A variety of projects are being developed in a dozen states: Alabama, California, Florida, Georgia, Kansas, Louisiana, Mississippi, Montana, New Mexico, North Dakota, Texas and Wyoming. “States that have a long history of oil and gas operations and a wealth of subsurface data and technical knowledge are leading the way,” Cowin says. “When a state has regulatory bodies that view utilization and storage projects favorably, and either has or is near ideal geological conditions and/or existing transportation infrastructure, that state is more conducive to this type of development.”
Class VI UIC permitting involves two distinct areas of permitting. Most capital development projects require standard environmental permits that address potential impacts to the environment. Class VI UIC storage requires additional permitting that addresses permanent geologic storage.
A competent seal rock formation must be present to hold the CO2 in place and prevent migration to shallower underground sources of drinking water (USDWs) or other environmental receptors. The porosity and permeability of the host rock is also important because it determines the permissible injection rate and total volume of CO2 that can be stored at a location. Several measures are evaluated to confirm CO2 injection activities won’t endanger drinking water or cause other harmful environmental effects.
Class VI injection well requirements address siting, construction, operation, testing, monitoring and site closure. The regulations focus on the unique nature of CO2 injection and address relative buoyancy; subsurface mobility; CO2 corrosivity in the presence of water; pressure, temperature and volume conditions at various depths; and anticipated injection volumes.
During the permitting process, monitoring requirements that address well integrity, CO2 injection and storage, and groundwater quality (during both the injection operation and post-injection site care period) are reviewed. Financial commitments demonstrating the availability of funds for the life of the project — including emergency response and post-injection site care for up to 50 years — are required. Reporting and record-keeping documents that provide project-specific information are also continually evaluated to confirm USDW protection.
The Power of Partnership
A program designed to protect the public’s drinking water has created many challenges for CO2 storage deployment. But if done right, it has the potential to create abundant jobs, as well as generate billions of dollars in economic growth and infrastructure investment. As a result, speeding up federal approvals, while securing the most optimal environmental and social outcomes, is critical.
“All the public and private money used for new technology and test programs won’t mean anything if permits can’t be secured in a timely manner,” Cowin says. “Systems need to be put in place that allow more storage wells to be developed quicker. But before that can take place, many issues need to be resolved — such as who owns the rights to the land below ground. Having a uniform way to address concerns like this is key if CO2 storage is going to really take off at the rate it needs to.”
In anticipation of the industry ramping up, Cowin notes that industrial producers of CO2 need to have staffers — and/or knowledgeable consultants — who understand the importance of feasibility/design studies; are up to speed on funding sources and incentives; are familiar with environmental regulations; and are knowledgeable about capture and sequestration technology.
To help navigate permitting requirements, reduce costs and speed the process along, hub-and-spoke networks are gaining momentum.
“Hub-and-spoke partnerships are the future,” says John Hesemann, environment department manager at Burns & McDonnell. “High-capital CO2 producers, considered the spokes, are coming together and joining forces with pipeline providers and storage facility partners, the hubs. This helps minimize financial risks and obligations. It just makes good economic sense and is more cost-effective to bring together multiple entities versus doing solo projects."
What would be the largest hub-and-spoke partnership to date is the Houston Ship Channel CCS Innovation Zone project, proposed in 2021 by ExxonMobil. It’s projected this network would inject more than 100 million metric tons of CO2 annually — the equivalent of emissions from 44 million light trucks — beneath the Gulf of Mexico.
The U.S. government is another key partner in carbon storage efforts. The bipartisan Infrastructure Investment and Jobs Act allocates roughly $18.6 billion for CCUS projects. This includes establishing the CO2 Infrastructure Finance and Innovation Act that will provide loans for CO2 transport infrastructure projects. Industry stakeholders hope future legislation will support storage efforts with additional funding, including increases in incentives such as 45Q tax credits.