This chapter provides an overview how monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions 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 CCSCarbon dioxide Capture and Storage projects have incorporated monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions plans in their permit applications.
Regulatory regimes in different countries across the world vary. Some countries chose an integrated approach to CCSCarbon dioxide Capture and Storage regulation (i.e. to develop stand-alone legislation), while others decided for a piecemeal approach (i.e. basically amending/updating existing laws and regulations). However, many regulatory regimes took the IPCCIntergovernmental Panel on Climate Change Special Report (IPCCIntergovernmental Panel on Climate Change; 2005) and IPCCIntergovernmental Panel on Climate Change Guidelines (IPCCIntergovernmental Panel on Climate Change, 2006) as a starting point. The EUEuropean Union and Australia can be considered the leading players in establishing CCSCarbon dioxide Capture and Storage related regulation frameworks, closely followed by the US and Canada.
A comparison of regulatory documents from different jurisdictions showed, that the objectives for monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions are similar in terms of tracking the injected fluid in the subsurface and to monitor key risks related to HSEHealth, safety and environment. There is also a common denominator, that monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions plans should be riskConcept that denotes the product of the probability of a hazard and the subsequent consequence of the associated event and objectives based, site specific and non-prescriptive in terms of technologies applied. While the EUEuropean Union regulation is entirely focused on emissions reductionThe gain of one or more electrons by an atom, molecule, or ion objectives, the USA regulation seems more focused on enhanced oil production (EOREnhanced Oil Recovery: the recovery of oil additional to that produced naturally, achieved by fluid injection or other means) and so called CCUS (carbon captureThe separation of carbon dioxide from other gases before it is emitted to the atmosphere, use and storage(CO2) A process for retaining captured CO2, so that it does not reach the atmosphere). EUEuropean Union legislation does accept combined EOREnhanced Oil Recovery: the recovery of oil additional to that produced naturally, achieved by fluid injection or other means and CCSCarbon dioxide Capture and Storage operations, though strictly regulated through the CCSCarbon dioxide Capture and Storage Directive. Moreover, EUEuropean Union legislation requires permanency of stored CO2Carbon dioxide, while the US (and Canadian) legislation seem to accentuate stronger the utilisation of injected CO2Carbon dioxide. In all cases long-term liability provisions need further revision and consolidation.
After reviewing the EUEuropean Union and other international/national legislation related to monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions we can summarize, that regular reporting of the results of monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions to some kind of competent authority is always requested. In order to verify the content, the performance quality and the relevancy of specific operational procedures and/or corrective measures taken, it will be crucial the reports are inspected by a competent authority. In Annex V of the ETSEmissions Trading System, defined in the EU ETS Directive 2003/87/EC amended by Directive 2009/29/EC Directive minimum competency requirements for the verifier are stated. However, the EU CCS DirectiveDirective 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide does not deal with issues concerning verifier's competency. It may be worth considering the introduction of standards for verification(CO2 storage) The proof, to a standard still to be decided, of the CO2 storage using monitoring results; (in the context of CDM) The independent review by a designated operational entity of monitored reductions in anthropogenic emissions bodies regarding their knowledge, experiences, independency etc. This may result in the introduction of an accreditation procedure for verifiers under the CCSCarbon dioxide Capture and Storage Directive at different levels (national, international).
The permanency of containmentRestriction of the movement of a fluid to a designated volume (e.g. reservoir) of CO2Carbon dioxide underground, other than in case of most other subsurface uses, implicates that monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions data shall be acquired for much longer periods. This issue is related to the handover and specific liability requirements of the state where CCSCarbon dioxide Capture and Storage takes place.
Data retention and ownership of the information from monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions reports are mentioned in Guidance Document 2 and possible solutions are offered. For example in Europe at present, it is up to the Member States to choose which approach to follow and to establish appropriate regulations concerning the access to and the rights to use the information. It is important to balance between proprietary rights and the transparency for public. At many events (conferences, workshops, panel debates etc.), the dilemma on whether the results of monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions shall be communicated to a general public arises. Eminent discussion participants (scientists, stakeholders, regulators) are of the opinion that openness and transparency should be a top priority. At least two reasons exist for such conviction: firstly the ability to develop new knowledge through circulation of information and secondly to build public confidence in CCSCarbon dioxide Capture and Storage technology. However, how, who and to what extent to communicate the monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions results (and other information on CCSCarbon dioxide Capture and Storage in general) remains ambiguous.
Only a limited number of examples of industrial scale integrated projects falling under recent CCSCarbon dioxide Capture and Storage legislation are available. A few of them have been evaluated in this document. Though differences can clearly be identified, all examples follow a similar riskConcept that denotes the product of the probability of a hazard and the subsequent consequence of the associated event-based approach for defining the monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions plan.
In all cases wells were identified as potential hazards, either in terms of potential CO2Carbon dioxide leakage(in CO2 storage) The escape of injected fluid from the storage formation to the atmosphere or water column along the wellboreThe physical hole that makes up the well, it can be cased, open, or a combination of both; open means open for fluid migration laterally between the wellbore and surrounding formations; cased means closing of the wellbore to avoid such migration, or induced brine migrationThe movement of fluids in reservoir rocks by the elevated pressures in the reservoirA subsurface body of rock with sufficient porosity and permeability to store and transmit fluids. MonitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions tecniques selected depend on the geological settingThe geological environment and on the type of wells. Nevertheless, the monitoringMeasurement and surveillance activities necessary for ensuring safe and reliable operation of a CGS project (storage integrity), and for estimating emission reductions plans do show many similarities.
Probably an issue, that needs to be dealt with in more detail, is on the handling of uncertainties. As stated earlier: "Models should represent the entire uncertainty range, but need to provide sufficient confidence at the same time to carry on the operations."