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Direct Implementation Programs
The U.S. Environmental Protection Agency, Region 4 office in Atlanta, Georgia directly implements UIC programs in Kentucky, Tennessee, and all Indian lands. In addition, Region 4 also administers the Class 2 program in Florida. Programs in other Region 4 States are administered by one or more State agencies.
The effective date for each EPA Region 4 UIC program is as follows:
- June 25, 1984 for the Commonwealth of Kentucky,
- June 25, 1984 for the State of Tennessee,
- December 30, 1984 for the State of Florida (Class 2 program)
- November 25, 1988 for all Indian Lands in Region 4.
Where are the injection wells which are regulated by EPA Region 4?
Historically, Kentucky and Tennessee had several large facilities that used Class 1 injection wells for disposal of industrial (hazardous or non-hazardous) wastes. Currently, only one facility is authorized to inject into a Class I well.
Since Florida, Kentucky, and Tennessee are all oil producing states, Class 2 injection wells have been, and continue to be, used extensively. Currently, there are about 3200 Class 2 wells in Kentucky, 10 in Tennessee, and 60 in Florida. There are no Class 2 wells on Indian lands in Region 4. Within the mature oil producing areas of Kentucky and Tennessee, injection wells tend to be relatively shallow, and injection operations are mechanically simple. In contrast, Class 2 injection wells in Florida are often drilled to more than 15,000 ft. and injection operations tend to be far more complex.
Class 5 wells are mainly found in rural and suburban areas not covered by sewage systems. Most Class 5 wells are large capacity septic systems.
How does one obtain the authority to conduct injection operations?
For all injection wells covered under UIC, underground injection is prohibited unless the well is either authorized by rule or authorized by permit. In simple terms, existing injection wells were authorized by rule (grand-fathered) if the well was properly inventoried within one year after the effective date of the applicable UIC Program (as shown above). All wells constructed or converted thereafter require authorization by permit.
How does one apply for a Class 2 injection well permit?
Region 4 has a "permit package" for Class 2 wells
which is mailed to operators on request. This permit package contains basic
information for completing a permit application. Forms
included in the package are now available online. Among other things, a permit
application generally requires well construction and plugging documentation
for all wells within 1/4 mile of the proposed injection well. The availability
of oil and gas well information online through the Kentucky
Geological Survey 
may help applicants with the AOR requirements for
permits in the Commonwealth of Kentucky.
Region 4 staff are available to answer questions prior to submitting a permit application and during application review. A permit may be issued for a single well or for an area. Although an area permit application may take longer to prepare, an area permit may allow greater flexibility in the operation of large well fields. Permits require public notice and at least 30 days for public comment. Therefore, applicants should expect the entire process to take about 10 to 12 weeks from the date a complete permit application is received.
What is needed to demonstrate financial responsibility?
An owner/operator of Class 1, Class 2, or some Class 5 wells must demonstrate adequate financial resources are available to properly plug injection wells by submitting one of the following: a letter of credit and standby trust agreement, a surety performance bond and a standby trust agreement, a trust agreement secured with a certificate of deposit, or a financial statement. Financial forms are available upon request.
What about oil and gas production wells?
UIC regulations do not cover production wells. Production
wells in the Commonwealth of Kentucky are regulated by the Division
of Oil and Gas Conservation. In Tennessee, production wells are regulated by
the State
Oil and Gas Board and the Tennessee
Division of Geology. In Florida, the Florida Geological Survey Oil
& Gas Section regulates production wells.
What are the monitoring requirements for Class 2 injection wells?
For rule authorized wells, EPA requires operators to observe injection pressure, flow rate, and cumulative volume at least monthly. The specific conditions of an issued permit determine the frequency of pressure, rate, and volume observations for permitted wells. An annual monitoring report must be submitted for each injection well whether rule authorized or permitted, regardless of whether or not the well was in use during the year.
Wells located on the same lease or field, or part of the same project, cannot be combined on an annual monitoring report unless those wells are operated with a common manifold. When manifold monitoring is used, the operator must demonstrate that such monitoring is comparable to individual well monitoring. At a minimum, an annual monitoring report should identify which wells are connected through a common manifold, and show which wells were operated and which wells were shut in. Injection volume and pressure may then be reported collectively.
Annual reports may cover a calendar year (preferred), a federal fiscal year, or a year as defined by the specific conditions of the permit. Whatever starting and ending dates are used, the annual monitoring report should cover 12 months.
What are the fluid analysis requirements for Class 2 injection wells?
The operator of a Class 2 injection well is required to monitor the nature of the injected fluid with sufficient frequency to yield data representative of fluid characteristics. For rule authorized injection wells, an initial fluid analysis may have been submitted and may be on file here. If so, a new analysis is required only when changes are made to the injected fluid or when requested, in writing, from this office. For permitted injection wells, a fluid analysis is required annually, and whenever changes are made to the injected fluid. At a minimum, a fluid analysis should include pH, specific gravity, and total dissolved solids (TDS). Some permits require analysis of other constituents, as well. Please check your permit to be sure.
How does one apply for rule authority or a permit for a Class 5 well?
At a minimum, the owner/operator must provide basic inventory information and demonstrate that the well will not endanger any underground source of drinking water. EPA staff will review this information and determine whether the well may be authorized by rule or will require a permit.
Where may one find additional information about Class 5 injection wells?
Additional information about Class 5 wells is available from EPA Headquarter's Office of Ground Water and Drinking Water website at http://www.epa.gov/safewater/uic/class5/index.html
Does federal authorization by rule or an EPA-issued permit preclude the need to comply with State requirements?
No. The operator of an injection well is required to comply with any applicable State requirement in addition to complying with federal UIC regulations.