundation, informing plans
for site operation, computational modeling, testing
and monitoring, and other aspects of the project.
Preparing the site characterization component of a
Class VI permit application generally involves both
desktop analysis of secondary information and the
collection of primary data in the field, such as ground
water sampling or geophysical surveying. Some of
these analyses may be supported with literature
reviews and summaries of existing information about
the site. The UIC Program Class VI Well Site
Characterization Guidance presents
recommendations for gathering necessary data and
demonstrating the suitability of a proposed GS site.
The site characterization material can be incorporated
into the 40 CFR 146.82(a) narrative template,
available in the Project Information Tracking module of the GSDT. The narrative should
integrate the information specified under 40 CFR 146.82(a)(2)-(3) and (5)-(6) to demonstrate a
clear and data-driven understanding of the site and show how the site meets the criteria at 40
CFR 146.83. When the narrative is complete, it should be submitted using the Project
Information Tracking module as part of the permit application. Note that certain site-related
information will also be provided as part of the AoR delineation submission in the AoR and
Corrective Action module (see Section 3.1.2).
Site Characterization Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(2)-(3), (5)-(6)
•	40 CFR 146.83
Relevant GSDT modules:
•	Project Information Tracking module
•	AoR and Corrective Action module
Reference documents:
•	UIC Program Class VI Well Site
Characterization Guidance
Electronic resources:
•	40 CFR 146.82(a) narrative template
•	GSDT user guides
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As stated above, the EPA recommends that the 40 CFR 146.82(a) narrative be provided as a
single PDF file, with supplemental materials provided separately using the module field
designated for "any other information requested by the UIC Program Director." Supplemental
materials, such as legacy data, historical maps, or similar materials should be legible and clear
(e.g., contour lines are unambiguous, legends are visible, acronyms are defined, images have an
appropriate scale, etc.). If secondary data are used, sources should be clearly cited to support an
evaluation of this information. For primary data, relevant reference information—such as the
date/time, location/depth, method name, test conditions, assumptions, limitations, quality
assurance (QA) protocols, etc.—associated with a sampling event should be included. This
reference information is particularly important for baseline data, such as that required by 40 CFR
146.82(a)(6), because it will be used as a point of comparison for future monitoring results. If
calculations or experimental results are provided in the permit application, the permitting
authority will likely ask for documentation of assumptions and methods used to interpret the
results.
The Class VI Rule recognizes that project sites will have varying levels of pre-existing
information and that some data submitted with a permit application will be preliminary. As part
of the site characterization narrative, the EPA recommends discussing data gaps and
uncertainties that will be addressed through the formation testing program and other activities
conducted after well construction/conversion, but before receiving authorization to inject (see
Section 3.1.5 and Section 4). The ultimate goal of the site characterization information is to
demonstrate that the site is suitable, pursuant to 40 CFR 146.83; the EPA encourages permit
applicants to include any additional information they deem necessary to support this
demonstration even if it is not explicitly identified in the rule.
Because many of the Class VI Rule requirements are designed to be site-specific, site
characterization information forms the foundation for several other components of the permit
application. Therefore, site characterization materials should be consistent with related permit
application components. For example, site parameters entered into the AoR and Corrective
Action module for the critical pressure calculation should not conflict with the content of the
narrative. More broadly, the site characterization submission should support the other site-
specific aspects of the permit application, such as the proposed well construction procedures, the
injection and post-injection phase testing and monitoring strategies, the Emergency and
Remedial Response Plan, etc.
Permit applicants should contact their permitting authority if questions arise about whether a
certain type of information is necessary or if the recommended level of detail is unclear. The
EPA recommends discussion of how certain Class VI Rule requirements apply to an individual
project (e.g., whether a secondary confining zone is necessary) before permit application
submittal.
3.1.2 AoR and Corrective Action
The Class VI Rule, at 40 CFR 146.84(a), requires that the well's AoR be delineated using
computational modeling that accounts for the physical and chemical properties of all phases of
the injected carbon dioxide stream, based on available site characterization, monitoring, and
operational data. The purpose of this effort is to delineate a project area where USDWs may be
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endangered due to the injection activity. AoR delineation also supports other components of the
permit application and the project as a whole, such as defining the area where corrective action
may be needed, determining financial responsibility
cost estimates, developing project-specific testing
and monitoring strategies for the injection and post-
injection phases, and supporting alternative PISC
timeframe demonstrations.
In the pre-construction phase, delineation of the
AoR relies on existing site data and proposed
project information. As new information becomes
available throughout the lifetime of the project, the
AoR will need to be reevaluated pursuant to 40 CFR
146.84(e). Therefore, permit applicants must submit
an AoR and Corrective Action Plan that proposes
site-specific procedures for delineating the AoR and
periodically reevaluating this delineation, as well as
for performing any necessary corrective action [40
CFR 146.84(b)], In addition, 40 CFR 146.82(a)(4)
specifically requires permit applicants to provide a
tabulation of wells in the AoR to support the
corrective action evaluation.
The computational modeling effort is the primary
focus of the AoR and corrective action components
of the permit application. However, in addition to the modeling information, well data (e.g., from
state oil and gas databases) and proposed procedures for conducting AoR reevaluations and
performing corrective action must also be submitted to fulfill Class VI Rule requirements under
40 CFR 146.84. Detailed information on model development and AoR delineation can be found
in the UIC Program Class VI Well Area of Review Evaluation and Corrective Action Guidance
and recommendations for developing project plans is presented in the UIC Program Class VI
Well Project Plan Development Guidance.
The AoR and Corrective Action Plan and the detailed information that supports it (e.g.,
computational modeling data such as simulator information and model input, assumptions,
output, etc., and the tabulation of wells in the AoR) can all be submitted using the AoR and
Corrective Action module. This module contains a plan template that can be downloaded,
populated, and uploaded back to the module. Recommendations for compiling and providing
each component of the AoR and corrective action submittal are provided in the subsections
below.
It may be helpful for permit applicants to discuss any questions related to data files and formats
with their permitting authority prior to entering the information into the AoR and Corrective
Action module. The EPA recommends that applicants work with their permitting authority to
identify the best approach for submitting project-specific modeling information; this will also
help the permitting authority determine the most efficient and effective process to evaluate this
information. Following successful submission of information in the AoR and Corrective Action
AoR and Corrective Action
Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(4), (13)
•	40 CFR 146.84
Relevant GSDT modules:
•	Project Information Tracking module
•	AoR and Corrective Action module
Reference documents:
•	UIC Program Class VI Well Area of
Review Evaluation and Corrective
Action Guidance
•	UIC Program Class VI Well Project Plan
Development Guidance
Electronic resources:
•	AoR and Corrective Action Plan
template
•	GSDT user guides
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module, the relevant boxes in the Project Information Tracking module can be checked. Note
that the permitting authority's evaluation depends on the submission of complete, accurate, and
consistent information and cannot be completed before the full set of information is submitted.
AoR and Corrective Action Plan
The detailed computational modeling and corrective action data submitted via the AoR and
Corrective Action module represent essential supporting information for the AoR and Corrective
Action Plan. However, it is the plan itself that will be incorporated into the Class VI permit and
will become directly enforceable per 40 CFR 146.84(b). In the plan, permit applicants should
explain how they will demonstrate compliance with the Class VI requirements relevant to AoR
delineation, corrective action, AoR reevaluation, and the plan itself. The EPA recommends that
the plan consist of a narrative that describes procedures for delineating the AoR using
computational modeling, addressing all deficient artificial penetrations within the AoR, and
reevaluating the AoR periodically throughout the life of the project.
The EPA recommends that the AoR and Corrective Action Plan be provided as a single PDF file,
uploaded to the AoR and Corrective Action module. As noted above, a template is available in
the module to guide development of this document. The template was designed to help ensure
that the plan meets all the Class VI Rule requirements while allowing for project-specific
flexibility. Within the standardized format of the template, applicants are encouraged to tailor
their plans to the needs of their particular projects. Information submitted elsewhere in the AoR
and Corrective Action module may be referenced in the narrative (e.g., in the context of
describing how the information is used in the delineation process, how it supports the proposed
strategies for the corrective action or AoR reevaluation, etc.). Cross-references to other GSDT
submittals are also encouraged wherever appropriate.
Pursuant to 40 CFR 146.84(b), the requirement to maintain and implement the AoR and
Corrective Action Plan is directly enforceable regardless of whether that requirement is a
condition of the Class VI permit. Supplemental or supporting material that informs evaluation of
the plan but is not intended to become an enforceable requirement for the project (e.g., reference
documents, descriptions of alternative methods considered for AoR delineation, etc.) should not
be incorporated into the plan file but should be submitted elsewhere in the module.
Detailed Computational Modeling and Corrective Action Data
The EPA recommends that permit applicants submit all information that the UIC Program
Director would need for an independent evaluation of the AoR delineation and the associated
corrective action strategy. The AoR and Corrective Action module of the GSDT provides a
structured approach to submitting (and, later, updating) the detailed data that support the
narrative portion of the modeling information. This information serves to benchmark the AoR
delineation at this phase, to provide continuity in decision making and support AoR
reevaluations and the non-endangerment demonstration in later phases of the project.
The AoR and Corrective Action module facilitates submission of the following categories of
information: model domain, processes modeled, rock properties, boundary conditions, initial
conditions, operational information, model output, AoR pressure front delineation, and corrective
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action. The module prompts users to provide information in several formats, including image
files, tabular data, and short written descriptions. The EPA recommends following the
instructions in the module itself and in the associated user guide to ensure that the appropriate
type of information is submitted. Explanations for all data files, either in the file itself or in the
description/comment fields of the module, should be submitted so that the data can be
understood and evaluated appropriately. Explanations should include a description of what is
included in each file, how the data are formatted, and any necessary identifying information
(e.g., model domain coordinates, simulation duration, etc.). Because an important component of
the permitting authority's review is evaluating the degree to which the model simulates actual
conditions, all site-related information should be clearly presented and consistent with the site
characterization narrative.
The EPA recognizes that some Class VI permit applications may rely on proprietary models,
software, or inputs. Users should submit only non-proprietary information with the GSDT. The
AoR and Corrective Action module does not necessitate user submittal of actual models or
code—only the parameters, assumptions, results, and other supporting information that will
allow the permitting authority to fully evaluate the AoR delineation are required. Also,
remember that the GSDT is not designed to accept CBI. If permit applicants would like to claim
information as CBI or otherwise discuss the possibility of submitting data outside of the GSDT,
they should contact their permitting authority for further information and instructions.
In addition to the actual modeling data, the module includes a section for corrective action data.
Users are encouraged to submit the population of wells in the AoR either in a tabular format
(e.g., .CSV) or as a GIS file (e.g., shapefile). The well construction/plugging information
required by 40 CFR 146.82(a)(4)—well type, construction, date drilled, depth, record of
plugging and/or completion—can also be included directly in this file (e.g., as metadata
associated with a shapefile).
Permit applicants should contact their permitting authority if they have questions about how to
submit modeling information, e.g., to determine if certain file types are acceptable or for
clarification on how to format output data. It may also be helpful to discuss how to most
efficiently submit related information, such as modeling information associated with an
alternative PISC timeframe demonstration. While the AoR and Corrective Action module
provides flexibility in choosing the file formats for submission, the EPA recommends that permit
applicants discuss which file formats to use, as well as any other questions they may have, with
their permitting authority. This communication can help determine the best approach(es) for
submitting this information and will facilitate the technical evaluation conducted by the
permitting authority.
3.1.3 Financial Responsibility Demonstration
The Class VI Rule, at 40 CFR 146.85, requires owners or operators of Class VI wells to
demonstrate and maintain financial responsibility for performing corrective action, injection well
plugging, PISC, site closure, and emergency and remedial response. The purpose of the financial
responsibility demonstration submitted with the permit application, required by 40 CFR
146.82(a)(14), is to ensure that sufficient resources exist to carry out activities related to closing
and (if necessary) remediating GS sites so that they do not endanger USDWs.
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The financial responsibility demonstration in the permit application has two main components:
cost estimates for the applicable project activities and financial instruments sufficient to cover
those costs. Pursuant to 40 CFR 146.85(c), the cost estimate must reflect costs of hiring a third
party to perform the required activities; as a result, the EPA expects that the cost estimate
provided as part of the permit application will be an independent estimate generated by an
organization that is not within the corporate structure of the owner or operator. Most financial
instruments will be generated by a financial institution, but this depends on the instrument type.
More detailed information on developing the financial responsibility demonstration is given in
the UIC Program Class VIFinancial Responsibility Guidance. Additional EPA resources that
may be helpful for permit applicants are available at http://www.epa. gov/uic/fmancial-
responsibilities-underground-iniection-well-owners-or-operators.
Both the cost estimate and the financial instruments
are submitted using the Financial Responsibility
Demonstration module. For the cost estimate, permit
applicants should enter the costs for each covered
activity and upload the independent cost estimate.
Applicants may also include supplemental materials,
such as engineering reports, that support the estimate.
Similarly, for the financial instruments, owners or
operators should make the selections on the
appropriate tab(s) and upload copies of the
instrument(s) and/or documents that prove the third-
party instrument or self-insurance is in place and
sufficient to cover the estimated costs. Because
banks, insurers, or other financial institutions may
not provide the specific instruments until the
applicant is prepared to purchase them, the initial
permit application may only contain information
about the types of financial instruments to be used
rather than the instruments themselves. For insurance
policies, the EPA recommends that a copy of the
policy be included in addition to the certificate of insurance, when it is available. Some
instruments have special requirements; for example, the owner or operator must document the
financial strength of the provider pursuant to 40 CFR 146.85(a)(6)(ii) for third-party instruments.
The instructions within the Financial Responsibility Demonstration module guide the submission
of information to fulfill these requirements.
Permit applicants should contact their permitting authority if they have questions about what
information is necessary to include in the financial responsibility demonstration. It may be
appropriate to request a preliminary, informal review of one or more aspects of the cost estimate
before finalizing decisions about which financial instrument(s) to obtain. The Financial
Responsibility Demonstration module is designed to accommodate this review by allowing cost
estimate and financial instrument submissions to be made at different times. However, note that
the permit application (as a whole) will not be considered complete until all components
Financial Responsibility Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(14)
•	40 CFR 146.85
Relevant GSDT modules:
•	Project Information Tracking module
•	Financial Responsibility
Demonstration module
Reference documents:
•	UIC Program Class VI Financial
Responsibility Guidance
Electronic resources:
•	Online materials at
http://www.epa.gov/uic/financial-
responsibilities-underground-
iniection-well-owners-or-operators
•	GSDT user guides
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(including either copies of financial instalments or descriptions of the instruments to be secured)
are successfully submitted.
3.1.4 Well Construction and Operation
As part of the permit application, prospective owners or operators must submit proposed
construction and operating data for the Class VI project, including:
•	Proposed operational parameters and injectate characteristics [40 CFR 146.82(a)(7)],
•	Proposed stimulation program, if applicable [40 CFR 146.82(a)(9)],
•	Proposed operating procedures, outlining the steps necessary to conduct injection
operation [40 CFR 146.82(a)(10)].
•	Schematics or other appropriate drawings of injection well construction [40 CFR
146.82(a)(l 1)].
•	Proposed injection well construction procedures [40 CFR 146.82(a)(12)].
These materials must meet the requirements at 40 CFR 146.86 (to demonstrate that the planned
well construction is adequate to prevent movement of fluids into USDWs or other unauthorized
zones) and at 40 CFR 146.88 (to demonstrate that
the proposed operational procedures will be
protective of USDWs). Refer to the UIC Program
Class VI Well Construction Guidance for
information on designing and constructing an
injection well that meets the Class VI Rule
requirements.
Permit application components associated with
these requirements will likely be a combination of
narrative description (including tables, charts, etc.)
and figures/illustrations (such as from computer-
aided design programs). This material can be
incorporated into the 40 CFR 146.82(a) narrative,
using the template provided in the Project
Information Tracking module. As noted above, the
EPA recommends that the 40 CFR 146.82(a)
narrative be provided as a single PDF file.
Supplemental materials that accompany the
narrative but are not compatible with this format
(such as high-resolution images) may be provided separately, using the module field designated
for "any other information requested by the UIC Program Director." Regardless of whether
schematics and other images are incorporated into the narrative or provided separately, they
should be legible and clear (e.g., legends and scales included, labels visible, etc.).
Specifically, the EPA recommends that the well schematics/drawings include the following
elements: the wellhead; the surface casing, long-string casing, and any intermediate casings;
Well Construction and Operation
Submissions
Class VI Rule requirements:
•	40 CFR 146.81(c)
•	40 CFR 146.82(a)(7), (9)-(12)
•	40 CFR 146.86
•	40 CFR 146.88
Relevant GSDT modules:
•	Project Information Tracking module
Reference documents:
•	UIC Program Class VI Well
Construction Guidance
Electronic resources:
•	40 CFR 146.82(a) narrative template
•	GSDT user guides
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cement placement; the tubing and packer; the type and location of the safety valve(s) and any
landing nipples, if used; and proposed completion details, including perforated zones and
construction materials to be used. Examples of other documentation that may be submitted to
demonstrate compliance with the construction requirements include: copies of construction
specifications, references to any standards or best management practices to be followed during
construction, and manufacturer specifications on materials used for well construction (e.g.,
corrosion and temperature resistance ratings or material strengths).
