BY Tariq Siddiqui (UEPA)
This quick reference guide is designed for executives overseeing projects that involve CO2 injection under the U.S. Environmental Protection Agency’s (EPA) regulations. For any project seeking a permit for CO2 Injection, it is essential to comply with the Code of Federal Regulations (CFR) 40 CFR §§146.81–146.95. Title 40 of the CFR pertains to the ‘Protection of Environment,’ while Section 146 focuses on ‘Underground Injection Control (UIC).’ Specifically, §§146.81–146.95 outline the requirements and standards for Class VI wells, which are used for CO2 sequestration.
These codes / Class VI rules are:
å146.81: Applicability: Establishes criteria for UIC for CO2 injection in Class VI wells for long-term geologic storage.
å146.82: Required Class VI Permit Information: This section contains the required information submitted to EPA for approval of Class VI permits
3. å146.83: Minimum Criteria for Siting: The project owners must demonstrate that storage site has suitable geologic system, i.e. injection & confining zone.
4. å146.84: Area of Review (AoR) & Corrective Action: AoR is region surrounding injection well that may be endangered by injection activity and perform corrective action in natural or man-made conduits. AoR is delineated by computational modeling.
5. å146.85: Financial Responsibility: The owner or operator must demonstrate and maintain financial responsibility to address endangerment to under Ground Source of Drinking Water (USDW).
6. å146.86: Injection Well Construction Requirement: Owner & operator must ensure well meets special CO2well construction requirement.
7. å146.87: Logging, Sampling, and Testing Requirement Prior to Injection Well Operation: operator must run appropriate logs, surveys and tests prior to inaction, to determine or verify the depth, thickness, porosity, permeability, salinity, lithology and other characteristics to ensure storage compliance
8. å146.88: Injection Well Operating Requirements: Mandates operating requirements including but not limited to injection pressures etc.
9. å146.89: Mechanical Integrity: Owner & operator must demonstrate Mechanical Integrity of injection wells ensuring no leakages in casing, tubing or packer.
10. å146.90: Testing & Monitoring: Owner & operator must comply with testing and monitoring plan during the operation / injection period.
11. å146.91: Reporting Requirements: Owner & operator must provide at minimum reports within specified time (24 hour, weekly, monthly, semiannually etc.).
12. å146.92: Injection Well Plugging: Owner & operator must plug the injection well after the end of the operation as per specified requirement.
13. å146.93: Post-Injection Site Care (PISC): Owner & operator of Class VI well must prepare, maintain, and comply with a plan for post-injection site care and site closure that meets the regulatory requirements
14. å146.94: Emergency & Remedial Response (ERR): Owner and/or operator must provide ERR plan that describes actions the owner or operator must take to address movement of the injection or formation fluids that may cause an endangerment to a USDW during construction, operation, and post-injection site care periods.
å146.95: Class VI Injection Depth Waiver Requirement: Owner and/or operator must seek a waiver if injecting below the lower most USDW aquifer, demonstrating it is laterally continuous and its not a USDW aquifer and a continuous confining zone isolates it with any USDW