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 Employer 
Letter 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 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 further evaluation of potential public health and drinking water quality 

impacts would not be recommended at this time. 

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

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

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

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

Regional Carbon Sequestration Partnerships (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 injection in their state, EPA notes that if a state 

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

additional limitations or constraints 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 sequestration of Carbon Dioxide, 

in terms of both the amount of sequestered and storage suitability. 

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

under §146.82) is essential to evaluating the presence and adequacy of the various geologic 

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

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

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

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

of geological formations for long-term 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 contain the CO2 (§146.82) and ensure protection of USDWs from 

endangerment. 

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Letter 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 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. 

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

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

before finalizing the GS rule. EPA believes that establishing a regulatory framework for the 

future development and deployment of CCS technology protects USDWs from endangerment 

and will not impede industry adoption of CCS. EPA 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 Escatawpa, Mississippi; the 

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

has used the data generated to inform the final rule and will continue to monitor ongoing 

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

determine whether the appropriate amount and types of information and appropriate 

documentation are being collected, and to determine 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 Norwegian North Sea (operating since 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 operate 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. 

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