6.2.3 Demonstrating the safety of stored CO2

To demonstrate the safety of CO2 a huge variety of different information can be used, but the main condition being conformity of the monitored data with the predicted models. The EU Guidance Document states that conformity with the model for at least 5 years before transfer of the liability is required. It is also mentioned that the predictions for well pressure, location of the CO2 plume, chemical composition, geochemical changes and surface deformations should lay within a specified uncertainty range, which is defined by the relevant authority.

However, there are different definitions on leakage. The EU CCS Directive 2009/31/EC states that leakage is the "release of CO2 from the storage complex including secondary containment formations". The WRI guidelines define leakage as any significant movement of CO2 outside the confining zone. In the OPA Bill already CO2 migrating outside the defined migration path is considered leakage. In general the definition of the IEA CCS model regulatory framework can be used, where leakage is defined as the unintended release of CO2 from the storage complex into the atmosphere.

Methods to demonstrate the safety of stored CO2 can be any well monitoring of pressure and geochemistry data in the permeable layer above the confining zone, geophysical imaging of the plume and any surface detection-installations like soil-gas monitoring.

The major factor of post closure is still that the system should show stable conditions or at least be evolving towards long-term stability. For these requirements there are different indicators:

  • The rate of change of the key parameters is small or declining; simulations for some thousand years and the requirements for the rate of change of the key parameters is within x%;
  • CO2 is permanently contained. The pressure is lower than the fracturing pressure, geochemistry monitoring and modelling indicate no danger and there is no well corrosion;
  • There is no indication of fault-fracture opening due to micro-seismic events or injection pressure;
  • Injection without any problems.

The requirement of complete stability of the CO2 plume may be over restrictive as the plume can move horizontally at a slow rate without posing any danger. Also the plume may migrate vertically through a non-conventional seal interval over a large time-scale and the CO2 may be dissolved or be lost as residual gas. Another possibility may be that the plume is trapped by buoyancy and slowly dissolving or mineralizing.

International regulations

The OSPAR and London Convention regulations require a post-cessation, site-abandonment plan. They state that monitoring should be continued until "confirmation that probability of any future adverse environmental effects has been reduced to an insignificant level". They leave the final decision up to the relevant authority.

The IEA model framework requires that there is no significant risk of future leakage or any other irregularity. All the required data should be summarized within a report on CO2 behaviour in the reservoir, the modelling results and the anticipated state of the storage system. However, no minimum time period is specified.

European regulations

Article 18 of EU CCS Directive 2009/13/EC requires the operator to show that CO2 is completely contained and that no leakage is occurring. Further the modelled behaviour should match the predictions and the storage system should be evolving towards long-term stability.

USA regulations

EPA UIC requires that the operator is obligated to monitor the site to show the location of the plume, the pressure front and to demonstrate that drinking water is not endangered. It is also required to demonstrate that the pressure front and the CO2plume have stabilized for at least 50 years after cessation of injection that no additional monitoring is required. This is different to the EU Directive on CO2 storage where a trend to stable conditions is required. Also the EPA UIC only mentions drinking water and no other environmental impact caused by the site.

The WRI guidance regulations require data on:

  • Location, magnitude and extent of plume and the region of elevated pressure;
  • CO2 movement and pressure matches predictions;
  • No evidence of significant leakage or failure of confining zone;
  • No potential leakage pathway;
  • Proven well integrity,