5.2 Regulatory regimes and guidelines relevant to CO2 storage remediation

A systematic approach to the selection and qualification of storage sites and projects for CO2 geological storage is provided by the CO2QUALSTORE guideline (Aarnes et al., 2010). Its intention is to harmonise the implementation of CGS in compliance with regulations, international standards and directives while avoiding additional documentation and reporting requirements. This is fully valid also for storage site remediation, although the authors use the terms contingency, contingency plan, contingency measures, contingency monitoring, rather than remediation.

CO2QUALSTORE considers contingency and remediation planning an essential part of the risk and uncertainty management. Planned contingency measures represent one type of measures aimed at reduction of risk and associated uncertainties. In the bow-tie risk management model (Fig. 5-3), remediation and mitigation measures are part of the consequence reducing measures (right part of the diagram) that are implemented after a feature, event or process (FEP) has occurred. They can be regarded as emergency response measures. A collection of such measures should be assessed and planned in a contingency (remediation) plan. In general, such plans should provide sufficient confidence to the regulators as well as to other stakeholders, including the public, that the storage site will provide long-term storage of CO2.

O. Fig. 5-3

Fig. 5-3: Bow-tie risk management model according to CO2QUALSTORE (Aarnes et al., 2010). Mitigation and remediation are part of consequence reducing measures (right-hand part of the diagram).

The guideline suggests as a good practice that early warning signals (of an irregularity or leakage) detected by base case monitoring trigger additional contingency monitoring, aimed at acquisition of additional data that can be used, among others, to properly select and design remediation measures. The whole process represents a part of the risk-reduction procedure, as illustrated by the risk reduction triangle in Fig. 5-4.

O. Fig. 5-4

Fig. 5-4: Risk reduction triangle according to CO2QUALSTORE (Aarnes et al., 2010). Remediation is shown at the bottom vertex of the triangle

CO2QUALSTORE recommends that a contingency plan is an integral part of a CO2 development plan, the basic component of a storage permit application ( Fig. 5-5). The contingency plan is defined as a plan to implement corrective measures, if a significant irregularity occurs. The corrective measures should be prioritised and ranked according to the assessed cost-effectiveness of their risk/uncertainty reducing effect. In addition, the plan should document that conceivable significant irregularities can be adequately controlled, and express the project developer's commitment to implement appropriate contingency measures, if necessary.

O. Fig. 5-5

Fig. 5-5: Components of the CO2 storage development plan according to CO2QUALSTORE (Aarnes et al., 2010).

Appendix B4 of CO2QUALSTORE (Aarnes et al., 2010) provides detailed guidelines on the preparation of the Contingency plan. The plan should be drafted together with another document - the Impact hypothesis. Both documents should be based on the conclusions of basic documents of the previous phase of storage site development procedure - the Environmental Impact Assessment (EIA) and the Storage Performance Forecast (SPF). While the impact hypothesis should focus on measures to prevent significant irregularities under normal operating conditions, the contingency plan should contain corrective measures plan for alternative scenarios (Fig. 5-6). In particular, the plan should describe how to control site performance scenarios that differ from the base case scenario during the operational lifetime of a CO2 geological storage project, and provide assurance that these scenarios can be adequately managed. Both documents together form the project risk management plan.

The key input to the development of the contingency plan is the risk and uncertainty assessment, including the assessed effectiveness of risk/uncertainty reducing measures (safeguards), and the defined project performance targets. Therefore, the process of developing the plan should start by reviewing the results of the risk and uncertainty assessment. For each of the identified risks, a list of associated safeguards should be compiled. Moreover, a rough estimate of the costs of each safeguard should be provided in order to be able to rank the corresponding cost-effectiveness of alternative safeguards.

The contingency plan should demonstrate that the collection of safeguards provide adequate assurance that the worst-case scenarios associated with the identified risks can be adequately controlled. For this purpose, it may be useful to classify the safeguards according to their objectives. For instance, it should be demonstrated that all safeguards aiming to manage and constrain reservoir pressure together provide adequate assurance that pressure can be properly controlled.

The contingency plan should describe contingency measures for a sufficiently broad range of alternative site performance scenarios, and provide rough estimates of the associated costs.

In general, current regulatory frameworks and supporting guidelines tend to a consensus that approaches for proper site management procedures must be tailored to the unique characteristics of each site (i.e., they should be site-specific). Risk-based approaches are promoted. These approaches direct attention towards the most significant risks, as opposed to consequence based approaches that direct attention towards events with the largest consequences. This gives more flexibility in the project design to project developers, and more influence on project management to the regulators. The risk-based approaches also give an incentive to reduce risks beyond established minimal thresholds. Acceptable risk levels, accompanied by proper remediation (contingency) plans, should be defined on a case by case basis for each project through an interactive dialogue between regulators and project developers (Aarnes et al., 2010).

O. Fig. 5-6

Fig. 5-6: Workflow for preparation of the Impact hypothesis (IH) and Contingency plan (CP) according to CO2QUALSTORE (Aarnes et al., 2010).

It also needs to be taken into account that the whole cycle of site characterisation, risk-assessment (including contingency and remediation planning) and monitoring and verification is a continuous process that extends throughout the project life-cycle. This means, among others, that all the relevant documents, including remediation (contingency) plans, should be periodically revised, according to the improved knowledge of the reservoir and its behaviour.

It is probable that a review and update of the storage permit is required during the operational phase. For instance, the EU CCS Directive (2009) requires a permit review not more than five years after issuing the permit and then after every 10 years. Moreover, a review, update or withdrawal of the storage permit can be ordered, based on subject to certain criteria, incl. a leakage or significant irregularity.

The US EPA rule (USEPA, 2010) suggest similar criteria and periods for permit review, although the injection permit is issued for the operating life of a CGS project. In case of significant irregularities, leakage, altered operation conditions, understanding that the storage integrity may be compromised or that the permit conditions may have been breached, a re-qualification of the permit is necessary.

Besides the above, other available general regulations and standards that are in broad agreement with the CO2QUALSTORE guidelines include the IEA CCS Model Regulatory Framework (IEA, 2010), the Canadian standard on CO2 storage CSA Z741 (CSA, 2012) and the more general risk management ISO 31000 (ISO, 2009).

The next section focuses on the regulatory regimes that are in place in various parts of the world where CO2 storage activities are on-going or likely to start in near future (Europe, USA, Canada and Australia).

 

in depth

5.2.1 Regulatory regime for site remediation in Europe

The EU CCS Directive and its Guidance Documents 1 and 2 represent the principal regulatory regime for all EU Member Stat...

5.2.2 Regulatory regimes for site remediation worldwide

The OSPAR Guidelines for Risk Assessment and Management of Storage of CO2 Streams in Geological Formations include a Fra...

5.3 Conclusions

Remediation measures are an integral part of regulatory regimes for CCS in all relevant countries and regions where CCS ...