Pursuant to 40 CFR 146.81(c), owners or operators of Class I, Class II, or Class V experimental
technology wells transitioning to Class VI do not need to meet the specific construction
requirements at 40 CFR 146.86(b). Instead, they must demonstrate that their wells were
engineered and constructed to meet the requirements at 40 CFR 146.86(a) and to ensure
protection of USDWs. For example, an owner or operator might demonstrate adequate materials
strength by providing computations showing calculated down-hole stresses on the casing, tubing,
cement, and packer. Because this demonstration will be specific to each individual well, the EPA
recommends that affected owners or operators communicate with their permitting authorities
before submitting a Class VI permit application, to determine what information will be necessary
to make the demonstration.
The EPA also recommends pre-construction discussions between permit applicants and
permitting authorities if site- or project-specific considerations may require alternative
construction procedures. For example, if cement cannot be recirculated to the surface, the UIC
Program Director may approve an alternative method of cementing; if this is the case, owners or
operators must submit logs to demonstrate that the cement does not allow fluid migration behind
the well bore, pursuant to 40 CFR 146.86(b)(4). Appropriate communication with the permitting
authority in the pre-construction stage will help ensure a more efficient permitting process.
Additionally, this communication can help streamline the pre-operational testing process (see
Section 4) because it provides an opportunity for permitting authorities and owners or operators
to discuss whether any additional or alternative methods may be necessary to meet the
requirements at 40 CFR 146.87.
3.1.5 Pre-Operational Testing Program
With the permit application, the prospective owner or operator must submit a proposed pre-
operational well and formation testing program to verify proper construction of the well and
obtain an analysis of the chemical and physical characteristics of the injection zone(s) and
confining zone(s) [40 CFR 146.82(a)(8)], This proposed program must meet the requirements at
40 CFR 146.87, which include elements related to both site characterization (to reduce
uncertainties associated with site characterization and the AoR delineation) and well integrity (to
demonstrate that the well itself will not create a pathway for fluid migration into USDWs). The
resulting data from these logs and tests will form the foundation of the pre-operation submissions
under 40 CFR 146.82(c), as described in Section 4.
The Class VI Rule, at 40 CFR 146.87, specifies certain minimum requirements or options for the
pre-operational testing program. Beyond that, owners or operators have the flexibility to design a
program that will collect sufficient information about the well's integrity and the geology of the
site to inform a determination that USDWs will be protected. Both the UIC Program Class VI
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Well Site Characterization Guidance and the UIC Program Class VI Well Construction
Guidance provide recommendations for this process.
The EPA recommends that the description of the proposed pre-operational testing program be
submitted as a single PDF containing the necessary narrative description, tables/charts, maps,
etc. While this submission is part of the permit application, it is uploaded separately in the Pre-
operational Testing module. This module will be used during the pre-operation phase to provide
the results of the logging and testing (see Section 4); using the same module for the proposed
activities and their results helps to ensure that all necessary materials are easily accessible for
review (both by the owner or operator, when submitting the logging and testing results, and by
the permitting authority, during evaluation of this material). The box indicating the submission
of the pre-operational testing program in the Project Information Tracking module should be
checked when finalizing the permit application submission.
Permit applicants should contact their permitting authority with questions about what materials
to include in the pre-operational testing program submission. The Class VI Rule, at 40 CFR
147.87(a)(5), allows permit applicants to use
alternative logging and testing methods that provide
equivalent or better information, provided that they
are approved by the UIC Program Director. The UIC
Program Director may also require the use of
alternative methods. The EPA recommends
discussing the potential use of alternative methods
with the permitting authority prior to submitting a
permit application.
Owners or operators of existing wells transitioning to
Class VI must demonstrate that the wells were
engineered and constructed to meet the requirements
at 40 CFR 146.86(a) and to ensure protection of
USDWs, in lieu of conducting the logs/tests specified
at 40 CFR 146.87(a). As with the construction
requirements, the EPA recommends that owners or
operators discuss the content of this demonstration
with their permitting authorities to determine what, if
any, information may be needed, e.g., results of
previous mechanical integrity tests (MITs) or data that may have been collected during the
construction of the well. Note that owners or operators of transitioning wells are responsible for
meeting all other requirements at 40 CFR 146.87.
3.1.6 Testing and Monitoring
The Class VI Rule, at 40 CFR 146.82(a)(15) requires permit applicants to submit a Testing and
Monitoring Plan describing how they will meet the requirements at 40 CFR 146.90. The Testing
and Monitoring Plan describes the permit applicant's strategies for identifying potential
endangerment of USDWs, demonstrating that the well is maintaining mechanical integrity, that
Pre-Operational Testing Program
Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(8)
•	40 CFR 146.87
Relevant GSDT modules:
•	Project Information Tracking module
•	Pre-Operational Testing module
Reference documents:
•	UIC Program Class VI Well Site
Characterization Guidance
•	UIC Program Class VI Well
Construction Guidance
Electronic resources:
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
24

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the project is operating as planned, and that the carbon dioxide plume and pressure front are
behaving as predicted.
Testing and monitoring results are the primary method of assessing the performance of the
project and provide points of comparison for modeled predictions. As a result, the Testing and
Monitoring Plan should present data collection methods sufficient to support AoR reevaluations,
demonstrations of whether project plan amendments or financial responsibility cost estimate
updates are needed, and the non-endangerment demonstration that will be made before site
closure. The UIC Program Class VI Well Testing and Monitoring Guidance and the UIC
Program Class VI Well Project Plan Development Guidance provide recommendations for
developing a plan that will meet the rule requirements and lead to the collection of the necessary
data.
A template for the Testing and Monitoring Plan is available in the Project Plan Submissions
module. Like the templates for the other Class VI project plans, this template was designed to
help ensure that the plan meets all the Class VI Rule
requirements while allowing for project-specific
flexibility; within the standardized format of the
template, applicants are encouraged to tailor their
plans to the needs of their particular projects. The
EPA recommends that the plan be provided as a
single PDF that includes the Quality Assurance and
Surveillance Plan (QASP) required by 40 CFR
146.90(k). Upload the completed plan to the Project
Plan Submissions module. The box indicating the
submission of the Testing and Monitoring Plan in
the Project Information Tracking module should be
checked when finalizing the permit application
submission.
Pursuant to 40 CFR 146.90, the requirement to
maintain and implement the Testing and Monitoring
Plan is directly enforceable regardless of whether
that requirement is a condition of the Class VI
permit. There may be supplemental or supporting
material that would inform evaluation of the submission but does not need to be in the
enforceable plan (e.g., reference documents or example specifications from equipment vendors).
These materials can instead be uploaded through the designated field in the module.
Permit applicants should contact their permitting authority if they have questions about what to
include in the Testing and Monitoring Plan or QASP (including which information to include in
the QASP rather than in the body of the plan). It may also be appropriate to discuss whether
alternative/additional monitoring activities (e.g., surface air and/or soil gas monitoring,
seismicity monitoring, alternative MITs, etc.) may be necessary for a given project.
Testing and Monitoring Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(15)
•	40 CFR 146.90
Relevant GSDT modules:
•	Project Information Tracking module
•	Project Plan Submissions module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	Testing and Monitoring Plan template
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
25

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3.1.7 Injection Well Plugging
Class VI permit applicants must submit an Injection Well Plugging Plan that describes how the
owner or operator will meet the requirements at 40 CFR 146.92 [40 CFR 146.82(a)(16)]. As
described at 40 CFR 146.92(b), the plan includes information such as planned tests or measures
to determine bottom-hole reservoir pressure and ensure external mechanical integrity; the type
and number of plugs to be used; the planned placement of each plug; the type, grade, and
quantity of material to be used in plugging; and the
proposed method for plug placement.
Similar to the injection well construction component
of the permit application, the EPA recommends that
the Injection Well Plugging Plan consist of narrative
description and schematics or other illustrations. As
with the other Class VI project plans, a
recommended template is provided in the Project
Plan Submissions module of the GSDT. The template
can be tailored as appropriate to reflect project-
specific considerations and uploaded after
completion to the Project Plan Submissions module.
Any supplemental or supporting material should be
submitted in the designated field, and the associated
box in the Project Information Tracking module
should be checked.
Permit applicants should contact their permitting
authority if they have questions about what to include
in the Injection Well Plugging Plan or if they wish to
discuss whether alternative/additional activities (e.g., alternative MITs) may be appropriate for a
given project.
3.1.8 PISC and Site Closure
The Class VI Rule, at 40 CFR 146.82(a)(17), requires permit applicants to submit a PISC and
Site Closure Plan that proposes post-injection monitoring strategies, describes how non-
endangerment of USDWs will be ensured throughout the post-injection phase, and provides
procedures for site closure in compliance with 40 CFR 146.93. Proper post-injection monitoring
and site closure procedures ensure that neither the injectate nor any mobilized fluids/increased
pressures endanger USDWs. The applicant may also submit a request for a PISC timeframe other
than the 50-year default, pursuant to 40 CFR 146.82(a)(18).
Both the PISC and Site Closure Plan and the alternative PISC timeframe demonstration (if
applicable) rely on predictions from the AoR modeling effort to support decisions about post-
injection activities. As a result, narrative descriptions in these submissions should be
accompanied by charts, graphs, tables, maps, and/or other materials showing the relevant results
from the AoR delineation modeling process. Refer to the UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site Closure Guidance and the UIC Program Class VI Well Project
Injection Well Plugging Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(16)
•	40 CFR 146.92
Relevant GSDT modules:
•	Project Information Tracking module
•	Project Plan Submissions module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	Injection Well Plugging Plan template
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
26

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Plan Development Guidance for recommendations on preparing the PISC and Site Closure Plan
and proposing an appropriate alternative PISC timeframe.
Like the other Class VI project plans, the PISC and
Site Closure Plan can be completed using a template
available in the Project Plan Submissions module.
Pursuant to 40 CFR 146.93(a)(2)(v), the plan must
state the duration of the PISC timeframe and
demonstrate that this timeframe provides for an
adequate duration of post-injection monitoring to
ensure that the carbon dioxide plume and pressure
front will not endanger USDWs. However, because
of the specificity and technical complexity of the
requirements for this demonstration, the EPA has
designed a separate GSDT module to guide permit
applicants through submitting the detailed data
required to support an alternative PISC timeframe
request. Permit applicants may refer to material
submitted using this Alternative PISC Timeframe
Demonstration module in their plans to meet the
requirements at 40 CFR 146.93(a)(2)(v).
Considerations for submitting both of these items
are provided below.
When finalizing the permit application submission
in the Project Information Tracking module, the box indicating submittal of a PISC and Site
Closure Plan and (if applicable) an alternative PISC timeframe demonstration should be checked.
PISC and Site Closure Plan
While the PISC and Site Closure Plan must include the components specified by 40 CFR
146.93(a), the Class VI Rule allows for substantial flexibility regarding the post-injection testing
and monitoring program. The PISC and Site Closure Plan template available for download in the
Project Plan Submissions module provides a general structure for the plan, but it should be
tailored to the needs of a particular project. In addition to the items specified in the Class VI
Rule, the EPA encourages permit applicants to include criteria for the non-endangerment
demonstration so that expectations for this demonstration are established from the beginning of
the project.
As with other Class VI project plans, the EPA recommends that the PISC and Site Closure Plan
be provided as a single PDF, with supplemental or supporting material not intended to be part of
the enforceable plan uploaded separately in the designated GSDT module field. Any schematics
or other images (e.g., for modeling results or monitoring well plugging) should be legible and
clear. The EPA also recommends that permit applicants either include a copy of the QASP from
the Testing and Monitoring Plan in the PISC and Site Closure Plan, or incorporate it into the
PISC and Site Closure Plan by reference.
PISC and Site Closure Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(17)-(18)
•	40 CFR 146.93
Relevant GSDT modules:
•	Project Information Tracking module
•	Project Plan Submissions module
•	Alternative PISC Timeframe
Demonstration module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	PISC and Site Closure Plan template
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
27

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Permit applicants should contact their permitting authority if they have questions about what to
include in the PISC and Site Closure Plan (e.g., how best to incorporate AoR modeling results or
how to refer to information submitted with the Alternative PISC Timeframe Demonstration
module) or if they wish to discuss the development of appropriate non-endangerment
demonstration criteria.
Alternative PISC Timeframe
As stated above, the GSDT includes a separate module for the detailed data that support an
alternative PISC timeframe demonstration. It can be used as a guide to ensure that all necessary
information is provided to inform the permitting authority's decision-making process. Several of
the requirements at 40 CFR 146.93(c) are related to other components of the permit application,
such as site characterization and AoR delineation modeling. The Alternative PISC Timeframe
Demonstration module allows users to submit a combination of new information and cross-
references to materials submitted using other GSDT modules. Provided that the references are
sufficiently specific and that the referenced material fulfills the specified requirement, no
duplicate information needs to be submitted as part of the alternative PISC timeframe
demonstration.
Some projects may not have sufficient data available in the pre-construction (or pre-operation)
phase to demonstrate that an alternative PISC timeframe will be protective of USDWs. However,
pursuant to 40 CFR 146.93(b)(2), an owner or operator may make a non-endangerment
demonstration before the end of the timeframe specified in the PISC and Site Closure Plan,
regardless of whether an alternative timeframe has been approved during permitting. The EPA
recommends that, where possible, permit applicants and permitting authorities discuss this
possibility at the outset of a project (for this reason, the EPA encourages owners or operators to
identify criteria for the non-endangerment demonstration at the time of the permit application).
Also, permit applicants should contact their permitting authority if they wish to discuss any
project-specific considerations related to the
alternative PISC timeframe, such as whether
additional site-specific factors will need to be
included in the demonstration per 40 CFR
146.93(c)(xi).
3.1.9 Emergency and Remedial Response
The Emergency and Remedial Response Plan is
required by 40 CFR 146.82(a)(19). Emergency and
remedial response planning pursuant to 40 CFR
146.94 helps ensure an expeditious and appropriate
response to protect USDWs from endangerment in
the event of an emergency during the lifetime of a
Class VI project.
The Class VI Rule, at 40 CFR 146.94(a), does not
specify the content of the Emergency and Remedial
Response Plan; instead, the permit applicant must
Emergency and Remedial Response
Submissions
Class VI Rule requirements:
•	40 CFR 146.82(a)(19)
•	40 CFR 146.94
Relevant GSDT modules:
•	Project Information Tracking module
•	Project Plan Submissions module
Reference documents:
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	Emergency and Remedial Response
Plan template
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
28

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provide appropriate site-specific information. The EPA anticipates that the Emergency and
Remedial Response Plan will be a narrative report that may be supported by data sets and maps
or other images (e.g., of potentially affected environmental resources or infrastructure such as
public water system drinking water supply wells). The UIC Program Class VI Well Project Plan
Development Guidance provides further recommendations for developing the plan.
The EPA recommends that permit applicants download the plan template from the Project Plan
Submissions module, populate it with project-specific information, and submit it through the
same module as a single PDF. As with the other Class VI project plans, applicants are
encouraged to tailor their submissions to the needs of their particular projects; this is particularly
important given the flexibility in the Class VI Rule requirements for emergency and remedial
response. Any supplemental or supporting material not intended to be part of the enforceable
plan can be uploaded separately in the designated GSDT module field.
Permit applicants should contact their permitting authority to discuss any questions related to the
content of the Emergency and Remedial Response Plan or how proposed emergency and
remedial response procedures may affect other aspects of the permit application.
3.2 Injection Depth Waivers
The Class VI Rule, at 40 CFR 146.95(a), requires owners or operators seeking a waiver of the
Class VI injection depth requirements to submit additional information for a comprehensive
assessment of site suitability to inject into a non-USDW above or between USDWs. Owners or
operators must submit a waiver application report
concurrent with the Class VI permit application
[40 CFR 146.82(d) and 146.95(a)].5 The waiver
application report is a separate submittal which
complements the Class VI permit application.
The EPA expects that the waiver application
report will contain some information that is
similar to (or references) information submitted in
the permit application. However, the submittal
must be tailored to demonstrate that all USDWs—
above and below the injection zone—will be
protected. There are also additional requirements
that apply only to owners or operators requesting
injection depth waivers. For more information, see
the UIC Program Class VI Well Injection Depth
Waivers Guidance.
The EPA recommends that injection depth waiver
applications contain the same information
5 Should a USDW be identified below the injection zone after a Class VI project is permitted or operational, the
requirements at 40 CFR 146.95 would apply and this section would remain applicable to such submittals.
