This comment letter response contains two parts:

(1) The original submittal from the commenter.

(2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the

original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA

‐ assigned comment code; and an

individual response. These are described and explained below.

• The data base contains Comment text from the letters submitted by commenters.

Many hard copy letters were scanned into electronic format for inclusion in the data

base. As a result, there may be some typographical errors attributable to optical

character recognition issues. However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and

appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique

Comment ID. Additionally, one or more Comment Codes (i.e., unique topic area ID) was

assigned to each discrete point raised by a commenter. This information was added to

the data base. To inform final rulemaking decisions, all comments and information

received on a given topic were reviewed by technical experts in each rule area (e.g., on

construction requirements).

• Following decisions on the final rule requirements, Individual responses were drafted

by topic area to ensure completeness and consistency of the responses with the final

rule and other responses to similar comments. Each discrete point made by a

commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.

Each letter response is a compilation of each comment and its individual response,

compiled in the order of the original comment letter. As a result of this process, there is

repetition in the response text. The Agency believes this approach ensures completeness

and attention to each comment letter that was submitted.

• All comments in a topic area were reviewed, evaluated, and responded to concurrently.

Responses on each topic area are compiled and are also available in the rulemaking docket.

### 15 -Q ` 3 %~

December 24, 2008

Water Docket

Docket ID No

. EPA-HQ-OW-2008-0390

Environmental Protection Agency, Mailcode : 2822T

1200 Pennsylvania Ave

., NW

., Washington, DC 20460

RE : Review

of EPA's proposed Rule for Geological Sequestering

- Carbon Dioxide

Dear EPA

: 

# JAN 0 8 2009

The Connecticut Department of Public Health, Drinking Water Section offers the following comments concerning

EPA's 2008 proposed Rule for Geological Sequestering of Carbon Dioxide :

1

. In order to ensure long term drinking water quality for the state of Connecticut's numerous sources of

public drinking water, more information needs to be obtained prior to implementation of the proposed

rule

. Given the state's small size, density of population and distribution of existing and potential public

drinking water sources, implementation of the proposed rule without finther evaluation of potential public

health and drinking water quality impacts would not be recommended at this time

. 2 : The proposed rules should be limited in the scope of its geographic coverage to areas that provide the

greatest potential for sequestration of Carbon Dioxide, in terms of both the amount of sequestered and

storage suitability

. 3

. Unintended consequences should be anticipated, and therefore more time to characterize these

consequences should be allowed

. Given the unknown factor of time on the reliability of sequestering

activities, the time required for these activities should be extended to insure there are no unintended

consequences

. Furthermore a period of assessment should be provided between the validation phase and

deployment phase

. Currently these two phases overlap

. To that end, it is recommended that more

extensive studies should be performed to indicate the impact of leakage on sources of public drinking

water in order to minimize the impact to public health

.

Thank you for the opportunity to provide comments

. Any questions please contact me at 860-509-7333

.

Lon't .-Giathieu

Public Health Services Manager

Drinking Water Section 

# STATE OF CONNECTICUT

DEPARTMENT OF PUBLIC HEALTH



# DEC ;3a M

Cc : D

. Mason, ASDWA

Lee Whitehurst, EPA HQ

EPA Admin efile

Phone :

Telephone Device for the Deaf (860) 509-7191

410 Capitol Avenue

- MS #

.' PO

. Box 340308 Hartford, CT 06134

A,~j''innative Action /An Equal Opportunity EmployerLetter ID: 0283

Commenter: Lori Mathieu

Organization: Connecticut Department of Health

Letter ID: 0283 Comment ID: 25296 Letter Lines: 36 to 42

Comment Code: 1650 1.3.5 Human health impacts

Comment: 1. In order to ensure long term dr inking water quality for the state

of Connecticut's numerous sources of pub lic drinking water, more information

needs to be obtained prior to implemen tation of the proposed rule. Given the

state's small size, density of populatio n and distribution of existing and

potential public drinking water sources , implementation of the proposed rule

without further evaluation of potential publ ic health and drinking water quality

impacts would not be reco mmended at this time.

