EPA's Regulatory Approach : Climate Mitigation via Sequestration of CO2:

by Rob Ferri (EPA - Underground Injection Control)

This presentation has not been reviewed by EPA. The views presented are those of the author and do not necessarily reflect those of the United States Environmental Protection Agency. All commercial products or entities that may have been mentioned or depicted in photographs is implied - all such mention or depiction is for illustrative purposes only.

Background

• CO2 is one of the greenhouse gases which may contribute to global warming and climate change

• It is produced by the burning of fossil fuels, such as oil, natural gas and coal, as well as natural events on Earth

• Reduction of CO2 is being pursued by the federal government as an environmentally-positive measure

• In order to achieve substantive CO2 reductions, only geologic sequestration offers practical technology and the means to emplace very large volumes - Injection Wells

Current Well Classes

Class I Wells deep disposal of manufacturing

process waste, RCRA & radioactive waste

Class II Wells Enhanced oil

recovery by injection of produced brines or

CO2 & crude oil (storage)

Class IV Wells Banned except

as part of an authorized clean-up.

Class V Wells storm water dry wells, cesspools,

geothermal wells, & experimental wells

Class III Wells “solution mining” w/ Injected steam or

water (Morton Salt)

The Underground Injection Control Program regulates well injection and protects Underground Sources of Drinking Water from contaminants injected into the ground by wells. Carbon dioxide can cause harm (acidify) to an aquifer. EPA directly implements the UIC program in NY. NJ Department of Environmental Protection regulates the program in NJ.

Regulatory Dilemma

• Carbon sequestration (CS) wells are classified as Class V experimental wells

• CS wells are regulated as if they were Class I non-hazardous waste wells

• Most experience with carbon sequestration has been as Class II enhanced oil recovery wells

Class II EOR/EGR Wells

• Owner/operators may transition to GS project

• Are authorized under a separate section of the SDWA and are typically regulated by “oil and gas” agencies

• Not effected by this rulemaking so long as the reservoir/field is being produced

• Non endangerment provision for EOR/EGR wells continues to apply

Regulatory Approach

• EPA Administrator convened representatives from EPA, state co-regulators, and the Department of Energy to write new regulations

• The rule proposes minimum federal requirements for GS of CO2 based on the existing UIC regulatory framework

• Proposed rule published July 2008

• Public Hearings - 9/30/08 Chicago & 10/2/08 Denver

I

Proposed Regulations

• Geologic siting (must have a confining zone)

• Area of review and corrective actions (based on modeling)

• Injection well construction (cement & additives must be compatible w/CO2 & of a quality & quantity to maintain integrity over the design life of the project)

• Injection well operation (automatic shutoff valves))

CO2 plume

GS Well

Proposed Regulations

• Mechanical integrity testing (every year)

• Plume and pressure front monitoring (continuous monitoring &

pressure falloff test every five years)

• Recordkeeping and reporting (air and surface monitoring) (semi-

annual reports)

• Well plugging and post-injection care (flush each well with a buffer

fluid & conduct a final MIT)

• Financial responsibility and long-term care. (post-injection care

period)

Rulemaking Background: Scope

The scope of the proposed rule will be limited to authorities under the Safe Drinking Water Act, which requires EPA to develop minimum federal requirements for state and tribal UIC programs to protect underground sources of drinking water (USDWs)

The proposal will not address accounting for climate impacts (e.g. carbon credits or releases to the atmosphere) Confining Zone

Injection Zone

USDWs

Potential Carbon Sequestration Areas

There are enhanced oil recovery wells and depleted oil and gas basins in western NY (suggested for CO2 storage) and deep saline aquifers in southern NJ (that would require more study of the geology).

New Jersey CS Options

• A deep saline aquifer runs through Southern NJ coastal plain

• The only viable location suitable for injection lies offshore, where the aquifer deepens, and has a secure confining layer and other geologic structures to sequester CO2

Depth in Feet of Deep Saline Aquifer Formation

New York CS Options

Best options currently available are to use deep saline aquifers and depleted oil and gas reservoirs in the Southern Tier of the state. Governor Paterson issued a $6 million grant supporting a Coal Plant with CCS in Jamestown NY.