Deliberative draft

— do not cite, quote, or distribute Page 1 Notes of National Drinking Water Advisory Council (NDWAC) Webinar on EPA’s Proposed Geologic Sequestration (GS) Rule November 6, 2008

Veronic a Blette welcomed the Co uncil and explained that the Webcast was a follow

- up to an overview of the rulemaking pr esented at the June NDWAC meeting. Because the proposed GS rule was still being written at the time , EPA was not able to provide details, and committed to a more detailed presentation of the rule before the NDWAC meeting on November 19

- 21and the November 24 close of the public comment period for the proposed GS rule

. Ms. Blette explained that , following a presentation b y Steve Heare on the proposed rule, me mbers of the NDWAC would be given time to ask questions and comment. Following that, members of the public wer e invited to submit comment s . Presentation/Overview of Proposed Requirements Steve Heare outlined the proposed requirements for siting, construction, operation, monitoring and testing, and plugging and post

- injection site care for wells used to inject CO 2 for the purpose of GS to protect underground sources of drinking water (USDWs)

. (See attached presentation.) Mr. Heare also outlined the comments raised during two public hearings on the proposed rule ( held on September 30, 2008 in Chicago, IL and on October 2, 2008 in Denver, CO)

. C omment er s raised the following issues at the hearings : **•** Grandfathering existing wells for GS.
**•** Conversion of Class II wells t o Class VI wells, particularly where GS is conducted concurrently with enhanced oil reco very ( EOR ) to assur e that GS does not negatively affect Class II activities.
**•** The proposed approach to defining the Area of Review (AoR) for GS projects.
**•** Whether to allow injection of CO 2 above or between USDWs for GS.
**•** Pros and cons of pre scriptive vs. site

- specific monitoring requirements

. **•** The duration of the post

- closure monitoring period, in particular that EPA ’s selection of 50 years appears to be arbitrary.
**•** The importance of public participation and transparency in decisions related to GS.
**•** The source an d sufficiency of funding for permitting activities.
**•** Allowing states to have primacy for Class VI wells only.
**•** EPA should adopt a holistic approach to addressing climate change, rather than adopting “piecemeal” requirements. Following his presentation, Mr. Heare , Lee Whitehurst , and Ann Codrington of the rule development team fielded questions from Council members. How many comments have been submitted ? To date, EPA has received 37 submissions (including comments and attachments) from 17 unique commenters.Deliberative draft

— do not cite, quote, or distribute Page 2 Will post
- injection site care include CO 2 plume monitoring? EPA is proposing that operators monitor all aspects of the project until it can be demonstrated that there is no further threat to USDWs. This would include monitoring the CO 2 plume

. As new m odels are developed, will operators be required to use them ? There is no specific provision for this in the proposed rule (although the rule would not preclude the use of newly developed models) . Any deci sion to re

- model the site woul d be at the Dire ctor’ s discretion and be addressed during the reevaluation of the AoR. Does the rule include provisions for involving local governments? There is no specific language for this at the moment. Does the rule address future non

- GS wells in the AoR? The permit t ee is required to demonstrate that they will have surface access to the whole AoR during the entire life of the project (including the post

- closure monitoring period ). Future wells in the AoR may not interfere with this requirement. What would happen if other entities want ed to site injection well s in the AoR? There are no specific provis ions for this in the proposed rule ; however, anyone wanting to inject in the AoR of the GS project would likely work with the same permit ting authority , so the GS projec t would be addressed during the AoR evaluation for the future project. Ha s EPA received any new input regarding GS in shales and coal seams ? EPA has not received any comments about these formation types so far. The proposed rule focuses on the process f or safely siting, constructing, operating, and closing GS wells, regardless of the formation type. Well casing integrity is critical to protecting U S

DWs

. How will GS wells withsta nd the high pressures and c orro sivity associated with GS? Well constructio n and monitoring requirements are the cornerstone of UIC protections. The proposed GS rule provides additional protection to address CO 2 injection for GS, including enhanced casing requirements and continuous internal mechanical integrity testing

