UNDERGROUND INJECTION CONTROL (UIC) CLASS VI PERMITTING LESSONS FOR CARBON STORAGE

From 2003 to 2021, the Midwest Geological Sequestration Consortium, one of the original seven U.S. Department of Energy’s (USDOE) Regional Carbon Sequestration Partnerships, partnered with the Archer Daniels Midland Company (ADM) and Schlumberger Carbon Services to demonstrate the first bio-energy carbon capture and storage (BECCS) project, Illinois Basin – Decatur Project (IBDP), for large-scale deep saline geologic storage of one million tons of CO₂. The IBDP was conducted at the ADM plant location in Decatur, Illinois. In addition, ADM conducts the Industrial Carbon Capture and Storage (ICCS) Project administered by the USDOE. The ICCS project is designed at an industrial-scale facility by injecting ~one million tons of CO₂ annually (3,000 tons/day). The ICCS and IBDP obtained the only two Class VI permits issued to date for wells operated under the U.S. Environmental Protection Agency (USEPA) Class VI underground injection control program. The IBDP injection well was initially constructed with a Class I permit issued by the Illinois Environmental Protection Agency before the USEPA promulgated the Class VI program. The IBDP Class I permit was then converted to a Class VI permit issued by the USEPA only after CO₂ injection had ceased, covering the post-injection site care period.

This presentation highlights some of the important lessons learned through the permit application and issuance process for these Class VI permits as well as the four Class VI permits issued to the FutureGen 2.0 project for wells that were not constructed. The lessons learned by the permit applicants as well as the permit application reviewers and permit writers reflect the novelty of geologic sequestration permitting under the Class VI regulations promulgated in December 2010 and the parallel challenges of developing, applying, and complying with the policies and procedures necessary to implement those regulations. Lessons learned can assist future applicants and the permit issuer to understand what is necessary and sufficient to comply with the requirements. The lessons also show how early discussions between applicants and reviewers can start permitting on the right track and how communications throughout the permitting process can avoid misunderstandings and unnecessary delays.