Presentation at the Advanced Workshop for CO2 Storage, Mexico City, 26-27 August 2014

1. Monitoring CCS / CCUS Projects for
Greenhouse Gas (GHG) Regulatory Compliance
Pamela Tomski
Senior Advisor, Policy & Regulatory – The Americas
Global CCS Institute
Advanced Workshop for CO2 Storage
August 26-27, 2014
DF IPN ESIA Ticomán Auditorium
SUPPORTED BY:

2. Outline
• Why monitor for greenhouse gas (GHG) regulatory
compliance?
• U.S. GHG reporting
• U.S. Underground Injection Control Program (UIC)
• CCS / CCUS in carbon markets – credits and offsets
• International Standards Organization (ISO) process
for CCS / CCUS
SUPPORTED BY:

3. Monitoring for Regulatory Compliance
From a regulatory perspective, monitoring plans and
monitoring is necessary to:
• Ensure safe, effective, and acceptable CO2 control
• Secure injection well permits
• Confirm / refine CO2 storage modeling predictions
• Verify safe and effective CO2 storage
• Support accounting and verification for credits / offsets
• Promote public confidence
SUPPORTED BY:

4. U.S. Greenhouse Gas (GHG) Reporting
• Requires annual GHG
reporting
• Includes geologic storage –
saline and EOR
• Data is reported to inform
future policy decisions related
to GHGs and CCS
• Information is reported via e-
GGRT (public, web-based
system)
SUPPORTED BY:
US EPA: http://www.epa.gov/ghgreporting/index.html

5. GHG Reporting Rule Subparts (EPA, 2013)
SUPPORTED BY:
US EPA, 2013

6. CO2 Injection Sites Reporting Under Subpart UU
US EPA: http://www.epa.gov/ghgreporting/reporters/subpart/uu.html
SUPPORTED BY:

7. Subpart RR –Geologic Storage
• Subpart RR - well(s) that injects
CO2 for long-term storage
• Reports mass balance: (1)
stored CO2 and (2) CO2 emitted
to atmosphere
• CO2 EOR facilities are not
required to report unless:
- Operator “opts-in” to RR
- Facility holds Class VI
(geologic storage) permit
CO2 received
CO2 injected
CO2 produced
CO2 emitted from
surface leaks
CO2 emitted from
equipment leaks
CO2 source (if known)
MRV Plan
US EPA: http://www.epa.gov/ghgreporting/reporters/subpart/rr.html
SUPPORTED BY:

8. Monitoring Reporting and Verification (MRV)
Plan – Major Elements
1. Identify maximum monitoring area (MMA) and
active monitoring areas (AMA)
2. Identify potential CO2 surface leakage pathways
(EOR focus on wells)
3. Provide a strategy for CO2 leakage detection /
quantification
4. Undertake “baseline” measurements (pre-injection
conditions)
5. Site-specific variables for the mass balance
equation CO2
SUPPORTED BY:
US EPA Class VI Well Project Plan Development Guidance:
http://water.epa.gov/type/groundwater/uic/class6/upload/epa816r11017.pdf

9. Underground Injection Control (UIC) Program
• UIC rules are to protect
underground sources of
drinking water
• Class II – EOR (reports
GHGs under Subpart UU)
• Class II – EOR-storage is
allowed but must “opt-in”
to Subpart RR
• Class VI – Geologic
Storage (reports under
Subpart RR)
US EPA: http://water.epa.gov/type/groundwater/uic/wells_sequestration.cfm
SUPPORTED BY:

10. Comparison of
Requirements:
Class II (EOR) and
Class VI (Geologic
Storage)

11. Class II – VI Transition
• EOR owner or operator with Class II (EOR) permit must
obtain a Class VI (Geologic Storage) permit when both:
(1) the primary purpose of CO2 injection changes
from the recovery of oil to long-term storage, and
(2) that change increases risk to underground
sources of drinking water
• Even if stakeholders agree CO2-EOR should receive
storage credit while remaining within EOR regulatory
framework (Class II), there is no consensus on what MVR
or other standards would be appropriate for verification
SUPPORTED BY:
US EPA Transitioning Class II to Class VI Wells – Guidance:
http://water.epa.gov/type/groundwater/uic/class6/upload/epa816p13004.pdf

