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.