(413c) Overview of the UIC Class VI Permit Application for San Juan Basin Carbonsafe Phase III Project

The San Juan CarbonSAFE Phase III project is one of five large scale CO₂ sequestration CarbonSAFE projects sponsored by the U.S. Department of Energy. The primary objective of this project is to perform a comprehensive commercial-scale site characterization of a storage complex located in northwest New Mexico to accelerate the deployment of integrated carbon capture and storage (CCS) technology at the San Juan Generating Station (SJGS), an 847 MW coal-fired electricity generation station in San Juan County, New Mexico. A great achievement by the project completion is to prepare and submit application and obtain a permit for Underground Injection Control (UIC) Class VI to construct injection facility from the US Environmental Protection Agency (EPA), thus for approval according to 40 CFR 40 CFR Part 146 to qualify for the tax credit in section 45Q of the federal Internal Revenue Code.

The USEPA promulgated federal requirements under the Safe Drinking Water Act for the underground injection of carbon dioxide in 2010 establishing a new class of injection wells (Class VI). The San Juan Basin (SJB) CarbonSAFE project team will apply the Class VI well permit directly from the EPA Region 6. Tremendous preliminary studies are required for this permit preparation process, which includes not only the detailed site characterization pre-construction phase of the Class VI well, but also the Testing &Monitoring plan and Corrective Action Plan during and after the CO2 injection well operating period.

Currently in the Characterization stage of this project, the SJB CarbonSAFE team, consisting of five universities, three national laboratories, service companies, and operating partners, is investigating and characterizing the site suitability to inject and store CO2 in saline storage reservoirs in San Juan Basin. The targeted CO2 storage formation complex includes the Slick Rock Member of the Jurassic Entrada Sandstone, the Bluff Sandstone, and the Salt Wash Member of the Jurassic Morrison Formation. A characterization well will be drilled to collect information on storage reservoirs and confining systems including petrophysical, mechanical and fluid properties of the system. Additional seismic and outcrop data will be collected to improve understanding of local structural geology. New and legacy data will be used to build a comprehensive data set of formation characteristics for development of more accurate geologic models. Numerical models will be constructed to predict the behavior of CO₂ in the reservoir, the impact of injection on caprock competence, and the potential injection-induced seismicity for the proposed life of the injection project. The project has acquired multiple data sets for site characterization, reservoir and caprock characterization, geological modeling, and simulation model. All the results will feed to the UIC Class VI permit application, to ensure the UIC Class VI well permit application will meet all requirements of 40 CFR 146.8 and those parts referenced therein. This paper will provide an overview of the work accomplished on the UIC Class VI permit application process by the team and some lesson learned via the permit application package preparation.

The success of the UIC Class VI permit application will achieve positive outcomes to encourage the New Mexico state or Navajo tribal agency to apply for and obtain primary responsibility to implement the Class VI program, otherwise known as primacy in compliance with federal and state regulations. Meanwhile, it will also stimulate the interest from the industry getting involved into the large number of carbon storage and thus accelerate the permit review process from EPA. From an economic perspective, it plays a critical role in keeping SJGS and the San Juan Coal Mine in operation, and in continuing operation of one of the biggest sources of income and revenue for the greater Four Corners area in US.

The work performed as part of the DOE project “San Juan Basin CarbonSAFE Phase III: Ensuring Safe Subsurface Storage of Carbon Dioxide in Saline Reservoirs” (DE-FE0031890).