Key Reports:

Operational and safety risk regulations

4.1.7 International regulations

In this section the contents concerning monitoring of various international documents are described. It must be noted, that the high level content of most of these documents have been assimilated in the EU storage directive.

IPCC issued two documents (IPCC, 2005; 2006) relevant for CCS and for monitoring of CO2 storage sites. The IPCC Special report on CCS (SRCCS) covers all aspects of CCS and as a result is fairly basic in terms of monitoring. However, it was one of the first documents on CCS that echoed a lot of response among professionals and general public. At the time of issuing the document, the injection into the water column was not yet prohibited. In SRCCS monitoring is recognized as an important compound of the entire CCS system along with a risk management strategy. Monitoring in the pre-injection, injection and long into post-injection phase was prescribed. An additional role of monitoring should be to estimate emissions from potential sources (i.e., injection wells, EOR operations, storage sites) to be included in the greenhouse gas (GHG) inventories (IPCC, 2005). Natural analogues are considered as an important source of information for the behaviour of the CO2 underground, particularly when practical experiences are still scarce. Within issues related to health, safety and environmental risks of geological storage of CO2, SRCCS concludes that the risks of CCS activities would be comparable to the risks of natural gas storage, enhanced oil recovery (EOR) with injection mediums other than CO2 and deep underground disposal of acid gas, provided that there is appropriate site selection, management and monitoring. This conclusion relates to both offshore and onshore geological storage sites.

The specifically developed legal and regulation framework was not yet available in 2005. The authors emphasize long-term liability issues such as longevity of the institutions, knowledge dissemination, property rights etc. A monitoring, verification and reporting framework was foreseen, but not yet detailed.

The focus of the Guidelines (IPCC, 2006) is a national inventory of greenhouse gases in various sectors. In it, the description of potential monitoring technologies to monitor the behaviour of the storage complex during storage operations (and beyond) is given. Capabilities, detection limits, applications, costs, limitations and the maturity status (prior to 2006) of potential monitoring technologies are presented. The monitoring technologies are further divided according to the target (i.e., deep/shallow subsurface, flux detection from ground/water, detection of raised CO2 levels in air/water/sea water, detection of leakage). The authors suggest how to properly characterize the storage site prior to any operations in order to identify possible natural leakage or migration pathways. The monitoring approach as well as the concept of a monitoring plan proposed here are basically the same as described later in the CCS Directive: "...site characterization, modelling, assessment of the risk of leakage and monitoring activities are the responsibility of the storage project manager and/or an appropriate governing body that regulates carbon dioxide capture and storage." (IPCC, 2006). However, the Guidelines refer several times to EOR, EGR and ECBM operations and suggest specific solutions, which are currently not covered in the CCS Directive.

The NSBTF group (2009) studied the applications, limitations and benefits of individual monitoring methods for offshore storage. They suggest some possible effective methods to be used to detect leakage and to define the leakage rates in offshore storage locations.

Offshore CO2 geological storage activities need to comply with the London Protocol (IMO, 1996), which is a modernised version of the earlier London Convention (IMO, 1972) on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter and with the OSPAR Convention (OSPAR, 2007aIMO, 1992), the North-East Atlantic's equivalent of the London Protocol. The amendment to the 1996 London Protocol, which entered into force in 2006, adopts the approach of, banning all forms of disposal unless specifically allowed. Carbon dioxide streams from carbon dioxide capture processes for sequestration is included on the list of acceptable materials for dumping (the so called »reverse list«). As a result, carbon dioxide storage in sub-seabed formations have been endorsed provided that (1) disposal is into a sub-seabed geological formation; (2) the carbon dioxide stream is of high purity containing only incidental amounts of associated substances; and (3) no wastes or other matter are added for the purpose of disposing of those wastes or other matter (WRI, 2008).

