The Leakage Risk Monetization Model for Geologic CO2 Storage.

We developed the Leakage Risk Monetization Model (LRiMM) which integrates simulation of CO2 leakage from geologic CO2 storage reservoirs with estimation of monetized leakage risk (MLR). Using geospatial data, LRiMM quantifies financial responsibility if leaked CO2 or brine interferes with subsurface resources, and estimates the MLR reduction achievable by remediating leaks. We demonstrate LRiMM with simulations of 30 years of injection into the Mt. Simon sandstone at two locations that differ primarily in their proximity to existing wells that could be leakage pathways. The peak MLR for the site nearest the leakage pathways ($7.5/tCO2) was 190x larger than for the farther injection site, illustrating how careful siting would minimize MLR in heavily used sedimentary basins. Our MLR projections are at least an order of magnitude below overall CO2 storage costs at well-sited locations, but some stakeholders may incur substantial costs. Reliable methods to detect and remediate leaks could further minimize MLR. For both sites, the risk of CO2 migrating to potable aquifers or reaching the atmosphere was negligible due to secondary trapping, whereby multiple impervious sedimentary layers trap CO2 that has leaked through the primary seal of the storage formation.

Regulating geologic sequestration in the United States: early rules take divergent approaches.

Regulations for geological sequestration (GS) of carbon dioxide (CO2) have been adopted in the state of Washington and proposed by the state of Kansas and the U.S. Environmental Protection Agency (EPA) Underground Injection Control (UIC) Program. These three sets of rules take significantly different approaches to regulating GS of CO2. This paper compares these rules, focusing on elements where their differences highlight the choices that must be made to create a regulatory framework for GS in the United States. Consensus is emerging in some areas, but there is still substantial disagreement regarding the allowable composition of the CO2 stream, the size of the area of review, reservoir performance goals, and management of risks other than those to groundwater. Gaps include issues related to ownership of subsurface pore space, greenhouse gas accounting, and long-term stewardship. The divergent approaches of these rules raise two overarching questions: (1) Should policy makers create GS regulations by modifying and supplementing UIC rules or through new enabling legislation? (2) What should be the relative roles of state and federal governments in GS regulation? We outline trade-offs between the consistency and coordination that federal involvement could offer and the reality that states need to be heavily involved with implementation of GS regulations. We conclude that federal involvement above and beyond the proposed EPA Class VI rules is needed to create effective GS regulation in the United States.

Regulating the geological sequestration of CO2.

Governments worldwide should provide incentives for initial large-scale GS projects to help build the knowledge base for a mature, internationally harmonized GS regulatory framework. Health, safety, and environmental risks of these early projects can be managed through modifications of existing regulations in the EU, Australia, Canada, and the U.S. An institutional mechanism, such as the proposed Federal Carbon Sequestration Commission in the U.S., should gather data from these early projects and combine them with factors such as GS industrial organization and climate regime requirements to create an efficient and adaptive regulatory framework suited to large-scale deployment. Mechanisms to structure long-term liability and fund long-term postclosure care must be developed, most likely at the national level, to equitably balance the risks and benefits of this important climate change mitigation technology. We need to do this right. During the initial field experiences, a single major accident, resulting from inadequate regulatory oversight, anywhere in the world, could seriously endanger the future viability of GS. That, in turn, could make it next to impossible to achieve the needed dramatic global reductions in CO2 emissions over the next several decades. We also need to do it quickly. Emissions are going up, the climate is changing, and impacts are growing. The need for safe and effective CO2 capture with deep GS is urgent.

Research for deployment: incorporating risk, regulation, and liability for carbon capture and sequestration.

Carbon capture and sequestration (CCS) has the potential to enable deep reductions in global carbon dioxide (CO2) emissions, however this promise can only be fulfilled with large-scale deployment. For this to happen, CCS must be successfully embedded into a larger legal and regulatory context, and any potential risks must be effectively managed. We developed a list of outstanding research and technical questions driven by the demands of the regulatory and legal systems for the geologic sequestration (GS) component of CCS. We then looked at case studies that bound uncertainty within two of the research themes that emerge. These case studies, on surface leakage from abandoned wells and groundwater quality impacts from metals mobilization, illustrate how research can inform decision makers on issues of policy, regulatory need, and legal considerations. A central challenge is to ensure that the research program supports development of general regulatory and legal frameworks, and also the development of geological, geophysical, geochemical, and modeling methods necessary for effective GS site monitoring and verification (M&V) protocols, as well as mitigation and remediation plans. If large-scale deployment of GS is to occur in a manner that adequately protects human and ecological health and does not discourage private investment, strengthening the scientific underpinnings of regulatory and legal decision-making is crucial.