I agree whole heartedly with Jim. If "we" take a high level scientific approach demanding transparency, full disclosure, and monitoring.
I would add two very important things.
First, with regard to long term liability for blowouts and leakage, at the PEA meeting at WVSU last year, Utility Industry lobbyist and attorney Dave Flannery was quite clear that the legal liability issues were still unresolved. He presented a plan that he, acting as the Association's attorney, was presenting to mitigate liability and transfer the legal liability from the utility doing the sequestering to the State, if after the operation had ceased and was idle for 10 years without leakage, the utility was no longer liable.
It seems to me that this lets them off the hook too easily and too early. Geological time clocks, as demonstrated with the frequency of earthquakes, are much much longer time frames. 10 years does not seem to be long enough to me.
Secondly, the only blowout of CO2 recorded happened in South Africa. And while it is dismissed by CCS addicts, as a natural phenomena, it was a CO2 blowout due I believe to a shift in the earths crust, or something like a seismic event at great depths that released enough CO2 to kill 1700 people living quietly in a valley where the gas surfaced. And being odorless and colourless, it filled the valley and put all those folks to sleep permanently.
Detection systems and community alarms for leaks in all the potential areas of leakage then must be included in ANY sequestration project. And based upon Flannery's descriptions that we really cannot be sure where the gas is going to migrate, or what seismic events it might trigger, those monitors must cover a wide area over and beyond the sequestration field with a safety factor of at least 2, maybe 5.
And in case anyone thinks I am overly concerned about seismic events just because I worked professionally as a consulting engineer in California, I acknowledge that the mountains of California are much younger, and like humans, much more active. But these mountains we live in are like us older folks, we move less often, but we do move now and then. We do live in a less active seismic area, but IT IS A SEISMICALLY ACTIVE AREA.
Hope this helps the planning and strategy for a serious role in monitoring these uncharted waters.
I will be happy to carry the discussion to the PEA whenever we all feel that is appropriate.
Allan ----- Original Message ----- From: William V. DePaulo, Esq.mailto:william.depaulo@gmail.com To: WV Chapter Energy Committeemailto:EC@osenergy.org Sent: Wednesday, December 17, 2008 10:45 AM Subject: [EC] Fwd: Carbon Sequestration - UIC permitNotice - County - Mason- AEP
ATTACHED IS TITLE 47, SERIES 13 OF THE STATE REGS RELATING TO UNDERGROUND INJECTION CONTROL.
---------- Forwarded message ---------- From: William V. DePaulo, Esq. <william.depaulo@gmail.commailto:william.depaulo@gmail.com> Date: Wed, Dec 17, 2008 at 9:10 AM Subject: Re: Carbon Sequestration - UIC permitNotice - County - Mason - AEP To: James Kotcon <jkotcon@wvu.edumailto:jkotcon@wvu.edu>
How do we know anything works? Monitoring? How would we know it doesn't? Same thing, no?
I think this is a very sensitive question, politically, and how we respond publicly will be very important. If there is no way to determine if it works, that leads to one set of questions. If there is a way that leads to another set.
It is certainly a fair position to state that no such thing as "clean coal" exists, and totally defensible to assert that development of carbon sequestration and storage technology is so remote a possibility that we should not invest a significant portion of finite resources into an improbable solution.
But confronted with a concrete proposal to "try it" the question changes....coal advocates will take the position that opponents of the proposal are simply trying to avoid their own inconvenient truths.
Secondly, if you engage all cynicism sensors, you'd conclude that -- having denied there was even a carbon problem -- once the sucker is built, the coal industry will claim to have "solved" the formerly non-existent problem.
I think we should be involved in this, big time, but I also think we should be prepared to let AEP spend any amount of its own money it wants trying to demo a solution...so long as the experiment is conducted in a way that its results are scientifically verifiable. In other words, insist on transparency, controls, immediate access to raw data unfiltered by AEP or its scientists. This is where, in my view, this battle should be fought. It is the high ground scientifically and politically.
Any other attitude on our part invites criticism, valid criticism, that we won't eve consider the theoretical possibility that we're wrong. The flip side of the coin is that if it fails, or succeeds only marginally, "clean coal" evaporates as an idea. Chu, Obama's nominee for DOE secretary raises questions about leakage and "bubbles" that are quoted in today's Gazette. See attached. And there will be more. But I do not think we should oppose this proposal on a knee jerk basis. Properly conducted, the test may sustain our position. Inartfully opposed, it will prove theirs.
On Wed, Dec 17, 2008 at 8:31 AM, James Kotcon <jkotcon@wvu.edumailto:jkotcon@wvu.edu> wrote:
If it doesn't, how would anyone know?