Individual Response: EPA believes that sufficient data and experience curre ntly exist to

develop regulations for Class VI wells. The GS rulemaking builds upon decades of knowledge

about safe injection practi ces regulated by the UIC Program. While developing the GS

regulation, EPA has evaluated rele vant GS research, including projects conducted by the seven

Regional Carbon Sequestration Pa rtnerships (RCSPs) funded by DOE and coordinated through

the National Energy Technology Laboratory (NETL) , and several international projects.

In response to the commenter’s concerns about inj ection in their state, EPA notes that if a state

has primacy for the Class VI program it may choos e to ban Class VI wells altogether or put

additional limitations or c onstraints on its usage.

Letter ID: 0283 Comment ID: 25297 Letter Lines: 44 to 46

Comment Code: 3100 2.1 Proposed Geologic Siting Requirements (40 CFR 146.83)

Comment: 2: The proposed rules should be limited in the scope of its geographic coverage

to areas that provide the greatest potential for seques tration of Carbon Dioxide,

in terms of both the amount of se questered and storage suitability.

Individual Response: EPA believes that a detailed geologic al site characterization (required

under §146.82) is essential to ev aluating the presence and adequ acy of the various geologic

features necessary to receive and confine inje cted CO2 for GS. The requirements for geologic

site characterization are base d on a long standing UIC regulatory framework developed to

address specific risks to USDWs posed by injection. The Clas s VI GS requirements are tailored

so that they are appropriate for the unique nature of injecting large volume s of CO2 into a variety

of geological formations for long-te rm storage. However, regardless of the history of the site, the

owner or operator must provide to the Director extensive information demonstrating the

adequacy of the site to co ntain the CO2 (§146.82) and ensure protection of USDWs from

endangerment.

1Letter ID: 0283 Comment ID: 25298 Letter Lines: 48 to 56

Comment Code: 1510 1.2.2.3 Need for additional study

Comment: 3. Unintended consequences should be anti cipated, and therefor e more time to

characterize these consequen ces should be allowed. Given the unknown factor of

time on the reliability of sequestering activities, the time required for these

activities should be extende d to insure there are no unintended consequences.

Furthermore a period of assessment should be provided between the validation

phase and deployment phase. Currently thes e two phases overlap. To that end, it

is recommended that more extensive studies should be performed to indicate the

impact of leakage on sources of public dr inking water in order to minimize the

impact to public health.

Individual Response: EPA agrees that continued research w ill be integral to development of GS

technology, but disagrees that the Agency should wait for the DOE p ilot studies to be complete

before finalizing the GS rule. EPA believes th at establishing a regulat ory framework for the

future development and deployment of CCS technology protects USDWs from endangerment

and will not impede industry adoption of CCS. EP A published a Notice of Data Availability and

Request for Comment (NODA) on August 31, 2009 (74 FR 44802), in which the Agency

described the results of research at three DOE partnership sites (in Esca tawpa, Mississippi; the

Aneth Field in Paradox Basin, s outheast Utah; and the Pump Canyon Site, New Mexico). EPA

has used the data generated to inform the fi nal rule and will conti nue to monitor ongoing

research. The Agency plans to, every six years, collect and review data on GS projects to

determine whether the appropriate amount a nd types of information and appropriate

documentation are being collected, and to determ ine if modifications to the requirements are

appropriate or necessary.

EPA believes that the ability to safely deploy CCS on a commercial-scale has been proven. EPA

is monitoring international GS efforts currently operating on a commercial scale. These include

the Sleipner Project in the No rwegian North Sea (operating si nce 1996); the Weyburn ER project

in Saskatchewan, Canada (since 2000); the In Salah Gas Project in Algeria (since 2004); and

Snohvit, also in offshore Norway in the Barents Sea (since 2008). Other projects EPA is tracking

include Gorgon and Otway (in Australia); Ketzin (in Germany); Lacq (in France); and CarbFix,

(in Iceland). These projects are designed to opera te for decades and plan to cumulatively inject

over 200 MT of CO2. A paper summarizing EPA's research on international GS projects and

legislation is in the rulemaking docket.

2