EPA issues Class VI drilling permits in Texas

On September 4, 2024, the EPA announced that it had issued draft Class VI permits to Oxy Low Carbon Ventures LLC for three proposed geologic carbon dioxide (CO) storage wells₂) in Ector County, Texas. These are the first draft permits issued by the EPA in Texas for Class VI wells under the Safe Drinking Water Act (SDWA) Underground Injection Control program, which establishes requirements to protect underground drinking water sources from contamination.

Such wells store CO₂ captured from an emission source or the atmosphere in deep underground boreholes. Located on former ranch land approximately 22 kilometers from the city of Odessa, this project includes three wells that will store approximately 722,000 tons of CO2₂ per year at a depth of about 4,400 feet.

“In developing the draft permit, the EPA required the company to provide a specific analysis of the site to ensure that the construction and operation of the proposed wells continued to protect the environment, including avoiding contamination of underground drinking water sources and man-made seismicity,” said he The agency’s press release says. “EPA evaluated these technical analyzes with the assistance of experts from the Department of Energy’s National Laboratories and additional data to verify that the geology of the site, other nearby subsurface activities, and the project scope and operation would ensure compliance with permitted activities become [SDWA] Requirements. The EPA also required the company to ensure plans are appropriate for conditions at and around the site, including construction materials, mechanical integrity and emergency planning.

“Once approved, Class VI wells require comprehensive monitoring of well integrity, groundwater quality and CO2 emissions₂ Movement. Well operators must also plan for emergencies and plan how the well will be capped after its lifespan. EPA also ensured that the language in the draft permit was clear and enforceable [SDWA] Regulations. During the development of the draft permit, EPA met with local elected officials and emergency responders, community members and property owners to explain the Class VI drilling program, listen to concerns and answer questions.”

The EPA has developed specific criteria under the SDWA to ensure that underground sources of drinking water are protected from CO2₂ stored in Class VI injection wells. These criteria include:

• Site characterization requirements to ensure that the geology in the project area can absorb and contain the CO₂ within the zone in which it is injected, including that the area is free of faults and fractures and that induced seismicity is not a problem.
• Requirements for predicting the extent of injected CO₂ Using computer modeling, you can identify the plume and associated pressure front for the project and identify and address any deficiencies of existing wells in the test area through corrective action. The study area includes the area where the injected cloud and the associated pressure front can impinge on pore fluids.
• Well construction requirements to ensure that the Class VI injection well is constructed to avoid CO₂ that it comes out outside the injection zone. Class VI injection wells and in-zone monitoring wells are designed for the life of the project. Owners or operators must demonstrate that well materials, including casing and cement, are corrosion resistant and compatible with the conditions and fluids to which they may be exposed.
• Testing and monitoring requirements to monitor injection well integrity, groundwater quality and CO movement₂ Cloud and pressure front throughout the entire project period, even after CO₂ Injection is terminated until the permitting authority determines that no additional monitoring is required to ensure that the geologic sequestration project does not pose a threat to underground drinking water sources (USDW).
• Operational requirements to ensure that the injection activity is suitable for the design and geological characteristics of the well so that neither USDWs nor human health are compromised.
• Requirements to close the injection well to prevent fluid movement that endangers USDWs.
• Requirements for the operator to establish and maintain sufficient financial instruments to cover the costs of corrective actions, plugging of the injection well, maintenance of the injection site, and emergency and remedial activities for the geological sequestration project (i.e., financial responsibility).
• Requirements to develop and maintain a site-specific emergency and remediation plan.
• Requirements for the owner or operator of Class VI wells to report all testing and monitoring results to the permitting authority to ensure that the project is operating in compliance with all permitting and regulatory requirements.

These injection wells – when used as part of carbon capture and storage (CCS) and CO₂ CDR projects are a critical tool for reducing carbon emissions to meet mid-century climate goals, according to the EPA.

“C.O₂ is injected through specially designed wells that deposit and store material deep underground in rock formations,” the EPA press release continued. “These formations need to be tested and evaluated to ensure geological formations are suitable for safe containment of CO.”₂ for long-term storage. This technology will create good paying jobs and can be used in an environmentally friendly way.”