. Do pr imacy state permit write rs have the technical capacity to write permits for these very complex projects ? P ermit writing will require adequate staff, training, and funding. Since most GS is being conduced at DOE pilot projects now, this is no t a concern ye t . H owever , EPA recognizes that it is a significant concern for many people and implementation issues will be the focus of future work. Is compliance with NEPA (or state equivalents ) incorporated into the Class VI permitting process? I f a project is fed erally funded, it is subject to NEPA requirements. This question will be addressed further. Who is liable if an earthquake damages the well? Should modeling of the site account for seismicity? The proposed rule requires that the owner/operator provide i nformation on the seismic history of a proposed injection site and demonstrate to the Director’s satisfaction that GS would not induce a seismic event. In the case of unrelated earthquakes, the owner/operator isDeliberative draft

— do not cite, quote, or distribute Page 3 still liable if damage associated with the CO 2 was to occur , but this is under consideration at the moment. Who is responsible for financing closure and post

- closure activities? The UIC regulations require the owner/operator of a well to demonstrate financial a bility f or well closure and re medi ation activities. EPA proposes that the owner/operator of a Class VI well also demonstrate an ability to finance post

- injection site care , site closure, and emergency response

. EPA solicited comments on financial responsibility issues in the proposed rule

. Public Comment Session EPA invited non - Council participants on the call to provide comments on the proposed GS rule. Steve Via, American Wa ter Works Association ( AWWA ) said that AWWA believes that more research is needed before the propos ed GS rule is finalized and implemented. AWWA’s s pecific concerns or suggestions include:
**•** Prohibiting injection of CO 2 above the lowermost USDW.
**•** Protecting lower quality aquifers that may serve as drinking water source s in the future, even if they are not currently ca tegorized as USDWs.
**•** Protecting beneficial uses by preventing impairment.
**•** Requiring subsurface monitoring to prevent and respond to USDW contamination.
**•** Requiring new, more precise site maps and geologic surveys.
**•** Integrating ongoing research into the final r ule requirements

. While c urrent research indicates that proposed testing will be adequate, this may not remain the case as more is learned.
**•** Requiring a minimum of 50 years of post

- injection site care. Mr. Via added that , while a ction is needed to address climate change, AWWA urges caution so that drinking water sources are not negatively impacted by GS . AWWA ask ed the C ouncil to tell EPA that a science

- based and thorough approach is need for this proposal. Scott Anderson, Environmental Defense Fund , said that t he proposed rule is superior to current regulations; it seems rigorous and science

- based without being burdensome . It is very close to adequately protecting USDWs. Mr. Anderson offered the following concerns and suggestions:
**•** R ewrit e the closure st andard to include a practical, clear, and objective test

. **•** Clearly differentiate between EOR and non

- EOR injections ; incorporate The World Resource s I nstitute’s (WRI) recent guidelines

. **•** M ore complete geomechanical information about injection pressures and r ates is needed . WRI could help with this as well.
**•** Chang e the definition of AoR to focus on the zone of elevated pressure. **•** Specify that injection of CO 2 is not a federally permitted release.
**•** Do not permit i njection to coal seams, basalts, shales, or salt c averns as Class VI wells . There is not enough information to regulate them under Class VI at the moment; they should continue to be permitted as Class V experimental technology wells

. **•** Prohibit interference between injection projects.Deliberative draft

— do not cite, quote, or distribute Page 4 **•** The iterative approac h to monitoring and permit revisions is a positive c omponent o f the proposed rule; there are still some missing elements, however. Emily Fisher, Edison Electric Institute (EEI) , stated that b alancing climate change actions and water quality protection is not a zero

- sum game , and that GS can be performed without risking drinking water

. S he added that site characterization and s ite

- specific permitting are key s to successful GS

. EEI has submitted additional comments to the proposed rulemaking docket. Coun cil Discussion Council members discussed how to move forward to prepare for further discussion of the proposed rule during the November NDWAC meeting . They offered the following observations:
**•** Comments seem to address three themes : initial evaluation/sit e characterization, well integrity during injection activities, and closure surety. Perhaps the Council ’s comments to EPA on the proposed rule should follow this lead