London Protocol Specific Guidelines (IMO, 2007) were developed and are intended for use by national authorities responsible for regulating the dumping of wastes. In 2007, OSPAR issued Guidelines for Risk Assessment and Management of Storage of CO2 Stream in Geological Formations (OSPAR, 2007b) with Annex 1 Framework for Risk Assessment and Management of storage of CO2 streams in geological formations (OSPAR-FRAM, 2007). The aim of OSPAR Guidelines is to assist in the management of storage of CO2 streams in geological formations in consideration of several aspects, including collection of necessary information (monitoring) and development of a strategy to manage uncertainties and minimise risks. Moreover the Guidelines provide general guidance for operators when applying for permits for the storage of CO2 streams in geological formations. Both documents (London Protocol Specific Guidelines and OSPAR Guidelines) are specific in terms of risks associated with CO2 storage in sub-seabed geological formations which include risks associated with leakage into the marine environment of CO2 and any other substances in or mobilized by the CO2 stream and are closely related in many further aspects of risk management in general. In OSPAR-FRAM (2007) it is emphasised that the management of a CO2 storage project during the project life cycle is an iterative process necessary for its continual improvement. An illustrative figure explaining the cyclic process of risk assessment and management during the entire lifecycle of a CO2 storage project is presented (see Fig. 4-2). Monitoring shall be performed from planning up to the post-closure phase. In the planning phase, risk management is used to design preventive measures based on predictions derived in particular from the outcome of the risk characterisation stage. Risk management further defines the requirements for monitoring, during and after injection of CO2 streams. The authors of OSPAR-FRAM express their concern about small leaks of CO2 and incidental associated substances from the storage formation that may remain undetected, when the resolution of the available monitoring techniques is less than necessary to observe such quantity (OSPAR, 2007b).

O. Fig. 4-2

Fig. 4-2: Cyclic process of risk assessment and management during the lifecycle of a CO2Carbon dioxide storage project (OSPAR, 2007b).

The results of monitoring can lead to the identification of additional preventive and/or mitigation measures. After site closure the monitoring should continue, but its intensity may decrease and, eventually, "monitoring may be discontinued when there is confirmation that the probability of any future adverse environmental effects has been reduced to an insignificant level." (OSPAR-FRAM, 2007).

Local and global aspects are addressed and over all timescales, but primarily at the local and regional scale and thus focus on the potential effects on the marine environment in the proximity of the receiving formations. Basically, it is required that the risks should be sufficiently described or quantified so that it is clear what variables should be assessed during monitoring.

The risk characterisation should lead to the development of an "Impact Hypothesis" which is an alternative approach to the one followed by the CCSCarbon dioxide Capture and Storage Directive. Impact Hypothesis is a concise statement of the expected consequences of disposal. Based on it, environmental monitoring requirements shall be defined. Risk based monitoring programmes will need to be designed to test the Impact Hypothesis but also to clearly define objectives which would enable to trigger mitigation or remediation plans. A set of key parameters for monitoring is proposed. Further baseline information is required so that any deviations from pre-disposal conditions in the receiving area could be detected. The monitoring programme should allow to detect CO2Carbon dioxide migration and potential leaks over a large area. It is specifically required to monitor the seafloor and overlaying water to detect leakage of CO2Carbon dioxide, or substances mobilized as a result of the disposal of the CO2 stream, into the marine environment and to monitor marine communities (benthic and water column) to detect effects on marine organisms. OSPAR-FRAM specifies some possible remediation methods in case of leakage through well(s) and/or faults or fractures. Other monitoring issues such as monitoring objectives, what to detect, key parameters to be monitored, monitoring tools, frequency, updates of the monitoring programme etc. are similar to provisions for onshore CO2Carbon dioxide storage sites. Permitting procedures should take into account monitoring results and regular reporting.

The OSPAR Commission (2006) issued a report in which it focuses on appropriate monitoring and surveillance technology and methodology for the safe storage of CO2Carbon dioxide. Geophysical techniques such as seismic methods and gravimetry should be used in a site specific manner to monitor the CO2Carbon dioxide storage and to enable the remediation of leakage. The report suggests the techniques which are based on decades of experience in the oil and gas industry. Direct measurements of fluxes may not be possible for off-shore deep seaThe sea below 1000m depth geological storage of CO2Carbon dioxide. Monitoring has therefore to rely on indirect methods, e.g. monitoring amounts and movement of CO2Carbon dioxide in the reservoir. Since some risks may be less severe for offshore storage sites compared with onshore ones, specific solutions concerning risk to humans and to ground water reservoirs are foreseen.

The OSPAR-FRAM document identifies several gaps in knowledge addressed to off-shore CO2Carbon dioxide storage sites (some are also relevant to onshore ones) at the time of issuing the document in 2006: "Further research is necessary in order to improve and adapt options for remediation, mitigation and monitoring, to improve predictions of exposure to CO2Carbon dioxide and incidentally associated substances and to improve the impact prediction on the effects on species and ecosystems as a result of leakage of CO2Carbon dioxide streams."