Injection Depth Waiver Requirements
•	Suitability of the injection and confining
zones
40 CFR 146.95(a)(l)-(2)
•	Computational modeling information
40 CFR 146.95(a)(3)
•	Injection well construction information
40 CFR 146.95(a)(4)
•	Testing and monitoring information
40 CFR 146.95(a)(5)
•	Water resource information
40 CFR 146.95(a)(6)
•	Any other information requested by the
UIC Program Director to support the
EPA Regional Administrator's evaluation
40 CFR 146.95(a)(7)
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
29

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types/data formats as Class VI permit applications, including narrative descriptions, tabular data,
maps (in flat images and/or GIS files such as shapefiles), charts/graphs, construction schematics,
and other types of visual information. As with all Class VI submissions, the files should be
legible and clear (e.g., contour lines unambiguous, legends visible, acronyms defined, images
have an appropriate scale, etc.). Sources of secondary data should be clearly cited. Primary data
should include relevant reference information such as the date/time, location/depth, method
name, test conditions, assumptions, limitations, QA protocols, etc., associated with a sampling
event.
Injection depth wavier application reports are submitted using the Injection Depth Waiver and
Aquifer Exemption Expansion module of the GSDT. In recognition that some aspects of the
waiver application report may be the same as components of the permit application, the module
allows users to submit a combination of new information and cross-references to materials
submitted using other GSDT modules. Cross-
references should point specifically to the relevant
parts of the permit application (e.g., references to
particular pages or subsections, rather than to an
entire project plan) to facilitate the review. Also,
referenced material should be sufficient to meet the
applicable requirements for both the permit
application and the injection depth waiver application
report. When finalizing the permit application in the
Project Information Tracking module, the owner or
operator should check the box indicating application
for an injection depth waiver.
Pursuant to 40 CFR 146.95(b)-(d), the determination
to grant an injection depth waiver for a given Class
VI project is the responsibility of the EPA Regional
Administrator (even in states with primacy for
implementing the Class VI program). This
determination is based not only on information provided by the permit applicant but also on
consultation with the Public Water System Supervision (PWSS) Director(s) of the state(s) and/or
tribe(s) in the AoR. Therefore, submitting a complete injection depth waiver application report
via the GSDT is not a guarantee that a waiver will be granted.
The EPA recommends that owners or operators contact their permitting authorities before
submitting an injection depth waiver application report to discuss any site-specific factors that
may affect the development of the report. For example, the Class VI Rule, at 40 CFR
146.95(a)(7), gives the UIC Program Director the discretion to request any other information
needed to inform the EPA Regional Administrator's decision to issue a waiver. This may include
a subset of the information listed at 40 CFR 146.95(b). Discussing what additional information
may be necessary to submit at the beginning of the process will help support efficiency and
reduce the need for additional information requests after the report is submitted.
Injection Depth Waiver Submissions
Class VI Rule requirements:
•	40 CFR 146.82(d)
•	40 CFR 146.95
Relevant GSDT modules:
•	Project Information Tracking module
•	Injection Depth Waivers and Aquifer
Exemption Expansions module
Reference documents:
•	UIC Program Class VI Well Injection
Depth Waivers Guidance
Electronic resources:
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
30

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3.3 Aquifer Exemption Expansions
No new aquifer exemptions will be granted for Class VI wells [40 CFR 144.7(a)], However, if an
owner or operator of a Class II enhanced recovery well injecting into an exempted aquifer makes
the business decision to transition to Class VI, the owner or operator may request an expansion
of the areal extent of the previously approved
aquifer exemption [40 CFR 144.7(d)], provided
they demonstrate that the area to be exempted meets
all of the requirements at 40 CFR 146.4(d).
The Class VI Rule, at 40 CFR 144.7(d)(1), requires
aquifer exemption expansion requests to define (by
narrative description, illustrations, maps, or other
means) and describe, in clear and definite
geographic and/or geometric terms (such as
vertical/lateral limits and gradient), all aquifers or
parts thereof that fall under the request. The UIC
Program Guidance on Transitioning Class II Wells
to Class VI Wells contains additional information
about aquifer exemption expansions, including
recommendations for the content to be submitted.
Owners or operators may submit various types of information to support this demonstration, such
as tabular data, maps (in flat images and/or GIS files), charts/graphs, reports developed by public
water systems, etc. As with all Class VI submissions, files should be legible and clear (e.g.,
contour lines unambiguous, legends visible, acronyms defined, images have an appropriate
scale). Sources of secondary data should be clearly cited. Primary data should include relevant
reference information such as the date/time, location/depth, method name, test conditions,
assumptions, limitations, QA protocols, etc.,
associated with each sampling event, particularly for
total dissolved solids (TDS) measurements.
Aquifer exemption expansion requests are submitted
using the Injection Depth Waiver and Aquifer
Exemption Expansion module of the GSDT. The
Class VI Rule does not specify when a request must
be submitted, but the EPA recommends that it be
submitted at the same time as the Class VI permit
application to allow sufficient time for review.
Pursuant to 40 CFR 144.7(d), such requests must be
treated as a revision to the applicable federal UIC
Program under 40 CFR 147 or as a substantial
revision to a state/tribal program under 40 CFR
145.32, and will not be final until approved by the
EPA (even in states with primacy for implementing
the Class VI program). Therefore, submitting a
Aquifer Exemption Expansion
Requirements
The area to be exempted:
•	Does not currently serve as a source
of drinking water
40 CFR 146.4(d)(1)
•	Has a TDS content more than 3,000
mg/L and less than 10,000 mg/L
40 CFR 146.4(d)(2)
•	Is not reasonably expected to supply a
public water system
40 CFR 146.4(d)(3)
Aquifer Exemption Expansion
Submissions
Class VI Rule requirements:
•	40 CFR 144.7(d); 146.4(d)
Relevant GSDT modules:
•	Project Information Tracking module
•	Injection Depth Waivers and Aquifer
Exemption Expansions module
Reference documents:
•	UIC Program Guidance on
Transitioning Class II Wells to Class VI
Wells
Electronic resources:
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
31

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complete aquifer exemption expansion request via the GSDT is not a guarantee that the request
will be granted.
Like injection depth waiver submissions, some aspects of the request may be the same as
components of the permit application, and the Injection Depth Waivers and Aquifer Exemption
Expansions module allows users to submit a combination of new information and cross-
references to materials submitted using other GSDT modules. Cross-references should point
specifically to the relevant parts of the permit application (e.g., references to particular pages or
subsections, rather than to an entire project plan) and the referenced material should be sufficient
to meet all of the applicable requirements. When finalizing the permit application in the Project
Information Tracking module, the owner or operator should check the box indicating a request
for an aquifer exemption expansion.
The EPA encourages owners or operators to communicate with their permitting authorities prior
to submitting an aquifer exemption expansion request. In particular, demonstrating that the
aquifer is not reasonably expected to supply a public water system [40 CFR 146.4(d)(3)] requires
a tailored, site-specific response, and the EPA recommends discussing this requirement with the
permitting authority.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
32

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4 Pre-Operation Phase Reporting and Recordkeeping
Before receiving approval for the operation of a Class VI well, owners or operators must conduct
certain pre-operational activities (as specified by 40 CFR 146.87) and submit the results to the
EPA. The Class VI Rule, at 40 CFR 146.82(c), also requires the UIC Program Director to
consider certain types of information before authorizing injection, and the EPA expects that
owners or operators will submit all of the information necessary to support the Director's review
when that information has not otherwise been made available to the Director.
Much of this pre-operation phase information serves to update or supplement the components of
the permit application submitted pursuant to 40 CFR 146.82(a), though some is new and specific
to the current phase. Overall, the purpose of the information specified by 40 CFR 146.82(c) is to
demonstrate that the injection project will not endanger USDWs. The new data considered by the
UIC Program Director address uncertainties identified in the permit application process and
ensure that all of the planned project activities appropriately reflect the necessary site-specific
considerations.
Like the components of a Class VI permit application, the pre-operation information includes
data related to site characterization, AoR delineation, corrective action, injection well
construction, operating information, and other topic areas. While the Class VI Rule does not
specify any pre-operation phase submittals related to injection depth waivers or aquifer
exemption expansions, owners or operators may also need to submit information related to these
items if requested by the UIC Program Director. See Sections 3.2 and 3.3 for recommendations
related to submitting injection depth waiver and aquifer exemption expansion materials.
The information relevant to the pre-operation phase is summarized in Table 4-1, and it is
described in more detail in the subsections below. Submitting complete, accurate, and consistent
information that clearly demonstrates compliance with the Class VI Rule requirements will
support timely authorization to inject, provide information to inform the public and address any
concerns about the project, support continuity in decision-making for the project, and facilitate
the development of an administrative record documenting permitting authority decisions. As
with information collected for a Class VI permit application, 40 CFR 146.91(f)(1) requires that
information collected to support 40 CFR 146.82(c) be retained throughout the life of the Class VI
project and for 10 years following site closure.
Table 4-1. Summary of submittals to be made during the pre-operation phase, to support the
determination to authorize injection.
Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Information for the UIC
Program Director to
consider before granting
authorization to inject [40
CFR 146.82(c) and
146.85]
Project Information
Tracking module (which
contains a checklist of
other modules to use for
more detailed
submissions; see
subsections below)
Basic project information
- directly entered into the
module
Information for the UIC
Program Director to
consider before granting
authorization to inject [40
CFR 146.82(c) and
146.85]
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Information for the UIC
Program Director to
consider before granting
authorization to inject [40
CFR 146.82(c)] continued
Project Information
Tracking module (which
contains a checklist of
other modules to use for
more detailed
submissions; see
subsections below)
Detailed data
submissions - other GSDT
modules (see below)
Additional information
requested by the UIC
Program Director -
uploaded file(s)
Information for the UIC
Program Director to
consider before granting
authorization to inject [40
CFR 146.82(c) and
146.85]
The information specified by 40 CFR 146.82(c), which is summarized in the box below, is
similar to that required under 40 CFR 146.82(a) with respect to the topic areas covered and the
type/format of the information. The reporting process is also similar; like the permit application,
the EPA recommends that owners or operators submit both:
1.	A narrative summarizing the changes to site characterization, strategies for site operation,
etc., as a result of pre-operational testing results (compiled into a single file and
submitted using the Project Information Tracking module of the GSDT).
2.	Specific, detailed information required by certain Class VI Rule provisions (submitted
using other GSDT modules, which are tailored to the applicable rule requirements).
As with the 40 CFR 146.82(a) narrative, owners or operators should use the Project Information
Tracking module to download a 40 CFR 146.82(c) narrative template, then upload the completed
file to the module along with any supplemental materials. For ease of submission and to facilitate
the permitting authority's evaluation, the EPA
recommends that the 40 CFR 146.82(c) narrative
be provided as a single PDF file. Supplemental
materials that accompany the narrative but are not
compatible with this format (such as tabular data,
high-resolution images, or GIS shapefiles) may be
provided separately, using the module field
designated for "any other information requested
by the UIC Program Director."
When owners or operators submit detailed
information using the other GSDT modules, they
will generally be updating previous submissions
made during the pre-construction phase, either by
entering new information directly into the module
or by uploading updated files. This process is
intended to streamline the reporting process as
well as facilitate the permitting authority's review.
One exception is the Pre-Operational Testing
module, which is used to submit the results of the
logging and testing activities required by 40 CFR
Pre-Operation Phase Requirements
•	Site characterization updates
40 CFR 146.82(c)(2), (3)
•	Amended AoR and Corrective Action
Plan, including final AoR delineation and
corrective action status
40 CFR 146.82(c)(1), (6), (9)
•	Injection well construction updates
40 CFR 146.82(c)(3), (5)
•	Pre-operational testing results
40 CFR 146.82(c)(4), (7), (8)
•	Amendments to other project plans
40 CFR 146.82(c)(9)
•	Any other information requested
by the UIC Program Director
40 CFR 146.82(c)(10)
•	Financial responsibility updates
40 CFR 146.85
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
34

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146.87; before the pre-operation phase of the project, owners or operators will have only used
this module to submit their proposed pre-operational testing program files.
While the GSDT modules used during the pre-operation phase can be populated and submitted in
any order, the EPA recommends the following process. First, owners or operators should review
the general project information sections of the Project Information Tracking module (including
the project name, contact information, etc.) to confirm that the information is accurate and up to
date. Second, owners or operators should populate and submit the modules used to provide
detailed information (e.g., the Pre-Operational Testing module). Third, they should finish
populating the 40 CFR 146.82(c) section of the Project Information Tracking module (by
uploading the completed narrative template and filling out the checklist) and submit it. The EPA
recommends that, throughout this process, owners or operators delete or replace any obsolete
information/files in the GSDT modules to ensure that the GSDT contains the most up-to-date
information for the project. Note that deleting a file does not alter or hinder the reporting and
recordkeeping requirements described in Section 2.5. The GSDT maintains a full record of all
previously submitted materials; if an owner or operator deletes/removes a file, this simply means
that the file will not be included in an owner or operator's next submission.
Also, similar to the permit application review process, the permitting authority's evaluation of
the pre-operation information will likely be an iterative one. Permitting authorities may need to
ask clarifying questions, request additional information, or discuss the content of a submittal
with owners or operators. As described in Section 2.4, the GSDT's Information Request module
will facilitate written communication between owners or operators and permitting authorities
during this process (and throughout the life of a Class VI project). In addition to the specific
information listed at 40 CFR 146.82(c)(l)-(9), the UIC Program Director may request any
additional information necessary to inform his or her decision to authorize injection [40 CFR
146.82(c)(10)]. The EPA recommends that owners or operators contact their permitting authority
with any questions about additional required information or the evaluation process.
Depending on a project's permit conditions and the timeframe of the permitting authority's
evaluation, an owner or operator may also need to begin certain periodic reporting activities,
such as providing financial responsibility updates using the Financial Responsibility
Demonstration module (see Section 4.6). The EPA recommends that owners or operators discuss
the need for such submittals with their permitting authority.
4.1 Site Characterization
The Class VI Rule, at 40 CFR 146.82(c)(2), describes updates that must be made to the project's
site characterization information during the pre-operation phase. To support the UIC Program
Director's evaluation, the EPA anticipates that the owner or operator will update the site
characterization information from the permit application based on the results of the pre-
operational testing required at 40 CFR 146.87 (see Section 4.4). As with the original site
characterization information, these updates serve to demonstrate that the project meets the
minimum criteria for site suitability specified at 40 CFR 146.83. They inform the final AoR
delineation, as well as updated plans for site operation, testing and monitoring, and other aspects
of the project.
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Data Management Guidance for Owners and Operators
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The data used to develop the site characterization
updates will be generated during the logging and
testing activities conducted pursuant to 40 CFR
146.87. Recommendations for gathering the data are
provided in the UIC Program Class VI Well Site
Characterization Guidance. In some cases, such as
those in which additional relevant scientific
publications or state well records become available
during the pre-operation phase, the updates could
also be supported by secondary data.
The site characterization updates can be incorporated
into the 40 CFR 146.82(c) narrative, using the
template available in the GSDT's Project Information
Tracking module. In this narrative, the EPA
recommends that owners or operators integrate the
formation testing results into the existing site
description, highlighting any changes in the understanding of the site since submittal of the
permit application. Ideally, the updates will address any key uncertainties identified in the permit
application and provide additional evidence to demonstrate that the site meets the suitability
criteria at 40 CFR 146.83. The narrative should also include new or updated information on the
compatibility of the carbon dioxide stream with the properties of the injection and confining
zones, based on the results of formation testing at 40 CFR 146.87(c)-(d) [40 CFR 146.82(c)(3)],
as well as any other relevant information that can support an evaluation of the site's geology.
When complete, the compiled 40 CFR 146.82(c) narrative should be submitted using the Project
Information Tracking module. As stated above, the EPA recommends that the 40 CFR 146.82(c)
narrative be provided as a single PDF file, with supplemental materials provided separately using
the module field designated for "any other information requested by the UIC Program Director."
These may include updated maps, figures, or other summary items providing a synthesis of the
logging and testing results. While the site characterization component of the 146.82(c) narrative
relies on the results of pre-operational testing, the actual logging and testing results (e.g., log
analyst reports) should be submitted separately, using the Pre-Operational Testing module (see
Section 4.4). The EPA recommends that owners or operators cross-reference their pre-
operational testing submittals in the 40 CFR 146.82(c) narrative file.
In addition to submitting the 146.82(c) narrative with the Project Information Tracking module,
owners or operators may also need to update certain site-related information in the AoR and
Corrective Action module, as part of the AoR and corrective action submission (see Section 4.2).
As with the site characterization components of the permit application, the pre-operation phase
site characterization information forms the foundation on which other UIC Program Director
decisions are based, pursuant to 40 CFR 146.82(c). Therefore, the EPA recommends that owners
or operators review the site characterization materials for consistency with related items, such as
the final AoR delineation, the Testing and Monitoring Plan, and (if applicable) the alternative
PISC timeframe demonstration. Owners or operators should contact their permitting authority if
Site Characterization Submissions
Class VI Rule requirements:
•	40 CFR 146.82(c)(2), (3)
•	40 CFR 146.83
Relevant GSDT modules:
•	Project Information Tracking module
•	AoR and Corrective Action module
Reference documents:
•	UIC Program Class VI Well Site
Characterization Guidance
Electronic resources:
•	40 CFR 146.82(c) narrative template
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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questions arise about site-specific considerations or about the level of detail necessary to fulfill
the Class VI Rule requirements.
