Overview of the IOGCC Phase II Carbon Capture and Geological … 1/IEA Network... · 2013-07-25 ·...
Transcript of Overview of the IOGCC Phase II Carbon Capture and Geological … 1/IEA Network... · 2013-07-25 ·...
REDUCING ANTHROPOGENIC SOURCES OF GREENHOUSE GASES
• ENERGY CONSERVATION• INCREASING ENERGY EFFICIENCIES• USE OF RENEWABLE ENERGY SOURCES• USE OF NON-FOSSIL FUEL ENERGY
SOURCES,SUCH AS NUCLEAR, HYDROGEN AND OTHER DEVELOPING TECNOLOGIES
• SEQUESTRATION THROUGH NATURAL PROCESSES OR PHYSICAL STORAGE
Overview StatementsFollowing conservation, geologic storage of CO2 is among the most immediate and viable strategies for mitigating the release of CO2 into the atmosphere. Envision that the report will result in a substantially consistent system for the geological storage of CO2 regulated at the state and provincial level in conformance with national and international law. Given the proposed long-term care-taker role of the states, they are likely to be the best positioned to provide the necessary cradle to grave regulatory oversight of CO2 storage.”
Lawrence Bengal, Chairman of the IOGCC Task Force
Brief Summary of Phase I Work and Recommendations
• Industry and states have 30 years experience in the production, transport and injection of CO.
• States have necessary regulatory analogues in place to facilitate development of a comprehensive CCGS regulatory framework.
• CO2 should be regulated as a commodity to allow the application of oil and gas conservation laws which will facilitate development of storage projects.
• Involve all stakeholders including general public in the development of regulatory frameworks.
Phase II Task Force Objectives
1. Creation of a nationwide guidance document, approved by the IOGCC, which is specific enough to enable each state to develop its own statutes and regulations while at the same time helping to lay the essential groundwork for a state- regulated, but nationally consistent, “cradle to grave” system for the capture and geologic storage of CO2.
2. Provide assistance to Regional Partnership Pilot Projects in (a) understanding and complying with regulatory requirements for field testing and injection; and (b) work with member state in implementing draft model laws and regulations and assessing adequacy of those laws and regulations.
Phase II Task Force ParticipantsBengal, Lawrence E., Chairman
DirectorOil and Gas Commission of Arkansas
Anderson, A. ScottSenior Policy AdvisorEnvironmental Defense, Austin
Bachu, Stefan, Ph.D., P.Eng.Senior AdvisorAlberta Energy and Utilities Board
Baza, John R.DirectorUtah Department of Natural ResourcesDivision of Oil, Gas & Mining
Bliss, KevinTask Force CoordinatorIOGCC Washington Representative
Braxton, Lowell ConsultantInterstate Oil and Gas Compact Commission
Carr, Timothy R.Petroleum Research Section Chief, Kansas Geological Survey
Coddington, KippPartner Alston & Bird Law Firm, Washington, DC
Coombs, Mary JaneResearch CoordinatorCalifornia Institute for Energy & EnvironmentUniversity of CaliforniaOffice of the PresidentWest Coast Regional Carbon Sequestration
Partnership (WESTCARB)Cooney, David Jr.
Environmental Affairs Attorney Railroad Commission of Texas
Curtiss, David K.Manager of International Strategy and Development / Senior Advisor to the DirectorEnergy & Geoscience InstituteUniversity of UtahSouthwest Regional Partnership on Carbon
SequestrationDrahovzal, James A, Ph.D.
Geologist and Section HeadKentucky Geological SurveyMidwest Regional Carbon Sequestration
Partnership (MRCSP) Esposito, Dr. Patrick
Chief Executive OfficerAugusta SystemsSoutheast Regional Carbon Sequestration
Partnership (SECARB)
Phase II Task Force ParticipantsFesmire, Mark E., PE
DirectorNew Mexico Oil Conservation DivisionNM Energy, Minerals and Natural Resources Department
Finley, Robert J.DirectorEnergy and Earth Resources CenterIllinois State Geological SurveyMidwest Geological Sequestration Consortium (MGSC)
Harju, JohnAssociate Director for Research Energy & Environmental Research CenterUniversity of North DakotaPlains CO2 Reduction (PCOR) Partnership
Hansen, ChristineExecutive DirectorInterstate Oil & Gas Compact Commission
Helms, LynnDirectorDepartment of Mineral Resource North Dakota Industrial Commission
Lawrence, Rob *Senior Policy Advisor-Energy Issues
U.S. Environmental Protection AgencyRegion 6 Office, Dallas, Texas
Mankin, CharlesDirctor/State GeologistOklahoma Geological Survey
Melzer, StephenConsulting EngineerMelzer Consulting
O’Dowd, WilliamProject ManagerNational Energy Technology Laboratories
Patchen, Douglas G.Chief GeologistWest Virginia Geological Survey
Perkowski, Joseph C.ManagerEnergy Initiatives Idaho National LaboratoryBig Sky Carbon Sequestration Partnership
* Observer
Phase II Task Force ParticipantsRogers, Marvin
Legal CounselState Oil and Gas Board of Alabama
Salzman, Stephen D. *Deputy Division Chief, Fluid MineralsBureau of Land Management Headquarters, Washington, DC
Smith, MikeAttorney at LawDunlap, Codding & Rogers Law FirmOklahoma
Stettner, Michael D.Sr. Oil and Gas EngineerCalifornia Division of Oil & Gas and Geothermal Resources
Taylor, CammyPetroleum Land ManagerDivision of Oil and GasAlaska Department of Natural Resources
Tew, Berry H. (Nick)State Geologist/Oil & Gas SupervisorGeological Survey of AlabamaState Oil and Gas Board of Alabama
Williams, Michael L.ChairmanTexas Railroad Commission
* Observer
The Task Force strongly believes that treatment of geologically stored CO2 as waste using waste disposal frameworks rather than resource management frameworks will diminish significantly the potential to meaningfully mitigate the impact of CO2 emissions on the global climate through geologic storage.
