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ways. A well with a single casing, for example, may need cementing at only one interval (ems., <br />through the confining stratum which separates the injection zone from the source of drinking <br />water). 'Other wells, which penetrate to greater depths or which involve more than one casing, <br />may need a more elaborate cementing procedure. Because of this range, EPA is proposing the <br />cementing requirement in general terms and intends to leave decision making to Directors' <br />discretion. Directors are instructed in the regulations to take a variety-of factors into account <br />when determining specific cementing requirements for individual wells.28 <br />All new Class II wells will be subject to requirements outlined above. Existing and <br />converted Class II wells need nut meet these requirements if they were subject to regulatory <br />controls at the time they were drilled and they are in compliance with those controls, and <br />injection will not result in the migration of fluids into an underground source of drinking water <br />so as to create a significant risk to the health of persons using the source as drinking water. <br />Similarly, new (newly drilled) wells in existing fields must meet casing and cementing <br />requirements applicable to the field, and cannot allow movement of fluids into an underground <br />source of drinking water if such movement will create a significant risk to health of persons " <br />For Class III wells, all new wells must comply with the requirements discussed above. <br />Existing wells which have long lives, such as salt solution and geothermal wells, must <br />demonstrate mechanical integrity; however, they are not required to meet other casing and <br />cementing requirements. Various considerations underlie this modified approach. <br />As mentioned in the preamble to these regulations, costs played a role: EPA data <br />indicates that compliance for Class II wells equivalent to casing and cementing requirements for <br />Class I wells could generate cos is to the oil industry of more than $20 billion over 5 years ",` <br />Imposing regulatory requirements of this financial magnitude in EPA's view, would interfere <br />with injection of brines or other fluids which are brought to the surface in connection with Oil <br />and natural gas production and with injection for secondary or tertiary recovery of oil or natural <br />gas without being essential to assure that underground sources of drinking water will not be <br />endangered by such injection. Moreover, the imposition of this casing and cementing <br />requirement could be an unnecessary disruption of state UIC programs currently in effect and <br />being enforced in a substantial number of states. <br />28 §§ 146.12(b),(I)-(7); 146.22(b),(1)-(7); 146.32(a),(1)-(7). <br />29 §146.22(b). <br />30 Estimated after discussions with consultants. See generally Cost of Compliance Proposed <br />Underground Injection Control Programs. Oil and Gas Wells, Arthur D. Little, Inc. (June, 1979) <br />("Oil and Gas Wells"). <br />" See generally Underground Injection Control Program Class II Well Incremental <br />Compliance Cost Refinements. Booz, Allen and Hamilton Inc., and Geraghty and Miller, Inc., <br />April 30, 1980. <br />Page 12 of 20