Daisy Gallagher, Geostock Sandia, LLC
CO₂ projects are subject to regulations at the Federal, and in some cases, a State level. As states more states apply and receive primacy, jurisdiction for the permit could change. At a minimum, states will need to develop regulations as stringent as the EPA. Many of the rules for the carbon sequestration Class VI wells have been built upon the established Class I No Migration Land Ban Petition regulations. Understanding these sets of rules and constraints helps for a strong basis for a Class VI Application. The EPA Headquarters have developed a set of templates as an outline to assist in the overall reporting. However, much of the technical work, formatting, additional requirements, and overall planning are left for the permittee to determine. Therefore, approaching a project with a defined strategy reduces timeline constraints, improves the quality of the application, and will reduce long-term costs associated with delayed projects due to application corrections. Permits for Class VI wells can take upwards or more of 2 years to be received. As such, it is critical to approach the application with a proper strategy. A Class VI Permit is considered a “two-step” process. Step 1 – Permit to Drill: will require a demonstration meeting all portions of the regulations, identification of all risks and uncertainties, as well as how these deficiencies will be met and/or tested. The first step has three potential routes that include potential Class V Test Wells to de-risk projects and provide geological data. However, dependent on the site selected, a Class V well may not be warranted. Addressing these uncertainties and developing a protocol and procedure for each technical report in the permitting strategy can determine which path is best suited. Step 2 – Permit to Inject: is issued after all additional information identified in the first step has been obtained and analyzed. The initial Step 1 application and technical report will then be updated. So, developing your Step 1 – Permit to Drill correctly is critical to the final permitting application. The site-specific information used in the Step 2 will identify the final Area of Review for the Plume, as well as for the Pressure front. A phased approach will identify pore space requirements, offset well impacts, and long-term project projections to meet the final Permit to Inject. In summary, a successful Class VI UIC application can be developed based on current experience working with EPA and State regulators and knowing what kind of technical report and documentation they will require. Approaching the application with things in mind, can help reduce the timeline to receive the final permit to inject.