Paper: Regulatory Issues Affecting Sour CO2 Floods Should Be Considered Early In Planning

This paper addresses one method of dealing with produced gas containing carbon dioxide (CO2) and hydrogen sulfide (H2S) in C02 secondary recovery projects in the Permian Basin of west Texas and southeast New Mexico. Reinjection of produced gas is becoming more common as Permian Basin C02 floods mature. Reinjection can be very cost effective, environmentally prudent, and technically beneficial. Reinjection reduces or eliminates sulfur emissions, reduces capital costs by eliminating sweetening facilities, and often reduces the cost of injection C02 purchases. However, reinjection of H2Scontaining ("sour") gas creates some regulatory concerns not present with CO2 or sweet gas. The Railroad Commission of Texas (RRC) has several rules in place designed to ensure public safety. Some of these regulations require expensive solutions if the regulatory issues are not planned in the initial stages of project design. This paper will review the regulations that will affect gas reinjection projects in the Permian Basin, and outline steps to efficiently address the regulatory concerns.