Open Meeting

The Railroad Commission of Texas will hold an open meeting at 9:30 a.m. on Tuesday, May 12, 2026, in Room 12-126, Twelfth Floor of the William B. Travis Building in Austin. To view the webcast, visit the AdminMonitor website at https://www.adminmonitor.com/tx/rrc/open_meeting/20260414/.

Area of Review (AOR) for Class VI Geologic Storage

The Area of Review (AOR) for a Class VI anthropogenic carbon dioxide (CO2) injection well is the three-dimensional extent of the CO2 stream plume and the associated pressure front. This delineation ensures that all artificial penetrations within the affected area are identified and adequately addressed to prevent the movement of fluids into protected water sources.

AOR Delineation Requirements

Applicants must use computational modeling to predict the lateral and vertical migration of the CO2 plume and formation fluids. The model must account for:

  • Time Periods: Predictions must be made for five years after initiation, the entire proposed injection period, and until the plume and pressure front stabilize.
  • Physical Properties: Modeling must consider the mass/volume of injected CO2, the physical properties of the injection and confining zones, and potential migration through known faults, fractures, or artificial penetrations.
  • Critical Pressure: The AOR must identify the area where pressure differentials are sufficient to cause the movement of injected or formation fluids into an Underground Source of Drinking Water (USDW).
  • Documentation: The applicant must provide the name and description of the model, software used, assumptions, and the equations solved.

Corrective Action and Well Verification

  • Table of Penetrations: The applicant must submit a table listing all active, inactive, plugged, or unplugged wells and underground mines in the AOR that may penetrate the confining zone.
  • Plugging Records: For every well on the table, the applicant must demonstrate that it has been plugged or closed in a manner that prevents fluid escape.
    • If Railroad Commission (RRC) plugging records are unavailable, the best available information, such as drilling logs showing the well does not reach the injection interval, must be provided.
    • If no records exist, the applicant may be required to re-enter and plug the well in accordance with Statewide Rule 14 (16 TAC §3.14).
  • Corrective Action Plan: A plan must be submitted describing how any necessary corrective action will be performed using materials compatible with the CO2 stream.

Special Requirements for Offshore Applications

In areas where a USDW may not be present, such as the Texas Offshore (Gulf of Mexico/America), the Commission is mandated to protect surface and subsurface water from pollution under 16 TAC §4.101.

  • Surface Water Protection: Applicants must demonstrate that both USDWs and surface water (including the Gulf of Mexico/America) can be adequately protected from CO2 migration or displaced formation fluids per 16 TAC §5.206(b)(2).
  • Offshore Critical Pressure: The "critical pressure depth," typically based on the base of the USDW, should instead be based on the deepest depth necessary to ensure no discharge to the seafloor.
    • Recommended Depth: Staff recommends using the seafloor ("mud line") or the base of the first permeable strata below the mud line as the reference depth for AOR calculations.
  • Modeling Requirement: Offshore applications must provide simulations of reservoir pressure increase and movement of formation fluids to ensure no discharge to surface water occurs.
  • Director’s Authority: The Director may require any additional information necessary to ensure the protection of surface waters under 16 TAC §5.203 (a)(3) and §5.203(p).

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