vvEPA
United States Environmental Protection Agency
Geologic Sequestration Data Tool (GSDT)
Background
Under the Class VI Rule at 40 CFR 146.91(e). owners or operators of Class VI wells must submit geologic
sequestration (GS) project information directly to EPA in an electronic format approved by EPA. This
requirement applies regardless of whether the project is located in a state with primary enforcement
responsibility (primacy) for Class VI wells.
EPA's Geologic Sequestration Data Tool (GSDT) is a centralized, web-based system that receives, stores,
and manages Class VI data, to:
• Fulfill the requirement at 40 CFR 146.91(e);
• Facilitate data access, sharing, and technical evaluations of submitted materials;
• Develop and manage a comprehensive administrative record, consisting of all documents and
communications supporting permitting decisions; and
• Ensure continuity over the potentially long lifespans of Class VI projects.
The GSDT provides a national, transparent, comprehensive, and cost-saving solution for Class VI data
and records management.
Class VI Users arid Data
The GSDT is currently designed for two main groups of users; permit
applicants/owners or operators and permitting authorities.
Owners or Operators
The Class VI Rule requires owners or operators to submit certain types
of information during each phase of a GS project:
• The pre-construction phase, prior to well construction or
conversion;
• The pre-injection phase, prior to operation;
• The injection phase, during which C02 injection operations
occur; and
• The post-injection phase, including post-injection site care
(PISC) and site closure.
Beginning with the permit application and continuing through the life
of the project, owners or operators must submit materials related to:
• Site characterization and pre-injection logging and testing;
• Area of Review (AoR) modeling and corrective action;
• Well construction and operation;
• Financial responsibility demonstrations;
• Testing and monitoring during the injection and post-
injection phases;
• Weil plugging and site closure, including non-endangerment
demonstrations; and
• Emergency and remedial response.
Class VI well schematic.
EPA's Geologic Sequestration Data Tool (GSDT) November 2019 j Page 1
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vvEPA
United States Environmental Protection Agency
If applicable, owners or operators may also submit information related to alternative post-injection site
care (RISC) timeframe demonstrations, injection depth waivers, and/or aquifer exemption expansion
requests. Each of these categories of information must be evaluated both individually and in the context
of the other types of submissions.
Permitting Authorities
Permitting authorities—primacy states and EPA regional offices—also generate information when
permitting, managing, and overseeing Class VI projects. These materials may include:
• Permitting documents, including permit conditions and docket support materials;
• Reports generated during technical evaluation of materials submitted by permit
applicants/owners or operators;
• Communications with owners or operators, such as responses to Notices of Deficiency (NODs)
or Requests for Additional Information (RAIs);
• Public participation/outreach materials, including comment/response documents; and
• Compliance-related materials, including inspection and violation records.
GSDT User Access
All users access the GSDT at https://epa.velo.i3nnl.gov/. where they are directed to separate areas for
owners or operators and permitting authorities.
Owners or operators have access
limited to their project site, which
allows them to submit
information. This group of users
submits information via a series of
topic-specific modules, accessed
from a central landing page for
their projects (see image at left).
Permitting authorities have full
access, which allows them to
access all the files and other
information submitted via the
modules. They can also use the
tool to conduct technical
evaluations, manage
communications, and store all
Example project landing page.
manipulate information while preserving the integrity of the original submitted data.
GSDT Modules
information related to a project.
The GSDT allows permitting
authorities to review and
All information submitted by permit applicant/owner or operator users is submitted via a series of
modules that are designed to address certain components of Class VI data (AoR modeling, financial
responsibility, etc.). Permit applicants/owners or operators can submit data using the following modules
(see images on the following page):
EPA's Geologic Sequestration Data Tool (GSDT)
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vvEPA
United States Environmental Protection Agency
Project information tracking;
AoR and corrective action;
Financial responsibility demonstration;
Pre-operational testing;
Project plan submissions;
Alternative PISC timeframe demonstrations-
Injection depth waivers and aquifer
exemption expansions;
Non-endangerment demonstrations-
Injection and post-injection phase
reporting; and
• Information requests.
Depending on the topic and the type of data that
must be submitted, some modules (such as the
AoR and corrective action module) consist of fairly
detailed proscriptive workflows to collect highly
technical information. Others (such as the project
plan submissions module) allow the user a great deal of flexibility in uploading required files and
supplemental materials.
Permitting Authority Capabilities
Permitting authority users have multiple options for viewing, downloading, and sharing files. When
submissions are made, the designated permit writer(s) for a project will receive an email with a
summary of the submission. The summary highlights any changes since the previous submission and
includes links to uploaded files.
The version control features of the GSDT allow permitting authorities to more easily identify the most
current version of a submitted file. Also, because all submissions are made through the tool, the tool
supports the development of a comprehensive administrative record for a permitting decision.
Examples of GSDT modules.
&*
1 EPA Class VIUIC Submission: Permit Application Upload
To Permitting Authority
Mtstagt % SuanKUOn.02-M-aiS-10S449.pdt <22 KB)
This is a system-generated message regarding your recent EPA Class VI UIC initial or updated
submission from the Permit Application upload tool. Attached for your records is a read-only
copy of this submission, jr^—. in
updated/corrected Infoi'" "
UIC Program Director re'' , t . *„ . —
This submission was ma
Please do not reply to tl
Qil-- k.» x »i ii"
1
File Manager
;«J # X $ »H? E=S
0 El j ADMCCS2-R05-IL-0002
B j Prelnj-PreConstnjction
|[j) B lijJ-TechnicalDo'CS
S ^Application
® jAoRModeling
' 3 | E Tj-Monitoring
r PermitPsdiage
^AdminRecocd
> Prelnj-PreOperation
Injection
(Postlnjection
ESA-Frommelt.pdf
Automatic email notifications and versioning
capabilities for permitting authorities.
Examples of options for accessing files.
EPA's Geologic Sequestration Data Tool (GSDT)
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