. **•** The AWWA comments are on

- point and should be considered. I s further research ne cessary to meet the pr imary goal of protecting d rinking w ater ?
**•** Local governments (and states without primacy) need to be notified and included early in the permitting process for GS wells

. **•** Technical and financial capacity to issue permits is a big concern. One option is a provision that the operator be required to pay for a n independent assessment by a government

- select ed con sultant

. **•** Given that CO 2 injection wells can be approved in the absence of Class VI regulations (i.e., as Class I wells) , it is important to move forward with the Class VI regulations with an appropriate balance between quick action and striving for perfection.
**•** There should be a periodic review of the rule as new research results become available. A subgroup of NDWAC will talk before the Nove mber meeting to expedite the discussion at that meeting. Perchlorate The Committee spent a few final minutes discussing the perchlorate determination. Since the public comment period for the determination ends on November 10 (before the NDWAC meeting), it may be appropriate to request an extension of the comment period so the NDWAC could decide at the November meeting whether to submit a comment to EPA. The Council decided unanimously to request an extension of the comment period. A letter will be sent to the Administrator, and another NDWAC subgroup will discuss this issue before the November meeting.Deliberative draft

— do not cite, quote, or distribute Page 1 Notes of National Drinking Water Advisory Council (NDWAC) Webinar on EPA’s Proposed Geologic Sequestration (GS) Rule November 6, 2008

Veronic a Blette welcomed the Co uncil and explained that the Webcast was a follow

- up to an overview of the rulemaking pr esented at the June NDWAC meeting. Because the proposed GS rule was still being written at the time , EPA was not able to provide details, and committed to a more detailed presentation of the rule before the NDWAC meeting on November 19

- 21and the November 24 close of the public comment period for the proposed GS rule

. Ms. Blette explained that , following a presentation b y Steve Heare on the proposed rule, me mbers of the NDWAC would be given time to ask questions and comment. Following that, members of the public wer e invited to submit comment s . Presentation/Overview of Proposed Requirements Steve Heare outlined the proposed requirements for siting, construction, operation, monitoring and testing, and plugging and post

- injection site care for wells used to inject CO 2 for the purpose of GS to protect underground sources of drinking water (USDWs)

. (See attached presentation.) Mr. Heare also outlined the comments raised during two public hearings on the proposed rule ( held on September 30, 2008 in Chicago, IL and on October 2, 2008 in Denver, CO)

. C omment er s raised the following issues at the hearings : **•** Grandfathering existing wells for GS.
**•** Conversion of Class II wells t o Class VI wells, particularly where GS is conducted concurrently with enhanced oil reco very ( EOR ) to assur e that GS does not negatively affect Class II activities.
**•** The proposed approach to defining the Area of Review (AoR) for GS projects.
**•** Whether to allow injection of CO 2 above or between USDWs for GS.
**•** Pros and cons of pre scriptive vs. site

- specific monitoring requirements

. **•** The duration of the post

- closure monitoring period, in particular that EPA ’s selection of 50 years appears to be arbitrary.
**•** The importance of public participation and transparency in decisions related to GS.
**•** The source an d sufficiency of funding for permitting activities.
**•** Allowing states to have primacy for Class VI wells only.
**•** EPA should adopt a holistic approach to addressing climate change, rather than adopting “piecemeal” requirements. Following his presentation, Mr. Heare , Lee Whitehurst , and Ann Codrington of the rule development team fielded questions from Council members. How many comments have been submitted ? To date, EPA has received 37 submissions (including comments and attachments) from 17 unique commenters.Deliberative draft

— do not cite, quote, or distribute Page 2 Will post
- injection site care include CO 2 plume monitoring? EPA is proposing that operators monitor all aspects of the project until it can be demonstrated that there is no further threat to USDWs. This would include monitoring the CO 2 plume

. As new m odels are developed, will operators be required to use them ? There is no specific provision for this in the proposed rule (although the rule would not preclude the use of newly developed models) . Any deci sion to re

