Observations on Class VI Permitting: Lessons Learned and Guidance Available

The Midwest Geological Sequestration Consortium, one of the U.S. Department of Energy’s Regional Carbon Sequestration Partnerships, partnered with the Archer Daniels Midland Company (ADM) and Schlumberger Carbon Services to conduct the Illinois Basin – Decatur Project (IBDP) in Decatur, Illinois, for large-scale deep saline geological storage of 1 million tons of carbon dioxide. In addition, ADM conducts the Industrial Carbon Capture and Storage (ICCS) project, which is administered by the U.S. Department of Energy’s Office of Fossil Energy and managed by the National Energy Technology Laboratory. The ICCS project is designed to demonstrate carbon capture and storage at an industrial-scale facility by injecting one million tons of carbon dioxide annually (3,000 tons/day). The ICCS and IBDP were able to obtain the only two Class VI permits issued to date for wells operated under the U.S. Environmental Protection Agency’s (USEPA’s) 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 Class I permit was then converted to a Class VI permit issued by the USEPA only after carbon dioxide injection had ceased. Accordingly, that Class VI permit (for ADM well CCS1) addresses only post-injection site care and site closure. 

This report 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 report also draws on lessons learned from the uncompleted permit application processes. 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 should help future applicants and permit issuers 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 target and how communication throughout the permitting process can avoid misunderstandings and unnecessary delays.

 Special Report 9, Observations on Class VI Permitting: Lessons Learned and Guidance Available by Bob Van Voorhees, Sallie Greenberg, and Steve Whittaker, is now available for free download from the University of Illinois' IDEALS repository, or you can purchase a printed copy for $6 plus shipping costs from our online shop