Det Norske Veritas coordinated a consortium which published a set of documents with the aim to accelerate the deployment of CCSCarbon dioxide Capture and Storage projects, in particular geological storage of CO2Carbon dioxide. In the CO2QUALSTORE documents (DNV, 2010a; DNV, 2010), a risk based approach to site selection and qualification of projects for CO2Carbon dioxide geological storage was used. The entire lifecycle of the project is considered. The documents are aimed at various users (i.e. developers, regulators, third parties) in five areas of application: guidance for implementation, information on best industrial practice, support for the implementation of the regulations, reference for verification and support to stakeholder communication. The primary intention of the guideline is to contribute to consistent implementation of CGS projects but also to help regulators to evaluate if a project is developed in accordance with industry practice and to support implementation of national and international regulations, codes and standards. Furthermore, the purpose of the guideline is to provide a basis for verification and validation. Independent verification can contribute to: demonstrate compliance; manage and minimise risks (and uncertainties); avoid future loss or liabilities; provide assurance to stakeholders; and secure a transparent, consistent and cost-effective process (DNV, 2010a). A generic workflow for CGS project activities is introduced in the guideline. For several project stages (operational stage being among them), a more detailed sub-flow is proposed with activity specific milestones and deliverables. CO2QUALSTORE documents cover a long list of issues for each stage (i.e. Screen, Assess & Select, Design, Construct, Operate, Close) (described in Appendix B of the guideline), including monitoring, verification, accounting and reporting (MVAR) plan to be performed in the operational stage. As far as monitoring and safety of operations are concerned, it is important to demonstrate adequate monitoring potential. Contingency and remediation plans shall be indispensable elements in the risk and uncertainty management. The CO2QUALSTORE consortium strongly suggests establishing a dialogue between the project developer and the regulator as early as possible in the qualification process. The objectives of such communication shall involve documentation requirements and performance targets for operational and closure stage. Here, it is beneficial to assess the potential impacts of the project and to agree on an MVAR program. It is essential to keep the regulator updated, to inform him on any uncertainty occurrence and/or alteration of predictive models. Recognizing the fact, that selection and quantification of storage sites should be an iterative process, any deviation from anticipated performance elements shall be reflected in the modification of performance targets and consequently of the MVAR program (and other relevant documents such as Storage Performance Forecast, Environmental Impact Assessment, Impact Hypothesis and Contingency Plan). Moreover, the MVAR program shall continue beyond the operational phase. Additionally, the CO2QUALSTORE consortium provided comparison of the guideline with the CCSCarbon dioxide Capture and Storage Directive, with the proposed U.S. EPA rules and with the Australian offshore greenhouse gas storage bill. Links with relevant standards such as ISO 31000 are also demonstrated.

The International Energy Agency (IEAInternational Energy Agency) released its CCSCarbon dioxide Capture and Storage Model Regulatory Framework (MRF) in November 2010 (IEAInternational Energy Agency, 2010). It is aimed at governmental bodies from diverse legal and regulatory environments to help them developing their own national regulatory framework. From this respect MRF is not very prescriptive and is not intended to provide detailed solutions. "Model text" is provided in order to facilitate countries to incorporate CO2Carbon dioxide storage issues in jurisdictionally appropriate way. MRF identifies 29 key issues as being critical in the process of regulation of CCSCarbon dioxide Capture and Storage activities - monitoring, verification and reporting being one of them. One of the conclusions of MRF is that most of the CCSCarbon dioxide Capture and Storage regulatory frameworks reviewedhave a similar focus on regulating the storage part and all documents use the methodology for site assessment and monitoring provided by the IPCC Guidelines (IPCC, 2006).

Monitoring, verification and reporting requirements are addressed in the MRF as »CCSCarbon dioxide Capture and Storage specific regulatory« issues. Main objectives for monitoring are addressed: appropriateness of operations, early warning, model calibration and validation and emission inventory. As far as monitoring requirements are concerned, storage authorization applications should include all data necessary for adequate monitoring in operational phase and beyond (results of site characterization, models, baselines, risk assessment etc.), as well as monitoring plan, corrective measures plan, closure plan and post-closure plan. Monitoring strategy and tools should periodically be refined and updated. In case of any incidental event, the storage authorization permit should be reviewed. The exact requirements will need to be determined by the relevant authority on a site or regional basis.

Environmental impact assessment as an integer element of the storage authorization application should identify and provide options for minimising local and regional environmental impacts related to storage. These should include monitoring of the entire storage site (sub-surface, injection facilities, surrounding domain). Baseline measurements should be considered. MRF recognizes the need for clarity in all risk assessment aspects; however, certain flexibility is also needed in project delineation when implementing any regulatory framework. During storage operations, the main regulatory consideration is compliance with agreed modes of operation, monitoring and reporting and inspections. When the operation phase ends, the relevant authority should be notified and provisions for the closure phase shall be enacted.

Monitoring requirements will also apply in case of transboundary CCSCarbon dioxide Capture and Storage projects. The MRF is particularly targeted at countries that are currently developing comprehensive regulatory frameworks to facilitate demonstration projects and/or large-scale projects.