A project to accelerate deployment of carbon capture, utilization and storage (CCUS) at San Juan Generating Station
About this Project
San Juan Basin CarbonSAFE Phase III: Ensuring Safe Subsurface Storage of CO2 in Saline Reservoirs is a project being conducted under a Department of Energy (DOE) cooperative funding agreement. The project led by the New Mexico Institute of Mining and Technology will perform a comprehensive analysis of a site in northwest New Mexico to accelerate deployment of carbon capture, utilization and storage technology at San Juan Generating Station. The data and analyses produced under the agreement will be used to prepare, submit and attain a permit from the Environmental Protection Agency to construct Class VI wells (CO2injection wells) that would allow for geologic sequestration of 50 million metric tons of CO2 at a site near the power plant.
Requirements for Class VI wells
EPA developed specific criteria for Class VI wells:
- Extensive site characterization requirements
- Injection well construction requirements for materials that are compatible with and can withstand contact withCO2 over the life of a geologic sequestration project
- Injection well operation requirements
- Comprehensive monitoring requirements that address all aspects of well integrity,CO2 injection and storage, and ground water quality during the injection operation and the post-injection site care period
- Financial responsibility requirements assuring the availability of funds for the life of a geologic sequestration project (including post-injection site care and emergency response)
- Reporting and recordkeeping requirements that provide project-specific information to continually evaluate Class VI operations and confirm underground sources of drinking water protection
Class VI Well Permit Application Sections
Class VI permit applications contain a wide range of information, including geologic data, an AoR delineation based on computational modeling, a financial responsibility demonstration, proposed project plans, proposed well construction plans and schematics, a planned pre-operational testing program, and proposed operating data [40 CFR 146.82(a)]. In addition, some permit applicants may need to submit supplemental information related to injection depth waivers [40 CFR 146.95] or aquifer exemption expansions [40 CFR 144.7].
All of this information is inter-related, and the information collected to meet one requirement may inform or be informed by other required submittals or analyses. Therefore, permit writers should ensure that, collectively, all of the information in the permit application is consistent and supports a determination of site-suitability. This necessitates a multi-disciplinary, team-based approach to the permit application review.
Source: Environmental Protection Agency. (2018, January). Geologic Sequestration of Carbon Dioxide Underground Injection Control (UIC) Program Class VI Implementation Manual for UIC Program Directors. Page 54. Retrieved from https://www.epa.gov/sites/production/files/2018-01/documents/implementation_manual_508_010318.pdf
Class VI permit applicants must provide extensive information about the local and regional geology and hydrogeology of the proposed site [40 CFR 146.82(a)(2),(3),(5),(6)]. The purpose of the UIC Program’s evaluation of this information is to inform a...
Area of Review (AoR) and Corrective Action
The Class VI Rule requires owners or operators to develop and submit an AoR and Corrective Action Plan as part of their permit application [40 CFR 146.82(a)(4),(13); 146.84(b)]. The plan must document the owner or operator’s compliance with the AoR delineation...
Financial Responsibility Demonstration
Class VI permit applicants must submit information to demonstrate financial responsibility for corrective action, injection well plugging, PISC and site closure, and emergency and remedial response [40 CFR 146.82(a)(14); 146.85(a)]. The purpose of the UIC...
Well Construction and Operation
Class VI permit applicants must submit proposed schematics and construction procedures for the injection well [40 CFR 146.82(a)(11),(12); 146.86]. The purpose of the UIC Program’s evaluation of well construction information is to ensure that the injection well...
Pre-Operational Testing Program
Permit applicants must submit a proposed pre-operational formation and well testing program that describes how they will test the well and analyze the chemical and physical characteristics of the injection and confining zones [40 CFR 146.82(a)(8); 146.87]. The...
Testing and Monitoring
The Class VI Rule requires Class VI permit applicants to develop and implement a comprehensive testing and monitoring plan for their projects that includes injectate monitoring, corrosion monitoring of the well’s tubular, mechanical, and cement components, mechanical...
Injection Well Plugging
Class VI permit applicants must submit a plan to plug the injection well in a manner that protects USDWs [40 CFR 146.82(a)(16); 146.92]. The purpose of the UIC Program’s evaluation of the proposed Injection Well Plugging Plan is to ensure that the proposed...
Post-Injection Site Care (PISC) and Site Closure
Class VI permit applicants must submit a PISC and Site Closure Plan that outlines the proposed post-injection monitoring strategies and how non-endangerment of USDWs will be ensured throughout the PISC phase [40 CFR 146.82(a)(17); 146.93]. The applicant may also...
Emergency and Remedial Response
The Class VI Rule requires owners or operators to develop and maintain an Emergency and Remedial Response Plan that describes actions to be taken to address events that could potentially cause endangerment to a USDW during the construction, operation, and PISC phases...