GWPC Workgroup Recommendations For CO2 Injection

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GWPC Workgroup Recommendations For CO2 Injection
John Veil Argonne National Laboratory Presented
at GWPC Policy Meeting March 17-18, 2008
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CO2 Management for Commercial Development
Legal
Technical/ Scientific
Financial
Regulatory
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Successful Commercial Implementation
Legal
Technical/ Scientific
Financial
Regulatory
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Caveats

• This presentation reviews a report prepared by an
  ad-hoc CO2 Workgroup focusing on regulatory
  recommendations
• The workgroup was coordinated under GWPC staff
  supervision but the recommendations have not yet
  been reviewed/ discussed by the GWPC board
• The presentation reflects the collected opinions
  of the work group

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Workgroup Members

• Environmental
• Scott Anderson - Environmental Defense
• Mike Nickolaus - Ground Water Protection Council
• State UIC Regulatory
• Mark Fesmire - New Mexico Division of Oil and Gas
• Ben Knape - Texas Commission on Environmental
  Quality
• Tom Tomastik - Ohio Division of Oil and Gas
• National Laboratories
• John Veil - Argonne National Laboratory
• Oil and Gas Industry
• Steve Crookshank - American Petroleum Institute
• Mike Parker ExxonMobil
• Scott Imbus Chevron
• Andrew Duguid - Schlumberger
• Electric Power Industry
• Theresa Pugh - American Public Power Association
• Legal
• Bob Van Voorhees - Bryan Cave and Associates LLP

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Recommendations Development Process

• Reviewed possible regulatory language scenarios
• Intent of the language
• Technical merit and practicality
• Consistency with existing UIC regulatory program
  language
• Developed a recommendations report

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Topical Discussion Areas

• Geologic Characterization
• Fluid Movement
• Area of Review (AOR)
• Well Construction
• Operation
• Mechanical Integrity Testing
• Measurement Monitoring and Verification
• Well Closure
• Financial Responsibility

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Format of Recommendations Document

• For each subtopic under the 9 main topics, the
  document includes
• Alternative regulatory approaches
• List of comments received from a survey of state
  regulatory agencies
• Workgroup recommendations
• Rationale for the recommendations
• An appendix includes comments received from other
  interested parties not on the workgroup

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Topic 1 - Geologic Characterization

• Recommendation 1.1- Geological System
• A geologic system comprised of
• An injection zone of sufficient depth, areal
  extent, thickness, porosity, and permeability
• A confining zone that is free of transecting
  transmissive faults and fracture zones
• A confining zone of sufficient areal extent and
  integrity to confine injected fluid and allow
  injection at proposed rates and volumes without
  reactivating transecting, transmissive faults or
  initiating or propagating transecting,
  transmissive fractures in any confining zone.

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Topic 1 - Geologic Characterization

• Critical Elements of Recommendation 1.2 Site
  Information
• Requirement to provide geologic and hydrologic
  properties of site including
• Names and descriptions of injection and confining
  zones
• Maps and cross sections of local geologic
  structure
• Known faults and fracture zones and an assessment
  of their effect on confinement
• A tectonic seismic history showing location,
  depth and magnitude of seismic events

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Topic 1 - Geologic Characterization

• Critical Elements of Recommendation 1.3 Site
  Characterization
• The subsurface within the AOR should be
  characterized based on
• Data acceptable to the regulatory authority about
  areal extent, thickness, porosity, and
  permeability of the injection zone and confining
  zone
• An estimation of injection zone capacity
• Geomechanical information on natural and induced
  fractures, rock stress and in-situ fluid pressure
  in the confining zone
• Maps and cross sections showing regional geology
  and stress state

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Topic 1 - Geologic Characterization

• Critical Elements of Recommendation 1.4 USDW
  Information
• Provide information to the regulatory authority
  including
• Name, depth and areal extent of USDWs that may be
  affected by injection
• Geochemistry and hydrology of the injection zone,
  confining zones and USDWs such as baseline fluid
  chemistry and geochemistry, formation porosity,
  permeability, pressure and either storage
  capacity or poroelastic parameter acceptable to
  the Director

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Topic 2 - Fluid Movement

• Recommendation 2 Fluid Movement
• Wells must be constructed, operated, maintained,
  converted, plugged, and abandoned in a manner
  that prevents the movement of fluid containing
  any contaminant into underground sources of
  drinking water, if the presence of that
  contaminant may cause a violation of any primary
  drinking water regulation under 40 CFR part 142
  or may otherwise adversely affect the health of
  persons.

