Director, Division of Water and Waste Management, DEP
601 57th Street SE
Charleston, WV 25304-2345
ATTN: Jeff Knepper, UIC Programs

Comments Regarding AEP's Applicaition for UIC Permit Application No. 1189-08-053

RE: AEPs Permit Application No. 1189-08-053 to geologically sequester carbon dioxide.

 

It is essential that the permit particulars include the requirement that a "tracer" be added to the sequestered gases and/or liquids.  This is necessary in order that the future status of these gases and/or liquids can be accounted for by the State, by AEP, and possibly by the federal government or the public at large.

 

The "tracer" can be a chemical substance in extremely low concentration that is non-toxic and a substance that can be detected by chemical instrumentation.  The choice of "tracer" can be made via consultation among the applicant (AEP), the State agencies involved, and the federal EPA and DOE.

 

If no tracer is used, it will never be possible to properly or legally account for the amount of dissipation and leakage that takes place over time.  Given the long term nature of this proposed storage, then accounting for the sequested material is essential.

 

Given the fact that this project represents a new activity, over which the State has no prior knowledge or experience, it is important that a means is provided to independently track the sequestered material.

 

Respectfully submitted by:

 

Dr. Duane G. Nichols, Chemical Engineer
Technical Representative,
MonValley Clean Air Coalition
January 30, 2009