If your CO2 injection project envisage geological storage in a saline aquifer in USA, a Class-VI injection permit is needed. Permitting for a geologic storage is one of the most important and time consuming step in a Carbon Capture & Sequestration (CCS) Project and policy & regulations must be understood before embarking on the project.
Class VI permit for underground CO2 injection is part of Storage Life cycle project. These project stages are:
- Site Selection & Characterization
- Application and Permitting
- Pre-Injection Stage
- Injection Period
- Closure Period
- Post-Closure Period
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.
INSIGHTS
A comprehensive Site Development Plan (SDP) is needed for developing underground geologic storage site, a document similar to Field Development Plan (FDP) needed for the development of hydrocarbon-resources. Specific skills and competencies are needed to develop a Carbon Capture & Storage (CCS) project, the surface and sub-surface skills acquired in oil and gas field development are easily transferable to the CCS development projects with little re-structuring. The biggest challenge for CCS is the the upscaling to commercial level (Technology Readiness Level-11; something that commercial solar farm have achieved globally!).  Capture of CO2 at large scale  and its geologic storage underground requires meeting the regulatory challenges in shorter time. In USA the biggest hurdle can be Class VI well permitting.  States that have primacy in permit approval (N. Dakota, Wyoming and recently Louisiana) have reduced the permit processing time to less than 10 months compared 3-4 years in states that do not have primacy and handled at Federal level by EPA.
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