4.2 AoR and Corrective Action
The Class VI Rule, at 40 CFR 146.82(c)(1), (6), and (9), requires updates to the AoR and
corrective action materials submitted with the permit application, including the delineation of the
final AoR (based on data obtained during logging and testing of the well and the formation), an
update on the corrective action status of wells in the AoR, and an amended AoR and Corrective
Action Plan that reflects the pre-operation phase activities. To support the permitting authority's
evaluation, the EPA recommends that owners or operators submit the following, using the AoR
and Corrective Action module:
•	An amended AoR and Corrective Action Plan. This plan should present the final AoR
delineation, describe how the delineation is supported by the newly collected data, and
contain any necessary updates to the procedures for corrective action (including phased
corrective action, if proposed) and AoR reevaluation.
•	Updates to the detailed modeling data or any other information supporting the final AoR
delineation.
•	Documentation of any corrective action that has been completed.
Specific recommendations for submitting each of
these items are provided in the subsections below.
The content and format of the submissions will likely
be similar to those provided as part of the permit
application: detailed modeling information such as
input and output data, narrative descriptions, tabular
well data, etc. (see Section 3.1.2). Recommendations
for preparing these materials are provided in the UIC
Program Class VI Well Area of Review Evaluation
and Corrective Action Guidance and the UIC
Program Class VI Well Project Plan Development
Guidance.
The EPA recommends that owners or operators hold
a discussion with their permitting authority prior to
submitting any new modeling information, to address
any questions related to data files/formats or the
overall approach for submitting modeling data. Once
these questions have been addressed, owners or
operators should upload the amended AoR and
Corrective Action Plan to the AoR and Corrective
Action module and enter any updates to the detailed
computational modeling/corrective action information. Following successful submission of
information in this module, owners or operators can check the relevant boxes in the Project
AoR and Corrective Action
Submissions
Class VI Rule requirements:
•	40 CFR 146.82(c)(1), (6), (9)
•	40 CFR 146.84
Relevant GSDT modules:
•	Project Information Tracking module
•	AoR and Corrective Action module
Reference documents:
•	UIC Program Class VI Well Area of
Review Evaluation and Corrective
Action Guidance
•	UIC Program Class VI Well Project Plan
Development Guidance
Electronic resources:
•	AoR and Corrective Action Plan
template
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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Information Tracking module to confirm that they have completed this component of pre-
operation phase reporting.
AoR and Corrective Action Plan
To fulfill the requirements at 40 CFR 146.82(c)(1), (6), and (9), the EPA recommends that
owners or operators review the material in the approved AoR and Corrective Action Plan (i.e., as
it was incorporated into the Class VI permit) and amend it to:
•	Reflect the final AoR and the procedures used to delineate it.
•	Provide a status update on corrective action activities, including both completed and
remaining (planned) activities, in light of the final AoR delineation.
•	Include any necessary changes to the procedures for AoR reevaluation.
The AoR and Corrective Action Plan will serve as a benchmark for future activities. The
requirement to maintain and implement the approved plan is directly enforceable, pursuant to 40
CFR 146.84(b). Accordingly, the plan submitted during the pre-operation phase should reflect
the most up-to-date site characterization information and computational modeling procedures, to
most efficiently support these future activities.
At this stage of a Class VI project, the AoR and Corrective Action module should contain the last
version of the plan submitted before the Class VI permit was issued. The EPA recommends that
owners or operators delete this file and replace it with the up-to-date file.6 As with the initial plan
submittal, supplemental materials that are not part of the plan itself should be uploaded
elsewhere in the module and not incorporated into the plan file. In addition to the examples of
supplemental materials listed in Section 3.1.2, the EPA encourages owners or operators to submit
an explanation of the changes that have been made to the plan, especially if substantial changes
have been necessary.
In certain cases (e.g., for some well-characterized project sites with substantial existing data
available in the pre-construction phase), only minimal updates to the computational model may
be needed, and the final AoR delineation might be the same as the one included in the Class VI
permit. If this is the case, the EPA recommends that owners or operators amend the AoR and
Corrective Action Plan to include a technical description of how the newly obtained data support
the final delineation.
Detailed Computational Modeling Data
The computational modeling data supporting the final AoR delineation should be submitted
using the AoR and Corrective Action module, using the same procedures as the submittals made
during the pre-construction phase (see Section 3.1.2). The EPA recommends that owners or
operators review each component of the existing submission (as it appears in the module) and
6 If the permitting authority made any changes to the plan before incorporating it into the permit, the file in the
reporting module may not be exactly the same as the approved plan. When revising the plan file, EPA recommends
that owners or operators ensure that they are using the final, approved plan as a starting point.
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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edit or replace information as necessary. Regardless of the extent to which the AoR delineation
may change, the EPA recommends that owners or operators ensure that all fields in the module
reflect the most up-to-date information so that the permitting authority can confirm that the
modeling effort appropriately incorporates the results of the pre-operation phase activities.
Documentation supporting the corrective action status update described above can also be
submitted in the AoR and Corrective Action module. This documentation may include tables of
well information and/or plugging reports from any wells that have received corrective action.
4.3 Injection Well Construction
To support the review of final construction procedures required by 40 CFR 146.82(c)(5), the
EPA recommends that owners or operators submit final as-built drawings/schematics of the
injection well and a description of any deviations from the construction procedures included in
the Class VI permit. The UIC Program Class VI Well Construction Guidance contains
information on designing and constructing an injection well that meets the Class VI Rule
requirements, including considerations related to the pre-operation phase.
EPA recommends that the final construction information be incorporated into the 40 CFR
146.82(c) narrative. This component of the narrative can also be used to provide information on
the compatibility of the carbon dioxide stream with the materials used to construct the well [40
CFR 146.82(c)(3)], As noted above, the EPA
recommends that the 40 CFR 146.82(c) narrative be
provided as a single PDF file. Supplemental
materials that are not compatible with this format
(such as high-resolution images) may be provided
separately using the module field designated for "any
other information requested by the UIC Program
Director." Regardless of whether as-built drawings
and other images are incorporated into the narrative
or provided separately, they should be legible, clear,
and include all relevant legends, scales, labels, etc.
Injection Well Construction
Submissions
Class VI Rule requirements:
•	40 CFR 146.82(c)(3), (5)
•	40 CFR 146.86
Relevant GSDT modules:
•	Project Information Tracking module
Reference documents:
•	UIC Program Class VI Well
Construction Guidance
Electronic resources:
•	40 CFR 146.82(c) narrative template
•	GSDT user guides
The EPA recommends that owners or operators hold
a discussion with their permitting authority if the
actual well construction procedures varied
significantly from the approved procedures
incorporated in the Class VI permit. (Ideally, owners
or operators will notify the permitting authority as
soon as possible after identifying the need for such a change—e.g., if relevant information about
subsurface formations arises during drilling—to ensure that the well, as built, meets the Class VI
requirements.) The EPA also recommends that owners or operators and permitting authorities
discuss the ramifications of any changes on other aspects of the project, including operations,
well plugging, and associated financial responsibility costs.
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Data Management Guidance for Owners and Operators
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4.4 Pre-Operational Testing
The Class VI Rule requires owners or operators to conduct certain activities to verify proper
construction of the well and obtain data on the chemical and physical characteristics of the
injection and confining zones [40 CFR 146.87], These activities should be performed pursuant to
the approved pre-operational testing program in the Class VI permit (see Section 3.1.5) and the
results submitted during the pre-operation phase to inform the UIC Program Director's
evaluation pursuant to 40 CFR 146.82(c)(4), (7), and (8).
Before conducting the logs and tests required by 40 CFR 146.87, owners or operators must
notify their permitting authority and provide them with an opportunity to witness the logging and
testing. An owner or operator must provide a testing schedule to the permitting authority at least
30 days before the first test takes place, and any changes to the schedule must be submitted at
least 30 days before the next scheduled test [40 CFR
146.87(f)]. These notifications can be submitted
using the Pre-Operational Testing module.
The EPA anticipates that the pre-operational testing
results will include a combination of narrative
information (including third-party materials, such as
log analyst reports), graphs/figures, and tabular data.
Log results may be submitted in Log ASCII Standard
(LAS) format, if desired. Both the UIC Program
Class VI Well Site Characterization Guidance and
the UIC Program Class VI Well Construction
Guidance provide recommendations for conducting
the required logs and tests. In addition, the UIC
Program Class VI Well Testing and Monitoring
Guidance includes recommendations related to
MITs.
The Pre-Operational Testing module was designed to
facilitate submission of the logging and testing
results. Unlike most other GSDT modules used
during the pre-construction and pre-operation phases, owners or operators will not yet have used
the applicable components of the Pre-Operational Testing module. Therefore, the EPA
recommends that owners or operators contact their permitting authority before populating the
module to discuss any questions about how to use the module or about the specific types of
information to submit. Following successful submission of the module, owners or operators can
check the corresponding box in the Project Information Tracking module to confirm that they
have completed this component of pre-operation phase reporting.
During this phase of a Class VI project, the pre-operational testing results are likely to be the
primary source of site-specific information informing the final AoR delineation, Testing and
Monitoring Plan, and other project components. Therefore, the EPA recommends that
interpretive materials submitted with the pre-operational testing results include a discussion of
data limitations and remaining uncertainties at the site. The EPA also recommends that owners
Pre-Operational Testing Submissions
Class VI Rule requirements:
•	40 CFR 146.82(c)(4), (7), (8)
•	40 CFR 146.87
Relevant GSDT modules:
•	Project Information Tracking module
•	Pre-Operational Testing module
Reference documents:
•	UIC Program Class VI Well Site
Characterization Guidance
•	UIC Program Class VI Well
Construction Guidance
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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or operators provide information to document compliance with quality assurance/quality control
(QA/QC) procedures for the logs and tests, such as equipment calibration information and
QA/QC sample data (e.g., blanks, duplicates, or matrix spikes used during laboratory analyses).
The Pre-Operational Testing module provides a great deal of flexibility to owners or operators,
reflecting the flexibility of the associated Class VI Rule requirements. The EPA encourages
owners or operators to contact their permitting authority to discuss the best approach for
submitting a particular project's pre-operational testing results.
4.5 Other Project Plans
The Class VI Rule, at 40 CFR 146.82(c)(9), requires the UIC Program Director to consider any
amendments to the proposed Testing and Monitoring Plan, Injection Well Plugging Plan, PISC
and Site Closure Plan, and Emergency and Remedial Response Plan that are necessary to address
new information collected during logging and testing of the well and the formation. (See Section
4.2 for a discussion of the AoR and Corrective Action Plan.) This requirement also includes
consideration of any necessary updates to the alternative PISC timeframe demonstration, if one
has been proposed. The EPA expects that owners or
operators will submit amended project plan files to
support this evaluation.
The EPA anticipates that the amended project plans
will have a similar content and format as the original
approved plans (e.g., PDF files developed using the
templates provided in the Project Plan Submissions
module). See the UIC Program Class VI Well
Project Plan Development Guidance for more
information on the project plans, and refer to the UIC
Program Class VI Well Testing and Monitoring
Guidance and the UIC Program Class VI Well
Plugging, Post-Injection Site Care, and Site Closure
Guidance for recommendations on the information to
be included in these submittals.
At this stage of a Class VI project, the Project Plan
Submissions module should contain the last versions
of the project plans that were submitted before the
Class VI permit was issued. The EPA recommends
that owners or operators delete these files and replace
them with the most up-to-date files.7 Supplemental
materials that are not part of the plans can be
uploaded in the designated fields in the Project Plan
Submissions module. In addition to the examples of
7 If the permitting authority made any changes to the plan before incorporating it into the permit, the file in the
Project Plan Submissions module may not be exactly the same as the approved plan. When updating the plan, EPA
recommends that owners or operators ensure that they are using the final, approved plan as a starting point.
Other Project Plan Submissions
Class VI Rule requirements:
•	40 CFR 146.82(c)(9)
•	40 CFR 146.90
•	40 CFR 146.92(b)
•	40 CFR 146.93(a), (c)
•	40 CFR 146.94(a)
Relevant GSDT modules:
•	Project Information Tracking module
•	Project Plan Submissions module
•	Alternative PISC Timeframe
Demonstration module
Reference documents:
•	UIC Program Class VI Well Project Plan
Development Guidance
•	UIC Program Class VI Well Testing and
Monitoring Guidance
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
Electronic resources:
•	Project plan templates
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
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supplemental materials provided for the original proposed plans (see Sections 3.1.6, 3.1.7, 3.1.8
and 3.1.9), the EPA recommends that owners or operators consider submitting an explanation of
the changes that have been made to each plan, particularly if substantial changes were necessary.
Any revisions to the alternative PISC timeframe demonstration materials can be made directly in
the Alternative PISC Timeframe Demonstration module. The EPA recommends that owners or
operators delete any obsolete information from that module and replace it with information that
reflects the most up-to-date understanding of the site. Because this demonstration relies heavily
on computational modeling results, owners or operators are encouraged to reference the detailed
modeling submission as appropriate in their submission.
Following successful submission in the Project Plan Submissions module and (if applicable) the
Alternative PISC Timeframe Demonstration module, owners or operators can check the relevant
boxes in the Project Information Tracking module to confirm that they have completed the
corresponding components of pre-operation phase reporting.
In certain cases, it may not be necessary to amend one or more of the project plans. For example,
if sufficient project-specific data were available during the pre-construction phase and the AoR
delineation has not changed substantially, the existing strategy outlined in the Emergency and
Remedial Response Plan may still be appropriate. If owners or operators believe this may be the
case for their project, the EPA recommends that they discuss this possibility with the permitting
authority before making the relevant pre-operation phase submittals. In lieu of an amended plan,
the UIC Program Director may request a technical justification of why no amendment is needed.
This justification can be submitted using the supplemental materials field of the Project Plan
Submissions module.
4.6 Financial Responsibility
If amendments to the AoR and Corrective Action Plan, Injection Well Plugging Plan, PISC and
Site Closure Plan, or Emergency and Remedial Response Plan lead to increased costs for the
covered activities, the owner or operator must update
the cost estimate supporting the financial
responsibility demonstration within 60 days [40 CFR
146.85(c)(3)], Also, owners or operators must update
their cost estimates annually [40 CFR 146.85(c)(2)],
Given the likelihood that one or more project plans
will change and the time needed to construct the well
and perform all required pre-operational testing, it is
likely that an updated cost estimate will be needed
during the pre-operation phase.
Updated cost estimates should be submitted using the
Financial Responsibility Demonstration module, with
the same procedures used to submit the initial cost
estimate materials during the pre-construction phase
(see Section 3.1.3). The EPA recommends that
owners or operators delete any obsolete information
Financial Responsibility Submissions
Class VI Rule requirements:
•	40 CFR 146.85(c)(2), (4), and (e)
•	40 CFR 146.85(a)(5)(ii), (c)(4), and
(d)(3)
Relevant GSDT modules:
•	Project Information Tracking module
•	Financial Responsibility
Demonstration module
Reference documents:
•	UIC Program Class VI Financial
Responsibility Guidance
Electronic resources:
•	GSDT user guides
UIC Program Class VI Well Recordkeeping, Reporting, and
Data Management Guidance for Owners and Operators
42

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from the module and replace it with an up-to-date version. If final copies of financial instruments
were not provided during the pre-construction phase, they should be provided whenever they
become available. See Section 3.1.3 for more information about submitting materials related to
financial instruments. Once the updated financial responsibility information is submitted, the
owner or operator can check the corresponding box in the Project Information Tracking module.
Owners or operators are encouraged to contact their permitting authority to discuss the need for
(or the timing of) cost estimate updates or any other questions related to submitting financial
responsibility information.
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Data Management Guidance for Owners and Operators
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5 Injection Phase Reporting and Recordkeeping
During the injection phase, owners or operators must submit information at certain intervals as
specified by the project's permit and the Class VI Rule. The goal of injection phase information
collection and reporting is to demonstrate that the project is in compliance with the Class VI
permit, to identify any endangerment of USDWs, and to generate a body of data to support
project milestones (such as AoR reevaluations and the demonstration of non-endangerment made
at the end of the project). Specifically, owners or operators must submit periodic reports of
testing and monitoring results; notifications and results of well tests; and documentation related
to AoR reevaluations, financial responsibility updates, and project plan amendments, as well as
notifications and other information associated with emergency and remedial response activities
or adverse financial conditions. Table 5-1 summarizes these requirements and the associated
Class VI Rule citations, and further details are provided in the subsections below.
The Class VI Rule also specifies certain recordkeeping requirements for injection phase
information. Pursuant to 40 CFR 146.91(f)(2), data on the nature and composition of injected
fluids must be retained for 10 years after site closure, and the UIC Program Director may require
the owner or operator to deliver these records to him or her at the end of this retention period. In
addition, 40 CFR 146.91(f)(3) requires monitoring data collected pursuant to 40 CFR 146.90(b)-
(i) to be retained for 10 years after it is collected, and 40 CFR 146.84(g) requires that modeling
data and inputs used to support AoR reevaluations be retained for 10 years as well.
