Governmental Roles and Responsibilities Related to Underground Injection and Induced Seismicity - Induced Seismicity Potential in Energy Technologies - page 100

ing water and the surface environment. The EPA, however, does not grant a contractual
right to inject fluids or CO 2 underground by their permitting process. In the case of fluid
disposal or CO 2 sequestration, this right is granted by the property owner via a “surface
use agreement” with the injection well operator. These agreements may include fees paid
to the property owner based on a monetary charge per barrel of fluid or ton of CO 2 or a
charge for land rental per month. These agreements can also include requirements on how
fluid is delivered (by truck or by pipeline), how site security is handled, and what type of
facilities will be used on the well site (tank, pits, and offloading facilities). Property owners
can be private parties and/or governmental agencies such the BLM, the USFS, or state
land management organizations. Underground injection for the purpose of secondary or
tertiary recovery operations in an existing oil or gas field or injection to develop geothermal
resources are usually allowed via an oil and gas or geothermal mineral lease.
Specific regulations governing the requirements of the UIC program are documented in
40 CFR, Parts 144 through 149. These regulations outline the general requirements of the
UIC program, the requirements for state programs, and specific standards for well construc-
tion and testing. A comparison of these regulations is summarized in Table 4.4. This table
includes only those classes of injection wells that are connected with energy technologies.
These classes are Class II wells (associated with oil and gas production), Class V wells (as-
sociated with geothermal energy), and Class VI wells (associated with carbon sequestration).
Although Class I wells have also been proven to induce seismic events, they are excluded
from this study because they have no association with energy extraction.
In practice, the well construction requirements shown above are almost always met by
using standard oil and gas well construction techniques, such as setting surface casing below
all underground sources of drinking water and cementing casing high above all injection
horizons. This method of setting and cementing casing strings at strategic depths ensures
underground sources of drinking water are protected by at least two strings of steel casing
(sometimes more) and at least two barriers of cement (Figure 4.1). The ability of the tubing
or casing to contain pressure is required to be continuously recorded in a Class VI well and
is tested every 5 years for Class II wells.
Other governmental agencies, in addition to the EPA or a state agency, may have
jurisdiction over the injection permitting process. These additional agencies include the
BLM, USFS, and USGS.