- model the site woul d be at the Dire ctor’ s discretion and be addressed during the reevaluation of the AoR. Does the rule include provisions for involving local governments? There is no specific language for this at the moment. Does the rule address future non

- GS wells in the AoR? The permit t ee is required to demonstrate that they will have surface access to the whole AoR during the entire life of the project (including the post

- closure monitoring period ). Future wells in the AoR may not interfere with this requirement. What would happen if other entities want ed to site injection well s in the AoR? There are no specific provis ions for this in the proposed rule ; however, anyone wanting to inject in the AoR of the GS project would likely work with the same permit ting authority , so the GS projec t would be addressed during the AoR evaluation for the future project. Ha s EPA received any new input regarding GS in shales and coal seams ? EPA has not received any comments about these formation types so far. The proposed rule focuses on the process f or safely siting, constructing, operating, and closing GS wells, regardless of the formation type. Well casing integrity is critical to protecting U S

DWs

. How will GS wells withsta nd the high pressures and c orro sivity associated with GS? Well constructio n and monitoring requirements are the cornerstone of UIC protections. The proposed GS rule provides additional protection to address CO 2 injection for GS, including enhanced casing requirements and continuous internal mechanical integrity testing

. Do pr imacy state permit write rs have the technical capacity to write permits for these very complex projects ? P ermit writing will require adequate staff, training, and funding. Since most GS is being conduced at DOE pilot projects now, this is no t a concern ye t . H owever , EPA recognizes that it is a significant concern for many people and implementation issues will be the focus of future work. Is compliance with NEPA (or state equivalents ) incorporated into the Class VI permitting process? I f a project is fed erally funded, it is subject to NEPA requirements. This question will be addressed further. Who is liable if an earthquake damages the well? Should modeling of the site account for seismicity? The proposed rule requires that the owner/operator provide i nformation on the seismic history of a proposed injection site and demonstrate to the Director’s satisfaction that GS would not induce a seismic event. In the case of unrelated earthquakes, the owner/operator isDeliberative draft

— do not cite, quote, or distribute Page 3 still liable if damage associated with the CO 2 was to occur , but this is under consideration at the moment. Who is responsible for financing closure and post

- closure activities? The UIC regulations require the owner/operator of a well to demonstrate financial a bility f or well closure and re medi ation activities. EPA proposes that the owner/operator of a Class VI well also demonstrate an ability to finance post

- injection site care , site closure, and emergency response

. EPA solicited comments on financial responsibility issues in the proposed rule

. Public Comment Session EPA invited non - Council participants on the call to provide comments on the proposed GS rule. Steve Via, American Wa ter Works Association ( AWWA ) said that AWWA believes that more research is needed before the propos ed GS rule is finalized and implemented. AWWA’s s pecific concerns or suggestions include:
**•** Prohibiting injection of CO 2 above the lowermost USDW.
**•** Protecting lower quality aquifers that may serve as drinking water source s in the future, even if they are not currently ca tegorized as USDWs.
**•** Protecting beneficial uses by preventing impairment.
**•** Requiring subsurface monitoring to prevent and respond to USDW contamination.
**•** Requiring new, more precise site maps and geologic surveys.
**•** Integrating ongoing research into the final r ule requirements

. While c urrent research indicates that proposed testing will be adequate, this may not remain the case as more is learned.
**•** Requiring a minimum of 50 years of post

- injection site care. Mr. Via added that , while a ction is needed to address climate change, AWWA urges caution so that drinking water sources are not negatively impacted by GS . AWWA ask ed the C ouncil to tell EPA that a science

- based and thorough approach is need for this proposal. Scott Anderson, Environmental Defense Fund , said that t he proposed rule is superior to current regulations; it seems rigorous and science

- based without being burdensome . It is very close to adequately protecting USDWs. Mr. Anderson offered the following concerns and suggestions:
**•** R ewrit e the closure st andard to include a practical, clear, and objective test

. **•** Clearly differentiate between EOR and non

- EOR injections ; incorporate The World Resource s I nstitute’s (WRI) recent guidelines