JBK
>>> <william.depaulo@gmail.commailto:william.depaulo@gmail.com> 12/16/2008 5:50 PM >>>
What if it works????????? Sent via BlackBerry by AT&T
-----Original Message----- From: "James Kotcon" <jkotcon@wvu.edumailto:jkotcon@wvu.edu>
Date: Tue, 16 Dec 2008 17:20:03 To: <EC@osenergy.orgmailto:EC@osenergy.org> Subject: [EC] Fwd: [wvec-board] Fw: Carbon Sequestration - UIC permit Notice - County - Mason - AEP
Yess!!!! We needed one more thing to do.
Word is that this one may be mostly science fiction. Anyone know anything about these things?
JBK
>>> "cindyrank" <clrank@hughes.netmailto:clrank@hughes.net> 12/16/2008 4:23 PM >>> The underground injection (UIC) permit application for carbon sequestration by AEP in Mason County
To operate and maintain underground injection (UIC) permit to inject carbon dioxide through injection wells into the subsurface located in Mason County.
cindy
--------------------------------------------------------------------------------
----- Original Message ----- From: <dep.online@wv.govmailto:dep.online@wv.gov> To: <clrank@hughes.netmailto:clrank@hughes.net> Sent: Tuesday, December 16, 2008 4:10 PM Subject: DEP Public Notice - County - Mason - Applicant - American Electric Power - Application No. 1189-08-053
> The following was sent to you because you are a > Member of the DEP Public Notice mailing list. > =========================================================== > Tuesday, December 16, 2008 @ 4:10 PM > =========================================================== > > STATE OF WEST VIRGINIA > DEPARTMENT OF ENVIRONMENTAL PROTECTION > DIVISION OF WATER AND WASTE MANAGEMENT > > PUBLIC NOTICE > > WEST VIRGINIA DEPARTMENT OF ENVIRONMENTAL PROTECTION'S, PUBLIC INFORMATION > OFFICE, 601 57TH STREET SE, CHARLESTON, WEST VIRGINIA 25304-2345 TELEPHONE: > (304) 926-0440, TDD:(304) 926-0493, and VOICE-TO-TDD RELAY: 1-800-422-5700. > > APPLICATION FOR A CLASS 5 UNDERGROUND INJECTION CONTROL PERMIT > > Public Notice No.: P-01-09 Public Notice Date: December 18, > 2008 > > Paper: Point Pleasant Register > > The following has applied for a Class 5 Underground Injection Control Permit > for this facility or activity: > > Application No.: 1189-08-053 > > Applicant: AMERICAN ELECTRIC POWER > 1 RIVERSIDE PLAZA > COLUMBUS, OH 43215 > > > Facility: > Mountaineer Plant , WV > > Business conducted: > Power Plant > > Activity: > To operate and maintain underground injection (UIC) permit to inject carbon > dioxide through injection wells into the subsurface located in Mason County. > > The State of West Virginia will act on the above application in accordance with > the West Virginia Legislative Rules, Title 47, Series 13, Section 13.24 issued > pursuant to Chapter 22, Article 11 and Article 12. > > Any interested person may submit written comments on the draft permit and may > request a public hearing in writing within thirty (30) days of the date of this > public notice. Comments or requests should be addressed to: > > Director, Division of Water and Waste Management, DEP > 601 57th Street SE > Charleston, WV 25304-2345 > ATTN: Jeff Knepper, UIC Programs > > The public comment period begins December 18, 2008 and ends January 17, 2009 > > Comments received within this period will be considered prior to issuance of > the permit. Correspondence should include the name, address, and telephone > number of the writer and a concise statement of the nature of the issues > raised. A public hearing may be held if the Director determines there is > significant public interest in one or more issues relevant to the draft permit. > > The application, draft permit or factsheet may be inspected by appointment at > the Division of Water and Waste Management, between 8:30 a.m. to 4:30 p.m. on > business days. Copies of the document may be obtained for a nominal fee. For > further information contact the person identified above at (304) 926-0495, or > Fax (304) 926-0496. > > > =========================================================== > To view past notices of open public comment periods or to unsubscribe from this Mailing List, login at: > http://www.wvdep.org//MLists2/http://www.wvdep.org//MLists2/ > > >
_______________________________________________ EC mailing list EC@osenergy.orgmailto:EC@osenergy.org http://osenergy.org/mailman/listinfo/echttp://osenergy.org/mailman/listinfo/ec
-- William V. DePaulo, Esq. 179 Summers Street, Suite 232 Charleston, WV 25301-2163 Tel: 304-342-5588 Fax: 304-342-5505 william.depaulo@gmail.commailto:william.depaulo@gmail.com www.passeggiata.comhttp://www.passeggiata.com/
-- William V. DePaulo, Esq. 179 Summers Street, Suite 232 Charleston, WV 25301-2163 Tel: 304-342-5588 Fax: 304-342-5505 william.depaulo@gmail.commailto:william.depaulo@gmail.com www.passeggiata.comhttp://www.passeggiata.com/ _______________________________________________ EC mailing list EC@osenergy.org http://osenergy.org/mailman/listinfo/ec
"He presented a plan that he, acting as the Association's attorney, was presenting to mitigate liability and transfer the legal liability from the utility doing the sequestering to the State, if after the operation had ceased and was idle for 10 years without leakage, the utility was no longer liable. "
Externalizing costs - an industry favorite. This sound like abandoned mines and their inadequate bonds to treat ongoing/forever acid mine drainage.
