BY: Tariq Siddiqui Upstream EP Advisors LLC
As Carbon Sequestration (CCS) projects surge in the Texas Gulf Coast region, with 76 Class-VI injection permits filed in Louisiana and 45 in Texas, a crucial question arises: Are CCS project developers and service providers prepared to meet the stringent requirements set by the EPA’s UIC program for Class VI permits? This article explores how project developers and service providers can navigate these challenges effectively.
The EPA/UIC program acknowledges the complexity of Class VI permitting, which spans geology, engineering, modeling, and more. A collaborative team approach—combining in-house expertise and third-party support—is vital to meet these multifaceted requirements.
PROJECT DEVELOPMENT PHASES
Initiation & Communication: Notify the EPA/UIC Program Director and assemble a multidisciplinary team.
Site Screening, Selection & Characterization: Gather and assess data to demonstrate adequate capacity, injectivity, and containment of CO2.
Regulatory Requirements: Comply with EPA’s Class VI Rule (40 CFR 146 Subpart HH), covering everything from siting criteria to post-injection care (40 CFR 146.82 -186.95)
KEY PROJECT PLANS:
Area of Review & Corrective Action Plan
Injection Well Plugging Plan
Post-Injection Site Care & Closure Plan
Emergency & Remedial Response Plan
These plans must be submitted for EPA/UIC approval, ensuring they align with site-specific data. Once approved, they become enforceable under the Class VI permit.
EPA/UIC PROGRAM REVIEW PROCESSS
The EPA’s review process is iterative. For example, it is possible that not all information needed to make a final permitting decision will be available when the permit application is submitted. Therefore, the UIC Program is encouraged to identify uncertainties to be addressed via required pre-operational testing and/or through permit conditions.
Process has two main steps in each phase:
Receiving Information & Confirming Completeness
Conducting Technical Evaluations
Given the evolving nature of Class VI projects, developers and service providers must maintain adaptability and prepare for ongoing dialogue with the EPA.
THE WAY FORWARD
To succeed in the competitive Gulf Coast CCS market, developers and service providers must not only understand regulatory requirements but also adopt a clear strategy, sound business model, risk management, stakeholder engagement and a road map. Achieving success requires developing the necessary technical and operational capabilities to meet the challenges of Class VI projects.
The UEPA : Navigating CCS Complexity for Client Success
For your next CCUS project, trust the expertise of UEPA. With our in-depth knowledge of CCS project development, we offer precise and efficient support for your project. Our comprehensive services cover the full lifecycle of project development and reservoir characterization, ensuring successful Class VI permit applications. Partner with UEPA to ensure your CCUS project is executed smoothly and sustainably.
Comentarios