Legal, Regulatory, and Operational Hurdles in the Kentucky Consortium for Carbon Storage (KYCCS) Western Kentucky CO₂ Storage Test

J. Richard Bowersox¹, David A. Williams², David C. Harris¹, and Phillip Papadeas^3
1Kentucky Geological Survey, University of Kentucky, Lexington, KY 40506-0107, [email protected]
²Kentucky Geological Survey, Henderson, KY 42420
³Sandia Technologies, LLC, Houston, TX 77066

The KYCCS (www.kyccs.org) western Kentucky deep carbon storage test well Marvin Blan #1, Hancock County, commenced drilling in April 2009 after 15 months planning. This project was accomplished through the teamwork of the Kentucky Geological Survey and industry partners. Five legal, regulatory, and operational hurdles were addressed on intertwined timelines: consortium organization, budgeting, and drill-site selection; drill-site acquisition and due diligence; project management; State and Federal permitting; and public outreach. Consortium organization and funding commitments, geologic and geophysical evaluations, and test site selection were completed in the first half of 2008. Agreements with the landowner and oil and gas leaseholder were negotiated during the second and third quarters of 2008, concurrent with drill-site due diligence, Phase I environmental survey, geotechnical seismic survey, drill-site location survey, and public meetings with county officials and residents.

A project manager was contracted in June 2008 to complete well design and testing programs, assist in EPA Class V UIC permit application preparation, equipment contracting, drill-site construction, and drilling and injection testing. The well was permitted by the State as an exploratory test in November. A 24.1-mile seismic program was completed in January to characterize the geology in the drill-site vicinity where there is sparse deep-well control. The EPA permit application was filed in October and the permit issued effective April 10, 2009, following public comment. Groundwater monitoring and a monitoring well were required by the EPA. This lengthy legal and regulatory process illustrates the steps required to conduct even a small-scale CO₂ storage test.

AAPG Search and Discovery Article #90095©2009 AAPG Eastern Section Meeting, Evansville, Indiana, September 20-22, 2009