. **•** M ore complete geomechanical information about injection pressures and r ates is needed . WRI could help with this as well.
**•** Chang e the definition of AoR to focus on the zone of elevated pressure. **•** Specify that injection of CO 2 is not a federally permitted release.
**•** Do not permit i njection to coal seams, basalts, shales, or salt c averns as Class VI wells . There is not enough information to regulate them under Class VI at the moment; they should continue to be permitted as Class V experimental technology wells

. **•** Prohibit interference between injection projects.Deliberative draft

— do not cite, quote, or distribute Page 4 **•** The iterative approac h to monitoring and permit revisions is a positive c omponent o f the proposed rule; there are still some missing elements, however. Emily Fisher, Edison Electric Institute (EEI) , stated that b alancing climate change actions and water quality protection is not a zero

- sum game , and that GS can be performed without risking drinking water

. S he added that site characterization and s ite

- specific permitting are key s to successful GS

. EEI has submitted additional comments to the proposed rulemaking docket. Coun cil Discussion Council members discussed how to move forward to prepare for further discussion of the proposed rule during the November NDWAC meeting . They offered the following observations:
**•** Comments seem to address three themes : initial evaluation/sit e characterization, well integrity during injection activities, and closure surety. Perhaps the Council ’s comments to EPA on the proposed rule should follow this lead

. **•** The AWWA comments are on

- point and should be considered. I s further research ne cessary to meet the pr imary goal of protecting d rinking w ater ?
**•** Local governments (and states without primacy) need to be notified and included early in the permitting process for GS wells

. **•** Technical and financial capacity to issue permits is a big concern. One option is a provision that the operator be required to pay for a n independent assessment by a government

- select ed con sultant

. **•** Given that CO 2 injection wells can be approved in the absence of Class VI regulations (i.e., as Class I wells) , it is important to move forward with the Class VI regulations with an appropriate balance between quick action and striving for perfection.
**•** There should be a periodic review of the rule as new research results become available. A subgroup of NDWAC will talk before the Nove mber meeting to expedite the discussion at that meeting. Perchlorate The Committee spent a few final minutes discussing the perchlorate determination. Since the public comment period for the determination ends on November 10 (before the NDWAC meeting), it may be appropriate to request an extension of the comment period so the NDWAC could decide at the November meeting whether to submit a comment to EPA. The Council decided unanimously to request an extension of the comment period. A letter will be sent to the Administrator, and another NDWAC subgroup will discuss this issue before the November meeting.

### 1 

# U.S. Environmental Protection Agency Office of Ground Water and Drinking Water November 6, 2008 

# Geologic Sequestration of Carbon Dioxide Post Proposal NDWAC Consultation

### 2 

# EPA’s Proposed GS Rule: Outline

 Underground Injection Control (UIC) Program Background

 Geologic Sequestration of CO 2 

#  Proposal Development Process

 The Proposed Rule

 Schedule

### 3 

# UIC Program Background

 The 1974 Safe Drinking Water Act (SDWA; Reauthorized in 1996)

 Federal regulations for protection of Underground Sources of Drinking Water (USDWs)

 USDW defined:

 Any aquifer or portion of an aquifer that contains water that is less than 10,000 PPM total dissolved solids or contains a volume of water such that it is a present, or viable future source for a Public Water Supply System


#  UIC Program regulates underground injection of all fluids

– liquid, gas, or slurry

 Designation as a commodity does not change SDWA applicability

 Some natural gas (hydrocarbon) storage, oil & gas production, and some hydraulic fracturing fluids exempted


#  Existing UIC program provides a regulatory framework (baseline) for the Geologic Sequestration of CO 2

### 4 

# UIC Program Background UIC Well Classes
Class I Class II Class III Class V

### 5 

# UIC Program Background Primacy

 33 States have primary enforcement authority (primacy) for the UIC program; EPA and States share program implementation in 7 States; EPA directly implements the entire UIC Program in 10 states

