Decoding Class VI Permits: Clear & Simple Guide

By Tariq Siddiqui

In this article, we provide an overview of the application process for obtaining a Class VI well permit for CO2 injection for geologic storage under the Underground Injection Control (UIC) program. Our previous article, "Class-VI Injection Well: Tips For CO2 Project Developers," highlighted the EPA’s six injection classes managed through the UIC program, offering tips for CCS storage project developers focused on Class VI wells.

Carbon dioxide geological storage is a component of overall CCS projects, which involves capturing produced CO2 from emitters, compressing and transporting it in supercritical liquid form, and injecting it into subsurface geological formations for storage. The title slide illustrates the lifecycle stages of geologic storage projects:

1. Site Selection & Characterization

2. Application and Permitting

3. Pre-Injection

4. Injection

5. Closure Period

6. Post-Closure

Obtaining an EPA Class VI injection well permit can be a complex and time-consuming process. In the U.S., the states that lack primacy to issue Class VI permits may experience a federal EPA application process that takes 3-4 years, compared to 8-10 months in states with primacy (such as North Dakota, Wyoming, and recently Louisiana).

The following outline provides an overview of the key steps necessary for securing the permit:

1. Characterize the geologic setting of the storage site.

2. Prepare the Area of Review delineation and a corrective action plan.

3. Provide evidence of financial responsibility.

4. Submit the proposed well construction schematic.

5. Prepare a pre-operational testing plan.

6. Describe the proposed operational conditions.

7. Prepare proposed testing and monitoring (MVA) plans.

8. Prepare the proposed injection well plugging plan.

9. Prepare the proposed emergency and remedial response plan.

10. Prepare the injection depth waiver application.

11. Apply to expand the areal extent of the Class II aquifer exemption.

This list is not exhaustive but serves as a guide. The application for a Class VI CO2 injection well permit is part of the broader geologic storage development lifecycle, similar to an oil and gas Field Development Plan (FDP). Geologic storage of CO2 requires a Site Development Plan (SDP) that encompasses site characterization through site closure and post-closure monitoring periods. Upstream EP Advisors (UEPA) can assist CCS project developers in navigating the complexities of storage project development.

Readers are also encouraged to read our blogs from Upstream EP Advisors

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Decoding Class VI Permits: Clear & Simple Guide

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