12. Regulatory Gaps and Issues
• Like most jurisdictions, the U.S. does not have a comprehensive,
integrated CCS / CCUS regulatory framework
• GHG reporting rules compliment – but are not integrated with -
UIC rules
• Transition from Class II – Class VI is currently not workable
according to EOR operators
• Only EPA can determine site closure, which is unacceptable for mineral
owners who must wind down activities following EOR
• 50-year post-closure monitoring and long-term liability problematic
• There are no standards governing MRV Plans or timelines for EPA
approval
• Many open questions such as – Will purchasers of CO2 from power
plants be expected / required to report under Subpart RR?
SUPPORTED BY:

13. CCS / CCUS in carbon markets – credits and
offsets
• Credits can generate income to offset the cost of CCS /
CCUS (current carbon prices too low to make a
meaningful difference and policy action is needed)
• CCS / CCUS accounting methodologies are still under
development but are considered in some markets:
• Kyoto Protocol Clean Development Mechanism (CDM)
• European Union Emission Trading System (EU ETS)
• Alberta Offset System quantification protocols for EOR
• American Carbon Registry (ACR) – California
• Emerging market linkages (e.g. California / Alberta)
offers potential for Mexico and CCUS projects
SUPPORTED BY:

14. American Carbon Registry (ACR)
• 1st U.S. voluntary carbon registry –
39.5 MMT CO2 since 1996
• Develops and approves carbon
accounting protocols and verifies
projects
• Approved offset registry under
California’s Cap-and-Trade Program
• Five registered CCS projects
including EOR
SUPPORTED BY:
Winrock, 2013

15. ACR Methodology for CCS / CCUS
• Methodology for CCS-EOR / CCUS
developed by Blue Strategies is
currently undergoing peer review
• Ongoing discussions on
methodology for saline storage
• Methodologies are consistent with
industry best practices, EPA
reporting requirements and the
C2ES report Greenhouse Gas
Accounting Framework for Carbon
Capture and Storage Projects (Feb
2012)
http://www.c2es.org/publications/greenhouse-gas-accounting-framework-carbon-capture-and-
storage-projects
SUPPORTED BY:

16. Some key issues and questions
• Project boundary
• Leakage – how long do you
monitor post-injection? How
do you assure permanence?
• Crediting Period – 10 years
or longer to recover
investment
• Eligibility – can ACR be used
to comply with new EPA
proposed rules for power
plants? Class II vs Class VI?
* MRV – should requirements be prescribed or developed on
project basis? Can methodology evolve to incorporate MRV
improvements?
SUPPORTED BY:

17. Standards
• The International Organization for Standards (ISO)
develops and publishes standards
• Developed by a panel with technical committees made
up of experts (e.g. industry, consumer associations,
academia, NGOs, government) from all over the world
• The ISO process is not legislative – it draws on industry
best practices and influences them
• Various jurisdictions often reference ISO standards and
incorporate them into regulatory developments
SUPPORTED BY:

18. World’s first formally recognized CCS standard
SUPPORTED BY:

19. ISO TC 265 for CCS / CCUS - Participating
Countries
Australia Malaysia
Canada Netherlands
China Norway
France South Africa
Germany Spain
India Sweden
Italy Switzerland
Japan United Kingdom
Korea United States (ANSI)
SUPPORTED BY:
 Voting
Members
 Guaranteed
International
Expert
Participation
on all WGs
Steve Carpenter (ARI), 2014

20. ISO TC 265-Working Groups
SUPPORTED BY:
Steve Carpenter (ARI), 2014

21. ISO TC 265-Working Group 6 – CO2-EOR
US Chair, Norway support
• Low-pressure subsurface oil
field operating environments
• Reservoir and pore space
management
• Manage known lateral
stratigraphic traps in the target
formation
• Coordination with WGs1-5
SUPPORTED BY:
 14 US Members
 1 - Norway
 5 - Canada
 2 – China
 2 - Japan
 2 - IEA
 26 Total Members
Expected:
 France
 UK
 Liaisons
Steve Carpenter (ARI), 2014

22. ISO TC 265-Working Group 4 – Quantification &
Verification
China Chair, France support
• Project boundary and leakage
• CO2 quantification
• Monitoring and reporting
• Third party verification
• Life Cycle Analysis
SUPPORTED BY:
Steve Carpenter (ARI), 2014

23. Thank You! Questions?
Pamela Tomski
Senior Advisor, Policy & Regulatory – The Americas
Global CCS Institute
Washington, DC
Pamela.Tomski@globalccsinstitute.com
Tel: 202 390 8896
SUPPORTED BY: