Geologic Sequestration of Carbon Dioxide under the Safe Drinking Water Act s Underground Injection Control Program

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1 Geologic Sequestration of Carbon Dioxide under the Safe Drinking Water Act s Underground Injection Control Program Ann M. Codrington, Chief, Prevention Branch U.S. Environmental Protection Agency Office of Ground Water and Drinking Water National Conference of State Legislatures July 21,

2 Geologic Sequestration of CO 2 CCS Process Geologic Sequestration Focus 2

3 EPA s Underground Injection Control (UIC) Program The 1974 Safe Drinking Water Act (SDWA) requires EPA to develop minimum federal regulations for state and tribal Underground Injection Control (UIC) Programs to protect underground sources of drinking water (USDW) USDW defined: Any aquifer or portion of an aquifer that contains water that is less than 10,000 PPM total dissolved solids or contains a volume of water such that it is a present, or viable future, source for a Public Water Supply System The UIC program regulates underground injection of a all fluids liquid, gas, or slurry Natural gas storage, oil & gas production, and some hydraulic fracturing are exempt from UIC requirements 3

4 UIC Program Background: State Implementation States may seek primary enforcement authority for the UIC program States must meet specific minimum federal requirements For oil and gas related injection, states demonstrate that their programs are effective States can be more stringent than minimum federal requirements EPA is responsible for implementing the program when states do not 4

5 UIC Program Background: Primacy 33 States have primary enforcement authority (primacy) for the UIC program; EPA shares program implementation in 7 States and two tribes; EPA directly implements the entire UIC program in 10 states 5

6 UIC Program Background Well Classes Class I Class II Class III Class V 6

7 EPA s GS Rulemaking: What are the Risks? CO 2 Corrosivity CO 2 in water can form carbonic acid Acids cause the release of organic and inorganic compounds from the formation Changes in color, odor or taste of water possible Brine displacement Increased pressure could force brine into aquifers Additional Concerns: Long-term behavior of CO2 in the subsurface is not fully understood Abandoned wells & loss of well mechanical integrity are key potential sources of leakage 7

8 EPA s GS Rulemaking: Approach to Rulemaking Special Considerations for GS I Large Volumes Buoyancy Viscosity (Mobility) Corrosivity Develop new well class for GS Class VI UIC Program Elements Site Characterization Area Of Review Well Construction Well Operation Site Monitoring Well Plugging and Post-Injection Site Care Public Participation Financial Responsibility 8

9 EPA s GS Rulemaking: Coordination EPA regulatory workgroup (~48 members) including: EPA Regions and Program Offices Department of Energy (DOE) IOGCC and GWPC State permitting agencies Collaborating with EPA s Office of Air and Radiation (OAR) on policy, technical and cost analyses Attending and Presenting at National Meetings: GWPC, IOGCC, ECOS Consulting with Federal agencies, States, and Tribes: The Bureau of Land Management The United States Geological Survey The Internal Revenue Service Tracking progress of State regulatory and legislative developments on GS Co-funding research with DOE on modeling ground water impacts of CO 2 injection at Lawrence Berkeley National Laboratory 9

10 EPA s Proposed GS Rule: Outreach States Ground Water Protection Council (GWPC) and Interstate Oil & Gas Compact Commission (IOGCC) Industry Groups BP, Shell, Chevron, American Petroleum Institute, Schlumberger, Edison Electric Institute, etc. Non-Governmental Organizations and Water Utilities National Resources Defense Council, World Resources Institute, Environmental Defense, AWWA and others Federal Advisory Committees National Drinking Water Advisory Council (NDWAC) and Clean Air Act Advisory Committee (CAAAC) All Stakeholders technical workshops and public meetings 10

11 EPA s Proposed GS Rule: Selected Requirements Site Selection Injection zone that can accept fluids Confining zone (system) above the injection zone, that contains all fluids plus additional zone if needed Information on geologic structure, stratigraphy, seizmicity and geochemistry Identify and evaluate all artificial penetrations and other features that may allow upward migration of fluids Plug and or remediate as appropriate abandoned wells Use computational modeling Reevaluate Area of Review at a minimum of every 10 years USDWs Confining Zone Injection Zone I 11

12 Workgroup EPA s Proposed Recommendations: GS Rule: Area of Review and Corrective Action Area of Review Selected Requirements I Construction and Operation Engineer well components to ensure protection of USDWs Inject below the lowermost USDW Ensure that well materials are compatible with injectate and formation fluids Monitor internal and external well mechanical integrity Ensure that injection pressure does not exceed 90 percent of fracture pressure in the confining zone Track plume and pressure front Long-string casing Annulus Wellhead Tubing Surface casing Cement Packer 12

13 Workgroup EPA s Proposed Recommendations: GS Rule: Well Closure and Financial Responsibility 50-year Post-injection site care period may be modified with a demonstration that the plume has stabilized and the pressure has dissipated sufficiently Well-plugging materials must be compatible with CO 2 stream Liability stays with the owner/operator Demonstrate and maintain financial responsibility for post-injection site care, site closure, and emergency and remedial response Selected Area Requirements of Review I 13

14 Anticipated Next Steps for GS Rulemaking Technical Workshops, Data Collection & Analysis Stakeholder Meetings Activity Interagency Review of Proposed Rule Administrator s Signature of Proposed Rule Public Comment Period for Proposed Rule Supplementary Publication (if needed) Final UIC Rule for GS of CO 2 Milestone Ongoing December 2007/February 2008 Late May - Early June 2008 July 15, 2008 July 25 December 24, Late 2010 / Early

15 More Information For more information about the UIC Program EPA Geologic Sequestration of Carbon Dioxide Website Code of Federal Regulations: Underground Injection Control Regulations 40 CFR frbrowse/title40/40cfrv22_02.tpl 15