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Policy and Regulation of Class VI wells for Carbon Capture and Storage Projects

Joshua Regorrah holds a B.S. degree in Geology and a B.S.E.D. in Secondary Composite Science from the University of North Dakota. Josh joined the Environmental and Energy Research Center in the Summer of 2020 as a Permitting and Regulatory Specialist, concentrating in the creation and submission of Class VI Storage Facility Permits along with other regulatory considerations involving salt storage, produced water, and CCUS projects. Josh’s previous experience includes time spent as a wellsite geologist for Neset Consulting in the Williston Basin for close to 2 years, with mud logging experience on Three Forks and Bakken horizonal oil and gas wells. Catherine Stevens has a BS in mechanical engineering with over 25 years of experience in the petroleum field, She managed several projects from project management to wellsite engineering, spanning all areas from project feasibility to field reclamation, drilling, completions, production, workovers, salt water commercial injection and disposal wells, produced water treatment, Enhanced Oil Recovery, extensive regulatory from federal to county agencies, and CO2 storage sequestration now with the EERC Efforts to mitigate global climate change through the reduction of carbon dioxide (CO2) in the atmosphere instigated a strategy to sequester CO2 into subsurface geologic formations. The United States Environmental Protection Agency (EPA) established the Underground Injection Control (UIC) Program for Carbon Dioxide Geologic Sequestration Wells in 2010, referred to as the Class VI rule. The Rule established the EPA as governing administrative body of a new class of injection wells (Class VI) and set minimum federal technical criteria for the purpose of protecting underground sources of drinking water (USDWs) and to meet the evergreen climate changes. With the EPA authority over Class VI wells, states such as North Dakota and Wyoming, promptly began the process to gain primacy to regulate and administer Class VI well permits by individual states. In April 2018, North Dakota gained primacy and has approved three Class VI storage facility permits, demonstrating the State’s rapid progression for Carbon Capture and Storage (CCS) projects. In September 2020, Wyoming Department of Environmental Quality received primacy enforcement responsibility for UIC Class VI wells. Other states across the country are in pursuit of primacy. Class VI well permits, along with CCS projects, are accumulating across the states, with North Dakota currently regulating more than half of active Class VI well permits in the United States. It is essential for business ventures to clearly understand the dynamics of the regulatory rules and policies for future Carbon Capture and Storage projects.