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Abstract On 25 July 2008, US Environmental Protection Agency (EPA) proposed a rule governing carbon dioxide (CO2) sequestration wells, e.g., newly EPA designated Class VI wells. The Agency cites many references regarding Enhanced Oil Recovery (EOR) wells, but demonstrates a lack of applying these concepts to CO2 retention projects. Literature citations range from pulling cemented casing, milling thousands of feet of casing, to using "milling stones" give experienced oil and gas operators pause for concern: Is the Agency in over their heads? One of the major concerns regarding the proposed rule is the high degree of technical support expected by the Agency from the oil and gas upstream industry.
The agency looks to API and other standards writing bodies to prospectively develop materials, hardware and techniques to make the rules viable. Currently, upstream oil and gas operators are experience difficulty staffing in-house engineering groups for the purpose of producing sufficient oil and gas to meet demands. Availability of industry engineers to simultaneously design CO2 sequestration projects appears highly questionable. The lack of qualified industry engineers can lead to speculators submitting inferior sequestration plans to EPA. If the plans are accepted and the speculator starts injection, but goes bankrupt, the project is left to the agency to complete. Is the Agency capable?
The paper discusses the EPA printed proposal, cites concerns, reviews some of the questionable citations, and recommends minimum technical qualification requirements and written examinations for EPA reviewers and Regional Directors so they can recognize speculator's questionable sequestration project proposals from well engineered proposals.
Introduction The Environmental Protection Agency (EPA) at 73 FR 43492–43541 requested comments regarding the proposed regulations for Class VI injection wells under the authority of the Safe Drinking Water Act (SDWA). The SDWA was passed only to protect underground sources of drinking water from contamination. Nevertheless, EPA proposes using SDWA to control design and operation of wells injecting and retaining supercritical pressure (2200± psia) carbon dioxide in existing reservoirs, e.g., depleted oil/gas fields, salt domes, known saline water reservoirs or enhanced oil/gas recovery reservoirs. Neither the SDWA nor any other United States statute provides protection from death or injury caused by high pressure carbon dioxide. The Agency proposes to sequester buoyant CO2 until the end-of-time by requiring 50 years of monitoring after ceasing injection (40 CFR 146.93(b)(1)). In addition, EPA proposes using well completion materials not currently developed and/or proven corrosion-resistant under carbonic acid exposure.
Currently, serious consideration is being given climate change mitigation. The cause of global warming is believed by some people to be the result of anthropogenic generation of greenhouse gasses. There is no question global warming has occurred. The global temperature has increased for the last 400 years, ever since the end of the Little Ice Age in 1850, Spencer (2008a), Singer and Avery (2007). The total increase equals about 0.82º C., Spencer (2008) in 400 years. Starting in 2002 the Earth's temperature has decreased at the rate on 0.1° C., Figure 1. Nevertheless, the world's population has been indoctrinated to believe the temperature continues to increase resulting in an impending catastrophe.
There are two schools of thought regarding the contribution of greenhouse gases to global warming. First, and currently the most popular theory, is the earth's heating is caused by greenhouse gasses trapping heat near the earth's atmosphere. This phenomenon accelerates global temperature rise and causes rising seas, more and stronger hurricanes and storms, tsunamis and in general earth devastation, Gore (1992) The second school believes the temperature change is a naturally occurring cyclic phenomenon, probably cause by solar activity, Singer and Avery (2007).
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