Jim Sconyers jim_scon@yahoo.com 603.969.6712
Remember: Mother Nature bats last.
________________________________ From: Allan Tweddle allantweddle@msn.com To: WV Chapter Energy Committee EC@osenergy.org; "William V. DePaulo, Esq." william.depaulo@gmail.com Cc: Don GARVIN dsgjr@aol.com Sent: Wednesday, December 17, 2008 12:07:27 PM Subject: Re: [EC] Fwd: Carbon Sequestration - UIC permitNotice - County - Mason- AEP
I agree whole heartedly with Jim. If "we" take a high level scientific approach demanding transparency, full disclosure, and monitoring.
I would add two very important things.
First, with regard to long term liability for blowouts and leakage, at the PEA meeting at WVSU last year, Utility Industry lobbyist and attorney Dave Flannery was quite clear that the legal liability issues were still unresolved. He presented a plan that he, acting as the Association's attorney, was presenting to mitigate liability and transfer the legal liability from the utility doing the sequestering to the State, if after the operation had ceased and was idle for 10 years without leakage, the utility was no longer liable.
It seems to me that this lets them off the hook too easily and too early. Geological time clocks, as demonstrated with the frequency of earthquakes, are much much longer time frames. 10 years does not seem to be long enough to me.
Secondly, the only blowout of CO2 recorded happened in South Africa. And while it is dismissed by CCS addicts, as a natural phenomena, it was a CO2 blowout due I believe to a shift in the earths crust, or something like a seismic event at great depths that released enough CO2 to kill 1700 people living quietly in a valley where the gas surfaced. And being odorless and colourless, it filled the valley and put all those folks to sleep permanently.
Detection systems and community alarms for leaks in all the potential areas of leakage then must be included in ANY sequestration project. And based upon Flannery's descriptions that we really cannot be sure where the gas is going to migrate, or what seismic events it might trigger, those monitors must cover a wide area over and beyond the sequestration field with a safety factor of at least 2, maybe 5.
And in case anyone thinks I am overly concerned about seismic events just because I worked professionally as a consulting engineer in California, I acknowledge that the mountains of California are much younger, and like humans, much more active. But these mountains we live in are like us older folks, we move less often, but we do move now and then. We do live in a less active seismic area, but IT IS A SEISMICALLY ACTIVE AREA.
Hope this helps the planning and strategy for a serious role in monitoring these uncharted waters.
I will be happy to carry the discussion to the PEA whenever we all feel that is appropriate.
Allan ----- Original Message ----- From: William V. DePaulo, Esq. To: WV Chapter Energy Committee Sent: Wednesday, December 17, 2008 10:45 AM Subject: [EC] Fwd: Carbon Sequestration - UIC permitNotice - County - Mason- AEP ATTACHED IS TITLE 47, SERIES 13 OF THE STATE REGS RELATING TO UNDERGROUND INJECTION CONTROL.
---------- Forwarded message ---------- From: William V. DePaulo, Esq. william.depaulo@gmail.com Date: Wed, Dec 17, 2008 at 9:10 AM Subject: Re: Carbon Sequestration - UIC permitNotice - County - Mason - AEP To: James Kotcon jkotcon@wvu.edu
How do we know anything works? Monitoring? How would we know it doesn't? Same thing, no?
I think this is a very sensitive question, politically, and how we respond publicly will be very important. If there is no way to determine if it works, that leads to one set of questions. If there is a way that leads to another set.
It is certainly a fair position to state that no such thing as "clean coal" exists, and totally defensible to assert that development of carbon sequestration and storage technology is so remote a possibility that we should not invest a significant portion of finite resources into an improbable solution.
But confronted with a concrete proposal to "try it" the question changes....coal advocates will take the position that opponents of the proposal are simply trying to avoid their own inconvenient truths.
Secondly, if you engage all cynicism sensors, you'd conclude that -- having denied there was even a carbon problem -- once the sucker is built, the coal industry will claim to have "solved" the formerly non-existent problem.