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Topic 3 - Area of Review

• Recommendation 3.1 AOR Determination
• The AOR should be determined and re-evaluated
  during the life of project as necessary, based on
  generally accepted and site relevant techniques,
  such as modeling, that define, in three
  dimensions, the maximum extent of the modeled CO2
  plume and associated pressure front. Any models
  used must account for the buoyant nature and
  specific properties of separate phases of
  injected CO2, and the multi-phase nature of
  fluids within the injection zone.

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Topic 3 - Area of Review

• Recommendation 3.2 Artificial Penetration
  Identification
• Provide information on the AOR including
• Maps and cross sections
• A description of each artificial penetration of
  the confining zone, including active and
  abandoned wells, in the AOR. The description
  shall include all relevant available information
  on the well or penetration type, construction,
  date drilled, location, depth, record of plugging
  and/ or completion, and any additional
  information the Director may require.

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Topic 3 - Area of Review

• Recommendation 3.3 - Corrective Action
  Identification
• Review all available data on all abandoned wells
  in the AOR, assess if they have been plugged in a
  manner that prevents the movement of fluid
  containing any contaminant into a USDW, if the
  presence of that contaminant may cause a
  violation of any primary drinking water
  regulation under 40 CFR part 142 or may otherwise
  adversely affect the health of persons.

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Topic 3 - Area of Review

• Recommendation 3.4 Corrective Action
• Remediate those artificial penetrations in the
  AOR, as necessary, to prevent the movement of
  fluid containing any contaminant into a USDW, if
  the presence of that contaminant may cause a
  violation of any primary drinking water
  regulation under 40 CFR part 142 or may otherwise
  adversely affect the health of persons.

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Topic 4 - Well Construction

• Critical Elements of Recommendation 4.1- Well
  Construction and Fluid Movement
• Construction should prevent movement of fluids
  into USDWs that may cause a violation of any
  primary drinking water standard
• Long strings should be cemented above the top of
  the injection and confining zones
• Appropriate logs and other tests shall be run
  during well construction
• Logs and test shall be interpreted by a
  knowledgeable log analyst and the results
  submitted to the regulatory authority

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Topic 4 - Well Construction

• Critical Elements of Recommendation 4.3 Casing
  and Cement
• Casing and cement designed for the operating life
  expectancy of the well
• Specifications for casing and cement that factor
  in
• Depths of injection zone and USDWs
• Pressures (injection, internal, external, axial
  loading)
• Hole size and size and grade of casing strings
• Injection fluid characteristics
• Lithology of injection and confining intervals
• Type and grade of cement
• Planned well operation results on casing/ cement

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Topic 4 - Well Construction

• Critical Elements of Recommendation 4.3
  (continued)
• Specifications for tubing, packer and annular
  fluid that factor in
• Packer setting depth and temperature at that
  depth
• Pressures (injection, annular)
• Injection fluid characteristics
• Rate, temperature, composition, and
  volume of injection
• Casing size, weight, and grade

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Topic 4 - Well Construction

• Recommendation 4.4 Tubing and Packer
• Inject through tubing and packer that is set
  opposite a cemented interval of the long string
  casing above the uppermost perforation or open
  hole for the injection zone at a depth acceptable
  to the Director

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Topic 5 - Operation

• Recommendation 5.1- Injection Pressure
• Injection should be conducted such that the
  pressure during injection and storage does not
  initiate new transecting or transmissive
  fractures or propagate existing fractures in the
  confining zone exceed the seal competence of the
  confining zone, or cause transecting faults that
  are not transmissive to become transmissive.

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Topic 5 - Operation

• Recommendation 5.3 Operational Monitoring
• Throughout injection, continuously monitor,
  without precluding the use of digital monitoring,
  the injection pressure, flow rate, injected
  volumes, and pressure on the annulus between the
  tubing and the long string casing

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Topic 5 - Operation

• Recommendation 5.4 - Automatic Shutoff Equipment
• Equip injection wells with safety shutoff
  equipment that engages if any operating
  parameters are exceeded

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Topic 5 - Operation

• Recommendation 5.5 Odorants and Tracers
• The use of tracers is not recommended except
  under specific risk-based site-by-site
  conditions.