Table 5-1. Summary of submittals to be made during the injection phase.
Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Semi-annual reports of
testing and monitoring
results [40 CFR 146.91(a)]
Injection and Post-
Injection Phase Reporting
module
A single uploaded PDF
containing the narrative
component of each semi-
annual report, with
supporting data and
other supplemental
materials uploaded
separately as necessary
Semi-annually, on the
schedule set in the plan
or permit
Notifications of well tests
and stimulation activities
[40 CFR 146.91(d)]
Injection and Post-
Injection Phase Reporting
module
An uploaded PDF letter
At least 30 days before
the event
Results of MITs,
workovers, and other
tests of the injection well,
if required by UIC
Program Director [40 CFR
146.91(b)]
Injection and Post-
Injection Phase Reporting
module
An uploaded PDF, with
supporting data and
other supplemental
materials uploaded
separately as necessary
Within 30 days of the
event
With the next semi-
annual report, for certain
types of activities per 40
CFR 146.91(a)(7)
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Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Submissions associated
with an AoR reevaluation,
including AoR and
Corrective Action Plan
amendments, or
justification that no
amendment is needed
[40 CFR 146.84(e)]
AoR and Corrective
Action module
A combination of
uploaded PDF files
(including a single
uploaded PDF containing
the narrative component
of the plan) and data files
in other formats, as well
as information entered
directly into the module
According to the schedule
(or triggering criteria) set
in the permit or the
approved AoR and
Corrective Action Plan
Testing and Monitoring
Plan amendments, or
justification that no
amendment is needed
[40 CFR 146.90Q)]
Project Plan Submissions
module
A single uploaded PDF,
with supporting data and
other supplemental
materials uploaded
separately as necessary
Within 1 year of an AoR
reevaluation, following
significant changes to the
facility, or when required
by the UIC Program
Director (as specified in
the permit or the
approved Testing and
Monitoring Plan)
Emergency and Remedial
Response Plan
amendments, or
justification that no
amendment is needed
[40 CFR 146.94(d)]
Project Plan Submissions
module
A single uploaded PDF,
with supporting data and
other supplemental
materials uploaded
separately as necessary
Within 1 year of an AoR
reevaluation, following
significant changes to the
facility, or when required
by the UIC Program
Director (as specified in
the permit or the
approved Emergency and
Remedial Response Plan)
Financial responsibility
cost estimate updates
[40 CFR 146.85(c)(2),
(c)(4), and (e)]
Financial Responsibility
Demonstration module
A combination of
uploaded PDF files and
information entered
directly into the module
Annually, 60 days before
instrument anniversary
Within 60 days of project
plan amendment or
notification by UIC
Program Director
Financial responsibility
instrument updates
[40 CFR 146.85(a)(5)(ii),
(c)(4), and (d)(3)]
Financial Responsibility
Demonstration module
A combination of
uploaded PDF files and
information entered
directly into the module
Annually
Within 60 days of cost
estimate increase to
greater than value of
current instrument
Within 60 days of
notification of third-party
adverse financial
conditions
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Data Management Guidance for Owners and Operators
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Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Emergency notifications
[40 CFR 146.88(f)(3),
146.91(c), 146.94(b)(3)]
Injection and Post-
Injection Phase Reporting
module
An uploaded PDF letter,
with other supplemental
materials uploaded
separately as necessary
Within 24 hours
Included in the semi-
annual report, for certain
types of events per 40
CFR 146.91(a)(3)-(4)
Follow-up submissions
after an emergency
shutdown or loss of
mechanical integrity
[40 CFR 146.88(f)(4)-(5),
146.94(c)]
Injection and Post-
Injection Phase Reporting
module
One or more uploaded
file(s)
Before resuming injection
or as required by the UIC
Program Director
Notifications of adverse
financial conditions
[40 CFR 146.85(d)]
Financial Responsibility
Demonstration module
An uploaded PDF letter
(submission by certified
mail also required)
Within 10 days of the
start of bankruptcy
proceedings
5.1 Semi-Annual Reports of Testing and Monitoring Results
The Class VI Rule, at 40 CFR 146.91(a), requires owners or operators to submit semi-annual
reports of testing and monitoring results. These reports must contain the results of monitoring
conducted pursuant to 40 CFR 146.90, as specified
in the approved Testing and Monitoring Plan, as
well as certain summary statistics of operational
parameters and descriptions of permit exceedances
and emergency shut-offs. Recommendations for
submitting each of these components are provided
in the subsections below.
The Injection and Post-Injection Phase Monitoring
module of the GSDT facilitates submission of the
semi-annual reports and any supplemental
information supporting those reports. The module
provides a semi-annual report template that can be
downloaded, populated, and uploaded back to the
module. The EPA recommends that owners or
operators use the template, which includes specific
instructions and examples for each required
component.
For ease of submission and to facilitate the
permitting authority's evaluation, the EPA
recommends that each semi-annual report be
provided as a single PDF file. This file should
include a summary of the activities conducted and
Semi-Annual Report Requirements
•	Changes to the characteristics of the
carbon dioxide stream compared to the
proposed operating data
40 CFR 146.91(a)(1)
•	Operational monitoring results,
including monthly and cumulative
summary statistics
40 CFR 146.91(a)(2), (5)-(6)
•	Description of permit exceedances or
events that triggered shut-off devices
40 CFR 146.91(a)(3)-(4)
•	Results of monitoring prescribed under
40 CFR 146.90, including corrosion
monitoring, ground water monitoring,
external MITs, pressure fall-off tests,
plume and pressure front monitoring,
surface air and/or soil gas monitoring (if
required), and any other activities
included in the approved Testing and
Monitoring Plan
40 CFR 146.91(a)(7)
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an interpretation (supported by graphics/charts) that synthesizes the results of these activities and
their relevance to the permit conditions and Class VI Rule requirements. Supplemental materials
or appendices that accompany the report but are not compatible with this format (such as tabular
data, high-resolution images, and GIS files) may be provided separately in the designated
module field.
Because injection phase testing and monitoring activities are conducted according to the project-
specific Testing and Monitoring Plan, the specific content of the semi-annual report will vary
among projects, and, potentially, among different reporting periods for a single project.
However, in general, EPA recommends that owners or operators submit the following types of
information for each testing and monitoring activity, if applicable:
•	The purpose, date, time, and location of sampling event, test, or survey.
•	A list or brief description of methods used.
•	Interpretation of results with respect to permit conditions/regulatory requirements and
past results.
•	Any identified data gaps.
•	The QA/QC procedures employed.
•	The names of any contractors or laboratories involved in sampling and analysis (and their
certifications, if applicable).
•	Any identified amendments to the Testing and Monitoring Plan that may be necessary to
continue protection of USDWs.
Additional recommendations for reporting the results of specific types of monitoring are
provided in the subsections below. Again, these general recommendations may not apply to all
projects or to all components of an individual project's semi-annual report. The EPA
recommends that owners or operators contact their permitting authority before submitting their
first semi-annual report, to discuss any questions about how to submit particular types of
information. Background information on conducting all required testing and monitoring for Class
VI projects can be found in the UIC Program Class VI Well Testing and Monitoring Guidance.
5.1.1 Carbon Dioxide Stream Monitoring Results
The Class VI Rule, at 40 CFR 146.91(a)(1), requires the semi-annual report to include any
changes to the physical, chemical, and other relevant characteristics of the carbon dioxide stream
compared to the proposed operating data. Carbon dioxide stream monitoring is also a required
component of the Testing and Monitoring Plan, pursuant to 40 CFR 146.90. As a result, the
requirement at 40 CFR 146.91(a)(7) to include the results of 40 CFR 146.90 monitoring
activities in the semi-annual report applies to this information. This means that the overall results
of carbon dioxide stream monitoring must also be included in the semi-annual report, not just
changes compared to what was proposed.
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Changes in the carbon dioxide stream may lead to
changes in the potential for interactions with the
injection formation, subsurface fluids, and/or
injection well construction materials. Additionally,
monitoring the chemical and physical characteristics
of the carbon dioxide stream may help distinguish
the injectate from the native fluids in case of fluid
migration out of the injection zone. An individual
project's Class VI permit may also specify certain
carbon dioxide stream characteristics (e.g., water
content, concentrations of certain impurities) that
must be maintained to remain in compliance with
the permit.
Data on the carbon dioxide stream's characteristics
will be generated during periodic injectate
monitoring, which is required to be included in the
Testing and Monitoring Plan by 40 CFR 146.90. The monitoring frequency, parameters,
procedures, etc., will be specified in the approved plan. Owners or operators can consult Section
3.1 of the UIC Program Class VI Well Testing and Monitoring Guidance for further information
on conducting carbon dioxide stream monitoring.
Carbon dioxide stream monitoring results can be incorporated into the semi-annual report
template available in the GSDT. The EPA recommends that owners or operators include a list of
chemicals analyzed (including carbon dioxide and any other constituents specified in the
approved Testing and Monitoring Plan), a description of the sampling methodology, a tabulation
of the analytical results, including results from any QA/QC samples, and a synthesis of the
results interpreting any changes in the characteristics of the injected carbon dioxide stream. The
EPA also recommends that owners or operators submit the results of previous analyses to
facilitate evaluation of temporal trends. In general, owners or operators should provide any
information necessary to demonstrate compliance with the Class VI permit and the approved
Testing and Monitoring Plan, including the approved QASP.
When complete, the compiled semi-annual report file should be submitted using the Injection
and Post-Injection Phase Reporting module. As stated above, the EPA recommends that the
semi-annual report be provided as a single PDF file, with supplemental materials (e.g., copies of
laboratory reports or tabular monitoring data) uploaded separately using the designated field in
the module.
5.1.2 Operational Monitoring Results
The Class VI Rule requires that the following types of operational monitoring information be
included in the semi-annual report:
• Monthly average, maximum, and minimum values for injection pressure, flow rate, and
volume and annular pressure [40 CFR 146.91(a)(2)],
Carbon Dioxide Stream Submissions
Class VI Rule requirements:
•	40 CFR 146.90(a)
•	40 CFR 146.91(a)(1), (7)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	Semi-annual report template
•	GSDT user guides
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•	The monthly volume and/or mass of the carbon dioxide stream injected over the reporting
period and the volume injected cumulatively over the life of the project [40 CFR
146.91(a)(5)],
•	The monthly annulus fluid volume added [40 CFR 146.91(a)(6)],
Continuous monitoring of each of these parameters is a required component of the Testing and
Monitoring Plan pursuant to 40 CFR 146.90(b), and 40 CFR 146.91(a)(7) requires that results of
these activities are included in the semi-annual report. Operational monitoring results are used to
demonstrate compliance with permit conditions and identify any deviations from permitted
conditions that may result in USDW endangerment.
Data to support this reporting requirement will be
generated by continuous recording devices required
by 40 CFR 146.88(e)(1) and 146.90(b), as specified
in the approved Testing and Monitoring Plan.
Sections 3.2 and 3.3 of the UIC Program Class VI
Well Testing and Monitoring Guidance provide
information on conducting continuous monitoring
during injection.
Continuous monitoring results can be incorporated
into the semi-annual report template available in the
GSDT. The EPA recommends that the monthly and
cumulative data required by 40 CFR 146.91(a)(2),
(5), and (6) be presented in one or more tables within
the semi-annual report file. EPA also recommends
that, to ensure compliance with 40 CFR 146.91(a)(7),
owners or operators submit all available results for
these parameters; the EPA recommends a summary tabular and/or graphical format for these data
(i.e., owners or operators should not only submit the monthly/cumulative values). The data can
either be incorporated directly into the semi-annual report file or uploaded separately using the
field for supplemental information.
5.1.3 Description of Exceedances or Shut-Offs
The semi-annual report must include a description of any event that exceeded or otherwise
diverged from permitted levels for annulus pressure or injection pressure, pursuant to 40 CFR
146.91(a)(3). In addition, the semi-annual report must include a description of any event that
triggered a shut-off device, as well as a description of the activities conducted in response to
such an event. Importantly, permit exceedances and automatic shut-offs may also require 24-
hour reporting pursuant to 40 CFR 146.91(c), as described in Section 5.4.1; this section only
describes the requirements applicable to the semi-annual report. The purpose of including this
information in the semi-annual report is to allow the permitting authority to evaluate it in the
context of other monitoring results, with the ultimate goal of ensuring USDW protection.
Operational Monitoring Submissions
Class VI Rule requirements:
•	40 CFR 146.90(b)
•	40 CFR 146.91(a)(2), (5)-(7)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	Semi-annual report template
•	GSDT user guides
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The underlying data for this component of the sem
annual report will be generated during the
continuous monitoring required by 40 CFR
146.90(b), with supplemental information
potentially coming from the project's operational
records (e.g., internal incident reports) or
emergency reporting submissions (see Section
5.4.1). The continuous monitoring information in
Sections 3.2 and 3.3 of the UIC Program Class VI
Well Testing and Monitoring Guidance may be
useful to owners or operators when preparing this
component of their semi-annual report.
The EPA recommends that owners or operators
incorporate these event descriptions directly into tl
semi-annual report file, using the template available
in the GSDT. The EPA recommends that the descriptions consist of brief narrative explanations,
supported by tables, charts, graphs, or images as appropriate. Appendices (e.g., a record of 24-
hour emergency notifications), attachments, etc., can also be incorporated into the semi-annual
report PDF or be uploaded separately in the designated GSDT module field.
In general, the EPA recommends that the event descriptions include a brief overview of what
occurred, any identified causes, the duration of the exceedance, and a description of the owner or
operator's response. If any emergency reporting was conducted pursuant to 40 CFR 146.91(c),
owners or operators are encouraged to include cross-references to those previous submissions.
5.1.4 Other Testing and Monitoring Results
In addition to the specific components listed at 40 CFR 146.91(a)(l)-(6), the Class VI Rule
requires that the semi-annual report include the results of monitoring prescribed under 40 CFR
146.90 [40 CFR 146.91(a)(7)], This means that the semi-annual report must include the results of
monitoring conducted to comply with the approved Testing and Monitoring Plan. Because
testing and monitoring strategies (and, therefore, the associated results) will vary from project to
project, the following recommendations may not apply to all projects in all situations. The EPA
recommends that owners or operators consult with their permitting authorities to determine how
best to present results from their individual projects, especially if a project's approved Testing
and Monitoring Plan includes monitoring methods not specified under 40 CFR 146.90.
Corrosion Monitoring
The Class VI Rule, at 40 CFR 146.90(c), requires quarterly corrosion monitoring of well
materials, by analyzing coupons of well material, routing the carbon dioxide stream through a
loop of well material, or an alternate method approved by the UIC Program Director.
Furthermore, the UIC Program Director may require casing inspection logs to be run [40 CFR
146.89(d)], Section 3.4 of the UIC Program Class VI Well Testing andMonitoring Guidance
provides information related to corrosion monitoring.
Exceedance and Shut-off Submissions
Class VI Rule requirements:
•	40 CFR 146.91(a)(3)-(4)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	Semi-annual report template
•	GSDT user guides
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The EPA recommends that corrosion monitoring results be incorporated directly into the semi-
annual report file, using the template provided in the GSDT. The EPA recommends that owners
or operators provide a brief narrative describing the method of sampling/measurement (e.g., the
method for retrieval of coupons, the material from which coupons or loops are made, etc.) and an
interpretation of the measured or observed results. This should be accompanied by the actual
measurements of mass and thickness loss in any corrosion coupons or loops used (e.g., in a
tabular or graphical format), presented in the context
of all previous results. If casing inspection logs were
run, the owner or operator may submit information
about the measured casing inspection logs and
comparison to previous logs; information about the
thickness of the casing (referencing the original
casing thickness); and the locations of any detected
anomalies such as pits, scratches, and splits.
Supplemental items such as photographs can be
incorporated into the semi-annual report file or
uploaded separately in the designated field.
External MITs
The Class VI Rule, at 40 CFR 146.89(c) and 40 CFR
146.90(e), requires annual external MITs. This
testing may take the form of a tracer survey (e.g.,
oxygen activation log), a temperature log, a noise
log, or another test required or allowed by the UIC
Program Director, as specified in the approved Testing and Monitoring Plan. External MITs are
described in Section 2.3 of the UIC Program Class VI Well Testing and Monitoring Guidance.
MITs are subject to special reporting requirements under 40 CFR 146.91(b) and (d), as described
in Section 5.2. Because MIT results must be submitted within 30 days of the test, owners or
operators may have already submitted these results by the time they prepare their semi-annual
report in a given reporting period. To avoid duplicative reporting, the EPA recommends that
owners or operators include a short statement in the semi-annual report indicating the date of the
test, the outcome, and a cross-reference to the previous submission that includes the complete
results.
Pressure Fall-Off Testing
Pressure fall-off testing is required by the Class VI Rule at least once every five years, unless
more frequent testing is required by the UIC Program Director, pursuant to 40 CFR 146.90(f).
