4 DIRECTIVES AND REGULATIONS RELATED TO STORAGE SITE MONITORING

This chapter provides an overview of how monitoring is addressed in legislation and directives, how guidelines and protocols have been developed to interpret the legislation and how some of the early integrated industrial scale CCS projects have incorporated monitoring plans in their permit applications.

The chapter starts with a thorough review of the various legislative regimes, with a main focus on Europe and the CCS directive. The associated guidelines developed in the so-called Guidance Documents provide more practical information on how to translate legislative monitoring requirements to a practical implementation. Besides the CCS directive, the ETS directive and its associated ETS-MRG guidelines are discussed. The latter describe at a high level, how monitoring should be measured and quantified in case leakage to the surface or sea water column occurs.

Besides European legislation, developments in the US, Canada and Australia are described, where legislation is furthest advanced after Europe. It is not surprising, that many similarities can be observed.

Finally the contents concerning monitoring of various international documents such as OSPAR, the London Convention, the IEA-MRF and CO2QUALSTORE are described. It must be noted, that the high level content of most of these documents have been incorporated in the EU storage directive.

The last part of the chapter is dedicated to examples of integrated industrial scale projects implementing monitoring plans in their permit applications (several located in the EU and one in Canada). Information has been taken from published FEED studies as well as from storage permit applications. As one might expect, major differences exist between onshore storage (e.g. the Quest project in Canada) and offshore storage (e.g. the ROAD project in the Netherlands). However, it is worth mentioning, that with existing current technology decent monitoring programs have been proposed.

Risk assessment is considered a key element in a CO2 storage project, as exemplified by the prominent position of risk assessment in the various regulatory documents including the EU storage directive. The most important tool for successful risk management is monitoring. Smith et al., 2011a provide a good basic definition of monitoring, namely "continuous or repeated observation of a situation to detect changes that may occur over time". The essential role of monitoring according to the EU directive Guidance Document 2 can be summarised as: a) to confirm containment of CO2, b) to alert in case of increased leakage risk, c) to identify leakage and/or significant irregularities, and d) to verify the CO2 plume behaviour. Moreover, monitoring should ensure the effectiveness of any corrective measures applied. As a result, monitoring issues are given top priority in the EU and other international legal documents and guidelines.

The regulatory process on CCS started in the early nineties after energy policy strategies were adopted at an international level. The list of regulatory documents which paved the way towards CCS at the industrial level is extensive. The aim of this Chapter is not to describe all of these documents in detail, but rather to point to some of the most prominent milestones for the implementation of CCS technology with a particular focus on monitoring and reporting with respect to the geological storage of CO2 at the EU level.

At present, the EU legal framework that enables CCS industrial operations is in place, though revisions based on experiences are still foreseen by June 30, 2015 (recital 48, EU CCS Directive 2009/31/EC). Regulatory processes ran simultaneously in other parts of the world. Relevant legislation on monitoring and reporting for CCS is currently implemented amongst others in the USA, Canada and Australia.

In this Chapter specific provisions and solutions related to monitoring and reporting issues from different regulatory regimes are compared, but with the main emphasis on EU regulations. The following sections discuss various approaches that were followed in individual countries, differences and similarities in provisions applied, specific requirements in the reporting and verification process and solutions adopted for on- and offshore storage sites.

The main emphasis is on the EU CCS Directive, but a brief overview of other documents will be discussed. In general one could say that all early regulatory documents are included in the EU CCS Directive.

As examples the monitoring plans of a number of industrial projects, that will operate under the umbrella of the most recent CCS legislation, have been analysed. It must be noted, that none of these projects is operational yet, and the advancement in applying for storage licenses varies widely. Nevertheless, it is instructive to see, how legislation has been interpreted and applied by the various industrial proposers in their applications. The analysis is limited in the sense, that it is only based on information publicly available. A number of potential storage sites in Europe have been analysed, of which the information on one Dutch and two UK projects is furthest advanced. Besides the European sites, also the Quest project in Canada has been analysed, since it received a license with minister's approval together with well license approval in 2012.

 

in depth

4.2 Current industrial-scale applications operating under CO2 legislation

In this sections the monitoring plans of a number of projects, that will operate under the umbrella of the most recent C...

4.4 Main differences with gas storage, or other oil- and gas operations

Obviously hydrocarbon storage operations can be labelled as a more mature technology, with experiences dating back for a...

4.5 Conclusions

This chapter provides an overview how monitoring is addressed in legislation and directives, how guidelines and protocol...