I think we should be involved in this, big time, but I also think we should be prepared to let AEP spend any amount of its own money it wants trying to demo a solution...so long as the experiment is conducted in a way that its results are scientifically verifiable. In other words, insist on transparency, controls, immediate access to raw data unfiltered by AEP or its scientists. This is where, in my view, this battle should be fought. It is the high ground scientifically and politically.
Any other attitude on our part invites criticism, valid criticism, that we won't eve consider the theoretical possibility that we're wrong. The flip side of the coin is that if it fails, or succeeds only marginally, "clean coal" evaporates as an idea. Chu, Obama's nominee for DOE secretary raises questions about leakage and "bubbles" that are quoted in today's Gazette. See attached. And there will be more. But I do not think we should oppose this proposal on a knee jerk basis. Properly conducted, the test may sustain our position. Inartfully opposed, it will prove theirs.
On Wed, Dec 17, 2008 at 8:31 AM, James Kotcon jkotcon@wvu.edu wrote:
If it doesn't, how would anyone know?
JBK
william.depaulo@gmail.com 12/16/2008 5:50 PM >>>
What if it works????????? Sent via BlackBerry by AT&T
-----Original Message----- From: "James Kotcon" jkotcon@wvu.edu
Date: Tue, 16 Dec 2008 17:20:03 To: EC@osenergy.org Subject: [EC] Fwd: [wvec-board] Fw: Carbon Sequestration - UIC permit Notice - County - Mason - AEP
Yess!!!! We needed one more thing to do.
Word is that this one may be mostly science fiction. Anyone know anything about these things?
JBK
"cindyrank" clrank@hughes.net 12/16/2008 4:23 PM >>>
The underground injection (UIC) permit application for carbon sequestration by AEP in Mason County
To operate and maintain underground injection (UIC) permit to inject carbon dioxide through injection wells into the subsurface located in Mason County.
cindy
--------------------------------------------------------------------------------
----- Original Message ----- From: dep.online@wv.gov To: clrank@hughes.net Sent: Tuesday, December 16, 2008 4:10 PM Subject: DEP Public Notice - County - Mason - Applicant - American Electric Power - Application No. 1189-08-053
The following was sent to you because you are a Member of the DEP Public Notice mailing list. =========================================================== Tuesday, December 16, 2008 @ 4:10 PM ===========================================================
STATE OF WEST VIRGINIA DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF WATER AND WASTE MANAGEMENT
PUBLIC NOTICE
WEST VIRGINIA DEPARTMENT OF ENVIRONMENTAL PROTECTION'S, PUBLIC INFORMATION OFFICE, 601 57TH STREET SE, CHARLESTON, WEST VIRGINIA 25304-2345 TELEPHONE: (304) 926-0440, TDD:(304) 926-0493, and VOICE-TO-TDD RELAY: 1-800-422-5700.
APPLICATION FOR A CLASS 5 UNDERGROUND INJECTION CONTROL PERMIT
Public Notice No.: P-01-09 Public Notice Date: December 18, 2008
Paper: Point Pleasant Register
The following has applied for a Class 5 Underground Injection Control Permit for this facility or activity:
Application No.: 1189-08-053
Applicant: AMERICAN ELECTRIC POWER 1 RIVERSIDE PLAZA COLUMBUS, OH 43215
Facility: Mountaineer Plant , WV
Business conducted: Power Plant
Activity: To operate and maintain underground injection (UIC) permit to inject carbon dioxide through injection wells into the subsurface located in Mason County.
The State of West Virginia will act on the above application in accordance with the West Virginia Legislative Rules, Title 47, Series 13, Section 13.24 issued pursuant to Chapter 22, Article 11 and Article 12.
Any interested person may submit written comments on the draft permit and may request a public hearing in writing within thirty (30) days of the date of this public notice. Comments or requests should be addressed to:
Director, Division of Water and Waste Management, DEP 601 57th Street SE Charleston, WV 25304-2345 ATTN: Jeff Knepper, UIC Programs
The public comment period begins December 18, 2008 and ends January 17, 2009
Comments received within this period will be considered prior to issuance of the permit. Correspondence should include the name, address, and telephone number of the writer and a concise statement of the nature of the issues raised. A public hearing may be held if the Director determines there is significant public interest in one or more issues relevant to the draft permit.
The application, draft permit or factsheet may be inspected by appointment at the Division of Water and Waste Management, between 8:30 a.m. to 4:30 p.m. on business days. Copies of the document may be obtained for a nominal fee. For further information contact the person identified above at (304) 926-0495, or Fax (304) 926-0496.
=========================================================== To view past notices of open public comment periods or to unsubscribe from this Mailing List, login at: http://www.wvdep.org//MLists2/
_______________________________________________ EC mailing list EC@osenergy.org http://osenergy.org/mailman/listinfo/ec
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Allan Tweddle -
Jim Sconyers