In late July, the US Environmental Protection Agency (EPA) proposed new federal requirements under the Safe Drinking Water Act for the underground injection of CO2 for the purpose of long-term underground storage (a.k.a. or geologic sequestration [GS]). The objective of the regulation is to ensure underground sources of drinking water are protected from activities related to CO2 injection.

Because GS is of interest to our industry, so are the newly proposed requirements.

According to the announcement, this proposal applies to “owners or operators of wells that will be used to inject CO2 into the subsurface for the purpose of long-term storage.

It will also affect state agencies that choose to administer the program in the future.”

In short, the proposed rule would establish a new class of injection well – Class VI – as well as technical criteria for geologic site characterization, to include:

  • Area of review and corrective action;
  • Well construction and operation;
  • Mechanical integrity testing and monitoring;
  • Well plugging;
  • Post-injection site care; and
  • Site closure for the purposes of protecting underground sources of drinking water.

The proposal also includes public participation requirements that would be associated with issuing permits for GS wells.

When finalized, the EPA says, “The GS rule will provide certainty to industry and the public about requirements that would apply to GS by providing consistency in requirements across the nation and transparency regarding the requirements that apply to owners and operators.”

According to the EPA notice, for the past several years, the organization has worked with the Department of Energy (the lead US agency conducting GS field research) to monitor the progress of pilot GS projects. Since 2005, the DOE has held seven workshops to discuss technical issues associated with GS. There have also been two public stakeholder meetings during that time frame to identify and discuss questions relevant to the effective management of CO2 GS. The EPA reports that more than 200 stakeholders attended these events. They represented a broad range of interests, the EPA statement says, including government, industry, public interest groups, and the general public.

The EPA also worked closely with four state co-regulators affiliated with the Ground Water Protection Council and the Interstate Oil and Gas Compact Commission.

The proposed rule, supporting information, and information on how to comment on the proposal are available on the EPA Web site http://www.epa.gov/safewater/uic/wells_sequestration.html.