### 6 

# Carbon Capture and Storage/Geologic Sequestration of CO 2



#  Important terms:

 CCS: Carbon Capture and Storage (includes capture, transport, and injection of carbon dioxide for long term storage)

 GS: Geologic Sequestration (the injection of carbon dioxide for long term storage)


#  GS is one tool that can be used to reduce emissions of carbon dioxide to the atmosphere (there are others)

 CCS is key to meeting the Administration’s climate goals

 GS rule addresses potential endangerment to underground sources of drinking water from CO 2 

# injection activities

 provides consistency across US

 provides transparency that will build public confidence

### 7 

# CO 2 

# Storage Capacity ~3,500+ Gigatons (Gt) CO 2 

# capacity within 230 candidate geologic CO 2 

# storage reservoirs

 Oil and gas reservoirs

 Deep saline formations

 Deep coal seams

 Basalt formations

### 8 

# EPA’s Proposed GS Rule: Rule Development Process

 EPA has developed a Proposed Rule for Geologic Sequestration (GS) of CO 2 

#  Announced October 2007

 Signed & published July 2008

 120 day comment period through November 24, 2008


#  Proposed rule uses Safe Drinking Water Act authorities and revises Underground Injection Control Program requirements for GS

 Priority placed on avoiding endangerment of underground sources of drinking water

### 9 

# EPA’s Proposed GS Rule: 

# Collaboration

 Inter

- and Intra

- Agency Coordination

 Workgroup of ~48 members

 State co

- regulators

 Department of Energy and other Federal Agencies



#  Stakeholder Outreach

 Federal Advisory Committees

 Non

- governmental Organizations

 Industry Groups

 States and Tribes

### 10 

#  Develop proposed rules that would protect underground sources of drinking water under SDWA

 Tailor existing UIC program requirements to unique needs of GS of CO 2 

# for long

- term storage

 Ensure adaptive approach to incorporate new data

 Use existing experience with industrial and enhanced oil/gas recovery injection 

# EPA’s Proposed GS Rule: Goals of the Rulemaking Process

### 11



# Special Considerations for GS

 Large Volumes
 Buoyancy
 Viscosity (Mobility)
 Corrosivity

I 

# EPA’s Proposed GS Rule: Approach to Rulemaking UIC Program Elements

 Site Characterization
 Area Of Review
 Well Construction
 Well Operation
 Site Monitoring
 Post

- Injection Site Care
 Public Participation
 Financial Responsibility
 Site Closure 

# Develop new well class for GS

– Class VI

### 12 

# Basic Requirements

 Injection zone that can accept fluids

 Confining zone (system) above the injection zone, that contains all fluids

 Owners and Operators submit information on the following:

 Structure and stratigraphy

 Seismicity

 Baseline geochemistry
I 

# EPA’s Proposed GS Rule: Site Characterization

Confining Zone

Injection Zone USDWs

### 13 

# Proposed Approach

 Director has discretion to require identification of additional confining zones

 Additional zones may be used for:

 Pressure dissipation

 Monitoring

I 

# EPA’s Proposed GS Rule: Site Characterization

Confining Zone

Injection Zone USDWs

### 14 

# AoR: The region surrounding the project that may be impacted by injection activity 

# Basic Requirements

 Delineate the AoR

 Identify and evaluate all artificial penetrations and other features that may allow upward migration of fluids