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Topic 5 - Operation

• Recommendation 5.6 Corrosion Monitoring Plan
• Submit a corrosion monitoring and prevention plan
  for wells acceptable to the Director

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Topic 6 - Mechanical Integrity Testing

• Recommendation 6.1- Mechanical Integrity
  Demonstration
• Demonstrate mechanical integrity using a method
  and at a frequency acceptable to the Director
• A well has mechanical integrity it there is no
  significant leak in the casing, tubing and packer
  and there is no significant fluid movement into a
  USDW through vertical channels adjacent to the
  injection well bore

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Topic 7 - Monitoring, Measuring and Verification

• Recommendation 7.1- Baseline Determination
• Conduct baseline geochemical analysis within the
  injection and confining zones before injection
  commences

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Topic 7 - Monitoring, Measuring and Verification

• Recommendation 7.2 Injection Fluid Monitoring
• Monitor the nature of injected fluids at a
  frequency sufficient to yield data representative
  of their characteristics and to demonstrate their
  compatibility with the well materials

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Topic 7 - Monitoring, Measuring and Verification

• Recommendation 7.3 Geochemical Monitoring
• Monitor geochemical changes of the confining zone
  using a network of monitoring that could be
  conducted from injection or observation wells,
  that are constructed consistent with the
  requirements of recommendation 4.3 and whose
  number and location are sufficient to monitor
  geochemical changes.

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Topic 7 - Monitoring, Measuring and Verification

• Recommendation 7.4 Plume Monitoring
• Conduct monitoring to evaluate the injection zone
  performance using methods and frequencies
  acceptable to the Director

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Topic 7 - Monitoring, Measuring and Verification

• Recommendation 7.5 Monitoring Plan
• Develop and implement a plan for monitoring
  chemical and physical changes of USDWs within the
  AOR caused by leaking CO2 or movement of fluids
  related to CO2 injection

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Topic 7 - Monitoring, Measuring and Verification

• Critical Elements of Recommendation 7.6
  Modeling and Reporting
• Report the characteristics and cumulative volumes
  of injected fluids, injection and annular
  pressures, injection rates for each injection
  well.
• Report the results of any MITs conducted during
  this time period, and the extent of the injected
  CO2 and the pressure front based on current data.
• Update site operations and site modeling results
  reflect current data.  
• Compare the updated results to the previous
  results. 
• Identify and explain to the Director any
  discrepancies between the updated results and the
  previous results.

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Topic 7 - Monitoring, Measuring and Verification

• Recommendation 7.7 Post-Closure Monitoring
• Conduct post-closure monitoring, and associated
  modeling, for a period sufficient to demonstrate
  to the Director that fluid movement will not
  endanger USDWs

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Topic 8 - Well Closure

• Recommendation 8.1 Plugging Preparation
• Flush the well with a buffer fluid

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Topic 8 - Well Closure

• Recommendation 8.2 Well Stabilization
• Ensure that the well is in a state of static
  equilibrium prior to the placement of the final
  plug

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Topic 8 - Well Closure

• Recommendation 8.3 Plugging Methods and
  Materials
• Plug the well with cement in a manner that will
  prevent the movement of fluid containing any
  contaminant into a USDW, if the presence of that
  contaminant may cause a violation of any primary
  drinking water regulation under 40 CFR part 142
  or may otherwise adversely affect the health of
  persons
• The cement used should be compatible with the
  injected fluids

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Topic 8 - Well Closure

• Recommendation 8.4 Plug Placement and Testing
• Place and test cement plugs by a method
  acceptable to the Director

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Topic 8 - Well Closure

• Recommendation 8.5 - Pre-plugging Mechanical
  Integrity Demonstration
• Ensure the internal and external integrity of
  that portion of the long string casing and cement
  that will be left in the ground after closure

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Topic 9 - Financial Responsibility

• Recommendation 9 - Plugging and Post Closure
  Monitoring Assurance
• Demonstrate and maintain financial responsibility
  for closure of the well(s) and post-closure
  monitoring

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Workgroup Approach and Recommendations

• Use the language of the existing UIC program
  while stressing performance-based standards
• Provide regulatory certainty and consistency to
  industry, while preserving regulatory flexibility
• Avoid the imposition of impractical, costly and
  unnecessary requirements that would impede
  implementation
• Take advantage of the current state of knowledge
  about underground injection of CO2
• Avoid the use of language that could result in
  unintended consequences

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Where Do We Go from Here?

• Provide the recommendations to the GWPC Board of
  Directors for review/ discussion
• Provide the recommendations to state agencies,
  industry representatives, and environmental
  stakeholders for comment
• Use the recommendations and updated comments from
  stakeholder groups as the foundation for
  submitting comments to EPA following publication
  of the draft regulations in the Federal Register

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