The schedule for pressure fall-off testing and the associated reporting will be specified in a
project's approved Testing and Monitoring Plan. Section 3.5 of the UIC Program Class VI Well
Testing and Monitoring Guidance provides more detailed information about pressure fall-off
testing.
Results of pressure fall-off testing must be reported within 30 days of the test, if required by the
UIC Program Director [40 CFR 146.91(b)(3)] (see Section 5.2). If pressure fall-off test results
Other Testing and Monitoring
Submissions
Class VI Rule requirements:
•	40 CFR 146.90(c)-(i)
•	40 CFR 146.91(a)(7)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	Semi-annual report template
•	GSDT user guides
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were submitted within the 6 months covered by the semi-annual report, the EPA recommends
that owners or operators include a short statement in the semi-annual report indicating the date of
the test, any notable results, and a cross-reference to a previous submission that includes the
previous results. (If the UIC Program Director/the project's Testing and Monitoring Plan does
not require 30-day reporting of pressure fall-off results, owners or operators should include the
full set of results in their semi-annual report.)
Ground Water Quality Monitoring Above the Confining Zone
Periodic monitoring of ground water quality above the confining zone(s) is required by the Class
VI Rule [40 CFR 146.90(d)], Owners or operators of wells operating under injection depth
waivers must also sample ground water below the lower confining zone [40 CFR
146.95(f)(3)(i)]. The parameters, methods, schedule, and other specifics of this monitoring
activity will be established in the project's approved Testing and Monitoring Plan.
Recommendations for conducting ground water monitoring are covered in Section 4 of the UIC
Program Class VI Well Testing and Monitoring Guidance.
Ground water monitoring results can be incorporated directly into the semi-annual report
template available in the GSDT. The EPA recommends that owners or operators include a list of
parameters analyzed (as specified in the approved Testing and Monitoring Plan), a description of
the sampling locations and methodology, a tabulation of the analytical results (including results
for any QA/QC samples), and a synthesis of the results in the context of permit/regulatory
compliance (e.g., an interpretative narrative that discusses any changing trends, any evidence of
fluid leakage/fluid migration above the confining zone, and any implications for project
operations or USDW protection, supported by maps and graphs as appropriate). To facilitate
identification and evaluation of temporal trends, the EPA recommends that owners or operators
submit the results of previous analyses, including baseline data. Any supplemental materials that
owners or operators wish to provide (e.g., copies of laboratory reports) can be provided
separately using the designated field in the module.
Carbon Dioxide Plume and Pressure-Front Tracking
The Class VI Rule, at 40 CFR 146.90(g), requires the owner or operator to perform direct and
indirect monitoring to track the carbon dioxide plume and pressure front. As described in Section
5 of the UIC Program Class VI Well Testing and Monitoring Guidance, owners or operators may
incorporate a variety of methods/techniques into their Testing and Monitoring Plans to fulfill this
requirement. Accordingly, the specific types of information submitted related to plume and
pressure-front tracking will vary from project to project.
In general, the EPA recommends that owners or operators incorporate the following items into
their semi-annual report files (as applicable):
•	One or more maps showing the locations/spatial extents (including, if applicable,
depths/elevations), dates, and types of monitoring activities.
•	Time-series graphs/charts showing monitoring results over time (including the current
reporting period, previous reporting periods, and baseline data). For example, pressure or
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saturation profiles at a given location or profiles of carbon dioxide trapping indictors
could be submitted in this manner.
•	Snapshot figures showing distributions of parameters over a given spatial extent at a
particular time, such as one or more images showing the interpreted location of the
carbon dioxide plume and pressure front in cross-sectional and plan/map view.
•	A description of data processing methods used for geophysical surveys, as well as the
major assumptions employed when analyzing monitoring results.
•	Instrument calibration data, method sensitivity information, QA sample results, or other
information to demonstrate compliance with the approved QASP.
In addition to the actual monitoring results, the EPA recommends that owners or operators
include an interpretative narrative that synthesizes the results from the various monitoring
methods, compares the results to the predictions generated during AoR delineation modeling,
identifies any anomalies, and discusses any implications for project operations or USDW
protection. Owners or operators should keep in mind that plume and pressure-front monitoring
results are a key component of AoR reevaluations (see Section 5.3.1), as well as the project's
ultimate non-endangerment demonstration (see Section 6.2.3). Submitting clear, organized,
relevant, and complete results in the semi-annual reports will support efficient evaluations of
these other Class VI project components.
To supplement the information included in the semi-annual report file, owners or operators may
submit contractor's reports, GIS files, well log results, or other types of information that would
not be practical to incorporate directly into the report PDF. These supplemental materials can be
uploaded separately in the designated field in the GSDT.
Surface Air and/or Soil Gas Monitoring
The Class VI Rule allows the UIC Program Director, at his or her discretion, to require surface
air and/or soil gas monitoring [40 CFR 146.90(h)], If such activities are determined to be
necessary, they will be incorporated into the approved Testing and Monitoring Plan. See Section
6 of the UIC Program Class VI Well Testing and Monitoring Guidance for more information.
Similar to the other types of testing and monitoring results, the EPA recommends that surface air
and/or soil gas monitoring results be incorporated directly into the semi-annual report template.
The EPA recommends that owners or operators include a list of parameters analyzed (as
specified in the approved Testing and Monitoring Plan), a description of the sampling locations
and methodology, and a tabulation of the analytical results, including results from any QA/QC
samples. To facilitate identification and evaluation of temporal trends, the EPA recommends that
owners or operators submit the results of previous analyses, including baseline data. In addition
to the analytical testing results, the EPA recommends that owners or operators include an
interpretative narrative that discusses any changing trends, any evidence of carbon dioxide
reaching the surface, and any implications for project operations or USDW protection. This
narrative may be supported by maps and graphs, as appropriate. In general, owners or operators
should provide any information necessary to demonstrate compliance with the Class VI permit
and the approved Testing and Monitoring Plan, including the approved QASP. Any supplemental
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materials that owners or operators wish to provide (e.g., copies of laboratory reports, GIS files)
can be provided separately using the designated field in the module. If any emergency reporting
was conducted pursuant to 40 CFR 146.91(c)(5), as described in Section 5.4, the EPA
recommends that owners or operators include a cross-reference to the associated submittals.
5.2 Well Testing Notifications and Results
The Class VI Rule contains special reporting
requirements for well tests and related activities,
including MITs, stimulation activities, and
workovers. First, owners or operators must notify
the UIC Program Director in writing 30 days
before any planned workovers, stimulation
activities (other than those conducted for formation
testing under 40 CFR 146.82), and other planned
tests of the injection well [40 CFR 146.91(d)],
Second, owners or operators must submit the
results of MITs, workovers, and other tests of the
injection well (if required by the UIC Program Director) within 30 days of the activity [40 CFR
146.91(b)], The EPA expects that any project-specific requirements, such as which well tests
require 30-day reporting under 40 CFR 146.91(b)(3), will be incorporated into the project's
permit conditions and/or the approved Testing and Monitoring Plan.
Both types of submissions described above can be made using the GSDT's Injection and Post-
Injection Phase Reporting module. Background information on well testing and the associated
Class VI Rule requirements can be found in the UIC Program Class VI Well Testing and
Monitoring Guidance.
For notifications made pursuant to 40 CFR 146.91(d), the EPA recommends that owners or
operators upload a PDF letter stating the date/time/location of the planned activity and providing
a brief description of what will be done. Owners or
operators may also want to state the purpose of the
activity or the applicable permit condition/Class VI
Rule requirement that it will fulfill. The EPA does
not anticipate that owners or operators will need to
submit any supplemental materials to accompany this
notification letter, but the Injection and Post-
Injection Phase Reporting module does provide the
option to do so.
When submitting the results of well tests and other
activities pursuant to 40 CFR 146.91(b), the EPA
recommends that owners or operators upload a brief
narrative report (in PDF) summarizing the
procedures used and any key interpretations/
outcomes. Owners or operators may use the field for
supplemental materials to upload items such as log
Well Testing Notifications and Results
Requirements
•	Notifications of planned workovers,
stimulations, and well tests
40 CFR 146.91(d)
•	Results of MITs, workovers, and other
well tests (if required by the UIC
Program Director)
40 CFR 146.91(b)
Well Testing Notifications and Results
Submissions
Class VI Rule requirements:
•	40 CFR 146.91(d)
•	40 CFR 146.91(b)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	GSDT user guides
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files or log analyst reports; alternatively, these items may be incorporated directly into the owner
or operator's narrative file.
While the specific information to be submitted will vary depending on the type and purpose of
the test or other activity, owners or operators are encouraged to submit details such as the
following (as applicable):
•	Operating conditions during testing, including injection rate, pressure, and temperature,
or the conditions and timing associated with shutting-in the well.
•	The numbers and locations of measurement stations (e.g., for oxygen activation logs).
•	The name of the logging company and log analyst(s) responsible for preparing or
interpreting the results.
•	Plots of results (e.g., for pressure fall-off tests, a plot of change in pressure as a function
of time) and information on any data processing methods used.
•	Details on instrumentation, including relevant information related to calibration or
QA/QC.
•	A description of any anomalous results, including records of any corrective action or
other activities undertaken in response to the test results.
•	A comparison of the current results to previous results and any implications for project
plans, predictions, or operations.
The EPA encourages owners or operators to contact their permitting authority to discuss any
questions related to submitting well test results. Note that any failure to maintain mechanical
integrity must be reported within 24 hours, pursuant to 40 CFR 146.91(c); see Section 5.4.1 for
more information on the associated submissions.
5.3 Project Plan Amendments and Other
Periodic Reporting
In addition to the specific reporting requirements at
40 CFR 146.91, owners or operators must also
submit information related to AoR reevaluations,
project plan amendments, and financial
responsibility during the injection phase. Like other
planned reporting during the injection phase, the
purpose of these submissions is to demonstrate
compliance with permit and Class VI Rule
requirements and to demonstrate that the project is
operating in a way that is protective of USDWs.
While the Class VI Rule includes minimum timing
requirements for these periodic reporting activities,
the actual reporting schedule for an individual
project (including criteria that would trigger
Project Plan Amendments and Other
Periodic Reporting Requirements
•	AoR reevaluations, including an
amended AoR and Corrective Action
Plan or a demonstration that no
amendment is needed
40 CFR 146.84(e)(4)
•	Other amended project plans, or (if
applicable) justifications that no
amendments are needed
40 CFR 146.90Q), 146.93(a)(4),
146.94(d)
•	Financial responsibility cost estimate
and instrument updates
40 CFR 146.85(a)(5)(H), (c)(2), (c)(4),
(d)(3), (e)
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unscheduled AoR reevaluations or plan reviews) will be specified in that project's permit and
approved project plans. Depending on the item to be submitted, owners or operators will use the
AoR and Corrective Action module, the Project Plan Submissions module, and/or the Financial
Responsibility Demonstration module to make these submissions. The subsections below
provide recommendations for each action.
5.3.1 AoR Reevaluations and Corrective Action
Owners or operators of Class VI injection wells are required to reevaluate the AoR delineation at
a fixed frequency not to exceed five years, as specified in the AoR and Corrective Action Plan,
or when warranted by monitoring and operational conditions [40 CFR 146.84(e)], The purpose
of the reevaluation is to ensure that the AoR delineation continues to represent the area where
USDWs may be endangered by the injection activities, as required by 40 CFR 146.84(a).
Procedures and processes associated with AoR reevaluations are described in Section 4 of the
UIC Program Class VI Well Area of Review Evaluation and Corrective Action Guidance. In
general, the EPA anticipates that owners or operators will compare testing and monitoring results
and other newly acquired project data to the modeled predictions generated during AoR
delineation. Depending on the project and the approach that the owner or operator chooses to
take, this may or may not involve additional computational modeling. Regardless of the
approach used, the owner or operator will ultimately need to submit one of two items:
1.	A technical demonstration, supported by project data, that the existing AoR delineation
(and the AoR and Corrective Action Plan) remains appropriate; or
2.	An amended AoR and Corrective Action Plan with a modified AoR delineation based on
computational modeling (and, potentially, an updated corrective action strategy).
• UIC Program Class VI Well Project
Plan Development Guidance
template
• GSDT user guides
Class VI Rule requirements:
• 40 CFR 146.84(e)
Relevant GSDT modules:
• AoR and Corrective Action module
Electronic resources:
• AoR and Corrective Action Plan
• UIC Program Class VI Well Area of
Review Evaluation and Corrective
Action Guidance
Reference documents:
AoR Reevaluation and Corrective
Action Submissions
Owners or operators can submit all reevaluation
information using the AoR and Corrective Action
module of the GSDT. For a demonstration that the
existing AoR remains appropriate, the EPA
recommends that owners or operators submit a
narrative PDF document that compares all available,
relevant project data (e.g., from site characterization,
operations, and testing and monitoring) to the
computational predictions and/or the inputs that
supported the existing AoR delineation. The EPA
recommends that data presentation formats such as
maps, diagrams, and charts/graphs be incorporated
into the narrative; the actual data supporting this
synthesis can be submitted separately as a
supplement to the narrative PDF. Owners or
operators are also encouraged to cross-reference
semi-annual reports or other testing and monitoring
submissions. If any computational modeling was
conducted to support the demonstration, the owner or
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operator may also need to update some of the other tabs in the module to reflect the changes to
the associated parameters, results, etc. When considered together, this submission will serve as
the demonstration that no plan amendment is needed, pursuant to 40 CFR 146.84(e)(4).
If the owner or operator is submitting an amended AoR and Corrective Action Plan as a result of
the reevaluation, the EPA expects that an analysis of the reevaluation and its outcome (similar to
that described above) will also be submitted. The owner or operator should use the AoR and
Corrective Action module to submit a description of inconsistencies found during the
reevaluation and all necessary changes to the modeling data (e.g., associated with the calibration
of the model) used for the delineation of the new AoR. The amended AoR and Corrective Action
Plan should benchmark any changes to the AoR delineation process and provide an updated
corrective action strategy (or a demonstration that one is not needed). Note that, if the permitting
authority made any changes to the submitted plan before incorporating it into the permit, the
existing file in the module may not be exactly the same as the approved plan. When amending
the plan, the EPA recommends that owners or operators ensure that they are using the current,
approved plan as a starting point.
Because of the flexibility that the Class VI Rule allows for AoR reevaluations and associated
reporting, the EPA encourages owners or operators to contact their permitting authority prior to
submitting their first AoR reevaluation documentation to discuss any questions related to the
reevaluation approach or what information should be submitted.
If a revised AoR has been delineated, owners or operators must also identify all wells in the
reevaluated AoR that require corrective action [40 CFR 146.84(e)(2)], For any newly identified
wells (i.e., wells that were not within the previously delineated AoR), the owner or operator must
submit a description of each well's type, construction, date drilled, location, depth, and record of
plugging and/or completion, as well as any additional information required by the UIC Program
Director [40 CFR 146.84(c)(2)] and, if necessary, perform corrective action on these wells [40
CFR 146.84(e)(3)], The EPA recommends that owners or operators communicate with their
permitting authorities before conducting corrective action on wells that were not previously
identified in the AoR and Corrective Action Plan. As described above, the AoR and Corrective
Action module is designed to facilitate submission of all corrective action materials, including
any documentation of corrective action that has been performed, such as plugging reports,
records of any remedial cementing, etc.
The AoR and Corrective Action module can also be used to submit documentation of corrective
action conducted on a phased schedule during the injection phase (i.e., pre-scheduled corrective
action that is not associated with an AoR reevaluation), if such activities are included in the
approved AoR and Corrective Action Plan. For these phased corrective action submissions,
owners or operators may update just the corrective action section of the reporting module; no
modeling or project plan submissions are necessary.
5.3.2 Other Project Plan Amendments
Owners or operators must periodically review their Testing and Monitoring Plan and Emergency
and Remedial Response Plan, and either make amendments or demonstrate that no amendments
are needed [40 CFR 146.90(j) and 146. 94(d)], These reviews will occur after AoR reevaluations
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and/or significant changes to the facility; like AoR reevaluations, the actual reporting schedule
for an individual project (including criteria that would trigger unscheduled plan reviews) will be
specified in that project's permit and approved project plans. The Class VI Rule does not require
formal periodic reviews and amendments of the Injection Well Plugging Plan or the PISC and
Site Closure Plan during the injection phase; however, 40 CFR 146.93(a)(4) states that owners or
operators may submit a modified PISC and Site Closure Plan at any time during the life of the
project.
Depending on the results of the most recent AoR
reevaluation (see Section 5.3.1), the extent of any
recent changes to the project, and other factors,
owners or operators may submit either an amended
project plan or a demonstration that no amendment
is needed. More information on completing and
documenting project plan amendments can be found
in the UIC Program Class VI Well Testing and
Monitoring Guidance, the UIC Program Class VI
Well Plugging, Post-Injection Site Care, and Site
Closure Guidance, and the UIC Program Class VI
Well Project Plan Development Guidance.