Appropriate Regulatory Framework
CO2 CAPTURE TRANSPORTATION AND GEOLOGIC STORAGE PROCESS
Existing State and Federal Regs Existing State and Federal
Pipeline Regs.Existing UIC Regs
Long Term Storage Regs Missing
Task Force Guiding Principles
• MUST BE SEAMLESS – maximize economic and environmental benefits, establish “cradle to grave” framework to provide for fully integrated regulatory oversight and clearly identify risk parameters for industry.
• KEEP IT SIMPLE – do not over-regulate for the exotic, initially address what will most likely occur, amend regulations with experience.
• BE FLEXIBLE AND RESPONSIVE – modify as gain knowledge with easy projects, respond to constantly changing technologies, which is a certainty, “one size” will not fit all projects.
• “DOABLE” - implement regulations which can be fielded now, problems will occur, but most are solvable, can not be focused on resolving every conceivable issue before initiating regulations.
• MAINTAIN POSITIVE PUBLIC PRESENTATION – CGS is part of a solution with economic and environmental benefits and not a waste problem waiting for a regulatory protection solution.
Guidance Document Components:• Analysis of Property Rights Issues Related
to Underground Space Used for Geologic Storage of Carbon Dioxide
• Overview and Explanation of the Model General Rules and Regulations
• Model Statute for Geologic Storage of Carbon Dioxide
• Model General Rules and Regulations
STATE ADMINISTERED “CRADLE TO GRAVE” CGS REGULATORY FRAMEWORK
SITE LICENSING AND CERTIFICATION
STATE MODIFIED GAS STORAGE AND UNITIZATION REGULATIONS
SITE AND WELL OPERATIONS
STATE MODIFIED GAS STORAGE AND UIC REGULATIONS
SITE CLOSURE AND WELL PLUGGING
STATE MODIFIED UIC AND GAS STORAGE REGULATIONS
LONG TERM
STORAGE STATE ADMINISTERED MODIFED ABANDONED WELL PROGRAM
INCORPORATE FEDERAL UIC “LIKE” WELL OPERATIONAL REQUIRMENTS IN A STATE RUN PROGRAM (EXCLUDES FEDERAL OVERSIGHT AUTHORITY)
STATE CERTIFICATION AS QUALIFIED CGS PROJECT (INCLD EOR)
Analysis of Property Rights Issues Related to Underground Storage • Control of the reservoir and associated pore space used
for CO2 storage is necessary to allow for orderly development
• The right to use reservoirs and associated pore space is considered a private property right in the United States, and must be acquired from the owner.
• Control of the necessary storage rights should be required as part of the initial storage site licensing to maximize utilization of the storage reservoir.
• In the U.S., with the exception of federal lands, the acquisition of these storage rights, which are considered property rights, generally are functions of state law.
STATE ADMINISTERED FRAMEWORK “CRADLE TO GRAVE” CGS REGULATORY
SITE LICENSING AND CERTIFICATION
OPERATIONAL BOND
SITE AND WELL OPERATIONS
INDIVIDUAL WELL BONDS
SITE CLOSURE AND WELL PLUGGINGLONG TERM
STORAGE
BONDS RELEASED AS WELLS PLUGGED
BOND RELEASED 10 YEARS AFTER INJECTION CEASES
PAYMENT OF STORAGE FEE
STATE ADMINISTERED TRUST FUND ASSUMES RESPONSIBILITY FOR OVERSIGHT AND LIABILITY
STATES CURRENTLY DEVELOPING REGULATIONS USING DRAFT VERSIONS OF MODEL REGULATIONS
• New Mexico
• California
• North Dakota
• Texas
• At least 5 other states beginning work
MMV Components of Draft Regulations• Task Force has proposed a two-stage Closure Period and Post-
Closure Period to deal with long-term monitoring and liability issues. • Operator of the storage site would be liable for a period of ten years
after the injection site is plugged, unless otherwise designated by the state regulatory agency.
• At the end of the Closure Period, the liability for ensuring that the site remains a secure storage site during the Post-Closure Period would transfer to the state.
• A trust fund that is industry-funded and state administered would provide the necessary oversight during the Post-Closure Period. The trust fund would be funded by an injection fee assessed to the Carbon Storage Project operator and calculated on a per ton basis.
Framework – 4 Analogues1) naturally occurring CO2 contained in geologic reservoirs, including
natural gas reservoirs; 2) the large number of projects where CO2 has been injected into
underground formations for EOR operations; 3) storage of natural gas in geologic reservoirs; and 4) injection of acid gas (a combination of H2S and CO2), into underground
formations, with its long history of safe operations. • Together the EOR, natural gas storage, and acid gas injection models
provide a technical, economic, and regulatory pathway for long-term CO2 storage.
• However, owing to the scarcity of post-injection CO2 EOR projects and abandoned natural gas storage fields, inadequate guidance for a long- term CO2 storage regulatory framework exists.
• Consequently, a regulatory framework needs to be established to determine long-term liability and to address long-term monitoring and verification of the reservoir and mechanical integrity of wellbores penetrating formations in which CO2 has been emplaced.