Building an EPA Class VI Permit Application
Authors: Koperna G. , Riestenberg D. , Leierzapf J. , Roth B. , Esposito R. , Sams Gray K. 
Published: April 2023

Summary
To accelerate the commercialization of carbon capture and storage (CCS), the US Department of Energy (US DOE) is building on decades of characterization efforts and pilot-scale projects through their CarbonSAFE program. Administered through their National Energy Technology Laboratory, this program seeks to bring fully integrated projects to the sector that can store more than 50 million tonnes of CO2 over a 30-year period. The program, which was enacted before the enhancement of Internal Revenue Code Section 45Q, is in the capture assessment, characterization, and permitting phase. The objectives of this paper are to discuss (a) the injection permitting requirements of the CarbonSAFE projects; (b) information gathering in support of the permit; (c) the timelines of field development and permit-related activities; (d) the major technical components of the field development plan; and (e) early feedback from the regulators toward acceptance of the permit.
In Mississippi, more than 30,000 acres have been characterized by six deep characterization wells, a deep groundwater well, and 92 line miles of 2D seismic as part of the CarbonSAFE Project ECO2S. During the acquisition of seismic data, all receiver lines were live, which resulted in the generation of a pseudo-3D seismic design. The incorporation of a 3D seismic survey was not included as part of this project due to logistical difficulties presented by the undulating, wooded surface terrain. A suite of openhole geophysical logs was taken from each well, allowing for a detailed interpretation of prospective storage reservoirs and confining intervals to complement the analysis carried out on the 290 ft of a whole core that was cut through the prospective confining zone and storage reservoir. The detailed geologic and reservoir data were assembled and entered into a 3D model to assess the injection capacity and the area of review (AoR). This information fed into the detailed corrective action, monitoring, testing, and postinjection site care (PISC) modeling.
The results have been exceptional. The geologic assessment has revealed three primary storage targets, ranging in depth from 3,500 ft to 6,000 ft. These storage reservoirs net 1,300 ft of sandstone, with mean porosity and permeability of 29% and 3.6 darcies, respectively. Together, these reservoirs have storage capacities that may exceed 20 million tonnes per square mile, making this a gigatonne prospect. Forward modeling of the project resulted in an AoR of 16 sq miles, injecting about 8000 t/d, for 30 years, via two deep injection wells. The excellent confining characteristics of the caprock, relatively simple geologic structure, and lack of historical well drilling activity in this area provide excellent containment of the injected CO2. Based on this work, the project has proposed 20 years of PISC.
To date, only two US CO2 injection permits have been granted. These projects relied on a singular capture point feeding a singular sequestration point (source to sink), and considerations have not been made to garner CO2 emissions from other industrial sources. The Kemper County Storage Complex is a first-of-its-kind storage hub concept that looks to develop an area capable of storing significant quantities of CO2 from the region. Also, this work will show how characterization efforts, geological and numerical modeling efforts, and plan development were constructed in support of permit and incentives acceptance.