Both the amended project plans and the
justifications that no plan amendments are needed
can be submitted using the Project Plan Submissions
module. If owners or operators determine that no
plan amendment is necessary, the EPA recommends
that, to meet the requirements for this
demonstration, owners or operators submit a
narrative document describing the approach used to
evaluate the plan (which should be consistent with the approach outlined in the existing approved
plan) and the outcome of this evaluation. Owners or operators should support this discussion
with project data presented in the form of maps, graphs/charts, tables, diagrams, or other formats
as appropriate. The EPA recommends that the demonstration document be provided as a single
PDF; supplemental items that are not compatible with this format, like GIS files, can be
uploaded separately in the field designated for appendices and supporting materials.
The EPA expects that amended project plans will have a similar content and format as the
original approved plans: PDF files developed using the templates provided in the Project Plan
Submissions module, with any materials that cannot or are not intended to be incorporated into
the plan uploaded separately. Owners or operators can use the same procedures to submit
amended plans as in previous project phases (see Section 4.5). Note that, if the permitting
authority made any changes to a plan before incorporating it into the permit, the existing file in
the Project Plan Submissions module may not be exactly the same as the approved plan. When
amending a project plan, the EPA recommends that owners or operators ensure that they are
using the current, approved plan as a starting point.
Other Project Plan Submissions
Class VI Rule requirements:
•	40 CFR 146.90(j)
•	40 CFR 146.93(a)(4)
•	40 CFR 146.94(d)
Relevant GSDT modules:
•	Project Plan Submissions module
Reference documents:
•	UIC Program Class VI Well Testing and
Monitoring Guidance
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	Project plan templates
•	GSDT user guides
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5.3.3 Financial Responsibility Updates
The Class VI Rule requires that owners or operators update their financial responsibility cost
estimates on an annual basis to adjust for inflation [40 CFR 146.85(c)(2)], The cost estimate
must also be updated if the AoR and Corrective Action Plan, the Injection Well Plugging Plan,
the PISC and Site Closure Plan, or the Emergency
and Remedial Response Plan are amended [40 CFR
146.85(c)(2)], or if the UIC Program Director
determines during the annual adjustment that the
estimate is no longer adequate [40 CFR 146.85(e)], In
addition, the Class VI Rule requires that the financial
responsibility instruments be updated (or additional
instruments secured) if the cost estimate increases to
an amount greater than the face amount of the
financial instrument(s) currently in use [40 CFR
146.85(c)(4)],
Recommendations for generating these materials
(including developing cost estimates) is provided in
the UIC Program Class VI Financial Responsibility
Guidance. The EPA anticipates that the content and
format of the updated documentation will be similar
to that of the items submitted during the permit
application process or the previous financial
responsibility update (see Sections 3.1.3 and 4.6).
Both cost estimate and financial instrument updates can be submitted using the GSDT's
Financial Responsibility Demonstration module, using the tabs associated with the applicable
activity or instrument. When preparing these submissions, the EPA recommends that owners or
operators delete any obsolete information from the module (including both directly entered data
and uploaded files) and replace it with an up-to-date version. The EPA encourages owners or
operators to contact their permitting authority to discuss the timing of cost estimate or financial
instrument updates or any other questions related to submitting financial responsibility
information.
5.4 Emergency and Remedial Response and
Other Occasional Reporting
In certain situations, owners or operators must
submit notifications and other documentation
associated with unexpected events. The Class VI
Rule includes specific requirements for reporting
associated with emergency and remedial response,
as well as for adverse financial conditions (such as
bankruptcy) experienced by either the owner or
operator or a third-party provider of a financial
responsibility instrument. While the EPA
Financial Responsibility Submissions
Class VI Rule requirements:
•	40 CFR 146.85(a)(5)(ii), (c)(2) and (4),
and (e)
Relevant GSDT modules:
•	Financial Responsibility
Demonstration module
Reference documents:
•	UIC Program Class VI Financial
Responsibility Guidance
Electronic resources:
•	Online materials at
http://www.epa.gov/uic/financial-
responsibilities-underground-
injection-well-owners-or-operators
•	GSDT user guides
Emergency and Remedial Response
and Other Occasional Reporting
Requirements
•	Emergency notifications and follow-up
submissions
40 CFR 146.88(f)(3)-(5), 146.91(c) and
(e), 146.94(b)-(c)
•	Notifications of adverse financial
conditions
40 CFR 146.85(d)
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anticipates that emergency situations will likely require direct (non-GSDT) communication
between the owner or operator and the permitting authority, all notifications, reports, and other
required submissions must still be submitted electronically in compliance with 40 CFR
146.91(e).
The GSDT's Injection and Post-Injection Phase Reporting module and Financial Responsibility
Demonstration modules facilitate the submission of emergency and remedial response materials
and notifications of adverse financial conditions, respectively. The subsections below provide
recommendations specific to both of these types of submissions. The Injection and Post-Injection
Phase Reporting module can also be used to submit other types of materials that may be required
by a Class VI permit and are not otherwise accommodated by the GSDT. Owners or operators
can use the Other Submissions tab of the module for this purpose and enter a brief description of
the item they are submitting in the designated text-entry field.
5.4.1 Emergency and Remedial Response
The Class VI Rule lists several situations or events that require owners or operators to submit
emergency notifications. Specifically, the owner or operator must report any of the following
within 24 hours:
•	Any evidence that the injected carbon dioxide stream or associated pressure front may
cause endangerment of a USDW [40 CFR 146.91(c)(1), 146.94(b)(3)],
•	Any noncompliance with permit conditions or equipment malfunctions that may cause
fluid movement into a USDW [40 CFR 146.91(c)(2)],
•	Any triggering of the automatic shut-off system [40 CFR 146.88(f)(3), 146.91(c)(3)],
•	Any failure to maintain mechanical integrity [40 CFR 146.91(c)(4)],
•	Any release of carbon dioxide to the atmosphere or biosphere, for projects with surface
air and/or soil gas monitoring [40 CFR 146.91(c)(5)],
The EPA anticipates that the initial emergency
notification will likely take the form of a phone call or
other immediate mode outlined in the Emergency and
Remedial Response Plan. However, the formal
notification must still be submitted electronically in
compliance with 40 CFR 146.91(e). In addition, after
an emergency event has occurred, an owner or
operator may need to submit follow-up information,
such as a demonstration that USDWs will not be
endangered by resuming injection [40 CFR
146.94(c)], a demonstration that mechanical integrity
has been restored [40 CFR 146.88(f)(4)], or
documentation that remedial actions or other
procedures have been carried out according to the
Emergency and Remedial Response Plan or as
requested by the UIC Program Director. Any project-
Emergency and Remedial Response
Submissions
Class VI Rule requirements:
•	40 CFR 146.88(f)(3)-(5), 146.91(c) and
(e), 146.94(b)-(c)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Project Plan
Development Guidance
Electronic resources:
•	GSDT user guides
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specific requirements associated with these notifications and follow-up submissions will be
established in the project's approved Emergency and Remedial Response Plan. See the UIC
Program Class VI Well Project Plan Development Guidance for further information.
Both notifications and follow-up submissions can be submitted using the Emergency and
Remedial Response tab of the Injection and Post-Injection Phase Reporting module. The EPA
recommends that notifications consist of a PDF letter containing the date/time/location of the
event and a brief description of what occurred. Follow-up documentation may take various
formats, such as narrative descriptions of remedial activities, results of MITs, monitoring data, or
additional notifications (e.g., notifications that injection will resume, per 40 CFR 146.88(f)(5)).
Because of the wide variety of potential follow-up submissions, the EPA recommends that
owners or operators review their Emergency and Remedial Response Plan and consult with their
permitting authority to determine the appropriate materials to submit.
5.4.2 Notifications of Adverse Financial Conditions
The Class VI Rule requires owners or operators to notify their UIC Program Director of any
adverse financial conditions that may affect their ability to cover the costs of any of the required
activities guaranteed by the financial responsibility instruments [40 CFR 146.85(d)], These
events could include bankruptcy or other adverse financial conditions experienced by the owner
or operator, a third-party provider of a financial
instrument, or a corporate guarantor.
The EPA anticipates that specific conditions
associated with these notifications will be stated in
the financial instruments themselves. The UIC
Program Class VI Financial Responsibility
Guidance provides further information on this.
Unless otherwise specified in the permit or financial
instruments, the EPA recommends that the
notification consist of a PDF letter describing the
situation and the owner or operator's plans to
establish other means of financial assurance.
Note that, in the case of bankruptcy proceedings, the
Class VI Rule requires that a notification be sent by
certified mail within 10 days of commencement of
the proceedings [40 CFR 146.85(d)(1)], The EPA recommends that owners or operators submit
the notification first using the GSDT and follow it with the certified mail letter. Submitting the
notification via the GSDT allows owners or operators to rapidly alert their permitting authority,
as well as to comply with the Class VI Rule's electronic reporting requirement under 40 CFR
146.91(e).
Adverse Financial Conditions
Submissions
Class VI Rule requirements:
•	40 CFR 146.85(d) and 146.91(e)
Relevant GSDT modules:
•	Financial Responsibility
Demonstration module
Reference documents:
•	UIC Program Class VI Financial
Responsibility Guidance
Electronic resources:
•	GSDT user guides
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6 Post-Injection Phase Reporting and Recordkeeping
Following cessation of injection, a Class VI project enters the post-injection phase. During this
phase, owners or operators will plug the injection well, perform PISC testing and monitoring,
demonstrate that the site no longer poses an endangerment to USDWs, and close the site,
pursuant to 40 CFR 146.92 and 146.93. These activities (and their associated reporting
requirements) are intended to demonstrate that the site is managed and monitored properly
following the cessation of injection, to maintain protection of USDWs through the end of the
project's lifespan. Because injection wells may be converted to monitoring wells after injection
has ceased, injection well plugging is not required to take place at the beginning of the post-
injection phase. However, pursuant to 40 CFR 146.93(f)(1), the site closure report must include
documentation of appropriate injection well and monitoring well plugging as specified in 40
CFR 146.92 and 146.93(e), regardless of when the injection well plugging took place.
Information that owners or operators will submit during this phase of a Class VI project is
summarized below in Table 6-1. The Class VI Rule, at 40 CFR 146.91(f)(4), states that well
plugging reports, PISC data (including information used to develop the alternative PISC
timeframe), and site closure reports must be retained for 10 years following site closure. Pursuant
to 40 CFR 146.93(h), the owner or operator must deliver the records to the UIC Program
Director at the conclusion of this retention period. Owners or operators should discuss plans for
this transfer with their permitting authority. Note that the Class VI Rule, at 40 CFR 146.91(f)(5),
also grants the UIC Program Director the authority to require owners or operators to retain
records from any project phase for more than 10 years after site closure.
Table 6-1. Summary of submittals to be made during the post-injection phase.
Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
Injection Well Plugging
Plan amendments, if
necessary
[40 CFR 146.92(c)]
Project Plan Submissions
module
A single uploaded PDF,
with supporting data
and other supplemental
materials uploaded
separately as necessary
Upon cessation of
injection
Notice of intent to plug
the injection well
[40 CFR 145.92(c)]
Injection and Post-
Injection Phase Reporting
module
Uploaded PDF letter
At least 60 days before
scheduled well plugging
Well plugging report
[40 CFR 146.92(d)]
Injection and Post-
Injection Phase Reporting
module
A single uploaded PDF,
with supporting data
and other supplemental
materials uploaded
separately as necessary
Within 60 days of well
plugging
PISC and Site Closure Plan
Amendments or
justification that no
amendment is needed
[40 CFR 146.93(a)(3)]
Project Plan Submissions
module
A single uploaded PDF,
with supporting data
and other supplemental
materials uploaded
separately as necessary
Upon cessation of
injection
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Reporting Requirement
Relevant GSDT Modules
Recommended Format
Timing and Frequency
PISC monitoring results
[40 CFR 146.93(b)]
Injection and Post-
Injection Phase Reporting
module
A single uploaded PDF
containing the narrative
component of each
report, with supporting
data and other
supplemental materials
uploaded separately as
necessary
As specified in the
approved PISC and Site
Closure Plan
Non-endangerment
demonstration
[40 CFR 146.93(b)(3)]
Non-Endangerment
Demonstration module
Uploaded files in PDF
and other formats and
references to previously
submitted materials
At end of 50 years or the
approved alternative PISC
timeframe, or based on
site-specific data
Notice of intent for site
closure
[40 CFR 146.93(d)]
Injection and Post-
Injection Phase Reporting
module
Uploaded PDF letter
At least 120 days before
site closure
Notice of intent to plug
monitoring wells
[N/A*]
Injection and Post-
Injection Phase Reporting
module
Uploaded PDF letter
N/A
Site closure report
[40 CFR 146.93(f)]
Injection and Post-
Injection Phase Reporting
module
A single uploaded PDF,
with supporting data
and other supplemental
materials uploaded
separately as necessary
Within 90 days of site
closure
*This item is not specifically required by the Class VI Rule; however, the EPA recommends that owners or
operators provide notification before plugging monitoring wells. The requirement to plug monitoring wells
appears in the Class VI Rule at 40 CFR 146.93(e).
In addition to the reporting requirements that are specific to the post-injection phase, some
injection phase reporting requirements continue to apply after injection has ceased. (Other
injection phase reporting requirements, such as those associated with operational monitoring, do
not.) To avoid redundancy, the injection phase reporting activities that continue through the post-
injection phase activities are not discussed in the subsections below; refer to Section 5 for
recommendations on submitting the associated materials. Injection phase reporting requirements
that continue to apply through the post-injection phase are as follows:
•	AoR reevaluations and corrective action updates, including amendments to the AoR and
Corrective Action Plan, if necessary (see Section 5.3.1).
•	Other project plan reviews and amendments (see Section 5.3.2). While the Testing and
Monitoring Plan will no longer be in effect after the cessation of injection, the
Emergency and Remedial Response Plan may need to be amended following AoR
reevaluations or other project-specific criteria. Note that there are also post-injection
phase requirements related to the Injection Well Plugging Plan and the PISC and Site
Closure Plan, which are discussed in Sections 6.1.1, 6.2.1, and 6.3.1 below.
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•	Financial responsibility cost estimate and financial instrument updates (see Section
5.3.3). Note that, pursuant to 40 CFR 146.85(b)(2), an owner or operator may be released
from a financial instrument by the UIC Program Director if the associated project phase
has been completed and the owner or operator has fulfilled all necessary financial
obligations.
•	Emergency and remedial response reporting, if necessary (see Section 5.4.1).
•	Notifications of adverse financial conditions, if necessary (see Section 5.4.2).
The post-injection phase reporting schedule for each of these items will likely vary among
projects and will be specified in each project's permit conditions and/or the applicable approved
project plans. The EPA encourages owners or operators to contact their permitting authorities to
discuss any questions or concerns related to post-injection phase reporting of these activities.
6.1 Injection Well Plugging
Requirements for injection well plugging are provided in the Class VI Rule at 40 CFR 146.92.
Before plugging the injection well, owners or operators must notify the UIC Program Director
and (if necessary) submit an amended Injection Well Plugging Plan [40 CFR 146.92(c)], After
the plugging activities are complete, the owner or
operator must submit an injection well plugging
report [40 CFR 146.92(d)], The Injection and Post
Injection Phase Reporting module and the Project
Plan Submissions module of the GSDT were
designed to facilitate submission of these items.
As noted above, injection wells may be converted
to monitoring wells after injection has ceased, so
injection well plugging is not required to take place
at the beginning of the post-injection phase. The
only timing requirement specified in the Class VI
Rule is that plugging take place before site closure, so that the necessary plugging records can be
incorporated into the site closure report per 40 CFR 146.93(f)(1). The EPA recommends that
owners or operators notify their permitting authorities before and after converting the injection
well to a monitoring well, including a general description of what activities (e.g., removal of well
equipment) will take place/have taken place.
6.1.1 Pre-Plugging Submissions
The owner or operator must notify the UIC Program Director at least 60 days before plugging the
injection well (though a shorter notice period may be allowed by the Director), pursuant to 40
CFR 146.92(c). As noted above, the Class VI Rule allows injection well plugging to occur at any
time during the post-injection phase. However, if injection well plugging does take place at the
beginning of the post-injection phase, it may be necessary to submit the notice of intent to plug
before injection ends, in order to meet the 60-day requirement. In addition, if any changes have
been made to the original, approved Injection Well Plugging Plan, the owner or operator must
also provide the amended plan at this time. More details about the injection well plugging
Injection Well Plugging Requirements
•	Notice of intent to plug
40 CFR 146.92(c)
•	Amended Injection Well Plugging Plan,
if necessary
40 CFR 146.92(c)
•	Well plugging report
40 CFR 146.92(d)
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requirements can be found in the UIC Program
Class VI Well Plugging, Post-Injection Site Care,
and Site Closure Guidance, and recommendations
related to the Injection Well Plugging Plan are
provided in the UIC Program Class VI Well Project
Plan Development Guidance.
