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EPA Launches Review into Texas’ Underground Injection Program

The Environmental Protection Agency’s Region 6 will evaluate the Railroad Commission of Texas’ (RRC) implementation of the Class II Underground Injection Control (UIC) program.

The review stems from a petition submitted to the EPA in March 2024 by two environmental groups alleging concerns with Class II injection wells, which are used as disposal, enhanced recovery or hydrocarbon storage wells. The EPA responded to the petitioners saying there are “substantial concerns regarding the sufficiency of Texas’ implementation of the UIC Class II program” and the evaluation would need “extensive and thorough technical and legal review”.

The review and subsequent findings could have significant impacts on the CCS and oil industries in Texas, particularly as the state seeks to gain primacy from the EPA for Class VI storage wells. According to Mayer Brown, as much as 80 percent of active Class II wells are used for EOR, where fluids containing CO2, among other things, are injected into oil-bearing formations to recover residual oil and natural gas. In 2022, there were approximately 180,000 active Class II wells (mostly in Texas, California, Oklahoma, and Kansas) but only around 200 active Class VI wells.

Energy Workforce will continue to monitor the progress of the EPA evaluation and industry responses.

Maria Suarez-Simmons, Senior Director Energy Policy, writes about industry-specific policies for the Energy Workforce & Technology Council. Click here to subscribe to the Energy Workforce newsletter, which highlights sector-specific issues, best practices, activities and more.


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