 Plug and/or remediate as appropriate

I 

# Workgroup Recommendations: 

# Area of Review EPA’s Proposed GS Rule: Area of Review (AoR)

CO2 plume GS Well

### 15 

# Proposed Approach

 Use computational modeling

 AoR reevaluation at a minimum of every 10 years

I 

# Workgroup Recommendations: 

# Area of Review EPA’s Proposed GS Rule: Area of Review (AoR)

CO2 plume GS Well

### 16 

# Basic Requirements

 Well components engineered to ensure protection of USDWs

 Cased and cemented to prevent movement of fluids into USDWs

 Surface casing and long string casing

 Tubing and packer

I 

# Workgroup Recommendations: 

# Area of Review Area of Review and Corrective Action 

# EPA’s Proposed GS Rule: Well Construction

Annulus Packer Tubing

Long - string casing
Cement Wellhead

Surface casing

### 17 

# Proposed Approach

 Inject below the lowermost USDW

 Long

- string casing cemented in place for entire length

 Surface casing installed and cemented through the base of the lowermost USDW

 Well materials must be compatible with injectate and formation fluids

I 

# Workgroup Recommendations: 

# Area of Review Area of Review and Corrective Action 

# EPA’s Proposed GS Rule: Well Construction

Annulus Packer Tubing

Long - string casing
Cement Wellhead

Surface casing

### 18 

# Basic Requirements

 Procedures to ensure integrity of the well before, during, and after injection

 Injection may not fracture injection zone
 Monitor injection pressure, flow rate and volumes, and the nature of the injected fluid
 Perform mechanical integrity tests

I 

# EPA’s Proposed GS Rule: Well Testing and Operation

### 19 

# Proposed Approach

 Continuous internal well mechanical integrity tests (MIT) and annual external MITs

 Injection pressure should not exceed 90 percent of fracture pressure in the injection zone

I 

# EPA’s Proposed GS Rule: Well Testing and Operation

### 20 

# Proposed Approach

 Determine extent of CO 2 

# movement and associated area of pressure (pressure front)

 Tracking of the plume and pressure front is required, but techniques, frequency, and spatial resolution are not specified

 Surface

- air and soil

- gas monitoring are at the Director’s discretion

I 

# EPA’s Proposed GS Rule: Site Monitoring

Seismic Monitoring Results, Sleipner

### 21 

# Proposed Approach

 Post

- injection site care is set at 50 years; however, it may be modified with a demonstration that the plume has stabilized and the pressure has dissipated sufficiently

 Well

- plugging materials must be compatible with CO 2 

# stream

 Liability stays with the owner/operator

I 

# Workgroup Recommendations: 

# Area of Review EPA’s Proposed GS Rule: Post

- Injection Site Care

### 22 

# Basic Requirements

 Show financial responsibility for well plugging, corrective action, and site closure 

# Proposed Requirements

 Demonstrate and maintain financial responsibility for plugging and corrective action, injection well plugging, post - injection site care, site closure, and emergency and remedial response

I 

# Workgroup Recommendations: 

# Area of Review EPA’s Proposed GS Rule: Financial Responsibility

### 23 

# Basic Requirements

 30

- day comment period for permits following public notice

 Preparation of a responsiveness summary for the public record 

# Preamble seeks comment on

 Appropriate outreach techniques and technologies

 Engaging the public early in permitting process before siting I 

# Workgroup Recommendations: 

# Area of Review EPA’s Proposed GS Rule: Public Participation

### 24 

# EPA’s Proposed GS Rule: Schedule

Activity Milestone Technical Workshops, Data Collection & Analysis Ongoing Stakeholder Meetings December 2007/February 2008 Interagency Review of Proposed Rule Late May

- Early June 2008 Administrator ’ s Signature of Proposed Rule July 15, 2008 Public Comment Period/Two Public Hearings July 25

– November 24, 2008 Notice of Data Availability (if appropriate) 2009 Final UIC Rule for GS of CO 2 

## Late 2010 / Early 2011

### 25 

# Public Comment Period July 25

– November 24, 2008 

# Public Comments

 Inform future publications

 Include data and information

 Address merits of the proposal

 Identify alternatives to proposed approach/methodology

### 26 

# Thank you!
More information about the UIC Program

 EPA Geologic Sequestration of Carbon Dioxide Website

– http://www.epa.gov/safewater/uic/wells_sequestration.html

 Code of Federal Regulations: Underground Injection Control Regulations 40 CFR 144

- 148

– http://ecfr.gpoaccess.gov/cgi/t/text/text

idx?sid=d6ee71a544eca89c533c825135913f13&c=ecfr&tpl=/ec frbrowse/Title40/40cfrv22_02.tpl

 Written comments may be submitted at: www.regulations.gov (docket i.d.: EPA

- HQ

- OW

- 2008

- 0390)