The notice of intent to plug can be submitted using
the Injection and Post-Injection Phase module of the
GSDT, on the Other Submissions tab. The EPA
recommends that owners or operators upload a PDF
letter stating the time and date of the planned
activity and providing a brief description of what
will be done. A template to guide the development
of this letter is available for download from the
GSDT. The EPA does not anticipate that owners or
operators will need to submit any supplemental
materials to accompany this notification letter, but
the Injection and Post-Injection Phase Reporting
module provides the option to do so.
Pre-Plugging Submissions
Class VI Rule requirements:
•	40CFR 146.92(c)
Relevant GSDT modules:
•	Injection and Post-Injection Reporting
Phase module
•	Project Plan Submissions module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	Injection Well Plugging Plan template
•	Notice of intent to plug template
•	GSDT user guides
Owners or operators can use the Project Plan Submissions module to submit the amended
Injection Well Plugging Plan, if necessary. The EPA expects that the plan will have a similar
content and format as the original approved plan: a PDF file developed using the template
provided in the Project Plan Submissions module, with any materials that cannot or are not
intended to be incorporated into the plan itself uploaded separately. Owners or operators can use
the same procedures to submit amended plans as in previous project phases (see Section 4.5).
Note that, if the permitting authority made any changes to the plan before incorporating it into
the permit, the existing file in the Project Plan Submissions module may not be exactly the same
as the approved plan. When revising the plan file, the EPA recommends that owners or operators
ensure that they are using the current, approved plan as a starting point.
The Class VI Rule does not require that owners or operators submit a justification that no
amendment to the Injection Well Plugging Plan is needed. However, the EPA recommends that
owners or operators submit a statement to this effect in the Project Plan Submissions module
(e.g., in the form of a brief letter in PDF), so that the GSDT contains a full record of
documentation for the project. The EPA recommends that owners or operators contact their
permitting authority if there is uncertainty about whether an amended plan is needed.
In addition to the notice of intent to plug and the amended Injection Well Plugging Plan, owners
or operators may also need to conduct reporting related to the preparatory activities specified at
40 CFR 146.92(a). For example, the external MIT required before plugging the injection well is
subject to the notification and reporting requirements under 40 CFR 146.91(b) and (d). See
Section 5.2 for more information on these reporting requirements.
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6.1.2 Well Plugging Report
Following plugging of the injection well, owners or operators must submit a report detailing how
the well was plugged, pursuant to 40 CFR 146.92(d). The Class VI Rule specifies that this report
must be certified as accurate by the owner or operator and by the person who performed the
plugging operation (if other than the owner or
operator). The plugging report serves to demonstrate
that plugging was carried out in compliance with the
Class VI Rule and the approved Injection Well
Plugging Plan, so that the well does not pose an
endangerment to USDWs.
Well Plugging Report Submissions
Class VI Rule requirements:
• 40 CFR 146.92(d)
Relevant GSDT modules:
• Injection and Post-Injection Reporting
Phase module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
Electronic resources:
•	Well plugging report template
•	GSDT user guides
The Class VI Rule does not specify the contents of
the plugging report, but recommendations are
provided in the UIC Program Class VI Well
Plugging, Post-Injection Site Care, and Site Closure
Guidance, and a template is available for download
from the GSDT. In general, the EPA recommends
that the well plugging report include a description of
both the pre-plugging activities conducted pursuant
to 40 CFR 146.92(a), including the results of the
final external MIT, and the procedures/outcomes of
the actual plugging operation (including any
schematic/drawings). The EPA recommends that the well plugging report be compiled into a
single PDF and uploaded to the Other Submissions tab of the Injection and Post-Injection Phase
Reporting module. Supplemental materials not compatible with this format can be uploaded
separately in the designated field.
6.2 PISC Reporting
The Class VI Rule, at 40 CFR 146.93(a)-(b),
provides a set of requirements for PISC activities.
Upon cessation of injection, the owner or operator
must submit an amended PISC and Site Closure
Plan or a demonstration that no amendment is
needed [40 CFR 146.93(a)(3)], During the post-
injection phase, owners or operators must conduct
monitoring and submit the results as specified in
the approved PISC and Site Closure Plan, until
they can demonstrate that no additional
monitoring is needed to ensure that the project
does not pose an endangerment to USDWs [40
CFR 146.93(b)], In the GSDT, owners or
operators can use designated sections of the Project Plan Submissions module, the Injection and
Post-Injection Phase Reporting module, and the Non-Endangerment Demonstration module to
submit the required materials.
PISC Reporting Requirements
•	Amended PISC and Site Closure Plan, if
necessary
40 CFR 146.93(a)(3)
•	PISC testing and monitoring results
40 CFR 146.93(a)(2)(iv), (b)
•	Non-endangerment demonstration
40 CFR 146.93(b)(3)
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6.2.1 PISC and Site Closure Plan
Upon cessation of injection, the Class VI Rule requires that owners or operators either submit an
amended PISC and Site Closure Plan or demonstrate to the UIC Program Director through
monitoring data and modeling results that no amendment to the plan is needed [40 CFR
146.93(a)(3)], More information on completing and documenting this plan amendment can be
found in the UIC Program Class VI Well Plugging, Post-Injection Site Care, and Site Closure
Guidance and the UIC Program Class VI Well Project Plan Development Guidance.
Both the amended project plan and the justification that no plan amendment is needed
(whichever is appropriate for the individual project) can be submitted using the Project Plan
Submissions module. If owners or operators determine that no plan amendment is necessary, the
EPA recommends that they submit a narrative document describing the approach used to
evaluate the plan and the outcome of this evaluation. The EPA recommends that the narrative
address all of the elements in the approved plan and be based on both monitoring data related to
ground water quality and plume and pressure front tracking collected during injection and recent
revisions of the site computational model, to ensure compliance with 40 CFR 146.93(a)(3).
Owners or operators should support this discussion with project data presented in the form of
maps, graphs/charts, tables, diagrams, or other formats as appropriate. If an owner or operator
proposes an alternative PISC timeframe as part of the Post-Injection Site Care Plan amendment,
the EPA recommends that they thoroughly justify the alternative timeframe using the criteria at
40 CFR 146.93(c). The EPA recommends that the demonstration document be provided as a
single PDF; supplemental items that are not compatible with this format, like GIS files, can be
uploaded separately in the field designated for appendices and supporting materials.
The EPA anticipates that the amended PISC and Site Closure Plan, if one is needed, will have a
similar content and format as the existing approved plan (e.g., a PDF file developed using the
template provided in the Project Plan Submissions module, with any supplemental materials
uploaded separately in the designated field). The EPA recommends that owners or operators
discuss the need for plan amendments with their permitting authority, keeping in mind the need
to collect a sufficient amount of data to inform the non-endangerment demonstration and the UIC
Program Director's assessment that site closure is appropriate (see Sections 6.2.3 and 6.3).
6.2.2 PISC Monitoring Results
During the post-injection period, the owner or operator must implement the approved PISC and
Site Closure Plan and report the results of PISC monitoring as specified in the plan. Post-
injection monitoring must be performed for the duration of the PISC timeframe (either the
default 50-year period or an approved alternative timeframe) or until the owner or operator can
demonstrate non-endangerment to USDWs [40 CFR 146.93(b)(1)],
Similar to monitoring results submitted during the injection phase, post-injection monitoring
submissions serve to demonstrate that the project is in compliance with the Class VI permit, to
identify any endangerment of USDWs, and to generate data to support AoR reevaluations and
the demonstration of non-endangerment.
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The Class VI Rule does not specify the content, format, or timing of PISC monitoring
submissions; the EPA expects that these will be determined on a project-specific basis in each
project's PISC and Site Closure Plan. However, in
general, the EPA anticipates that these submissions
will have a similar format to the semi-annual reports
of testing and monitoring results submitted during the
injection phase: a PDF document containing a
compilation of monitoring results (e.g., of MITs,
ground water analysis, and plume and pressure front
tracking) and associated interpretation, accompanied
by attachments or other supplemental materials as
necessary. The GSDT provides a template that
owners or operators can download and use to guide
the development of this document.
Owners or operators can use the Other Submissions
tab of the Injection and Post-Injection Phase
Reporting module to submit their PISC monitoring
results. The UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site Closure Guidance
and the UIC Program Class VI Well Testing and
Monitoring Guidance provide recommendations for conducting PISC monitoring activities and
submitting the results.
6.2.3 Non-Endangerment Demonstration
Prior to receiving authorization for site closure, the owner or operator must submit a
demonstration, based on monitoring results and other site-specific information, that no additional
monitoring is needed to ensure that the Class VI
project does not pose an endangerment to USDWs
[40 CFR 146.93(b)(3)], Pursuant to 40 CFR
146.93(b)(2), owners or operators may submit this
non-endangerment demonstration at any time during
the post-injection phase, even before the end of the
designated PISC timeframe. This means that, if non-
endangerment is demonstrated to the satisfaction of
the UIC Program Director, an owner or operator
could potentially receive authorization for site
closure before the end of the PISC timeframe.
The data supporting the non-endangerment
demonstration will be generated throughout the life
of the Class VI project, during injection- and post-
injection-phase monitoring and modeling. While the
content of the demonstration will necessarily be site
specific, the EPA recommends that it address
ground water monitoring data, information on the
PISC Monitoring Results Submissions
Class VI Rule requirements:
•	40 CFR 146.93(a)(2)(iv), (b)
Relevant GSDT modules:
•	Injection and Post-Injection Phase
Reporting module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
•	UIC Program Class VI Well Testing and
Monitoring Guidance
Electronic resources:
•	PISC monitoring report template
•	GSDT user guides
Non-Endangerment Demonstration
Submissions
Class VI Rule requirements:
•	40 CFR 146.93(b)(3)
Relevant GSDT modules:
•	Non-Endangerment Demonstration
module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
Electronic resources:
•	Non-endangerment demonstration
template
•	GSDT user guides
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behavior of the carbon dioxide plume and pressure front, and the monitoring results' agreement
with any AoR modeling predictions that are being used to support the demonstration, as well as
an evaluation of potential conduits for fluid movement. The UIC Program Class VI Well
Plugging, Post-Injection Site Care, and Site Closure Guidance provides some additional
recommendations for making the non-endangerment demonstration.
The GSDT includes a specific reporting module for non-endangerment demonstrations. The
Non-Endangerment Demonstration module provides substantial flexibility to owners or
operators, while helping ensure that all the necessary information is submitted. The EPA
anticipates that the non-endangerment demonstration will be composed of one or more uploaded
files, supplemented by references to previously submitted information (e.g., modeling results
submitted using the AoR and Corrective Action module following the last AoR reevaluation).
The module provides a template that owners or operators can download and use to guide the
development of their submission.
The EPA recommends that owners or operators contact their permitting authorities to discuss any
questions related to the non-endangerment demonstration submission, especially if the content of
the demonstration is not specified in the approved PISC and Site Closure Plan.
6.3 Site Closure Reporting
Site closure is the final stage of a Class VI project, during which owners or operators submit a
notice of intent to close the site, plug all monitoring wells, submit a site closure report, and
record a notation on the deed to the facility property or other documents that the land has been
used to sequester carbon dioxide [40 CFR
146.93(d)-(g)]. The purpose of site closure
reporting is to demonstrate compliance with the
Class VI Rule and the permit, to demonstrate that
monitoring wells are plugged appropriately in a
way that is protective of USDWs, and to ensure
that future land owners are made aware of the
injection history of the site.
The Injection and Post-Injection Phase Reporting
module of the GSDT is designed to facilitate the
submission of site closure-related materials.
6.3.1 Pre-Site Closure Submissions
Owners or operators must notify the UIC Program Director of their intent to close a Class VI
project site at least 120 days in advance of the intended site closure date, or on a schedule with a
shorter notice period if allowed by the Director [40 CFR 146.93(d)], At this time, if any changes
have been made to the original PISC and Site Closure Plan, the owner or operator must also
provide the amended plan. More details about the site closure process and templates for the
submittals can be found in the UIC Program Class VI Well Plugging, Post-Injection Site Care,
and Site Closure Guidance, and recommendations related to the PISC and Site Closure Plan are
provided in the UIC Program Class VI Well Project Plan Development Guidance.
Site Closure Requirements
•	Notice of intent for site closure
40 CFR 146.93(d)
•	Amended PISC and Site Closure Plan, if
necessary
40 CFR 146.93(d)
•	Site closure report
40 CFR 146.93(f)
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The notice of intent for site closure can be
submitted using the Injection and Post-Injection
Phase module of the GSDT, on the Other
Submissions tab. The EPA recommends that owners
or operators upload a PDF letter stating the
date/time/location of the planned activities (e.g.,
monitoring well plugging, site restoration tasks) and
providing a brief description of what will be done.
The GSDT provides a template that owners or
operators can download and use to guide the
development of this letter. The EPA does not
anticipate that owners or operators will need to
submit any supplemental materials to accompany
this notification letter, but the Injection and Post-
Injection Phase Reporting module does provide the
option to do so.
Owners or operators can use the Project Plan
Submissions module to submit the amended PISC
and Site Closure Plan, if one is needed. The EPA
expects that the plan will have a similar content and
format as the existing, approved plan: a PDF file
developed using the template provided in the Project Plan Submissions module, with any
materials that cannot or are not intended to be incorporated into the plan itself uploaded
separately. Owners or operators can use the same procedures to submit amended plans as in
previous project phases (see Section 4.5). Note that, if the permitting authority made any changes
to the plan before incorporating it into the permit, the existing file in the Project Plan
Submissions module may not be exactly the same as the approved plan. When revising the plan
file, the EPA recommends that owners or operators ensure that they are using the current,
approved plan as a starting point.
The Class VI Rule does not require that owners or operators submit a justification that no plan
amendment is needed prior to site closure. However, the EPA recommends that owners or
operators submit a statement to this effect in the Project Plan Submissions module (e.g., in the
form of a brief letter in PDF), so that the GSDT contains a full record of documentation for the
project. The EPA recommends that owners or operators contact their permitting authority if there
is uncertainty regarding whether an amended plan is needed.
The Class VI Rule, at 40 CFR 146.93(e) requires owners or operators to plug all monitoring
wells after the UIC Program Director has authorized site closure. (If the injection well was
repurposed for use as a monitoring well, it must be plugged in accordance with the Injection
Well Plugging Plan, per 40 CFR 146.92(b); see Section 6.1.) While the Class VI Rule does not
specifically require advance notification of monitoring well plugging, the EPA recommends that
owners or operators notify the UIC Program Director before carrying out these activities (if the
specifics are not included in the initial notification of intent for site closure). The EPA
recommends that owners or operators use a letter similar to the one submitted in advance of
Pre-Site Closure Submissions
Class VI Rule requirements:
•	40 CFR 146.93(d)
Relevant GSDT modules:
•	Injection and Post-Injection Reporting
Phase module
•	Project Plan Submissions module
Reference documents:
•	UIC Program Guidance on Class VI
Well Plugging, Post-Injection Site
Care, and Site Closure
•	UIC Program Class VI Well Project
Plan Development Guidance
Electronic resources:
•	PISC and Site Closure Plan template
•	Notice of intent for site closure
template
•	GSDT user guides
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injection well plugging and upload it to the Other Submissions tab of the Injection and Post-
Injection Phase Reporting module.
6.3.2 Site Closure Report
The Class VI Rule requires owners or operators to submit a report within 90 days of site closure
[40 CFR 146.93(f)], The Class VI Rule, at 40 CFR 146.93(f)(l)-(3) specifies that the site closure
report must include documentation of appropriate injection and monitoring well plugging; a copy
of a survey plat that has been submitted to the local zoning authority, showing the location of the
injection well; documentation of appropriate notification to applicable state, local, and tribal
entities; and records reflecting the nature, composition, and volume of the carbon dioxide stream.
Recommendations for notifying the relevant authorities and preparing the site closure report are
provided in the UIC Program Class VI Well Plugging, Post-Injection Site Care, and Site Closure
Guidance.
The EPA recommends that the site closure report be
submitted as a single PDF file. The GSDT provides a
template that owners or operators can download and
use to guide the development of this document.
Supplemental materials that are not compatible with
this format (e.g., GIS files) can be uploaded
separately in the designated field in the reporting
module.
The owner or operator must also record a notation on
the deed to the facility property or any other
document that is normally examined during a title
search [40 CFR 146.93(g)], Pursuant to 40 CFR
146.93(g)(l)-(3), the notation must state that the land
has been used for GS; the name of the government
agency with which the survey plat was filed and the
address of the EPA regional office to which it was
submitted; and the volume of carbon dioxide injected, the injection zone(s), and the period over
which the injection occurred. While the Class VI Rule does not require any formal submissions
associated with the deed notation, the EPA recommends that the owner or operator provide
evidence of this notation to the EPA, for example by attaching copies of it to the site closure
report or uploading the documents separately within the Injection and Post-Injection Reporting
module.
Site Closure Report Submissions
Class VI Rule requirements:
•	40 CFR 146.93(f)
Relevant GSDT modules:
•	Injection and Post-Injection Reporting
Phase module
Reference documents:
•	UIC Program Class VI Well Plugging,
Post-Injection Site Care, and Site
Closure Guidance
Electronic resources:
•	Site closure report template
•	GSDT user guides
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Data Management Guidance for Owners and Operators
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